Water Reform Consultations

09 March 2005

Mr M McKee
Water Reform Unit
Lancashire House
5 Linenhall Street
Belfast
BT2 8AA

Dear Mr McKee

Reform of Water and Sewerage Services in Northern Ireland

Thank you for the opportunity to comment on the proposals for Water Reform.

Council welcomes proposals under Water Reform 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. We note that the reform must ensure full compliance with EU bathing waters UWWD and fishery directives, but we also advocate that compliance must also be pursued with the Water Framework Directive by contributing to the achievement of good ecological status of all water bodies by 2015. In this context special attention must be given to discharges affecting areas identified as sensitive and their catchments.

The Water Service has a substantial estate which could historically have been better used for biodiversity and public access. We would recommend that the legislation should empower the new GoCo to undertake and spend funds on works to enhance biodiversity and to facilitate public access thereby contributing to other government policy objectives.

The legislation should also allow the GoCo to provide incentives in both advice and financial support to consumers to introduce water saving measures such as grey water schemes and, support the installation of separating water efficiently and ensure drainage is adequately considered in all housing and road developments. Council considers that these schemes should also be able to access some of the NI block monies that would be released through water charging

The reform of the water and sewerage services will change delivery of services to the customers in regards to private sewerage disposal, such as septic tanks, or private water suppliers. Council believes that these changes could add to the deleterious cumulative impact on our water quality already presented by more than 60,000 septic tanks. Measures should be included within the legislation to control the environmental risk associated with "creeping" privatisation and to ensure that private suppliers of services are subject to a rigorous environmental regime and that any moves towards privatisation should be subject to a searching Strategic Environmental Assessment. Council has raised these issues with DOE.

Council has studied the Integrated Impact Assessment tool as applied to the Water Reform. We recognise that there should be proportionality of the effect of the environment, economic and social aspects of water reform, but we are concerned that the cumulative environmental effect is not adequately scored within this tool. We have requested further discussions with OFMDFM on this methodology.

I hope you find these comments helpful.

Yours sincerely

Dr Lucinda Blakiston Houston
Chairman