Environment, Food and Rural Affairs CommitteeWritten evidence submitted by WWF-UK

1. Introduction

WWF welcomes the Water White Paper and the vision it sets out for a sustainable water industry that can deliver affordable water for people and protect our precious rivers and wildlife. With climate change posing a very real threat, WWF believes the move by the Government to resolve future water-management issues and introduce stronger protection for the environment when and where water is scarce is vitally important. However, to address the damage caused by the legacy of historical over-licensing—which has already led to the taking of too much water from many of our rivers—we would urge the Government to ensure that the measures proposed in the White Paper are implemented as a matter of urgency.

2. A Sustainable Abstraction Regime

We are very supportive of the focus placed on dealing with over abstraction, which has been inadequately addressed by successive Governments, and of the vision of a future, sustainable abstraction regime. We fully support the case for change made by the Government and the principles set out (the need for abstraction licences to signal availability, reflect value including environmental scarcity, protect the environment and drive efficient use of water), which we think will act as cornerstones of an effective abstraction regime. Of course, the detail is yet to come and we welcome the opportunity to inform the development of this; WWF will be participating in the National Advisory Group. While we are pleased to see a clear timetable for the reforms, we are concerned about the intention that it will be the late 2020s before the reformed regime is in place. This is too late and we would like to see reforms beginning to be implemented to a much faster timescale. We are also concerned that legislation is to be put off until the next Parliament (most likely in 2016). A delay of this length risks greater uncertainty on the issue, which in itself could lead to a more expensive transition for water companies in particular. The longer action takes the longer water environments are exposed to the risk of damage. To reduce the potential costs of reforms to customers, companies must be able to start planning for changes now—if left to the last minute, it may be that expensive and otherwise inappropriate solutions (such as desalination plants) may be the only viable solutions in the reduced timescale. The forthcoming Water Bill should grant powers to reform the abstraction regime at a future date, in order to give abstractors clear notice that the Government intends to do so.

3. Addressing Current Unsustainable Abstraction

While the water scarcity situation will get worse as a result of rising demand, a growing population and climate change, unsustainable abstraction is very much a here and now issue. Drought over this last year has shown just what a devastating effect unsustainable levels of abstraction can have on our rivers and their wildlife. We agree with the Government that the current approach does not encourage change quickly at least cost, and that immediate action is needed to speed up and amend problematic licences. There are rivers all over the country that have waited over 10 years for changes to licences, largely related to inefficiencies, bureaucracy and lack of available funds in the Environment Agency’s Restoring Sustainable Abstraction (RSA) programme. The Water White Paper provides some very welcome ideas about how to add momentum, including: the proposal to include water company RSA schemes in the price review, the development of an Abstraction Incentive Mechanism to encourage companies to take less water from vulnerable sources during low flows and give greater consideration to environmental impacts when managing water supplies, and clear intention to start using the power in the Water Act 2003 to revoke or vary abstraction licences that are causing serious damage to freshwater systems. It is essential that these proposals are implemented quickly. Guidance to water companies (due in Spring 2012) must include instructions for the inclusion of all RSA sites in company Water Resource Management Plans and in Ofwat’s PR14 determinations. The consultation on Water Act 2003 section 27 powers (which has been expected for over 10 months) must now be published, and Government policy must be set out before the provisions are enabled in July 2012.

4. Metering

Widespread metering is essential to ensuring sustainable, reliable and cost-effective water supplies. With tariffs to protect the vulnerable and to encourage water efficiency, metering can help address affordability and keep water prices reasonable over the longer term. Significant reduction in per capita consumption is unlikely without widespread metering. We are extremely disappointed that measures to support significant increases in the level of metering are conspicuously missing from the White Paper, despite clear evidence of the benefits to customers and the water environment.1 Ofwat’s role is crucial, to drive companies to ensure that customers get the best deal over the medium to long term. The Government must emphasise the clear role that meters play in reducing demand, addressing affordability and keeping bills low in the medium to long term. In its guidance to Ofwat, Government should encourage an increase in household metering from 50% to 80% by 2020, over the next price review period (in line with Walker’s recommendation).

5. Water Efficiency

WWF welcomes the emphasis on linking water use with rivers and plans for an awareness campaign. However, the measures are note enough to drive water efficiency on the scale that’s needed. We are concerned that the expectation that companies will “produce a plan that will deliver overall demand reductions in the first five years [and looking ahead] demonstrate that the trend is significantly downward” (pp 51) is too vague to provide a real measure of success, and is not supported by policy instruments (such as incentives via the price review2) to deliver real savings. We feel that it is crucial that Ofwat takes a leading role in driving companies to promote water efficiency and to deliver sustainable water services. It is essential that Government’s guidance to Ofwat (and subsequent Ofwat and Environment Agency guidance to companies) includes emphasis on expectations on demand management, including leakage, metering and water efficiency, to significantly reduce water consumption.

6. Green Deal

Despite intentions in the White Paper to link water efficiency to the Green Deal, we are concerned that this could be lost across Government (eg the DECC consultation on eligible measures does not include hot water efficiency measures, even though such measures deliver clear water and energy savings for the householder).

7. Water Transfers

We understand the potential benefits of large-scale water transfers and trading in maintaining affordable security of supply and, potentially, in addressing over abstraction. Transfers via canals and rivers must be considered carefully, with publically available impact assessment and consultation with local stakeholders being imperative parts of the process, in order to ensure there are no adverse impacts on water chemistry or spread of invasive species and that any schemes do not prevent the UK from meeting the requirements of the Water Framework Directive.

23 January 2012