25/02/09
Innovative and difficult, the water framework directive can help us understand nature and work more effectively for a sustainable environment.
Artists and dreamers and unpractical types sometimes see further into things than the rest of us. The poet TS Eliot (1888-1965) memorably revealed our insouciant attitude to nature when he wrote about rivers:
I do not know much about gods; but I think that the river
Is a strong brown god – sullen, untamed and intractable,
Patient to some degree, at first recognised as a frontier;
Useful, untrustworthy, as a conveyer of commerce,
Then only a problem confronting the builder of bridges.
The problem once solved, the brown god is almost forgotten
By the dwellers in cities – ever, however, implacable,
Keeping his seasons and rages, destroyer, reminder
Of what men choose to forget. (1)
If Eliot’s 'brown god...keeping his seasons and rages' is the seer’s warning against complacency, the Water Framework Directive (2000/60/EC) is our practical response. In December the Environment Agency, the 'competent authority' in England and Wales, published draft River Basin Management Plans (RBMPs). This month a public consultation was launched.
To reach this point, the EA and its stakeholders have had to do a huge amount of work. The WFD was always different from other water legislation. Above all, economics was integral, not a sub-plot, in the story of 'good status for all water bodies'. A fresh approach was needed to combine best thinking on meeting human need with respect for 'untamed and intractable' nature. It was never going to be a stroll down the river. How are we doing?
Water UK summarised its view of progress in a recent statement looking at the role of water companies; the challenge of uncharted legislative territory; and the need for all sectors to be involved in sustainable outcomes. (2)
Fully committed
Water companies are active members of river basin district panels. They are fully committed to playing their part by building on the industry's success with earlier directives. They are working with others in the search for new initiatives.
In the first WFD cycle – 2009-15 which sort of matches the next regulatory investment period – the industry will invest heavily in National Environment Programme projects. The honest way to describe most of this work is 'necessary but not new'. It will contribute to WFD through existing directives, use mainly 'end-of-pipe' techniques, and prepare the ground for what should be more innovative projects in cycle 2 (2015-21). This investment will make the water industry by far the biggest contributor to these first RBMPs.
Fresh ground
Linked to the economics focus, the WFD also breaks fresh ground in highlighting the impact of land use – particularly farming and city living – on water bodies. It could easily have been called the Water AND LAND Framework Directive.
Earlier directives aimed to protect and enhance water quality mainly by applying chemical standards to effluent discharge. They were designed to limit pollution from known, regulated point sources, such as industrial plant and sewage treatment works. The RBMPs assume that improving point source discharges will go on making a contribution. But significantly they also take account of diffuse pollution – the impact of run-off from multiple, unregulated land sources, such as farms, highways and industrial sites. This is where things get tricky.
Policy gaps
The change has shown up some big gaps in policy. Gaps in understanding the impact of diffuse pollution, relative to point source; in enabling sectors beyond the usual suspects (heavy industry, water and sewerage) to play their part; in giving these new entrants incentives to contribute; in setting targets and allocating funds when they are in the public sector (such as local authorities and highway agencies); in the limited grants available to farmers through the 'Catchment Sensitive Farming' scheme.
The consequence is seen in the regulatory impact assessment of the first RBMPs. Diffuse pollution is the main risk to WFD objectives, responsible for some 75 per cent of pressure on water quality compared to point source at 25 per cent. Yet responsibility for improvement action is split differently: two thirds of assessed costs will fall on the water industry, one third on the rest. This may or may not be fair to water companies and their customers. But the bigger question is: will it be sustainable? Over time, will it provide best environmental benefit with lowest cost and least waste? Will it help us manage what 'men choose to forget'?
Essence of WFD
It was always going to be hard moving from sectors acting alone to sharing responsibility. But that is where the new and valuable approach of the WFD points unwaveringly.
In starting to look beyond the first cycle, the Environment Agency must work with government and stakeholders to promote genuinely integrated solutions. This means all sectors being able to contribute in proportion to their capacity to be effective. It is the essence of the WFD and the only sure way to a sustainable water environment.
We can hope too that it will help placate the sullen brown god which Eliot also tells us is ever 'Unhonoured, unpropitiated by worshippers of the machine, but waiting, watching and waiting'.
(1) The Dry Salvages, Four Quartets, Faber and Faber, 1941
(2) Water UK briefing pdf
A version of this article, by Barrie Clarke, appeared in Water & Wastewater Treatment Magazine, February 2009.
