Technical Development Services, and WA Consultancy              WQR0073

 

 

Written evidence submitted by Technical Development Services, and WA Consultancy

 

As Independent Consultants we welcome the Committee’s call for evidence relating to a matter of such fundamental importance.

During the last 6 years W A Consultancy Limited, (WAC) working with Technical Development Services (TDS), have been retained by numerous UK House Builders to provide technical advice and guidance on a range of issues. More recently this has been specific to matters centred on water & sewerage infrastructure provision, especially the fallout from the ongoing reforms that are taking place in the Water & Sewerage Sector.

Principal Partners of respective Consultancies have a combined level of technical experience in excess of 85 years, with both having held influential Technical Director positions at major UK house builders throughout their careers. Our combined skill set covers:

 

High level engagement with Defra, HM Treasury, MHCLG, Ofwat, Water UK and CCWater completes the skill set. In addition, TDS also has a dedicated Self-lay Utility business, inclusive of water infrastructure provision for new developments.

The range of Clients covers the full spectrum of Developers from SMEs to Major House Builders. More recently, and as a direct consequence of Ofwat’s reforms taking place in the Water & Sewerage Sector, a growing number of Engineering Consultants retained by House Builders have also sought specific guidance and advice on issues relating to the adoption of SuDS infrastructure and how best to deal with the barriers to adoption being presented by several Sewerage Companies 

1.0     INITIAL COMMENTS & OBSERVATIONS

 

1.1     Having considered the Committee’s terms of reference there are several areas where we believe we can provide important contributory evidence informed by our extensive experience in the ‘field’. Moreover, we fully recognise the fundamental importance of each of the areas under consideration but there is perhaps one crucial aspect that does not appear to feature. Each area identified by the Committee is intimately interconnected and therefore requires the application of a holistic but structured approach if unintended consequences are to be avoided, i.e., by working from the whole to the part and not the reverse. The concept of the ‘Golden Thread’, as defined by Dame Judith Hackitt in her Final Report – ‘Building a Safer Future’ (May 2018), represents an approach we would support.

 

1.2     In our view, the quality and veracity of both the evidence and science underpinning our present approach to water quality needs to be interrogated far more rigorously, especially if we are to avoid the imposition of subjectively determined (and conceivably) unnecessary mitigation requirements.

 

1.3     Finding the right balance between scientific rigour and engineering pragmatism, cognisant that there will be a need for sensible compromise, is perhaps an appropriate starting point when considering how best to achieve our water quality objectives. The source, pathway, receptor concept is a useful approach. Likewise, taking note of what assistive quantitative and qualitative data already exists. For example, British Geological Survey (BGS) mapping(1) that provides details of the prevailing geo-chemistry of the UK’s indigenous rocks, soils, and stream sediments – see later evidence.

 

1.4     It would help those involved in the development process if extant and relevant guidance were to be first crystallised rather than resort to emerging ad hoc guidance sometimes conceived by self-interest groups. This would represent a first step on the road to much needed consistency, whilst also reflecting on how best to respond to regional/local variations. Secondly, how research findings are reviewed and by whom. Thereafter, the management of transitional arrangements for the introduction of new and/or revised guidance will be a key consideration. As a suggestion, a dedicated cross-interest Water Quality - National Review Group could fulfil this function, with its recommendations and transitional arrangements effectively sanctioned by Defra, and/or MHCLG. Moreover, written Ministerial Statements could play a significant part in communicating both changes in national guidance and its implementation - a process that normally accompanies the issuing of revised national planning guidance. As a suggestion, a ‘Task and Finish Group’ approach, with a primary focus on all aspects of water quality, could be an effective delivery vehicle if allowed to function within a National Review Group. There is a pedigree of success in following this concept, but the underlying ethos must be to focus on what is practically achievable rather than an academic theory.

 

1.5     The starting point for any structured approach must be a clear and unequivocal statement of respective statutory roles and responsibilities, including the overarching legislation that defines who is responsible, and for what, both in terms of developing quasi-statutory guidance and for the necessary investment in improved infrastructure – see later comments.

 

1.6     In terms of water quality per se, information in this regard is sporadic with most adopted Strategic Flood Risk Assessments, as completed by Local Planning Authorities, frequently deficient in water quality data for many of the watercourses for which the Lead local Flood Authority (LLFA) have a statutory responsibility both to effectively manage and control. This is a key area to be addressed if we are to remove continued reliance on the application of subjective criteria. 

 

There follows an evidence-based commentary on each of the areas identified.

 

2.0     Best Indicators for River Quality

 

2.1       There is no substitute for the actual testing of river water quality. That said, data held by the Environment Agency tends to be insufficient both in terms of content and spatial distribution across the UK. In previous discussions the EA has advised, albeit verbally, that following crude water quality evaluations in the North of England involving the River Calder catchment, it has no issue with the quality of surface water run-off from new residential development. The EA’s main concern(s) centre on the wider urban environment and the uncontrolled surface water pollutant loading from agriculture – the latter being an issue currently affecting water quality in the Solent to the extent that excessive eutrophication (algal growth) is evident in coastal waters .

 

2.2       Whilst water quality data/information may exist principally for main rivers, when it comes to minor watercourses governed by the LLFA, the situation is markedly different. In these instances, we have encountered a paucity of information relating to both watercourse hydraulic performance and prevailing water quality. From our experience, it is quite clear there are resource issues within most LLFAs and IDBs affecting their ability to provide adequate, representative, and reliable qualitative and quantitative information capable of informing any site-specific flood risk assessment (FRA) – a situation that has to be better addressed.

 

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(1)     https://www.bgs.ac.uk/information-hub/publications/regional-geochemical-atlas-series/

Moreover, several LLFAs do not discharge their statutory obligations under the Land Drainage Act 1991 (as amended) when it comes to ensuring Riparian Owner responsibilities in terms of effective watercourse bank and channel maintenance is undertaken. Likewise, that there is effective management and control of polluted surface water run-off from the agricultural industry. This underlines the importance of first defining respective roles and responsibilities. In addition, whilst focus is being maintained on Nitrate and Phosphate levels in our ‘main river’ systems, other chemicals and residual pharmaceutical products are also becoming an issue. This needs to be captured in any sustained monitoring and management programme. Likewise, the impact of mine-water pollution given most subterranean pumping from old mine workings ceased quite some time ago. (See January 2021 flooding as a result of Storm Christoph and the resultant contribution to above ground flooding due to flooding in abandoned former mine workings in Goshen Park, Skewen, Wales).

 

2.3       In a more general context and reflecting upon our collective experience, the content and quality of Local Planning Authority Strategic Flood Risk Assessments needs to be improved so as to include data specific to the underlying water quality of those water bodies over which the LLFA/LPA has jurisdiction.

 

2.4       We have often advocated that the approach to determining water quality should mirror that which underpins the contaminated land regime, namely, the undertaking of a desk study, together with the preparation of a conceptual plan covering the catchment/area under consideration. In a new development context, especially involving the remediation of brownfield land, contaminated land considerations and water quality are two aspects that are interdependent and inter-related. For example, when considering possible options for SuDS infiltration drainage against the prevailing hydro-geological setting of a site and the transient nature of any groundwater that could so easily lose its benign statusThis first stage can evaluate available evidence and guidance, which in turn can help inform an appropriate investigation, testing and management regime. Furthermore, it provides an effective early stage in providing the necessary evidence relating to water quality, including that of groundwater. Likewise, the potential impact on Source Protection Zones specific to potable water abstraction and Nitrate Vulnerable Zones.

 

2.5       As part of the initial desk study British Geological Survey (BGS) has produced a series of geo-chemistry maps covering the majority of England. Each of these maps provides information relating to the level(s) of ‘contaminants’ contained in naturally occurring rocks, soils and most importantly, stream sediments. Whilst not all contaminants are included it is a useful reference starting point. Moreover, given that there is nothing we can do about the presence of naturally occurring contaminant levels and their leachability into the water environment, the BGS data, supplemented with any held by the Environment Agency provides a useful water quality benchmark.

 

2.6       The information gathered in this first phase could become an integral part of any Strategic Flood Risk Assessment, irrespective of whether it is at level 1 or 2. Likewise, Water Resource Management Plans, which were supposedly introduced in response to one of the keynote recommendations of the Final Pitt Report of June 2008. In addition, it would help eliminate those considerations regarding water quality over which there is little to no control. For example, several Highway Authorities allow the grass cuttings from highway verges to accumulate in the highway channel to be subsequently washed into road gullies. With extended periods before road gullies are emptied organic degradation and therefore increased surface water contaminant potency will be the outcome.  Moreover, localised flooding in January 2021, as a result of storm Christoph, was directly attributable to poor highway/road gully maintenance.

 

2.7       This again takes us back to the importance of defining respective roles and responsibilities and for the Committee to perhaps evaluate and consider the statutory maintenance responsibilities of Highway Authorities, LLFAs, Riparian Landowners etc., in addition to those of the EA.

 

3.0     DRAINAGE & SEWERAGE MANAGEMENT PLANS – A MEANS OF REDUCING SEWER DISCHARGES

 

3.1       In our view Drainage and Sewerage Management Plans should be a mandatory requirement for all Water & Sewerage Company business plans.

These should not only be approved by the Regulator, Ofwat but more robustly audited. However, it is essential that water usage becomes an integral part of any ‘management plan’. Water in effectively equates to water out, albeit established evidence shows that around 90% to 95% of water supplied actually results in foul sewage discharge.

 

3.2       As of 1st January 2021, Water Companies introduced their respective assessments for water demand from new residential dwellings – see chart 1. The first thing to note is the staggering variation in Company determined demand profiles. Moreover, based on established design conventions the daily demand from a new dwelling should ordinarily be around 550 litres/dwelling/day, after allowing for a sensible factor for peak flow. As can be seen, 16 Water Companies are effectively over-estimating demand and therefore the likely effluent discharge.

 

 

 

 

(Chart 1 – Water Company Assessed Daily Water Demand for a New Dwelling)

 

 

3.3       As initiatives evolve to reduce potable water consumption, largely driven through changes to the Building Regulations (AD ‘G’), this must be better recognised by the Water & Sewerage Sector and reflected in any assessment of network capacity and/or wastewater treatment works requirements.

 

3.4       That said, reduced water use leads to the unintended consequence of reduced domestic foul drainage flows. Research undertaken by the NHBC Foundation(2), in conjunction with WRc, Severn Trent Water, Defra and BPF revealed a progressive reduction in water use had the propensity to compromise the hydraulic performance of domestic foul drainage systems. It has been shown that discharges form baths and showers have insufficient flow velocity/energy to move solids within the drainage system. The discharge from WCs being the principal motive force but as the pressure increases to reduce WC flushing to less than 4 litres, domestic foul drainage systems are at risk of ineffective operation leading to potential blockage and resultant sewer flooding. As we pursue the objective of reduced water consumption to 80 litres/person/day we should we not lose sight of the importance of effective external drainage performance – an area that may need more detailed investigation. 

 

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(2)    Report No P7904: The Effect of Reduced Water Usage on Sewer Solid Movement in Small Pipes (October 2009)

3.5       Importantly, Section 94 of the Water Industry Act 1991 remains of fundamental importance as it defines in unequivocal terms the statutory responsibility imposed on all Sewerage Companies. However, the Developer Community continues to experience the consequences of a lack of infrastructure investment by Water & Sewerage Companies, inclusive of effective asset maintenance, in response to the statutory obligations imposed by S94.

 

3.6       In terms of reducing surface water discharges into public sewers and/or water bodies per se, the current approach to achieving this objective, i.e., through the planning process, makes a positive contribution. However, matters would be greatly improved if Sewerage Companies became responsible for the adoption of all surface water sewerage infrastructure – as we originally advocated prior to publication of the 2008 Pitt Report. Moreover, whilst certain Sewerage Companies are offering discounts on sewerage infrastructure charges paid by Developers and relating to the provision of SuDS infrastructure, these discounts remain both discretionary and nominal. The same applies to voluntary water usage reduction with several Water Companies offering water infrastructure charge discounts that do not offset the construction cost of meeting reduced per capita water consumption below current Building Regulation requirements.

 

3.7       Rainwater Harvesting (RWH) is considered by many to be a concept worthy of being a mandatory requirement. However, research by NHBC Foundation has flagged that RWH has a high energy/carbon footprint and is less of a sustainable solution many are not prepared to accept. Moreover, if the Government’s crystallised policy is to include embodied carbon counting as the primary net zero carbon metric, then RWH ceases to be a likely consideration. In addition, poor management, and maintenance of RWH systems may well exacerbate the pollutant loading of effluent discharges. Furthermore, there are wider public health issues associated with this alternative. Likewise, greywater recycling – see CDM Regulations and the statutory role of Principal Designer when it comes to public health and safety.  

 

4.0     MONITORING & REPORTING OF SEWERAGE COMPANY DISCHARGES

 

4.1       As we witnessed with the £123 Million penalty imposed by Ofwat(3) on Southern Water (10th October 2019) for repeatedly falsifying wastewater treatment/discharge records, there is considerable work to do in this area. Moreover, in their latest report(4) specific to Water and Sewerage Company environmental performance for 2019 (2nd October 2020) the EA voiced their concern at the increasing level of ‘sector’ pollution incidents, especially from Wastewater Treatment Works (WwTWs). Furthermore, in their October 2019 statutory decision notice, Ofwat confirmed Southern Water had failed in its responsibilities as defined by Section 94 of the Water Industry Act 1991. However, what is mystifying about Ofwat’s position as the statutory Regulatory Body, is not only their lack of stern corrective action/intervention but the fact that there is little evidence in their PR19 Final Determination for Southern Water that made the necessary funding available to ensure Wastewater Treatment Works operated as they should. In our view, Ofwat should be called upon ensure:

 

 

 

 

 

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(3)     Ofwat’s final decision to impose a financial penalty on Southern Water Services Limited (10th October 2019)

(4)     Water and sewerage companies in England: environmental performance for 2019 (2nd October 2020)

All CSO locations should be readily identified, inclusive of their potential pollutant loading, and progress on foul/surface water separation audited and reported by Ofwat.

 

 

4.2       It is accepted that effluent from new residential development contains nitrates and phosphates but by far the biggest contributor of respective pollutants, and therefore potential eutrophication of sensitive water receptors, is the agricultural industry. In many respects, House Builders and Developers are dependent upon Sewerage Companies meeting their WwTW effluent quality standards as there is no other effective and/or sustainable means readily available to Developers. Moreover, with house builders having paid around £2.8 Billion to Water & Sewerage Companies in the guise of Infrastructure Charges since sector privatisation in 1989, it is not as though Developers have not provided a substantial part of the necessary investment funding. These contributions are continuing at around £75m+/annum, but until becoming a mandatory requirement in April 2018, income versus expenditure reconciliations were never undertaken either by the companies themselves or Ofwat. Classed as general income, in the absence of definitive evidence to the contrary, there is nothing to prevent one concluding that these contributions may well have funded shareholder remuneration rather than infrastructure investment, especially when it comes to WwTWs and where greater focus must be applied on reducing nutrient levels in wastewater effluent.

 

5.0     IMPACT OF PLASTIC POLLUTION

   

5.1       This is not so easily dealt with given the ubiquitous nature of nano-plastics. It is known that these materials have an adverse effect on aquatic life and can enter the food chain. There is a compelling need for improved research and development if we are to develop not just options for possible reduction, but how these materials can be better screened-out at WwTWs or preferably reduced at source. Better and smarter regulation that seeks to remove our reliance on single use plastics also needs to be given far greater weight.

 

6.0     CONSUMER ATTITUDES

 

6.1       This is perhaps one of the more difficult aspects given societal reluctance to change. The one positive to report is the effect that water metering in new homes has on customer attitudes to water usage. Introduced in 1990, there are around 5.5 million homes that now have a metered water supply. The evidence is unequivocal that metered properties use significantly less water. However, the progression towards all-round compulsory metering is far too slow. Likewise, Water Company attitudes towards the introduction of truly smart metering whereby homeowners can have access to immediate water use data via a discrete ‘smart’ display in the home/kitchen. Further details of a system being trialled by a major house builder, working alongside United Utilities (UU) can be found by contacting United Utilities Developer Services. One of the distinct advantages of the UU system is that it flags almost immediately out of pattern water use. One of its many benefits lies in the fact that real time water use data is visible to United Utilities at the same time as the homeowner. It is therefore seen as a responsive and effective contribution to leak detection, in addition to being able to better communicate water use outcomes with the consumer and to provide further advice on how to reduce water consumption.

 

6.2       In our opinion, Ofwat should better incentivise Water Companies to invest in truly smart water metering. In addition, compulsory metering should be mandated by Ofwat with dedicated funding provided as part of each Company’s 5-year Asset Management Plan (AMP) accompanied by better reporting of what has been achieved against targets that have been set. A structured, quantitative approach to compulsory metering should be applied targeting those consumers with the greatest water demand/usage.

 

6.3       More extensive metering from collection source to the point of delivery will thereafter provide better water use data. It will also provide an improved means of assessing the nature and extent of future infrastructure investment, inclusive of leak detection and repair. Leakage currently stands at 130 litres/dwelling/day (2018/19) as reported the Government’s Public Accounts Committee with no real time evidence available to suggest improvements are taking place.

 

7.0     INVESTMENT TO MINIMISE STORM OVERFLOWS Vs NATURE-BASED SOLUTIONS

 

7.1       Section 21 of the Water Act 2014 empowered Sewerage Companies to construct and operate sustainable drainage systems as part of their Section 94 statutory obligations to effectually drain their area. This captures the ability to consider the provision of natural surface water attenuation systems. That said, there was little evidence of either a commitment or direct capital investment in such proposals in Ofwat’s December 2019 PR19 Final Determinations for each Water & Sewerage Company - PR19 constitutes the Sector’s business plan covering the period 2020 to 2025, as approved by the Regulator, Ofwat.

 

7.2       We would welcome far greater pressure being applied on all Water & Sewerage Companies to first identify the more serious CSO locations/incidents and for these to be the subject of more specific investment to facilitate separation using a suite of sustainable drainage options, including natural SuDS infrastructure.

 

7.3       With regard to natural SuDS infrastructure, the strategic location of such will necessitate Sewerage Companies working far more closely with Local Planning Authorities to identify possible solutions at the local plan/strategic plan stage, especially when land for new housing allocations is being considered. 

 

7.4       In tandem with the above the Water and Sewerage Sector has to begin to play a more influential role in the planning process by committing to the following as an integral part of the strategic planning process:

 

 

 

 

7.5       In the past, the Water & Sewerage Sector (through its trade association Water UK) has reported that it has little faith in the local plan/strategic plan process, especially when it comes to new housing provision. In our view, adopting the approach advocated in paragraph 7.4 would go a long way to resolving the Sector’s lack of ‘faith’ whilst simultaneously providing the necessary transparency to enable planning and investment decisions to be made by affected partner and stakeholder interests. It would also help negate sectoral fears about stranded water and sewerage assets, i.e., infrastructure that is provided but left unused for any length of time.

 

8.0     PLANNING POLICY VERSUS SuDS INFRASTRUCTURE TO REDUCE URBAN DIFFUSE POLLUTION

 

8.1       Based on our collective experience SuDS infrastructure has played an important part in the effective  management and control of surface water run-off. Moreover, it is not a new concept as the photographic example from the late-1970’s depicted demonstrates.

 

 

 

 A grassy area with trees in the background

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8.2       The example pictured mirrors the current approach to SuDS, as advocated in the present edition of the CIRIA SuDS Manual. It shows the combination of SuDS and public open space working in harmony to provide an effective surface water drainage solution. At the time of its construction, adoption and future maintenance was undertaken by the Local Authority in their capacity of Sewerage Authority, and without payment of a commuted sum for future maintenance.

 

8.3       Following Sector privatisation in 1989 there has been a perceptible decline in sewerage infrastructure investment. Reduced sewer capacity, coupled with an ineffectual response to national census population data by the Water & Sewerage Sector, has introduced quite severe constraints, especially when it comes to public surface water sewer capacity. If we add into the mix the additional dynamic of climate change, Water & Sewerage Sector investment has not kept pace with our national infrastructure needs. The response from the Development Community has been a default requirement to design and construct a differing array of surface water attenuation systems, both above and below ground, in response to Water & Sewerage Sector capacity limitations. In addition, on numerous residential developments, surface water infrastructure, other than piped systems, have been utilised wherever this has been possible.

 

8.4       What is lacking has been clear direction and representative guidance on water quality data, including that relating to groundwater. Likewise, the underlying quality of many receiving water bodies. This information is vital if we are to enhance the surface water drainage strategy for almost all sites – see earlier  comments.

 

8.5       If water quality is to be a key consideration, then much improved data must become available at the crucial land acquisition due diligence stage – the point at which layout and development principles begin to crystallise. In addition, it must form part of any Local Planning Authority’s SFRA and/or Water Cycle Study/Surface Water Management Plan. However, reference to the ‘scatter diagram’ accompanying our submission contextualises how uncoordinated and poorly communicated our approach to water and sewerage matters in general has become. The conviction to improve exists but effective leadership is lacking. 

 

9.0       HIGHWAY AUTHORITY ROLE IN PREVENTING POLLUTION

 

9.1       As referred to earlier in our submission, previous discussions with the EA concerning the quality of surface water run-off from new residential developments points to this not being the problem many perceive it to be.  Moreover, given the Government’s commitment to electric vehicle charging the risk of potential hydrocarbon pollution on these developments is set to reduce That said, based on our experience it has never been the problem many considered it to be, especially given the increasing provision of permeable paving.

 

9.2       The main concern, so we understand from the Environment Agency, is the urban environment per se and the surface water pollutant loading it contributes. Likewise, the uncontrolled discharges from the Agricultural Industry. However, what would help is a much-improved commitment from all Highway Authorities to undertake more regular road sweeping and gully emptying. Sadly, this is no doubt compromised by a lack of dedicated funding through Council Tax receipts. 

 

9.3       On 1st October 2020, Ofwat introduced ‘Codes’ for the adoption of sewerage assets under the provisions of S104 of the Water Industry Act 1991. Unilaterally, from this date almost all Sewerage Companies started to refuse to adopt sewers constructed under permeable paving, irrespective of whether such construction is a LLFA/LPA planning requirement. This decision by the ‘Sector’ and one currently being upheld by a Regulator (Ofwat) reluctant to get involved, is not only counter-intuitive to the collective need to apply sustainable construction principles, but it overturns a construction practice that has endured for nearly three decades. The raison d’etre for this change in attitude by Sewerage Companies is to mitigate what the ‘Sector’ perceives to be expensive reinstatement costs in the event that a subsequent  sewer repair becomes necessary. The Sector has produced no evidence to support its position but conversely, we can provide evidence that demonstrates just how infrequent such actions really are. In addition, Sewerage Companies are ignoring the technological improvements when it comes to the relining/refurbishing of existing sewers. 

 

10.0      Ofwat as an Effective REgulator

 

10.1         One of our principal concerns is Ofwat’s preference for a light touch regulatory approach when it is quite clear that greater intervention and prescriptive direction is called for. The earlier cited example of Southern Water being a case in point. In our view, after 32 years of sector privatisation, and taking cognisance of our wider environmental responsibilities, together with how we are to deal more effectively with the consequences of climate change, there is a compelling need for a root and branch review of Ofwat’s role.

 

10.2         As we have witnessed with Ofwat’s PR19 final determinations we have reservations regarding Ofwat’s commitment to infrastructure investment.

 

 

11.0      ADEQUATE INVESTMENT IN WATER TREATMENT SYSTEMS

 

11.1         Evidence points to an imbalance when it comes to ‘Sector’ investment in response to both demographic change and environmental challenge. The most recent report from the EA cites a growing number of pollution incidents, many associated with Sewerage Company WwTWs. In our view effluent quality standards need to be monitored on a more regular basis and the outcome(s) reported as part of an annual performance review of the Water and Sewerage Sector. 

 

11.2         When considering infrastructure investment needs Ofwat must take a more active stance in ensuring Sewerage Companies have the financial resources to meet their wastewater treatment obligations. Moreover, WwTW performance needs to be reported on a more transparent basis than at present. Simply reporting what investment has taken place without aligning this investment to a particular issue needing to be addressed is not the answer. Addressing these issues on a quantitative and qualitative basis must be the way forward. But first, the issues to be addressed and the financial quantum involved in effecting a satisfactory resolution must be measured/determined. (You can only begin to manage what you have measured).

 

11.3         Ofwat need to be encouraged to report in greater detail the source of Water and Sewerage     Company income streams and how these in turn have been invested. Ofwat’s New Charging Rules, effective from 1st April 2018 are a step in the right direction in terms of reconciling developer paid water and sewerage infrastructure charges versus in-consequence infrastructure investment, but this concept must be extended to other areas of income/expenditure. 

 

11.4         Water leakage continues to be an issue. It is now more than a perception that a substantial part of the 130 litres/dwelling lost each day is finding its way into foul drainage systems and therefore CSOs. Similarly, high volumes of groundwater entering foul sewers as a result of progressively deteriorating asset integrity. Moreover, we have evidence from at least 4 Sewerage Companies identifying the underlying condition of foul sewers is so poor that their hydraulic capacity is being assessed as though they are surface water sewers. The volume associated  extraneous inflow through cracked and poorly jointed sewers will be having an adverse effect on WwTW capacity and therefore the effectiveness in terms of meeting treated effluent quality standards. It is a fundamental issue and one that must be better dealt with both by Ofwat and Sewerage Companies, respectively.

 

12.0      BATHING WATER QUALITY STANDS VERSUS WATER COMPANY INVESTMENT  

 

Our experience in this area is limited but it makes eminent sense for established water quality standards to inform local drainage strategies, Likewise, targeted infrastructure investment, i.e., applying the concept of being able to effectively manage what is measured. See also our earlier comments regarding the role of the planning process and how this is a receptor for crucial water quality information when formulating planning and development policy.

 

SUMMARY

 

Whilst the recent reforms in the Water and Sewerage Sector are welcome, Ofwat’s role as an effective Regulator is disappointing. We do not believe a light touch regulatory approach is the way forward, especially when managing privatised monopoly companies that have crucial statutory roles and responsibilities. Across the globe, the UK is one of only two countries that have a privatised water and sewerage industry, and in our opinion, closer/tighter regulatory control is essential.

 

The Nitrate issue in the Solent is having a dramatic effect on the delivery of new homes with the construction of over 12,000 dwellings effectively held in limbo pending resolution of an issue that is largely attributable to the Agricultural Industry.

 

It is reasonable to presume that Sewerage Companies will fully discharge their Directive/Statutory responsibilities but in terms of providing the necessary wastewater treatment capability and capacity clearly this is not the case for certain Sewerage Companies. In response to the ‘nitrate’ issue affecting parts of the South Coast, Developers are now being coerced into paying up to £6000/dwelling towards nitrate mitigation measures in order to get house building under way. Conversely, Ofwat accept that Southern Water has defaulted on its Section 94 obligations at several WwTWs but considers it has no jurisdiction to deal with the issue by appropriate fiscal intervention – we find this of some concern.

 

The Local Planning Authorities concerned are demanding that any new development must be able to demonstrate that it is nitrate neutral – this is not so easy. The provision of site-specific wastewater effluent treatment, as part of the infrastructure associated with new development, is not a sustainable solution on many counts. For example, consider the energy/carbon footprint of a localised wastewater treatment process. Similarly, the final effluent quality on receiving groundwater and water bodies in general.

 

Since the Public Health Act of 1875, Sewerage Authorities have been required to provide the necessary infrastructure and wastewater treatment capacity. Moreover, since Sector privatisation in 1989, House Builders have also contributed nearly £1.5 Billion in sewerage infrastructure charges that could so easily have been invested in WwTW improvements rather than be directed towards shareholder dividends.

 

The Water and Sewerage Sector per se remains disjointed and fragmented whilst lacking any holistic direction. If we are to make a positive difference, then the Sector’s current approach has to change. Inconsistency prevails and it is clear that leadership and effective direction is called for.

 

In closing, should the Committee seek further evidence or input we are more than willing to do so. 

 

S E Wielebski                                                                                                             

Principal Partner

W A Consultancy Limited  

R Farrow

CEO

Technical Development Services 

 

February 2021