The Water White Paper

Written evidence submitted by Lucy Borland (WWP 31)

A double agenda is confusing the water demand management picture. To close a demand/supply gap through demand management you need to cut use by big users. This can be very successful, to the extent of being a revenue loss concern to potential investors. The MoD achieved a 25% reduction in UK estate water use 11 years ahead of target, employing the Aquatrine partnership in a PFI deal.

The Walker Review (looking at how ordinary people can be incentivised to use less water whilst ensuring it remains affordable to families), and water industry emphasis on household metering, also overlook a key pricing issue - a failure to match prices to location specific costs.

This creates cross-subsidies which distort choices between on and off grid supply. It removes incentives to prefer water abundant locations for new development, and to avoid water squeezed ones.

Upstream household/office use is a borrow, clean and return for reuse model. Awareness of this reuse aspect is very low and there are (US press) cases of expensive water recycling plant put into buildings despite ample local public water recycling capacity.

Downstream use, clean (a bit), discharge to the sea and wait for it to rain in your catchment - this is more expensive, especially in the context of expanding waste water treatment capacity on the south coast to catch up with population growth.

Off grid cycles can be very resilient, using and returning water at the same location.

If water for irrigation and cooling (lost to the atmosphere, not recycled) is currently cross-subsidised/underpriced, then it is likely we are underusing advanced irrigation techniques and alternatives to water cooling (air cooling or water recapture).

We are likely under using/researching traditional farming practices too, for example mist harvesting into dew ponds on the South Downs and planting local food plant varieties or mixed varieties to reflect unpredictable rainfall conditions.

A separate charging regime for irrigation water/water lost to evaporation, would allow water transfers for farming without burdening household bills.

Water abstraction charging is under review, but this process could usefully be expanded to consider location-sensitive pricing too.

We appear to have a disproportionate emphasis on cutting use by low-income low users, either as a prelude to raising prices (to fund closing the gap through higher supply) or as part of the long campaign to limit daily supply to those in water debt.

Water UK advise the re-use of cooled bath water on gardens. This is contrary to World Health Organisation guidance, and a transmission route for the norovirus and other pathogens ( http://www.emro.who.int/ceha/pdf/Greywter%20English%202006.pdf ).

Recent research for the Food Standards Agency found the norovirus in 76% of oysters from UK growing beds. A sewerage undertaker was fined £25,000 in 2011 for contaminating shellfish beds in 2009 - a trivial amount compared to the costs of norovirus outbreaks and loss of consumer confidence in UK shellfish as a food source in a time of global food insecurity.

New research from Brighton university casts doubt on the general adequacy of wastewater treatment plants in the Sussex Ouse to remove human pathogens, especially when rainfall is high (AquaManche project led by Professor Huw Taylor).

The funding required to address inadequate coastal wastewater treatment might more readily win support if the health and economic consequences of failures are more closely tracked.

To re-engage water supply and sewerage with health promotion goals, the Consumer Council for Water’s role could in future be split between Consumer Direct (billing issues) and local health/social care purchasing organisations (sewage flooding and water quality).

Smart meters are still on the water agenda despite a very mixed picture of evidence that they change behaviour - South West Water’s trial of 1,000 customers on block tariffs did not produce the desired behavioural results and will not be extended.

There is a risk that continuing to push expensive smart meters might provoke a backlash against the private sector’s leading role in UK utility provision. Enron found less than 1% of its US household customers wanted its smart energy meters. (Elkind and McLean, The Smartest Guys in the Room). The Enron experience perhaps continues to limit private sector involvement in US electricity supply.

Andrew Tyrie, MP, chairman of the Treasury select committee, is arguing against the planned Financial Conduct Committee having a duty to enhance confidence in the UK financial system - encouraging caution can be more appropriate.

Set up in 1990, the Drinking Water Inspectorate has a strategic objective to "maintain public confidence in drinking water." Encouraging caution can be more appropriate.

Copper has recently been shown to have useful antimicrobial properties and the trend to replace it with plastic water pipes may be one factor in rising failure rates in mains water samples at kitchen taps. (Nature’s Building Blocks, Emsley, 2011 edition, South East Water Environmental and Social Achievements 2010/11, p20).

My local water company has declined a request to inform residents when lead pipe work is discovered when meters are installed or to test water at this time, to avoid alarm. This is the prioritisation of maintaining public confidence over encouraging caution.

We have a double standard on lead - it was phased out of petrol on the basis of substantial 1970s US evidence on sub clinical effects (those never prompting medical investigation) on child development (IQ).

But only if clinical cases of acute childhood lead poisoning are linked to water pipes in an ongoing surveillance project here will legislation be proposed and water companies change tack (Correspondence with English water company. )

Meanwhile new research shows irreversible harm to children from low levels of lead exhibiting no clinical symptoms extends beyond cognitive damage to include cardiovascular, immunological and endocrine effects (US Advisory Committee on Childhood Lead Poisoning Prevention, report 4 Jan 2012).

10% of French children are estimated on the basis of blood testing to be irreversibly and subtly harmed by lead exposure - the UK might have similar figures - no routine testing is done. (European Environmental and Health Information System, jointly with World Health Organisation Fact Sheet 4.5 "Levels of lead in children’s blood" code: RPG4_Chem_Exi.)

A debate about the relatively high importance of water as a lead exposure route is accelerating. (Lead (Pb) in Tap Water and in Blood: Implications for Lead Exposure in the United States. Critical Reviews in Environmental Science and Technology, Accepted, 2011, doi:10.1080/10643389.2011.556556 .) In July 2011 the WHO revealed its lead in water standard is associated with an infant IQ loss of at least 3 points and adult blood pressure rise of 3 mmHg ( www.who.int/water_sanitation_health/publications/2011/dwq_guidelines/en/index.html ).

In Toronto, Canada, pregnant women and children under 6 in older homes were advised in 2011 to use bottled water until a suitable end of tap filter is installed in their homes ( http://www.toronto.ca/health/lead/drinking_water.htm#004 ).

Water quality standards are historically derived from occupational health data on adult exposures. This misses windows of special vulnerability during growth, including in the womb. A careful review by the US President’s Cancer Panel of limitations in methodology for setting safe exposures resulted in a 2010 recommendation that all households filter their mains or other water into glass or aluminium jugs (2008-9 Annual Report, Reducing Environmental Cancer Risk, What we can do now).

Newly released US documentary "Semper Fidelis" will likely draw public attention to the links between poorly regulated private water supplies, childhood leukemia and other cancers in 2012.

Problems recently identified here by the Drinking Water Inspectorate with private supplies include high levels of arsenic and bromate, as well faecal contamination issues. See http://dwi.defra.gov.uk/about/annual-report/2010/private-england.pdf .

The Drinking Water Inspectorate’s mandate might usefully be amended to prioritise caution over confidence. Attention should be paid to ensuring that the Inspectorate receives adequate funding from sources other than public water companies, as water from private supplies (holiday homes, hotels, food outlets, food preparation, work places) affects the public as a whole.

Funding of advice on household plumbing issues which give rise to water quality problems also requires attention. Companies such as British Gas are well placed to bid to provide water testing and solutions as a package, should this be separated out as an activity. Water companies are currently expected to provide this "for free."

January 2012