Consumer Council for Water                            WQR0033


Written evidence from Consumer Council for Water

  1. Introduction

CCW is the independent voice for water and waste water consumers in England and Wales. Since 2005, we have helped thousands of consumers resolve complaints against their water company, while providing free advice and support. All of our work is informed by extensive research, which we use to champion the interests of consumers and influence water companies, governments and regulators.


Our duty goes wider than today’s bill-payers. We also represent the interests of future generations whose water and wastewater services will be impacted by the decisions made today, as well as those directly or indirectly impacted by the water companies’ activities, whether or not they pay the bills. The sustainability of everybody’s water services relies on a healthy and resilient environment.


Consumers tell us that while they do care about the environment, they often don’t connect their use of water at home with the natural world, and are therefore largely unaware of the consequences of their actions.


Water companies can – and should – do more to address the inadequacies in their networks and treatment works that lead to environmental pressures and pollution events, but this must be part of a long-term strategy informed by robust and transparent data. Delicately balanced against this investment is the need to keep bills affordable for customers, particularly those in vulnerable circumstances and those facing financial hardship, the scale of which is particularly uncertain in light of the Covid-19 pandemic.


While water consumers have a part to play in tackling climate challenges, there are other players that have even more potential influence and impact – not least governments, regulators, the water companies, agricultural sector and other potential polluters like manufacturers of single-use plastic items. It is CCW’s view that we all need to be working together to address these challenges, and we are eager to play our part.


  1. CCW’s response to specific questions

In our response to this call for evidence, we have only provided answers to the questions that are relevant to our role as a consumer body.


  1. How could drainage and sewage management plans, introduced by the Environment Bill, play a role in reduced sewer discharges?


The introduction of Drainage and Wastewater Management Plans could potentially drive better outcomes for customers and communities as well as for the environment. CCW is supportive of a holistic approach to the planning and management of surface drainage, wastewater and flood management. However, the potential cost of the investment needed for this could be significant, meaning that the prioritisation and targeting of this investment will be key to delivering best value for consumers. 


From the outset of its introduction, the requirement to produce plans should identify where the worst problems exist, so that sewerage companies can develop targeted, effective and affordable investment plans that deliver real improvements for those who suffer from flooding, as well as to our rivers and coastal waters. Longer-term plans exploring natural solutions – including increased treatment / pumping capacity where needed – should help to reduce storm  water overflows and sewer discharges, but may come at a significant cost to customers, so should be prioritised accordingly.


  1. How adequate are the monitoring and reporting requirements around water company discharges? How can technology improve and assist with transparency and enforcement?


The Storm Overflows Taskforce – made up of Defra, the Environment Agency, Ofwat, CCW, Blueprint for Water and Water UK – has agreed to set a long-term goal to eliminate pollution from storm overflows.


Following recommendations from the Taskforce, water companies have also committed to increase transparency around when and how storm overflows are used. Originally, storm overflows were designed to be used during extreme weather, releasing diluted wastewater into rivers rather than allowing sewers to become overloaded with a combination of sewage and rainwater, which would ultimately back up into people’s homes. Climate change and development growth has meant that these overflows are now being used much more frequently than originally intended.


Water companies have agreed to make real-time data on sewage discharges available at bathing sites all year round, meaning that surfers, swimmers and other water users can check the latest information – especially after heavy rainfall. Water companies have also committed to accelerate their work to install monitoring devices to storm overflows, with the intention of creating a more complete picture of their activity by 2023.


The Storm Overflows Taskforce has also agreed with water companies that they will publish annual monitoring data on their websites, detailing their use of storm overflows so that progress in reducing their use can be tracked. The Environment Agency will compile this data into an annual report that is easily accessible to the public.


Transparency is important and for this reason, we agree that this monitoring data should be published.

However, doing so will raise people’s expectations that any environmental damage being caused will be addressed. While the frequency and duration of storm water discharges is an important factor in determining the prioritisation / targeting of investment, it is just one factor that affects the overall quality of the receiving waters. Looking at the holistic picture of all factors affecting water quality, as well as working in collaboration with all key stakeholders and potential partners, will be key to water companies tackling this issue effectively.


  1. What is the impact of plastic pollution and other materials on drainage and water quality in rivers and what should be done to mitigate it?


While consumer awareness of the impact of plastic pollution and sewer blockages from wet wipes has been boosted significantly by high-profile media coverage, there’s still a long way to go to ensure long-term behaviour change. It’s not just about wet wipes and drinking straws either – items like contact lenses, sanitary products and micro-plastics from scrubs and laundry detergents all contribute to this issue, which many consumers don’t realise.


CCW has worked with the water sector to develop the ‘Fine to Flush’ accreditation, but this work needs to continue in order to mitigate the ongoing impact on drainage systems and water quality. Manufacturers need to continue the work to produce a whole range of compliant products and develop clearer “Do Not Flush” labelling to avoid non-compliant items being flushed.


It is CCW’s view that all products that make their way into the sewerage system should be Fine to Flush. 

  1. How can consumers be persuaded to change their behaviour to minimise pollution?


If consumers understand the problem, they are more inclined to take action, and that’s why we think that a national, cohesive effort must be made in order to raise consumer awareness of the impact individual actions can have on our sewers, rivers and streams. This relates both to responsible use of sewers and wider water efficiency efforts.


To date, efforts to coordinate an industry-wide campaign have not been as successful or impactful as they need to be. It’s our view that the water industry should be funding and leading a long-term, national communications campaign to bring about the behaviour change we need to see in this area. This campaign would also benefit from the involvement of product manufacturers, retailers and Environmental NGOs. On an individual basis, water companies need to make more concerted regional and local efforts to tell their consumers what they are doing to minimise blockages and pollution of local waterways.


CCW continues to actively support joint campaigns and we are seeking to build coalitions to take a greater leadership role in this area.


  1. What is the required investment level needed to minimise storm overflows vs the scope for sustainable drainage and nature-based solutions?


CCW is an active member of the Storm Overflows Taskforce, which is currently in the process of gathering more data on costs and solutions. While we know that the investment level required will be high, it is too early to provide accurate figures.


  1. How effective is Ofwat’s remit and regulation of water companies? Does it facilitate sufficient investment in improvements to water quality, including sustainable drainage systems and nature-based solutions such as constructed wetlands?


Environmental legislation, government policy and regulation all help to determine what environmental standards water companies are required to meet. A programme of investment is proposed and agreed through company business plans developed at each Price Review.


It is right that Ofwat seeks to ensure the best value for water customers by challenging companies’  efficiency. The Water Industry National Environment Programme (WINEP) represents a significant component of the companies’ business plans and is developed in close collaboration with water companies and regulators. It is left to companies, however, to explore and propose nature-based solutions and is not prescriptive as to what should be considered and / or included.


While customer engagement tends to show support for nature based solutions, ultimately some technical expertise and judgement is required to determine whether this would satisfy requirements. At the 2014 Price Review (PR14), Ofwat changed its approach by introducing the Totex measure in order to avoid any bias towards investment in end-of-pipe engineering solutions rather than the more environmentally-friendly catchment management type approach. This approach is still developing, so it is important that the industry continues to share learnings and good practice from its successes.


To improve the effectiveness of its remit in this area, Ofwat should ensure water companies actively engage and forge local partnerships when developing their Drainage and Wastewater Management Plans. These partnerships should be encouraged to find the most sustainable and resilient local solutions, while identifying other funding schemes available. Again, the balance between affordability and ambition is crucial here.

  1. Is adequate investment being made in adapting water treatment systems to future climate change?


Investment in adaptation to climate change has clearly been inadequate, given the performance issues highlighted by the Environmental Audit Committee (EAC). Furthermore, continued climate change and population growth will put these systems under even greater pressure over time unless appropriate action is taken.


The development of Drainage and Wastewater Management Plans (DWMPs) should start to improve water companies’ approaches to this, however there is a definite need to join up companies’ long-term plans in order to manage water supply, drainage, waste water and flooding more holistically on a national level.


CCW sees climate change adaptation plans as an opportunity for water companies to explain the overall picture and strategy to their customers. We are encouraging companies to make the most of this opportunity through working in partnership and sharing good practice.


  1. How could the designation of inland bathing waters by water companies affect the costs of achieving the associated water quality standards?


Designation of bathing waters is controlled by the Government, rather than by water companies.


The costs of achieving water quality standards would potentially rise if local sewage / water works are impacting water quality in a stretch of river that has designated bathing water status. It is also important to note that designation only applies to a specific stretch of water, but factors at play further upstream may ultimately affect the water quality, for example. farm silage, livestock or other potential pollutants. That’s why we at CCW advocate a partnership approach as while water company activity does have a potential impact it is not the only thing effecting river water quality. Partnership working between local stakeholders is key to achieving higher water quality standards for inland waterways.



February 2021