Examination of Witnesses (Questions 100
WEDNESDAY 30 OCTOBER 2002
100. WaterVoice believesand I share that
beliefthat water customers have to be represented on the
co-ordination groups and such. We are aware that the Commission
invited the European consumer body BEUC to join in that, but they
have not as yet taken up their invitation. Are you aware of similar
concerns in other consumer bodies in other parts of Europe about
this? What is your view?
(Ms Reiter) The difficulty is that in other parts
of Europe there is not a body similar to ourselves. We are the
only water consumer dedicated body across Europe so that has made
life rather difficult. We had looked to BEUC to actually be helpful
from that point of view, but owing to their resources they felt
they were not able to take the place that they were allocated
on the co-ordination group. That has meant that there has been
no opportunity to represent a customer view point not only from
England and Wales but across Europe. We have been very disappointed
by that. We have now got to a position whereby BEUC are prepared,
we believe, to say to the Commission that with them not being
able to take up the place because of lack of resources they would
not be averse to us taking that seat if the Commission agreed
to it. On Friday of last week I attended a meeting between the
regulator, Phillip Fletcher, and Catherine Day (who is the new
DG Environment in Brussels). We raised this question with her
and she has taken a raincheck on it actually. She would like to
consult her colleagues because we would be breaking tradition
in Europe because they only consult with cross- European consumer
bodies not individual dedicated ones. But she seemed receptive,
is all I can say. We are very hopeful that, whilst it is very
late in the day, we might still get the opportunity to take that
101. That is the point I was going to take up
really, because by the time this all happens, some of the major
decisionscost benefit and everything elsewhich are
going to be the very things that consumers are going to be principally
interested in, might already be done and dusted.
(Ms Reiter) I think from the Water Framework Directive
that is the case, but the Bathing Water Directive is slightly
different. Once we got wind that that was likely to happen, we
did start working very positively with MEP's and with other bodies
out there, liaising with MEP's not only from England and Wales
but from other countries who also had similar concerns about the
Bathing Water Directive. We attended a lot of conferences, a lot
of meetings and seminars to get across the view of the consumer.
The point that we tried to make to Catherine Day last week is
that we do not go to Europe just to point out the England and
Wales point of view. The principles on which we are arguing are
those which are common across Europe (the decisions must be based
on sound science, there must be a scale of affordability et cetera).
The principles on which we are working are the same whether we
are representing England and Wales or other water customers.
(Mr Terry) I have a document, the latest draft, The
Common Strategy on the Implementation of the Water Framework Directive.
We welcome that because that should result in timely, cost effective
and proper implementation across all member states, avoidingwhat
the Chairman was sayingthe accusation that we gold plate
it. We do think it is a pity that the BEUC did not take up the
opportunity to have customers or consumers represented in that.
It is not sufficiently high on their agenda. We could not speak
for customers in Germany, but we know we could speak for customers
in England and Wales and we think we might be an effective voice
in such a body that just occasionally it puts up its hand and
says there is a principle here about who pays, how they pay and
why they pay.
102. Did you make representations to BEUC?
(Mr Terry) We have.
103. What did they say?
(Mr Terry) They will think about it. Now they have
come back and said they do not think it would be a bad idea, maybe
(Ms Reiter) If the Commission will accept you.
The decision has been left to the Commission.
(Mr Terry) We want to be an effective
voice for customers in England and Wales. If we can helpas
an ancillary functionwe will, but we are not going to set
out to represent customers in Germany or other nations.
(Ms Reiter) It would be interesting to
see how the consultation part of the Framework Directive will
be implemented in other countries. When you talk to MEP's at these
meetings and ask them how they get a consumer view, the MEP's
will say that the customers and water companies talk to them about
their water bills. Also, the unions are quite active in it. In
fact, there are no other properly constructed bodies (as we would
see them) to represent customers. It may well be that they may
have to be consulted now as a result of the Framework Directive.
It might be very beneficial to us.
104. You mentioned in your remarks a second
ago a phrase which also appears in your evidence, "sound
science". What do you think are the sources of sound science
that we ought to be aware of in assessing the proposals under
this Directive? Who are your sound science mentors?
(Ms Reiter) On water quality issues I think that the
basis has been the WHO requirements. I do not think I am really
qualified to say more than that. I just want to be reassured that
there is some scientific evidence and that it is internationally
accepted that the evidence they are giving is very sound.
105. The reason I mention that is thatas
we learnt last weekthere are going to be some new measures
to assess the quality of water, not just, for example, the number
of fish in a body of water. If, when people are working out the
costs, there is going to be a lot of science sitting underneath
(Ms Reiter) One of the things with us is, what is
the definition of "good status"? What does that actually
mean? That has not been defined. There is a lot of definition
still to be done. There is a tremendous amount of work to be done,
I believe, before they can really begin to start work in 2003.
106. You have a sentence in your submission
which says, "The precautionary principle is a case in point
where expensive preventative measures have sometimes been taken
while little is known about any actual health benefits".
That could be said of a whole range of issues from food safety
through to environmental issues. Do you think there is a real
danger here that we are trying to reach degrees of cleanliness
or purity which, in practice, are irrelevant to any outcome?
(Mr Terry) I do not think we are qualified to comment
on that in absolute terms, but it is a concern that a drive for
ever higher standardsthat is a natural drivewithout
asking what is the associated benefit and on what basis do you
assess that there is an improvement. I think it is probably more
a question for technical people, but it is a concern.
107. It is an issue. As far as you are concerned
it is an issue.
(Mr Terry) It is absolutely an issue.
(Ms Reiter) If you take the drinking water standard,
we have reached extraordinary high standards of drinking water
quality and the cost to increase that standard by even half a
per cent is very considerable. What we would want to know is are
the health benefits so considerable that it is worth the cost
of going up another half per cent? Or are we pushing them just
because we have reached one target point therefore we ought to
go up? There comes a point where the justification for going up
has got to be made.
(Mr Terry) I think there is another issue, if I might
build on that issue of drinking water. The drinking water inspectorate
have done a fantastic job and they have driven the standards so
high now that they are immaculate, but the things that bother
people now are not the last .01 per cent of a trace element: it
does not look very nice. So you are moving to some of these things
away from where you have a strict scientific measure to an aesthetic
quality: taste and smell. Those are issues and perfectly valid
issues, we think, as far as customers are concerned. I think we
are sounding a little warning bell about ever and ever higher
108. Can I turn to this question of consultation
that we looked at earlier. You do say in your written evidence
that you wish to see the government taking a lead in educating
and informing water customers and the public generally about the
aims, objectives and benefits of the directives. Does that imply
you feel that the government has not been taking a lead so far?
It has not done enough?
(Mr Terry) That is perhaps a subjective judgment as
to whether they have done enough. I think more needs to be done
and as we now move into what I call that implementation phrase
between about 2003 and 2010 I think one would want to see that
ratcheted up. There is a lot of technical technocrat work going
on in the background in DEFRA and in EA themselves because they
have looked at some studies in the Ribble area in Lancashire.
It is taking place. I think it needs to step up a gear. I think
the question is how do you most effectively wind it up so that
there is a public consultation and a public dialogue, both about
the benefits (which I accept entirely are not always pound for
pound that can be measured) and the costs (which are also a legitimate
area). As I say, I think one of the reasons we so much welcome
your work in this Committee is that we hoped it would identify
that as an issuenot just us as customer representativesfor
all stakeholders. We are fully aware that we are not the only
stake holder in the water environment.
(Ms Reiter) I think it is interesting, actually, that
customers, generally speaking, do not realise what they are paying
for in their water bills. I think that is one of the problems
and therefore we have been asking the water companiesand
many of them are now implementing itto say on the back
of their bill what per centage of a customers' bill has gone towards
improving the environment. We think that greater openness and
greater transparency about what the customers are paying for will
help them to understand the improvements that are being made on
their behalf and what the cost is.
109. In particular, the consultation on the
draft river basin management plansI think you have indicated
both in your written evidence and this morning before usthat
you see WaterVoice as having an important role to play in that
consultation, but perhaps not the lead role. Should that reside
with DEFRA, with the Environment Agency or where, and how do you
see that consultation taking shape?
(Mr Terry) I think our recent experienceand
Sheila was commenting on this market researchindicates
there has to be a lead organisation, an organisation that is prepared
to chair a fairly diffuse stakeholder group. I think there has
to be maybe the same body or maybe a different body that is prepared,
if you like, to put the staff work into that. In the last particular
case of market research it was chaired by DEFRA but the staff
work was done by Ofwat. You could adopt a similar sort of approach.
From my experience and background, I think unless you have a point
of responsibility and say it is that particular group that is
going to lead this process, you will end up with a process that
is probably less effective. Who should it be? I would personally
have thought that it probably cannot be anybody else other than
DEFRA. If it were to be led by the Environment Agency it would
have a particular slant; if it were to be led by the drinking
water inspectorate another slant; if it were to be led by Ofwat
it would have a financial regulatory slant. It seems to me the
over-arching body under these circumstances would be DEFRA, but
with key input from these other stakeholders, of which we regard
ourselves as one.
(Ms Reiter) I think from our point of view, because
we have a regional structureand the regional structure
very, very closely allies itself to the river catchment areas,
the river basin management areasI think our committees
will be quite well placed to work with the water companies and
whatever bodies are put in place to consult with in order to provide
a customer point of view.
110. It sounds as if there is a view that DEFRA
needs to get a move on.
(Mr Terry) DEFRA already has a group workingI
think it is called Implementation Stake Holders Working Groupof
which we are a member and I know a number of other groupsWater
UK are representatives of the industry and English Nature, EA,
RSPB, WWFare participating in that particular stakeholders
group. But at this stage it is a stake holders group with perhaps
not a clear objective that DEFRA is going to be the group that
is responsible for driving through all facets of the Framework
Directive. It seems to me, again, that one of the things we would
like this Committee to have in its outputif I might be
so boldis to say where that responsibility should lie.
But I think it would be an important point to identify.
111. Can I just then pursue that in conclusion.
You have said on a number of occasions that you welcome our inquiry.
Could I ask you to sum up what you think are the major issues
where answers are still needed, where the uncertainty is the greatest,
where are the edges fraying the most? That would give us some
navigational aids ourselves through this.
(Mr Terry) I think the first thing is cost. Cost and
time scale. Cost but time scale with it. It is going to take many
years to implement. We know that it is going to be fairly costly.
Even if you take the bottom end of the assessment of £4 billion
and the top end at £9 billion, that is a large amount of
money. I think there needs to be some homing in on what those
costs are. It needs to be more than back of an envelope stuff.
It needs to be the total cost. Then, how are you going to implement
it, what techniques are you going to use, how are you going to
plan the implementation over a period of time which gives you
the most cost effective implementation? It would be silly to do
one part of the clean up in one river basin that has an impact,
for some reason, on another river basin. There has to be a properly
defined programme that takes it through stages of what I would
probably define as key milestones. And, if I might say, build
into that at the same timeperhaps alongside itthe
process about public education, public consultation and engaging
all customers, not just water customers, customers in other stakeholders.
That, I think, would be it. Cost. Time scale. Programme. Let us
see it written down and then let us see if we can find out how
we manage it.
112. The water charge payers of the south west
would not forgive me if I did not raise the fact that they have
been paying over a hundred pounds on average higher than anybody
else because of the clean up around the coast which, in the end,
they accepted. Recognising that that has largely ceased, unsurprisingly
the bills have not been reduced. The likelihood of consumers in
that part of the world accepting the sort of things that you have
now been talking about would be extremely resistant, bearing in
mind the experience they have had in the clean up of the coast.
(Mr Terry) There is a major issue here. We very glibly
talk about average bills, average water and sewerage bills, but
there is no such thing as an average bill; it is an individual
bill. The most expensive is in the south west and the cheapest
is in the north east. If you now look at river basin management
because that is the heart of the Framework Directive (which area
has the most river basin, I do not have an answer for you) you
can see that the spread of how many billions of pounds is certainly
not going to be even across the country. It is going to fall differently
on different regions. I cannot tell you because I do not know
enough about it, whether it is going to have a bigger impact in
the south west than it will in the north west (which is the region
I represent). But undoubtedly it is an issue. It is an issue to
which customers will want answers. I think they will want to ask
why there is more cost. They are cynical. They read the recent
claims in the last two to three weeks that our river water quality
in this country has never been better. Absolutely true. Drinking
water compliance in this country has never been better. Absolutely
true. Service from the water and sewerage industry to customers,
never better. Bathing water, never better, never cleaner. Then
the customer has more bills. What is the logic about this? You
can see the cynicism, the glaze that is likely to come across
their eyes, even more the glaze across the eyes of those people
in the south west.
113. We were told last week that of the various
experimental schemes or whatever put forward by other countries,
this country has not put one forward at all. Should one?
(Mr Terry) Intellectually I would have probably said
yes, but I think it is a question you should address to the Environment
Agency. I would have thought so. I know they have doneand
I participated in ita theoretical study on the River Ribble
in Lancashire. Sheila tells me they have done several. Whether
they have gone on to the next stage which is an actual pilot study
and trying to work it through in terms of effects on estuaries
or effects on the Northern Irish Sea (which is an area which affects
my region) I do not know, but I would say to you the work should
be done. Again, if you had a total time scale and time frame you
might be able to put a point here to say that it needs to have
output at this particular point in time.
114. Is there anything you wished you had said
that you have not yet, or anything you have said which you wished
you had not? Is there anything you think is important which has
not yet been covered?
(Mr Terry) I think very little. I think we will probably
reflect and think we have said some things we wish we had not
said, but no, I think we have covered all the points.
115. Obviously our inquiry is going to take
a little while and if things crop up you will no doubt be in touch
(Mr Terry) We would be very happy to respond to any
specific points either in written format or, if you wanted, in
an oral form. We put quite a bit of time and effort into our submission
to you, but it was specifically from the perspective of us as
representatives of the paying customer.
116. We are grateful for that because it is
a focussed document which is very helpful in a diffused world,
if I may say so.
(Mr Terry) Including diffuse pollution.
Chairman: Thank you very much indeed.
1 Note by witness: "BEUC said it would
depend if the Commission will accept us." Back