Environment, Food and Rural Affairs CommitteeWritten evidence submitted by Food and Drink Federation

1. This submission is made by the Food and Drink Federation, the trade association for food and drink manufacturing. The food and drink manufacturing industry is the largest manufacturing sector in the UK, employing up to 400,000 people. The industry has an annual turnover of over £72.3 billion accounting for 15% of the total manufacturing sector. Exports amount to almost £11 billion of which 77% goes to EU members. The Industry buys two-thirds of all UK’s agricultural produce.

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?

2. Following on from the earlier Natural Environment White Paper, FDF considers that the White Paper correctly argues the need to protect our rivers and lakes as fully functioning ecosystems as a key principle underpinning the action needed now to tackle pollution and over abstraction. The Paper is also correct to point out that left unchecked this issue is likely to get worse with the combined effects of climate change and population growth. However when identifying future demand pressures on the water supply system the White Paper fails to acknowledge the implications of addressing the challenges set out in the Government’s Foresight report on “The Future of Food and Farming” published last year. This stated very clearly that changes in the UK (along with the global) food and farming system will be needed in order that it can produce more and with less impact in order to meet the twin challenges of future food security and climate change. This will have consequences for the food and farming sector’s future water needs and which suggests that some kind of priority use hierarchy (with a bias towards uses that are of national importance) in situations of water scarcity should be considered as part of a reformed abstraction system. Without some form of strategic prioritisation there is a risk that discretionary uses, such as irrigation for golf courses, take precedence over activities such as food production simply on a basis of ability to pay.

3. FDF welcomes the proposal to remove the annual water consumption threshold for businesses in England that wish to choose their water supplier particularly given the opportunity this will present to our members with more than one operating site to choose a single supplier and thereby benefit from efficiency savings.

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

4. Policies directed at addressing water security and supply issues should be flexible and responsive to particular catchment situations as opposed to imposing blanket national approaches.

5. We would stress that any new abstraction system will need careful design. Using price signals alone as a way of managing unsustainable abstraction would carry the risk that the environment can be damaged with impunity by anyone with sufficient cash which is surely not the intention. As mentioned under the question above this would also allow the Government no discretion as to which types of users could abstract the water according to what may be in the national interest.

6. FDF welcome the emphasis on the water companies needing to plan for their future needs more effectively, in particular the need to build resilience and flexibility into the system through for example joining up their own networks. But it will be important not to underestimate the challenge of achieving this given that the private water companies are incentivised to provide returns to shareholders rather than safeguard national infrastructure.

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

7. Regarding the aim of promoting water efficiency FDF has, as part of implementation of its Five-fold Environmental Ambition, been encouraging its members to make significant reductions in water use to help reduce stress on the nation’s water supplies. This is being achieved through the voluntary agreement administered by WRAP known as the Federation House Commitment which is focused on the use of water used in members’ own operations. FDF has also just launched a new leaflet “Every Last Drop” and associated campaign which aims to promote more sustainable use of water right across the supply chain including as individuals at home.

8. In situations where water is relatively cheap for consumers efficient use of water requires doing the right thing to be no harder than doing the wrong thing.

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

9. It is not appropriate for FDF to comment on this aspect.

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

10. As referred to in the preceding questions the main omission from FDF’s perspective and as mentioned above is the impact of addressing the challenges set out in the Government’s Foresight Report and the demand this likely to create for water in the food and farming sector in the UK through increases in food production.

THE UK FOOD AND DRINK MANUFACTURING INDUSTRY

The Food and Drink Federation (FDF) represents the food and drink manufacturing industry, the largest manufacturing sector in the UK, employing up to 400,000 people. The industry has an annual turnover of over £72.3 billion accounting for 15% of the total manufacturing sector. Exports amount to almost £11 billion of which 77% goes to EU members. The Industry buys two-thirds of all UK’s agricultural produce.

The following Associations are members of the Food and Drink Federation:

ABIM	Association of Bakery Ingredient Manufacturers
ACFM	Association of Cereal Food Manufacturers
BCA	British Coffee Association
BOBMA	British Oats and Barley Millers Association
BSIA	British Starch Industry Association
BSNA	British Specialist Nutrition Association
CIMA	Cereal Ingredient Manufacturers’ Association
EMMA	European Malt Product Manufacturers’ Association
FA	Food Association
FOB	Federation of Bakers
FPA	Food Processors’ Association
GPA	General Products Association
MSA	Margarine and Spreads Association
SB	Sugar Bureau
SMA	Salt Manufacturers’ Association
SNACMA	Snack, Nut and Crisp Manufacturers’ Association
SPA	Soya Protein Association
SSA	Seasoning and Spice Association
UKAMBY	UK Association of Manufacturers of Bakers’ Yeast
UKHIA	UK Herbal Infusions Association
UKTC	UK Tea Council

Within FDF there are the following sectoral organisations:

BCCC	Biscuit, Cake, Chocolate and Confectionery Group
FF	Frozen Food Group
MG	Meat Group
ORG	Organic Group
SG	Seafood Group
VEG	Vegetarian (Meat-Free) Group
YOG	Yoghurt and Chilled Dessert Group

January 2012