Environment, Food and Rural Affairs CommitteeWritten evidence submitted by The Chartered Institute of Plumbing and Heating Engineering

Does the White Paper set out the right principles for customers and the water and sewerage industry for taking forward reform of the market for water supply?

1. Although the principles may be correct the development of those principles into actions and policy is often questionable. The reduction of bills in the SW will no doubt be welcomed in that region, but this seems to be another step away from making customers fully aware of all of the externalities and better appreciating water.

Are the proposals to protect and enhance water resources, for example on abstraction regime reform, likely to be fully effective?

2. We have no comment on this aspect of the White Paper.

How best can the White Paper’s aims to promote water efficiency and the use of sustainable drainage be implemented?

3. Linking of water efficiency and SUDS is not always a good idea as they can impact very different users. The prerequisite with water efficiency is determining how much water is being used, then an appropriate programme of efficiency measures can be implemented and monitored. For SUDS the main impact is natural precipitation, over which we have no control, so a very different approach is needed to water efficiency. The only time they are linked are through systems such as rainwater harvesting, where the retention of peak rainfall can be useful in attenuating the flows to infiltration or other drainage.

4. It would also be beneficial if accurate, correct and factual data could have been included. For example, on page 83 in the green box titled “In the kitchen”, the second bullet point wrongly states that “a dripping tap wastes at least 5,500 litres of water a year..”. This is a sensational statement that is not true. Indeed a dripping tap can create a waste of water, but it depends on how frequently it drips and for how long.

5. The tips given in the various boxes in Chapter 6 are mainly aimed at garden watering which is well established to be a very minor consumer of household water in the UK. The tips given for bathroom and kitchen use are not new and do not indicate any development of policy to promote water efficiency. Although mention is made on page 86 of the Plug-It project, there is no mention of how the results will be used to help intermediaries, such as plumbers and shop counter staff, to promote water efficiency to their customers. Although 6.17 states that you will be developing and testing messages, no timescale is given. Will there be a follow-on project to Plug-It or is there now sufficient data to develop some clear policy on messaging?

Do you support the White Paper’s proposals on affordability of water bills for householders?

6. Water does need to be affordable, but when the cost of water is far less than the average monthly mobile phone bill it is questionable if it is sending the correct message to users. The lack of any incentives to use alternate water supplies is disappointing. Tariff structures should be in place that can take account of the use of greywater reuse or rainwater harvesting systems. The direct link between mains water supply and the wastewater charges need, at least an option, to be decoupled so that where there is a reduced flow to municipal treatment or discharge it can be accounted for.

Does the White Paper omit any key issues where further policy action is required to ensure sustainable, reliable and cost-effective water supplies?

7. Page 78 of Water for Life shows a professional carrying out a flow test on a kitchen tap and informing the householder of the results and implications. However, Chapter 6 Taking Action, makes no reference at all to water auditing, despite Ofwat stating that water audits can be very effective in producing significant water consumption reductions (see Table 1).

Table 1

(REF OFWAT -SERVICE AND DELIVERY—PERFORMANCE OF THE WATER COMPANIES IN ENGLAND AND WALES 2009–10)

Device	Assumed savings (Ml/d)
Cistern displacement devices	4.27
Retrofit	0.04
Outdoors	0.05
Household audits	2.38
Non-household audits	2.47
Additional activity	4.77
Total	14.05

8. Water audits can be carried out in a number of ways, but to get the most benefit from audits they need to be systematic and consistent. Currently many water companies promote DIY water audits for keen householders, but because they are carried out differently by untrained people they have little value for policy decisions beyond the building in which they were conducted. If professionals were used to carry out water audits the data collected could be used to inform Government and provide a measure of the effectiveness of water conservation policies. To help produce the required workforce, CIPHE has developed a professional Water Audit training program with WaterwiseEast and the Bathroom Manufacturers Association (BMA). The training is available in video form through Navigator Productions’ famous Learning Lounge website and is promoted through the CIPHE Website http://www.ciphe.org.uk/Professional/Water-Audit-Training/

9. No mention is made in the White Paper of the work being undertaken in Europe by DG Environment to develop a Directive on water use in buildings. The current consultation from the European Commission is due to end at the beginning of February and covers policy issues that it would have been good for Water for Life to have detailed. These include: appliance labelling, building rating and Certification schemes for water reuse systems. How the UK might deal with such a Directive should have been dealt with at this time and not omitted.

10. Consumers need to be better educated with regards to Using Water Wisely and Saving Water Safely, with regards to items such as thermostatic mixing valves, water reuse systems and legionella risks. Plumbing appliances and systems should be inspected annually for water efficiency and water safety measures. CIPHE members can play an important part in helping by installing water efficient devices and undertaking “Plumbing Health Checks”.

January 2012