Water & Wastewater Treatment Magazine
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In the know Digging deeper: policy and regulation 28 | DECEMBER 2016 | WWT | www.wwtonline.co.uk additional associated operating cost of £30M per annum thereaer. This represents both a considerable investment and a major programme of work for any water company, its service and equipment suppliers and contractors. However, little visibility of this potentially very significant demand appears to be actively transmitted within water companies, or to its providers, suppliers and contractors. As a consequence they are not aware of, and thus unable to prepare for, this significant future demand. Currently, the first many of them will know about this requirement will probably be a 'flood' of enquiries during PR19. Unless visibility is significantly improved across the whole industry, the UK could fail to meet its obligations regarding the WFD, let alone put itself in a position to exploit the opportunities presented by implementation of the WFD in the other 35 EU countries. It is recognised that some steps have recently been taken to improve visibility – for example, presentations at conferences on the CIP2 programme - and as welcome as this is, it is considered far from sufficient if the whole industry is to 'be prepared'. Furthermore, CIP2 is restricted to those technologies which it had to 'lock on to' at the beginning of the programme some three years ago, and a lot of new and potentially more cost effective technologies and techniques have come along during the intervening period. Brexit conundrum The whole situation is of course complicated by the outcome of the recent 'Brexit' referendum and it will inevitably take some time for a position regarding EU related legislation, and the WFD in particular, to be established. There are a range of possible scenarios as a result of 'Brexit' for the WFD; from implementation as is, through to further extensions of the timescale to spread the cost, through to a repeal of the whole Act (which would take time as this would have to go through Parliamentary Committees). There will be little clarity on the post-Brexit picture until well into 2017, with the Government's triggering of Article 50 in March set to be only the start of complex negotiations. This uncertainty is creating very real difficulty for the regulators and putting them in somewhat of quandary regarding PR19 and the content of AMP7. Do they push ahead regardless with the WFD while the UK remains in the EU, or do they stop, on the premise that the UK is leaving the EU and risk potential infraction proceedings or even compromising any negotiations arising from Article 50 activation? There are various mechanisms available to OFWAT which can be used to add additional programmes during an AMP, but they have never been used previously for work of such scale. Consequently, the next twelve months or so could be a critical time for the UK water industry in many respects, including how it prepares, manages and responds to the challenges associated with the WFD and the impact of Brexit. Everyone has a duty to try and minimise the cost impact to the UK, whatever the eventual outcome. However, this can only be achieved if all parties and participants have sufficient visibility. Collaborative platform It is for these reasons that the Water Framework Directive – UK Collaborative Platform (WFD-UKP) is being set-up. Platforms are becoming increasingly popular, and successful, in Europe as a way of encouraging collaboration to find better, more holistic, community involved solutions (which is a stated requirement of the WFD). The principal objective of the WFD-UKP (at least pre-Brexit) is to reduce the cost of implementing the WFD to the UK which benefits all platform members: regulators, academia, environmental bodies, water companies, consultants, contractors, equipment suppliers, consultants and others. Members of the WFD-UKP will get very much increased visibility of the WFD and its application within the UK allowing them to reduce their uncertainty and be better prepared for the eventual outcome(s). This visibility will be improved through newsletters, conferences and working groups as well as the opportunity to collaborate as never before in order to produce better total solutions to meet the requirements of the WFD. It is also ventured that this situation actually represents a significant opportunity for the UK in terms of the potential export of knowledge, expertise and technology which arise should we push on regardless of Brexit. So look out for further announcements, become a WFD-UKP member, and be prepared! -This article is an adapted version of a paper presented by Geoff Cooper- Smith to the 10th European Waste Water Management Conference on 11th-12th October in Manchester. The tougher requirements of the WFD are yet to be implemented