Memorandum by The Central Council of Physical
Recreation (DWB 12)
The CCPR would like Government to consider using
this opportunity to give the Guidelines to the Director General
of Water Services Under Section 4, issued in February 2000, full
legislative force. This would be a positive step giving protection
to voluntary sports clubs and others from unreasonable Water Bill
increases particularly those arising from surface water drainage.
For example, the regulations define a third category of consumers
those who are neither business nor households, which encompass
the voluntary sector. Such a measure to support voluntary sports
clubs would further the Government's public health, education
and social agendas to which sport makes a valuable contribution.
1.1 On behalf of the national governing
bodies of sport and recreation, the Central Council of Physical
Recreation (CCPR) is pleased to respond to the Environment Sub-committee's
pre-legislative inquiry into the draft Water Bill.
1.2 We welcome many aspects of the Bill,
particularly the moves to make consumer interests central to better
industry regulation. We hope that measures such as the creation
of a Consumer Council for Water will protect sport and recreation
consumers from unreasonable increases in water Bills.
1.3 We understand that the scope of the
draft Bill largely covers issues of regulation and water approbation,
and does not consider issues relating to charging. However in
our submission to the DETR consultation on the draft Bill, we
argued that the Government should use this opportunity to give
legislative force to the revised Guidance to the Director General
of Water Services under Section 4, published in February 2000,
following the passage of the Water Industry Act 1999. (See Appendix
for the sections of the guidance which are of particular relevance).
1.4 This guidance recognised the special
nature of voluntary organisations in water charging through recognition
of a third category of customer, which were neither business nor
household. It also addressed the problems faced by voluntary sports
clubs through water companies changing their system or charging
for surface water drainage from a system based on rateable value
to one based on surface area.
2.1 Sport in the UK is built upon the efforts
of an estimated 150,000 sports clubs. Many of these clubs are
voluntary community based organisations, who are non-profit distributing
and funded from membership fees. These clubs are a crucial link
in this country's sporting development, and have a contribution
to make to the Government's wider social agenda.
2.2 The April 1999 Department for Culture,
Media and Sport's report to the Social Exclusion Unit commented
on the effect sport and recreation could have on local regeneration
and in meeting local community objectives. In his foreword the
Secretary of State remarked:
"This report shows that art and sport can
not only make a valuable contribution to delivering key outcomes
of lower long-term unemployment, less crime, better health and
better qualifications, but can also develop individual pride,
community spirit and capacity for responsibility that enables
communities to run regeneration programmes themselves".
3. REVISED GUIDANCE
3.1 The CCPR warmly welcomed the DETR guidance
when it was published in February 2000. It was an appropriate
response to the difficulties faced by organisations such as schools
and voluntary sports clubs in paying water bills.
3.2 The guidance gave recognition to a third
category of customer, "those who are neither business nor
household", which encompassed those in the voluntary sector.
Previously voluntary sports clubs had simply been defined as non-households,
but it is inappropriate to class "non-profit distribution"
voluntary sports clubs in the same bracket as "for profit"
Furthermore the guidance recognises that "community
sports facilities, clubs... and voluntary bodies" are often
low volume users of water and hence tariffs should take this into
3.3 The guidance also addresses the issue
of surface water drainage, particularly the practice of setting
tariffs for drainage based on surface area (site area tariffs)
as opposed to the more common practice of rateable value. It supports
a system of tariff rebates when surface water does not flow into
public sewers and propose that water companies consider actual
sewer use when setting site area tariffs.
Putting the guidelines on a legislative footing
should prevent water companies introducing a site area tariff
system without first considering the impact on voluntary clubs.
Many clubs could be penalised for having large surface areas while
their pitches do not drain off into the sewer system.
3.4 In a Commons debate in June 2000, Jacqui
Smith MP highlighted the problems faced by some of her constituents
following Severn Trent's decision to introduce a site area tariff
"The effect of the change is regressive
in that it hits services that have little ability to find the
money to pay the increased charges. The determining factor for
the organisations that have been hit badly by the change is the
relationship between the rateable value of their property and
the surface area that it occupies. In other words, the losers
are the non-domestic customers whose property has a low rateable
value but a high surface area".
"Increases of hundreds of per cent in sewerage
charges are not isolated occurrences".
Source: House of Commons Hansard, 9 June 1999,
3.5 The case of Severn Trent provided a number
of examples of the subsequent effects on voluntary sports clubs.
For example, the Victoria Tennis Club in Leicester saw its rates
bill increase eleven-fold from £78 in 1998/99 to £953
in 2000, although this was later reduced on appeal.
The Woodfield Tennis Club in Shrewsbury demonstrated
the difficulties that can be faced by voluntary sports clubs in
challenging water companies' decisions. It took the club six months
and two appeals to have their surface water charges reduced from
£959 to zero. The club was lucky to have a chartered surveyor
in membership who was able to assist free of charge. Many clubs
will not be so fortunate and will therefore have to decide between
an expensive and lengthy appeals procedure or increasing membership
fees to pay the increased water charges. Any increases in subscriptions
risks excluding the poorer sections of society.
4.1 The CCPR welcomes the creation of the
Consumer Council for Water as an effective body for representing
consumer interests. We note that Schedule I of the draft Bill
does not specify detailed membership criteria for individuals,
but the CCPR would like to see the Council membership being representative
of a wide range of consumers, covering all three consumer categories.
We would welcome representatives from sport and recreation either
being considered for Council membership, or for the Council to
maintain close links with sporting bodies.
4.2 The new duty on the water regulator
to protect consumer interests is a positive step. We hope that
this will provide protection for consumers against unreasonable
water rates increases.
5.1 On behalf of the governing bodies of
sport the CCPR is pleased for the opportunity to comment on the
draft Water Bill. We welcome many aspects of the proposed legislation,
particularly measures to make consumer interests central to industry
5.2 However we would like Government to
consider using this opportunity to give the Guidelines to the
Director General of Water Services Under Section 4 issued in February
2000 full legislative force. This would be a positive step giving
protection to voluntary sports clubs and others from unreasonable
water bill increases, particularly those arising from surface
water drainage. Such a measure to support voluntary sports clubs
would further the Government's public health, education and social
agendas to which sport makes a contribution.
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