Select Committee on Environment, Transport and Regional Affairs Memoranda


Memorandum by The Central Council of Physical Recreation (DWB 12)

EXECUTIVE SUMMARY

  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.  INTRODUCTION

  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 [18] 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.  VOLUNTARY SPORTS CLUBS

  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 TO THE DIRECTOR GENERAL OF WATER SERVICES UNDER SECTION 4

  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" businesses.

  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 consideration.

  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 water drainage:

    "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".

  She added:

    "Increases of hundreds of per cent in sewerage charges are not isolated occurrences".

  Source: House of Commons Hansard, 9 June 1999, Col 623

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.  PROTECTION OF CONSUMER INTERESTS

  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.  CONCLUSION

  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 regulation.

  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.

January 2001


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