WFD by 2015: an unrealistic deadline?

The WFD aims to improve integrated water management at a catchment level. But uncertainty remains. Mike Woolgar analyses the issues and how the industry should proceed.

This is a critical year for the implementation of the Water Framework Directive (WFD) in England and Wales, particularly for the regulated water industry, as companies prepare for the next periodic review.

We are close to the point where money has to be committed. And consumers, who will bear the costs, will need to be engaged in the process.

Several forces are working together to put pressure on the water industry. There are increasing demands to improve water quality - whether by reducing point source pollution such as wastewater treatment works effluent or by better managing more diffuse sources of pollution.

At the same time, there are continuing market and regulatory incentives to minimise water service cost and price increases. On top of that, the industry must deal with society's need to reduce greenhouse gas emissions, either through carbon reduction commitments or emissions-trading schemes.

And this is all taking place in an economic environment where there is the strong
possibility of a downturn and a squeeze on industry margins.

In this challenging context, yesterday's solutions - or even today's - are unlikely to suffice in a more complex and demanding future. The key question for the industry now is: can we aim for a cost-effective implementation of WFD objectives by 2015, or is an adaptive/phased scenario the only answer?

In seeking to answer this, one of the biggest issues facing the water industry is the uncertainty surrounding so many key issues, but especially cost. Indeed, the Environment Agency's (EA) own analysis last year concluded: "Uncertainties in planning to meet WFD objectives are greater than normally experienced in water management. There are very significant uncertainties which may lead to a high risk of abortive expenditure and missed objectives."1

Given this backdrop, what are the main questions water companies need to focus on? The WFD seeks to drive improved water quality and better integrated management of water so as to reduce the effects of flooding and droughts, where necessary through the appropriate use of economic instruments.

It also makes specific reference to the need to reduce and ultimately phase out discharges and emissions of priority hazardous substances. These are substances which are deemed to be "toxic, persistent and liable to bio-accumulate". In other words, they are substances that are inherently likely to be difficult to remove from the environment once released.

Of course, preventing further release of such pollutants - ie source control, is the
right course of action to avoid further contamination. But the persistent nature of these substances means that there may be an implied duty on the water companies to take action to reduce existing pollution by treatment - as well as reducing future pollution by controlling emissions.

To date, removal of newly proscribed pollutants or contaminants has been achieved by improving existing water or wastewater treatment processes or by adding or substituting new ones. Technically this may continue to be possible - but at what cost?

Furthermore, in accordance with the polluter-pays principle required in the WFD, who should meet the cost of such additional capital cost, operating cost and additional carbon output?

If so-called end-of-pipe solutions to be installed by the water industry are preferred, water consumers will be carrying the costs through increased charges, irrespective of their individual or collective responsibility for the original contamination.

Of course, if industry has to cease polluting with particular chemicals, then either the cost of additional treatment or the costs associated with not using such chemicals in the first place will be passed on to the consumer of the product.

And what of diffuse pollution - from farmland, from road run-off or from underground storage tanks for example? While such pollution may not contribute much to chemical contamination of water, what is the overall contribution to impaired water quality?

The water industry is concerned about being driven to adopt measures which are not cost-effective for either the business or customers. As the objectives of the WFD are essentially to develop better integrated management of the aquatic environment, so the mechanisms to achieve compliance need to follow suit.

Atkins has concluded that water companies need to make serious progress in the following three critical areas:

· Understanding the environmental issues
In a similar fashion to the systematic approach applied to searching for and dealing with leakage in water networks or infiltration/exfiltration in sewer networks, we need to continue to improve understanding of physical, chemical and hydrodynamic processes at a catchment scale.

Many of the tools are already available for evidence gathering, baseline condition assessment and progress monitoring. These include: nutrient modelling; resource and flood modelling; fate of chemicals modelling; abstraction and discharge consenting; pollution plume monitoring; bioassay techniques; gene chemistry; and radioactive marking for source and fate assessment.

The question that needs to be asked is whether or not the suite of tools available is being used in a sufficiently joined-up way.

· Catchment management
Many of the tools for improving water quality are also available or becoming
available. There have been successes already in reducing nutrient inputs from agriculture by altering management practices, and there are surely more management practice approaches that can be taken - at relatively low cost - provided we have sufficient information to assess benefits as well as capture costs.

Reducing the input of potential pollutants must of course be addressed. But this assumes that their source is known, that the reduction can be made permanent and reliable and that it is cost effective.

For example, border strips on farmland may well be part of the answer if the land uphill is managed appropriately and consistently - but only if the border strips prove capable of reliably controlling the source.

Dilution may have its place, given that many of the proscribed pollutants are to be reduced to specified concentrations. But many water bodies are already under stress in certain months (during droughts) and it may be impossible to securely allocate sufficient water to ensure the necessary dilution.

In summary, the development of an integrated catchment management approach will be key to achieving the WFD goals. The good news is that UKWIR is proactively evaluating how catchment-based management can be delivered to meet the requirements of the WFD from the water industry standpoint.

· Technology development
There are existing, well known treatment technologies which water companies can add to their process streams. In some cases, this approach may be the only solution.

There are numerous new technologies being developed all the time, which seek to achieve improved outputs with lower energy input, or lower land footprint or both. It may be possible to deploy these, but their reliability is currently uncertain.

Where new technologies are developed, but which need to be proven for the industry to accept them, there needs to be an understanding between the water companies and environmental regulator on achieving full compliance with the WFD's target of achieving good ecological and good chemical status by 2015.

Without this, water companies are unlikely to take the risk on process critical, unproven technologies.

Technology also needs to be brought to bear on the enormous issue of making UK water more sustainable.

All technological solutions
- whether end of pipe or process improvements should aim to keep the carbon footprint of improvements to a minimum.

As we said before, the WFD seeks to stimulate an integrated approach, and it is likely that combinations of all of the above options, and others not listed, may be necessary to provide the most appropriate and sustainable programme of measures.

Clearly, in the absence of a sound understanding of the "water - contaminant sources - fate of contaminant" cycle, there is a risk that, for the sake of expediency, planned improvements could be less than optimal in terms of cost, carbon impact, operability and sustainability.

As indicated by the water industry's representative organisation: "High water customer bills are not acceptable unless the costs and benefits and improvement needed can be clearly justified. We are keen to see the polluter pays principle implemented as a given and any deviation by policy makers explained and justified."

Defra's last updated Overall Impact Assessment2 makes a brave attempt to calculate the cost to the water industry in England and Wales of both total compliance by 2015 and the second option of a phased implementation. The former could be as high as £2B or as low as £1.1B, according to the report, with the latter in a much narrower range of £646-£686M.

The authors of the report concede that this analysis is - once again - subject to considerable uncertainty. Assessing benefits is even more complex and open to interpretation.

Defra has helped to come up with some useful definitions of what the WFD means by "good" water status (for example, varied fish population, supporting diverse and native plants and animals). But assessing the "benefit" to the public of bringing the UK's water bodies to "good" status is a much more tricky exercise.

And the benefits to the water industry, in terms of improved long-term business performance, profitability, and reputation seem even less clear.

Once we move into the area of tackling climate change (which has been identified by the Environment Agency as part of the planning cycle for the WFD), any meaningful cost-benefit analysis becomes almost impossible, with no price (so far) for carbon in an ever-changing legislative framework.

While we may never satisfactorily assess the benefits of compliance with the WFD, we do know for certain is that - at some point - there will be a large bill heading towards the water industry. The current river basin planning process will be focusing top minds in the industry on making compliance as cost effective as possible and searching for the best solutions on the market.

Mike Woolgar is director, water management, Water & Environment at Atkins.

1 Water Framework Directive National Liaison Panel for England, October 2007, EA.
2 Water Framework Directive: River basin management planning, Defra



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