23/05/08
Water UK responds to the joint Defra and Welsh Assembly Government (WAG) consultation on Volume 2 of the river basin planning guidance and updated impact assessment.
The water industry is pleased that Defra and WAG are taking steps to provide clarity and direction to the Environment Agency in implementing the Water Framework Directive.
The guidance recognises that improvement schemes may have to be undertaken by sectors other than the polluter (in what Defra calls a deviation from the Polluter Pays Principle). However, where this is necessary there should be full and open justification.
Neither the guidance nor the impact assessment faces the effect of increasing water bills on low income families particularly in certain parts of the country. Equally they do not represent a fair and transparent picture of the expected costs and benefits.
Water UK believes:
• The water sector should be responsible only for the share of WFD work that relates to the services it provides to its customers. Otherwise government and regulators must be transparent about additional work they ask the sector and its customers to pay for. The current guidance does not fully reflect this requirment.
• The Secretary of State and Welsh Minister should not adopt all UKTAG standards
• Carbon has not been effectively considered and published studies on the potential impact of additional treatment processes have not been included
• The standards for protecting surface water and groundwater abstraction sources and in safeguard zones are not included - this is a serious omission which must be addressed
• The costs of implementing the directive appear to have escalated and are now presented over 43 years to reduce the impact
• There are no clearly stated benefits and the willingness to pay assessment does not match the potential costs of the higher estimates
• Diffuse pollution has not been fully integrated as a risk across all sectors. There is no indication as to the cost of controlling diffuse pollution.
Water UK response to Defra consultation on River Basin Planning Guidance Volume 2, May 2008
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