Environment, Food and Rural Affairs CommitteeWritten evidence submitted by the Mayor of London

Introduction

1.1 Whilst the Mayor of London has no formal responsibility for water, he has recently published the first water strategy for London as he believes that a London-specific perspective on water issues is required to ensure that London’s water interests are best served. This response is based on a comparison between the issues and actions raised in the Mayor’s water strategy and those in the WWP.

Sustainably Balancing Supply and Demand

2.1 The Mayor believes that reducing London’s demand for water through improved water efficiency is critical to sustainably balancing supply and demand, helping Londoners manage their utility bills and creating “green jobs” that will underpin our economic recovery.

2.2 To improve and sustain greater water efficiency, the Mayor’s water strategy sets out a “six point plan” of actions:

(1)improve the water efficiency of existing buildings;

(2)ensure all new development is “super” water efficient;

(3)raise Londoners’ awareness of the financial benefits of increased water efficiency;

(4)increase the number of homes with a water meter;

(5)change the way Londoners pay for their water; and

(6)continue to tackle leakage.

2.3 The Mayor believes that whilst the WWP is broadly supportive of most of the individual measures in the six point plan, DEFRA should integrate and present these actions as a coherent package of measures to ensure a self-reinforcing cycle of water efficiency.

2.4 Improving the water efficiency of existing development, particularly homes, is one of the most important elements in the six-point plan. The WWP refers to improving water efficiency through the Green Deal (but this only covers improving hot water efficiency) and through guidance to water companies on their Water Resource Management Plans (yet to be published).

2.5 The Mayor has developed with partners an integrated home water and energy efficiency retrofitting programme, called RE:NEW. This area-based scheme provides and installs water and energy efficiency measures, for free, aiming to retrofit 55,000 homes in London by spring 2012. Integrating the installation of water and energy measures at the same time, reduces the need for separate water and energy efficiency visits and encourages Londoners to make the connection between their energy and water use (and bills). Going forwards RE:NEW will provide a mechanism to deliver Green Deal and other retrofit programmes.

2.6 The Mayor welcomes the commitment to review the Sustainable Economic Level of Leakage (SELL). Half of London’s water mains are already over a century old and the current rate of replacement is not sufficient to reduce the overall age of the network. The SELL review should take account of the value of water in a water stressed area, the impact leakage has on customer engagement on water efficiency and the potential damage leakage has on infrastructure and the capital’s reputation.

2.7 As leakage rates are seasonal, with most leaks occurring during and following cold weather, the Mayor recommends that the deadline for reporting on leakage levels to Ofwat should be delayed to allow water companies more time to fix leaks in a planned and systematic approach.

2.8 The Mayor believes that consumers should be encouraged to and rewarded for using water efficiently, provided vulnerable consumers are protected. This requires consumers to have both a mechanism for measuring consumption (a water meter) and an incentivising cost structure (tariffs). Only about a quarter of London households currently have a water meter and Thames Water estimate that at least three quarters of properties need to be metered before tariffs can be effectively brought in. In their draft WRMP, Thames Water estimate that they will not achieve this level of metering until 2025. This places Londoners at a significant disadvantage and threatens London’s water security.

2.9 The Mayor questions the effectiveness of the “water calculator” as a measure of enabling greater water efficiency in new development and recommends that Defra and CLG consider alternatives, such as flow-based approaches.

Tackling Water Affordability (Water Poverty)

3.1 Londoners’ water bills are lower than the national average, but this disguises the fact that there are more London households in water poverty than any other water company area. Analysis by Ofwatⁱ suggests that over a million Thames Water customers struggle to pay their water bills, the majority of these in London.

3.2 The Mayor is committed to reducing water poverty in London and is working with the London Water Groupⁱⁱ to: a) review whether the current working definition of water poverty is applicable in London; b) identify groups of Londoners that are, or are at risk of being in water poverty; c) understand their needs; and d) examine how existing initiatives could be better targeted to help them.

3.3 The Mayor welcomes Government initiatives to tackle water affordability through the Company Social Tariffs Guidance but would encourage Government to provide support for a water affordability pilot in London given that there are more Londoners struggling with their bills than those in the South West. On the basis of Government’s support, the Mayor will work with the Citizen’s Advice Bureau and the water companies to develop a targeted package of measures that combines a social tariff trial with metering, retrofitting of energy and water efficiency fittings, enhancing understanding of water use and bills, payment and debt advice.

3.4 The Mayor encourages Government to amend the definition of water affordability to include “disposable income after living costs”, as living costs in London are higher than the rest of the country. Without a revised definition, Londoners struggling with their bills may not receive the help they need—because of where they live. Government should also consider defining “local” when referring to the design of company social tariffs taking into account “local needs”. In London’s case this needs to ensure London, with its very different circumstances to the rest of the country, has its own water affordability assessment, development and trial of a social tariff scheme. Government should also consider how water companies are enabled to target customers with water affordability problems to ensure that those struggling get the help they need.

Managing Surface Water Flood Risk and Diffuse Pollution

4.1 Surface water flooding represents the greatest short-term climate risk to London, with more than one million propertiesⁱⁱⁱ at risk of flooding from an extreme rainfall event. To address this challenge, the Mayor has created a partnership of the key organisations with responsibility for managing surface water flood risk to tackle the issue. To date, the partnership, known as Drain London, has mapped flood risk across London and developed a draft surface water management plan for every borough.

4.2 The Mayor welcomes the increased focus on surface water flooding in the WWP, but feels that the issue is not being given sufficient prioritisation. The scale and complexity of the challenge, the lack of delivery mechanism and incentives means that greater efforts are required. The Mayor is working with Thames Water and the Environment Agency to develop demonstration projects on how to work with communities to retrofit “green infrastructure” and rainwater harvesting into existing development, with the aim of managing local flood risk and extending the lifespan of “grey infrastructure”.

4.3 The Mayor welcomes the proposal to develop a national strategy on urban diffuse pollution. This will need to sort out some of the issues missed in the Flood and Water Management Act, such as defining ownership and responsibility for sections of watercourses and drainage infrastructure where no party claims ownership.

London Water Commissioner

5.1 The Mayor believes that Londoner’s water interests could be better served and is exploring the potential for an appointed “London Water Commissioner” to represent Londoners, ensuring transparency and accountability on key water issues and projects.

May 2012

References

ⁱ Ofwat. Analysis of Family Resources Survey 2008-09. Unequivalised income after housing costs.
http://www.ofwat.gov.uk/future/customers/metering/affordability/prs_pre110315affordability.pdf

ⁱⁱ The London Water Group is a partnership of the GLA, London’s four water companies, London Councils, Environment Agency, Ofwat, Waterwise, Consumer Council for Water, London Sustainability Exchange, Sustainable Water Industry Group that collaborate to tackle water issues in London.

ⁱⁱⁱ This figure was generated using a one-in-100 year plus climate change rainfall event. 80,000 properties are at “significant” surface water flood risk.