Thoughts from Abroad: One Journey's End
On July 9, 2003, I chaired the final meeting of the Water Regulations Advisory Committee of Defra--the U.K. Department of the Environment, Food and Rural Affairs. I had taken up the post in July 1996 under a Conservative government in a department known simply as Environment. Reaching the natural end of an appointment, albeit a voluntary and unpaid one, is a slightly sobering time and gives one the opportunity to look back at the role and achievements of the committee and to assess what we were really able to do.
In order to place this in context, it is necessary to describe briefly the arrangements for water supply in England and Wales--Scotland, naturally, has a separate procedure. In the early 1990s, the water industry was both "privatized" and given responsibility by the government for self-regulation. This was part of a Conservative agenda to reduce the level of state regulation, an agenda that arguably brought about BSE in the national cattle herd and hardship to the elderly in unregulated care accommodation. In 1995, the House of Commons Environment Committee undertook a study of water conservation, taking evidence in a manner similar to Senate Committees from a range of identified experts, as well as inviting written contributions. Among the invited experts were Steve Ostrega and Amy Vickers from the U.S. I made the life-changing decision to submit written evidence relating to my views on the foot dragging displayed by the British ceramic industry in not reducing flush volume to 6 litres and not introducing high performance flush valves as a means of taking the flush volume lower still. Our research between 1978 and 1981 had developed, under industry funding, a 6-litre close-coupled w.c. that performed to a high standard when installed in a wide range of locations across the Brunel University campus, where I then worked. Unbelievably, at the end of the project we were informed that we had missed the point; we were supposed to prove 6 litres was impossible, thereby assisting industry to rebuff governmental pressure for water conservation--hard to believe in 2003. Subsequently, in conjunction with one rather more enlightened manufacturer, we developed a three-litre w.c. that was used in aid program-supported installations in Southern Africa, Brazil and China. Thus, by 1990 we had developed w.c. designs that could have given the U.K. industry a pre-eminent position.
The outcome of expressing these views (which may be read in the report of the Environment Committee, "Water Conservation and Supply," House of Commons, London, 13 November 1996) was that I was invited to the Department of the Environment to discuss taking on the role of chairman of the newly formed Water Regulations Advisory Committee (WRAC). The WRAC chairman's duty would be to bring in new regulations and to address the issue of w.c. flush volume. From July 1996 to this month, I have enjoyed that role, being responsible initially for the drafting of broad regulations governing all aspects of appliance use--from water usage in washing and dishwashers, to the detail of the backflow prevention appropriate to various levels of contamination protection. In addition, my committee was responsible for drafting and implementing regulations governing the acceptance tests that must be passed by w.c. designs before they could be legally installed in the U.K. These tests included solid discharge at 6 litres, utilizing the DIN and Australian and New Zealand standard flexible water-filled solids; a water exchange test that used potassium permanganate as a dye, and set to 1% and 6% for 6- and 4-litre flush levels; and a controversial toilet tissue test that required six crumpled 25-mm balls of toilet tissue to be successfully discharged at 4 litres. These tests were based on our research at both Brunel and Heriot-Watt Universities, and were assisted by Larry Galowin's input, as he spent 1998/9 as a Visiting Professor at HWU.
However, it became clear to the committee that setting standards without an input to the enforcement regime administered by the water companies was insufficient. Therefore the initial three-year remit of the committee was extended to 2002, and then 2003, to allow us to undertake an audit of enforcement policy and practice, and subsequently to make recommendations to the responsible government minister as to the changes or modifications required. The form of the audit was unashamedly based on the university institutional audits I had taken part in during the early 1990s. They featured a 12-month information period where each water company recorded data against a proforma, followed by a paper assessment and committee appraisal of the companies responses. This latter phase took place over September 11-12, 2001. None of the committee will ever forget where we were on 9/11.
The final phase of the audit featured interviews with representatives of the water companies, where generic issues brought up by the audit were discussed in detail. As always in such situations, memorable quotes just happened; for example, there was a very serious assertion by one company employee that "we don't have targets, so we can't then fail to meet them."
The recommendations resulting from the audit have led to a number of beneficial changes, including the development over the past year of a "Best Practice Manual" to guide the water companies in their approach to the enforcement of the regulations, particularly in the area of site inspections and the identification of backflow protection requirements.
The first inevitable question is, "Was it worth it?" I believe it was, as the U.K. has now clearly moved towards a more water conservation-conscious stance, with dual flush as the norm. W.c. flush volumes continue to fall, and for the first time, the percentage of water use by w.c. flushing is below 25% of the total domestic usage. The guidance to water companies will assist in enforcement, and future audits will have reliable base data.
The second question is, "Was it worth it from a personal stance?" Again, the answer must be positive. It was an extraordinary exposure to the workings of government over three administrations featuring both main parties that demonstrated the impartiality and quality of the U.K. Civil Service.
And finally, "Will I miss it?" Again, the answer is, "Yes," as the lifetime of the committee covered an exciting time in the evolving water conservation and climate change debate in the U.K., and it was exciting to have been part of that process.