Environment, Food and Rural Affairs CommitteeWritten evidence submitted by RM Water Services

INCENTIVES FOR RAINWATER HARVESTING AND SUDS ON EXISTING SITES

Introduction and Overview

1.1 In response to the publication of the “Water for Life” white paper, R M Water Services wish to draw to the attention of the committee the absence of clear guidance from Water and Wastewater Companies (WaSC’s) regarding the cost treatment of sustainable drainage (SUDS) and rainwater harvesting and the need for incentives for the business community to invest in SUDS and rainwater harvesting systems on existing sites.

1.2 The inclusion of charge reducing benefits in WaSC’s Schemes of Charges, that produce realistic cost benefit returns for businesses, will have the effect of:

reducing WaSC’s abstraction requirements as a result of local collection and reuse of rainwater; and

reducing the number of flooding incidents from the public sewer system with the consequential environmental benefit of reduced pollution.

These benefits are clear objectives of the White Paper.

1.3 Whilst there are requirements in the planning process for developers to install both SUDS and rainwater harvesting on new sites, the benefits of investment on existing sites are less clear or absent. As can be seen in the attached table, Water Company Schemes of Charges add cost, give marginal benefit or are silent regarding the cost treatment of rainwater and SUDS schemes.

1.4 Whilst enhanced capital allowances are available against installation costs for rainwater systems that are included on DEFRA’s water technology list, the benefits are not available to all businesses and do not provide year on year reductions in cost.

1.5 In the absence of clarity in WaSC’s Schemes of Charges regarding financial incentives for existing sites, the motivation for a business to promote capital schemes is best described as being largely altruistic.

1.6 We believe that the development of clear incentives, through Schemes of Charges, for existing sites will provide benefits to business, WaSC’s and the environment and will promote investment on existing sites by business’ in both rainwater and SUDS schemes.

1.7 We fully support the site area principle of charging for the provision of a service to remove and dispose of surface water.

WaSC’s Schemes of Charges

2.1 The following table summarises each WaSC’s approach to charging where rainwater harvesting and/or SUDS are present on a site. It can be seen that some WaSC’s do not indicate how they will deal with rainwater that is collected and used by a business for say toilet and urinal flushing. Others will not reduce surface water area charges or provide standing charge rebates but will increase the wastewater charge in line with the amount of rainwater collected. In such circumstances a business that installs a rainwater system is charged twice for the removal of the rainwater that it uses.

2.2 If properly designed, both SUDS and rainwater systems incorporate an overflow that may be connected to a public sewer. Overflows are only required on collection systems to discharge water where rainwater events outside the design limits are experienced.

2.3 Where an overflow is connected to the public sewer system WaSC’s do not allow rebates on standing charges or reduce the area used for calculating site area charges. Because such connections are only operational in extreme storm events, we believe that they should be treated differently to direct site connections to the public sewer system for all rain and surface water flows.

2.4 As there is no link between a site’s area and the provision of a service to drain the public highway, the use of the site area formula by United Utilities and Northumbrian Water to charge for Highway Drainage even when there is no surface water connection should be removed.

SCHEMES OF CHARGES SUMMARY

Water Company	Wastewater charges for rainwater systems	Site area adjustment for SUDS and rainwater collection areas
Anglian Water	section 3 paragraph 2.5 rainwater or recycled water additional volume will be taken into account in wastewater charges	Fixed charge not based on site area. Section 10 paragraph 2.1 Reduced by £36 to £1,226 per year dependant on user tariff where there is no surface water connection
Northumbrian Water	No indication of cost treatment of domestic sewage derived through rainwater harvesting.	Section 6.4.3 Site area charges reduced by up to 70% of the area that does not drain to public sewer.
Severn Trent Water	Section 9 Discharges need to be metered and are charged at wastewater rates.	Page 37 of Scheme of Charges. Rainwater collection areas probably not excluded from site area calculation.
South West Water	Paragraph 5.30 rainwater volume used is taken into account in wastewater charges. Para 6.6 Rainwater must be metered and an additional charge of £6.50 per year is added for each rainwater meter.	Paragraph 6.27 Standing charge is reduced by £16 per annum where there is no surface water connection. There are no reductions for partial connections.
Southern Water	No indication of cost treatment of domestic sewage derived through rainwater harvesting.	Fixed charge not based on site area. For a 20mm meter this reduction is £22 per year. There are no reductions for partial connections.
Thames	No indication of cost treatment of domestic sewage derived through rainwater harvesting.	From their metered charges leaflet, rebate by way of reduction of standing charges where there is no surface water connection. For a 20mm meter this reduction is £47 per year. There are no reductions for partial connections.
United Utilities	No indication of cost treatment of domestic sewage derived through rainwater harvesting	50% reduction of the chargeable area of the roof. Site area charges are reduced where all or part of the site has no connection to the public sewer system. Highway drainage charges are not reduced but continue to be charge on full impermeable site area.
Welsh Water	No indication of cost treatment of domestic sewage derived through rainwater harvesting	Rebate where none of the surface water from the site drains to public sewer. £45 per year on standing charges and a reduction in the volumetric sewage rate of 32.55p per cubic meter. There are no reductions for partial connections.
Wessex Water	No statement regarding cost treatment of domestic sewage derived through rainwater harvesting.	Reduce the metered standing charge where there is no connection to the public sewer system for surface water. For a 20mm meter this reduction is £19 per year. There are no reductions for partial connections.
Yorkshire Water	Section 6 (1) (b) suggests that rainwater returning to the sewer will be charged on a volumetric basis.	No express exclusion areas of the site used for rainwater collection.

January 2012