Written evidence submitted the Environmental Treatment Concept Ltd
1. Executive Summary
1.1. There is a highly significant but largely overlooked factor that negatively impacts upon Energy Efficiency of Existing Homes for c.60% by geography (c.70% by population) of the United Kingdom (UK) – Hard Water Limescale.
1.2. This evidence is submitted by Environmental Treatment Concept Ltd (ETC). The company has been successfully treating hard water limescale since 1989 with sustainable, non-chemical, electronic Physical Water Treatment (PWT) systems. Founded by and employing ex-Royal Navy engineers, ETC provides bespoke system designs that optimise the effective treatment as opposed to other suppliers of similar technology without the specialist knowledge, who merely sell boxes and fail to achieve the results.
1.3. Significantly, ETC were engaged as the preferred supplier to the Ministry of Defence (MOD) £1.3Bn Single Living Accommodation Modernisation project (Project SLAM). Having studied the options for treating the accommodation blocks and the relative Whole Life Costs (WLC), the prime contractor, Debut Services Limited, a joint venture between Lendlease and Babcock Support Services, calculated that, compared to using traditional salt water softeners, ETC’s technology saved the MOD £75 million.
1.4. The extent of hard water in England and Wales is published by The Department for Environment, Food and Rural Affairs (Defra) at this Link and is referred to in the Drinking Water Inspectorate paper on Water Hardness at this Link.
1.5. All water companies publish figures for water hardness within their bailiwick but give little advice or assistance for combating its effects. There are a range of regulations, guides, certifications etc. that attempt to deal with energy efficiency, but all are either scant in their coverage of hard water at best, or at worst, remiss by completely omitting this important factor in their content. These include:
1.5.1. Building Regulations, that are informed by
1.5.2. Building Services Compliance Guides (Domestic & Non-Domestic)
1.5.3. Energy Performance Certificates (EPC)
1.5.4. Building Research Establishment Environmental Assessment Method (BREEAM)
1.6. As a result, energy efficiency, carbon reduction and climate change targets are undermined by this neglect.
1.7. Two major factors mitigate against the effective consideration of hard water limescale and its effect upon energy efficiency:
1.7.1. The variation in levels of hard water across the country presents an obstacle to giving guidance applicable to all areas, and
1.7.2. The lack of a regulator responsible for dealing with it. Neither of the regulators that might naturally be candidates, Ofgem and Ofwat, have been given the responsibility and do not recognise hard water as an energy efficiency issue and therefore ignore it.
2. Building Regulations
2.1. Among the references informing the content of Building Regulations are:
2.1.1. Domestic Building Services Compliance Guide, and
2.1.2. Non- Domestic Building Services Compliance Guide
2.2. The Domestic Building Services Compliance Guide (Link) does make mention of water hardness and limescale but is not sufficiently detailed to address the issues. The first failure is to not distinguish between Primary (closed loop) & Secondary (open loop) systems as these are affected very differently by limescale. The second is to not specify the elements to be measured in determining the need for treatment.
2.3. A Primary, closed loop system is filled with water on installation and to prevent water stagnating must be ‘conditioned’ using chemicals. However, as it is only filled once, the level of influence hard water has is very small, is mitigated by the conditioning and therefore has no significant scaling issue.
2.4. A Secondary, open loop system is constantly replenished with mains water and provides potable water for domestic use that is finally flushed away to the sewers. As it is potable, it cannot be treated by chemical means. It can be ‘softened’ to prevent limescale but in this case the water again becomes not potable and a separate drinking tap needs to be installed. More information on the handicaps of water softening follow below.
2.5. The guide states:
‘Where the mains total water hardness exceeds 200 parts per million, provision should be made to treat the feed water …… to reduce the rate of accumulation of limescale.’
This statement is negligent in not specifying the units of measurement.
2.6. Among the six measures widely used for water hardness there are only two that use parts per million (ppm) or the direct equivalent of milligrams per litre (mg/l). These are for Calcium (Ca) and Calcium Carbonate (CaCO3) and are very different atomic weights and therefore different measures.
2.7. Water companies and the vast majority, if not all other authorities dealing with water hardness, recognise that the standard measure is ‘as CaCO3’. However, through ignorance or trying to work around the guides for whatever reason, someone can, because of the loophole in the guide that does not specify CaCO3, ask a water company if the water supply is greater than 200 ppm of Calcium. In this case they will get a much lower reading and thus satisfy themselves that treatment need not be provided. ETC had precisely this experience with a certain city’s finance department.
2.8. The solution is quite simply to insert the amendment ‘… exceeds 200 parts per million (as CaCO3) …’.
2.9. The Non-Domestic Building Services Compliance Guide (Link) fails to mention or address the issue at all and urgently needs to have copies of the guidance inserted from the domestic guide.
- Energy Performance Certificates (EPCs)
3.1. EPCs Make two significant assumptions, that:
3.2. The boiler manufacturers’ efficiency figures are correct, and
3.3. These figures remain unchanged throughout its life
3.4. They are much like a car’s MOT test and only gives an assessment of the energy performance at the outset. They take no account of limescale that will inexorably build up in hard water areas and continuously reduce the efficiency of water systems, plus cause premature failure of systems.
4. Building Research Establishment Environmental Assessment Method (BREEAM)
4.1. BREEAM takes no account of hard water limescale inexorably reducing the efficiency and causing premature failure of systems
5. Drinking Water Inspectorate (DWI)
5.1. The DWI paper on Water hardness seeks to address the cause and effect of hard water. It refers to the Defra map of water hardness measurements in England and Wales and advises that local water companies provide accurate measurements for a given post code. An example is that for the Houses of Parliament; Thames Water advise:
5.2. Of interest, ETC, in partnership with Houses of Parliament Estates, are about to install 2 test systems under the Palace of Westminster: Restoration and Renewal project.
5.3. The DWI Water Hardness paper makes a number of significant observations, that:
5.3.1. Hard water causes scaling in hot water systems and appliances.
5.3.2. Scaling of heating elements shortens their life and makes appliances less efficient
5.3.3. In a hard water area, a softener will improve the efficiency and increase the life of domestic appliances
5.3.4. most water softeners work by replacing the hardness with sodium.
5.3.5. Too much sodium can be a problem for premature babies because their kidneys are not good at filtering it out of the blood, and for people who are on a low sodium (low salt) diet.
5.3.6. Artificially softened water may also be aggressive to plumbing causing leaching of copper and lead.
5.4. The DWI also quotes World Health Organisation (WHO) Guidelines 2004 which identified that:
5.4.1. water with a hardness of value of 200 mg/l or higher (measured as calcium carbonate) will produce scale
5.4.2. soft water with a value of 100 mg/l (as calcium carbonate) or less will have a low buffering capacity and be more corrosive to pipes.
5.4.3. recommended that artificially soften water should maintain a minimum total hardness of 150 mg/l (as calcium carbonate). This is because there is some limited evidence of a relationship between water hardness and cardiovascular health which may be related to the beneficial properties of magnesium and calcium in the diet.
6. Water Softeners
6.1. Definition: to be classified as a water softener the appliance must replace the scale forming minerals (Calcium, Magnesium (Mg) etc.) with sodium.
6.2. As identified by the DWI and WHO, these will have the benefit of preventing scale as well as scum and increasing lathering, making a more pleasant experience for the user. They can also improve the efficiency and increase the life of domestic appliances. However, the above mentioned problems occur:
6.2.1. Too much sodium can be a problem for the vulnerable
6.2.2. Soft water … more corrosive to pipes
6.2.3. Plus, they remove the minerals that, according to the WHO, can be beneficial for cardiovascular health, replacing them with potentially harmful sodium.
6.3. Economics – as identified by Project SLAM, the WLC of a water softener against PWT is far greater. This was also reflected in a study by Portsmouth University in a hotel in Hampshire. This limited study took into account the purchase and running costs of a softener against ETC’s PWT projected over 20+ years.
6.4. The carbon footprint takes no account of the mining, production, delivery and disposal of the sodium and brine effluent.
6.5. USA – For over ten years, many states in America have decided to ban salt water softeners entirely or restrict their use. Examples are:
6.5.1. California – Santa Clarita, 2008 approved removal of all residential water softeners. Fillmore, Chino, Chino Hills, Fontana, Montclair, Ontario, Upland, and the Cucamonga Valley and Monte Vista Water Districts all followed suit.
6.5.2. Michigan – 2010, Hamburg Township prohibited the use of salt water softeners
6.5.3. Connecticut – Brine discharge from salt water softeners is prohibited
6.5.4. Texas and Massachusetts – also introduced regulations on brine discharges.
6.6. The salt is used to replace the minerals like Ca and Mg, in a ratio of 2 parts sodium to 1 part Ca or Mg and is eventually flushed down the drains ending up in freshwater rivers, streams and aquifers.
6.7. Over time, discharge from salt water softeners lead to increasing levels of sodium in fresh water supplies, and excessive chloride levels in soil.
6.8. Many cities and states are opting to ban salt water softeners in order to halt the cycle of environmental damage.
6.9. This is inevitably also occurring in the UK and in 2016 the EU were reported to be in the process to decide new environmental regulations that would also address this issue.
June 2020