Environment, Food and Rural Affairs CommitteeWritten evidence submitted by David J Martin BSc(Eng) DpBA MICE FCIWEM, Chartered Civil Engineer, Chartered Water and Environmental Manager

1. The White Paper correctly identifies a number of concerns about future water resource needs and the requirements of environmental conservation in the context of climate change. Its emphasis on the desirability of long-term planning, reliable investment returns and overall stability in the water and sewage industry is wholly consistent with these concerns.

2. Unfortunately the good sense of these approaches is muddied by what appears as an ideological commitment to the benefits of competition, which is in practice inimical to these objectives. At present it is open to consumers either to take water and sewage services from their local supplier or to seek licences from the Environment Agency in order to provide those services for themselves, or to engage a specialist contractor to do it for them. This is a reasonable degree of freedom, regulated by the Agency, and likely to be useable only by larger organisations. Any facility going beyond it for another undertaker to move in to provide the services will most likely lead to duplication, short-termism, redundancy and inefficiency. Least of all do we need the sort of spurious competition familiar in electricity and gas supply, where pretended competition is offered for the same gas and electricity arriving in the same pipes and cables.

3. The only way to send the right signals to consumers about water (and sewage) economy is by metering, which must be universal. Offering metering as an option to “those who would benefit” is pointless; clearly they would take up the option and the rest would necessarily pay more to compensate. Only universal metering provides the means to charge differential tariffs and thereby reduce demand peaks and hence delay the need for infrastructure investments. The need to protect those on low incomes must be dealt with in some other way than cross-subsidising their consumption of water and sewage services.

4. Following on from 3, the uptake of water-efficient domestic equipment and other self-imposed economy measures such as rain water harvesting will only take off significantly when there is a recognisable price signal through payment by metered consumption. Exhortation is unlikely to be very effective.

5. The White Paper notes the difficulty of collecting water charges from tenants who are legally liable when there is no requirement on landlords to identify them. It seems that the approach to road traffic offences would be a good one to adopt, whereby the registered keeper of a vehicle is liable for eg a speeding fine if s/he chooses not to say who was driving at the relevant time.

6. On the subject of abstraction regime reform, the White Paper seems not to be aware of the work that is being undertaken by the Environment Agency, starting several years ago, to review critically all existing abstraction licences and where appropriate to reduce or revoke them.

16 January 2012

Prepared 4th July 2012