Local response to DEFRA public consultation on personal water use.

Hollingbourne Parish Council and other local Parish Councils has been asked to comment on a DEFRA consultation document on water use. Read More for the Joint Parishes Group response. The DEFRA document can be downloaded at Consultation-on-reducing-personal-water-use-FINAL2.pdf (3 downloads)

Consultation on measures to reduce personal water use- Response (written by John Horne).
Water Services
3rd Floor, Seacole Building
2 Marsham Street
London SW1P 4DF

Defra – July 2019 – Consultation on measures to reduce personal water use:

1. The Joint Parishes Group (JPG) is a consortium of some twelve parish councils within the North- Eastern and South- Eastern quadrant of Maidstone Borough in Kent. Amongst their objectives are; to make joint and several responses to Governmental and other public consultations which affect their communities.
2. We would like to thank the Minister (Dr. Therese Coffey MP ) for her succinct and apposite forward in highlighting the critical issues.
3. We also thank the officials within the Department for Environment, Food and Rural Affairs, for clearly setting out , with authority, the main issues for debate.
4. There are certain areas of common ground, which may be stated as a preliminary:-

4.1 The amount of moisture on Earth has not changed. The water the dinosaurs drank millions of years ago is the same water that falls as rain today. But will there be enough for a more crowded world ?
4.2 Water is life. Its’ the briny broth of our origins. The pounding circulatory system of the world. We stake our civilizations on the coasts and mighty rivers. Our deepest dread is the threat of having too little- or too much
4.3 As a chemical compound nothing could be simpler than water: two atoms of hydrogen joined to one of oxygen. From a human point of view simplicity fades. Though water covers our world, more than 97 per cent is salty. Two per cent is fresh water locked in snow and ice, leaving less than one percent for us. “This precarious molecular edge on which we survive will only grow more precarious.” Barbara Kingsolver NGM . Com April 2010.

4.4 Sources: Water supply may be drawn from groundwater, such as aquifers; surface water, such as rivers, lakes and reservoirs; or desalinated sea water. On nearly every continent groundwater in aquifers is being drained faster than the natural rate of recharge.

4.5 In summary; we cannot manufacture water (desalination does not provide a solution for all the world’s water woes ) but can merely collect, clean and store rainfall for distribution to consumers.

4.6 Current climatic shifts emphasise an imperative for water companies to protect vulnerable coastal assets from any sea level rises. Each year there are instances of sudden and violent inland flash flooding- Tewkesbury, Newbury, Cumbria etc. This gives problems on the supply side: How to capture and retain this abnormal level of sudden precipitation; while protecting existing systems from rising levels leading to contamination by sewage and other pollutants from the waste water network.
4.7 DROUGHT MEASURES: are simply a rationing of a decreasing available supply. There is no “new water”.

4.8 THE SHIFTING CLIMATIC CHANGE; YEAR 2050:- The Crowther Lab, Zurich has sought to understand climate change from a global analysis of city analogues.
“ By analysing city pairs for 520 major cities of the world, we test if their climate in 2050 will resemble more closely to their own current climate conditions or to the current conditions of other cities in different bioclimatic regions……As a general trend we found that all cities tend to shift towards the sub-tropics, with the cities from the Northern hemisphere shifting to warmer conditions. We notably predict that London’s climate will resemble Barcelona.
These results enable decision makers to envisage changes that are likely to occur in their own city and the required action to meet these environmental challenges……
In 2008 Barcelona experienced extreme drought which required the importation of €22 m. of drinking water. “

Future Cities Climates in 2050. Plos/One Crowther Lab 2019.

The Consultation at page 5 –Building regulations for water consumption- states:- The Government is committed to delivering 300,000 homes a year by the mid -2020s and there are major plans for new housing in every part of England. This will have a significant impact on water availability.
5. If this is simply stating-factually – there will be more housing and more impact on water availability. Then it is a self -evident fact.
6. However , if this is an endorsement of policy and a statement of fact, it is open to serious challenge.

REPORT BY THE COMPTROLLER AND AUDITOR GENERAL: HC 1923 Session 2017- 2019 08 February 2019 The key findings show that the planning system is dysfunctional and failing local communities; while the premise of the Ministry of Housing, Communities and Local Government in planning for new homes is flawed. This is a serious independent Report; from which one concludes , the planning system is not fit for purpose.
• It is noted that an Inspector holding a Local Plan Inquiry does not appear to hear evidence on water supply and, or the need for adaptive urban planning.
• The simplistic formula for determining need appears to act counter to the Government’s avowed intention to boost the economy in parts of the UK away from London and the South East: e.g. the Northern Powerhouse. Many Northern Authorities are denied the opportunity for new build; while the South East have unwanted additional housing imposed upon the Districts ( where the water supply is stressed ). Again, the formula is dysfunctional for any major commuting area, as median wages are judged by reference to local jobs; not taking into account the presumably higher wages that justify commuting out of the area.[Currently, there is a shortfall in new build completions for London Zone 2].
 The need for a sustainable water supply with catchment and reduced water loss. This includes a sponge city and rainwater cleansing.
 Within new build measures are required to achieve a lower usage of potable water and an application of grey water
 The conversion of office blocks into housing exacerbates the present water supply situation
 The need for cleaner air and a reduction in air borne particulates. For instance, it is possible to consider smaller hydro- electric generation from town centre water courses, which in turn could
 supply a charging point for a municipal electric van fleet. As M ark Carney, the governor of the Bank of England, stated on Channel 4 News: “The country is moving to net zero carbon by 2050. That is a legislative objective and that is going to require some pretty major changes. Companies that don’t adapt, including companies in the financial system, will go bankrupt without question.”
 The need to enhance natural waterways to manage flooding and provide wildlife habitat; aligned with strategic landscaping. Any new development must respect the existing topography, the need to protect Aquifers and conserve existing watercourses.
 Urban farms and gardens; to take advantage of hydrophonic technology for urban farming. Importantly, sustainable farming should be an integral part of the curriculum in future city schools.
7. The quest for a consistent and resilient supply of potable water cannot be divorced from spatial planning and development within the Local Plan and any subsequent Local Plan Review. There must be an immediate change of mindset ; within Government, Local Authorities, The Planning Inspectorate and the Building industry.
8. A pre-condition must be an authoritative Review of the natural environment and topography; setting out the optimum siting of water assets and the necessary conservation of meres, water courses and natural environment. Future development can then be built into the skein of the landscape. We need an Objective programme that is sustainable for human life. At present we are sailing on the wrong course.
9. THE CONCLUSION: As Wang Zhigao director of the low carbon cities programme at the Energy Foundation China has said :—

If we don’t get the urban form right it will be there for hundreds of years.

The Foundation paid for the redesign of Chenggong, which has reinforced a change of mindset. Chinese cities were to preserve farmland and their heritage, have smaller unfenced blocks and narrower pedestrian friendly streets, developed around public transit.
The current UK urban sprawl whilst conducive to short term gain is not sustainable in the long term.

There can no longer be isolated indifference. When the taps run dry, it may be too late.


1. Do you consider that the current approach in Building Regulations i.e. a mandatory minimum standard for new homes but with local authorities in water stressed areas having discretion to ask for a higher standard through a Buildings Regulations Optional Requirement ) is effective ?
No: for their effectiveness has yet to be demonstrated.
2. Do you consider that the current minimum standard of 125 litres per person per day and the optional requirement of 110 litres per person per day should be changed, and if so what might be an appropriate new standard ?
Yes: upon current conditions. Yet if more appropriate water conservation methods were available [ rainwater & grey water] then the wasteful use of potable water can be reduced.
3. Are there any other issues relevant to using Building regulations to set water efficiency standards that the government should consider ?
Agree with the statement in the supporting text.
4. To what extent do you agree or disagree that Government should work with water companies and local authorities to run partnership retrofit and behaviour change programmes in existing homes ?
Strongly agree. For this is where the rump of the issue lies. It should be a carefully structured and piloted scheme to achieve effectiveness and value for money.
5. To what extent do you agree or disagree that information on water efficiency should be displayed on water using products ?
Strongly agree: for in purchasing any other type of appliance the energy usage is an important consideration.
6. To what extent do you agree or disagree that providing information about products’ water efficiency changes peoples purchasing behaviour and reduces their use of water ?
Neither agree nor disagree. Some consumers are intent on particular products irrespective of the consumption rating.
7. To what extent do you agree or disagree that water efficiency labels should be linked to building standards and minimum standards?
Don’t know.

8. How else could government or water companies encourage people to use more water efficient devices/appliances at home ?
It is hard to see a role for water companies on this issue. The carrot by government could be to have a tierd application of VAT.
9. To what extent do you agree or disagree that people should pay for water according to how much they use ?
Slightly agree; in that vulnerable customers with medical conditions requiring additional water should have exceptional usage. There should not be a move towards dynamic metering.
10. To what extent do you agree or disagree that the amount of households charged by metered volume should be increased beyond and/or faster than is already planned by the water companies ?
Slightly agree; in that this approach is welcomed , but it should not be a priority at the expense of more urgent matters.
11. If you agree that the amount of households charged by metered volume should be increased, would do you think would be the best or most appropriate approach ? Do you have any suggestions for increasing metering other than what is mentioned above ?
No comment.
12. Are there any other issues we need to consider with regard to increasing metering ?
The meter should be readily available for the householder to read. At the moment it is usually situated in a 40cm deep hole in the footway , invariably covered with detritus and it is extremely difficult to read .
13. To what extent do you support or oppose the use of smart water meters instead of manual meters ?
Neither support/ nor oppose. Further information is required.
14. To what extent do you support or oppose use of incentives to encourage customers to use less water ?
Slightly support. In the sense that if this engages more people to take a more careful attitude to water use it is to be encouraged.
15. What incentives could water companies use to reduce customer use of water ?
There is a certain false premise in this question: it is asking water companies to reduce their sales volume .
16. To what extent do you support or oppose the use of RWH and GWR schemes at individual level.
Strongly support : with the caveat that further study would be helpful.
There should be a range of options available. For existing properties; this raises the critical issue of retro-fitting a dual pipe system. Again an individual RWH system raises issues of chlorination , storage and pumping. In the USA, there are examples of a dual pipe delivery by the water company with tariff incentives. This may incorporate a community application.
17. To what extent do you support or oppose the use of RWH and GWR schemes at community scale ?
Already answered.
18. How can government or water companies most effectively encourage people to reuse water in their homes ?
This is a slightly non-question. This needs to be careful modelling of the actual water use saving which can be achieved by the application of RWH and GWR . Also, a cost benefit saving analysis. Then; there need to be realistic schemes to apply that within existing homes. As a broad brush, current RWH proposals can include a flat plastic tank that goes onto the side of the house or a spherical tank that is sunk underground. To gain maximum use requires a dual pipe system built into the house with electric pumps. The cost outlay can be extortionate.
Equally, the use of GWR requires treatment, collection and storage and a separate dual pipe supply system.
There is an overall merit in these proposals, but the cost application is critical.
19. Do you have any evidence/views/comments on the potential impacts on water bills for various customers and geographical regions should the management of supply pipes be transferred to water companies ?
Further particulars are required.
20. Of the alternative options above, which is your preferred ? Please explain why or if you have other ideas.
Response: National policy for a single continuous pipe from main to wall mounted meter box in new build properties to address leakage.
At the same time; visual sight of the meter is required for all properties.
21. What other options are available to reduce leakage from customer supply pipes?
The short answer, for domestic premises , is to make the point of supply the outside of the house or other property. The electric and gas supply point is the gas meter within the house with an easement to run the supply pipe from the public highway. Why should water supply be any different ?
22. What are the main barriers to changing behaviours to reduce personal water use ? Please rank you top three options by other of importance:-
In reply: (b) insufficient information about personal water usage
(c) insufficient information about water scarcity
(d) lack of financial incentive and (a) support and advice.
23. Which organisation (s) ( if any) should communicate about how to reduce personal water use ? Please select all that apply.
Reply: (a) Water companies (d) environmental charities.
It is difficult. There needs to be an authoritative comment, which is seen to be on the side of the consumer.
24. If there are any further matters that you would like to raise or any further information that you would like to provide in relation to measures to reduce personal water use, please give details here.

25. Please provide evidence regarding what reduction in personal water use could be made by 2050 by using the following methods, plus any other you believe to be relevant.


1. This is an issue of fundamental importance in which the Department for Environment Food & Rural Affairs should be the lead Department.
2. There should be an immediate correction to the Planning System, which is not assisting in the reduction of personal water use.
3. Natural England, the Environment Agency, and the Water Companies should be evidential parties to any Local Plan substantive or review hearing. [A Local Plan Inquiry lacks the corrective mechanism of cross examination ].
4. DEFRA should take the lead and initiate, ( in conjunction with Natural England, and the Environment Agency) a topographical review to highlight the natural features for the optimum safeguarding of water courses, underground aquifers, river basins , flood prevention, coastal incursion, storm water pollution, together with the capture and storage of violent precipitation. Infrastructure and new build should complement those findings.
5. There is a thirty year window to achieve change. The opportunity must not be squandered.