Water Bill

Written evidence submitted by Lucy Borland (WB 14)

Summary : Basic information on water assets is secret , a stance which prevents comp e tition. The bill should recognize the sanitary purpose of water infr a structure as health risks are set to increase as antibiotics become ineffective . A mend ing the Water Industry Act of 1991 to secure the right to reasonable return s on human resources and intelle c tual property would curtail excessive capital spending.

1. Asking my water company to explain the source(s) of mains tap water to my vi l lage, I am told security advice from the Centre for the Protection of National I n frastructure requires all information on water assets be kept confidential. The Drinking Water Inspectorate agrees, and Ofwat states it "is not a matter for O f wat " whether or not the source of water supplied to customers must be kept co n fidential from them."

2. This information void discriminates against new entrants and c onsumers will be r e luctant to switch supplies between secret sources . To allow competition , Part, 1, Chapter 3 requires a new clause adding a duty on Ofwat to secure equal access to water asset information for all .

3. In Part 1 , Chapter 3, the consumer objective (subsection (2A) (a) of the 1991 Act), should be expanded thus " t o protect the interests of consumers, wherever appropriate by promoting effective competition between persons engaged in, or in commercial activities connected with, the provision of water and sewerage services and by promoting informed choice by consumers and groups of consumers .

4. Ireland is introducing domestic water bills to fund tertiary treatment of was te water, with a regulatory structure tuck ing water and energy together. Investors and i n novators may shun England in favour of Ireland and other EU states more open about water assets.

5. O fwat answered a request that it explain how customers can take a greater role without [access to] info r mation on water assets thus:
"We believe water companies should develop plans based on their customers’ priorities. This means companies need to be transparent about how they are spending customers’ money and why
." Transparency about current and future spending plans is not enough – a c cess to data about existing assets is required.

6. Equal access to data suffered a se t back when Ofwat end ed Annual Returns, ver i fied and commented on by Reporters (engineering experts). This process brought information into the public domain on a regular basis . It could have shed light on the topical issues of the extent to which new sewer maintenance tec h niques ( regrouting the joins of sewers to reduce infiltration by rai n water or leaking water mains) could cut the need for wastewater treatment capacity , and whether retrofitting sanitary (waste only, not rainfall) sewers could slash the costs of trea t ing sewage and drinking water.

7. Demand management for water needs to take place within a framework which r e cognizes both existing health risks, and those expected when antibiotics b e come ineffective and new, more virulent, forms of infectious diseases emerge in Britain with faecal-oral transmission. T he constant domestic water supply – eliminating unsafe storage practices around the home – was pioneered in Liverpool in 1840 by William Henry Duncan, the country’s first Medical Officer of Health . We must not go backwards.

8. I n Part 1, Chapter 3 , General duties of the Water Services Regulation Authority, Section 22, Primary duty to secure resilience, a new clause (f) should be inserted to give the authority a duty to promote water supply and sewerage as public health good s. C omplementing this change, i n Section 22, (3) (2DA) (b) "and the taking by them of a range of measures to manage water resources and reduce demand," the words " without detriment to human health " should be added. I n Section 24, (1) 2A (g), and at 117G (2) (f) and Part 2, Chap 3, section 44 (5) (f) include Public H ealth England as a body whom the Secretary of State is obliged to consult, and similar ly for Wales. In Part 1, Chapter 3 , section 28, require the publication of water safety plans as part of the publication of water resources management plans. Water safety plans are the World Health Organisation’s a p proach to securing affordable, safe water for domestic use.

9. Recognizing the sanitary (as well as economic) importance of affor d able water, we should look for cheaper solutions. So a new section should be added to the bill to amend the Water Industry Act 1991 c. 56 Part I General duties Section 2, (c) " to secure that companies holding appointments under Chapter 1 of Part 2 of this Act as relevant undertakers are able ( by securing reasonable returns on human resources and intellectual property) to finance the proper c arrying out of those functions…."

December 2013

Prepared 11th December 2013