Water Reform Concerns
09 March 2005 Judena Goldring
DOE
Environmental
Policy Group
River House
48 High Street
Belfast
BT1
2AW Dear Judena Water Reform Consultation Council
has welcomed the Water Reform proposals as a significant move towards provision of adequate incentives
to use water efficiently and believes that the industry should be able to recover the costs of the service.
However, within these Reforms, Council is concerned about the environmental
implications of some of the proposed changes. The change in the arrangements
for the emptying of septic tanks is a concern because of the potential risk that households will not
now empty tanks annually or when necessary, and hence this could contribute to the cumulative pollution
of our waterways, particularly since over 60,000 such tanks are involved to date. Housing pressure in
the countryside has trebled over the last few years and is now greater than that of rest of the UK.
The Water Service has recognised that there is an increased cost in running services particularly water
supply to dispersed housing in rural areas. Council would like to see some mandatory duty established
to ensure the correct maintenance of individual septic tanks and private sewerage schemes. Council
understands that a SEA will be applied to plans and programmes of the Water Service but not to private
suppliers. Council would recommend that a SEA is applied to the changes likely to happen under this
Reform concerning the replacement of government service by private company service Without mandatory
control, Council believes increased access to private water supplies and private sewerage will have
a serious cumulative environmental impact on water quality, particularly in catchments areas where development
pressures have increased. In this context we must not overlook the pressure
which catchment management planning under the Water Framework Directive will bring in pursuit of improved
water quality. Council would welcome the development of a separate drainage charge outwith the sewerage
charge and would ask that due consideration is given to encouraging sustainable solutions such as SUDS.
As metering is introduced, Council recommends that schemes are put in place to encourage the use of
grey water and of SUDS; we suggest that this should be a mandatory condition of all new housing development,
which might best be delivered through the legislation involved with the setting up of the new GoCo.
We would be grateful for early consideration of these matters and for an indication
of your views thereon. I enclose a copy of the CNCC response to the recent
consultation on Water Reform for your information. Yours sincerely Dr
Lucinda Blakiston Houston
Chairman CC Ian Maye
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