Influencing our environmental performance
The water industry is currently facing a dilemma, balancing the need to reduce our carbon footprint whilst maintaining the quality of treated water flowing into our rivers and seas, that uses energy intensive treatment processes. Going forward, joined up policies and joined up regulation are vital, if new requirements like those demanded by the Water Framework Directive are to be delivered at an acceptable environmental and social cost.
In order to protect the natural environment and drive down our carbon footprint we are proposing the following:

The creation of a clear policy framework for sustainability from Government and the development of incentives within the regulatory regime to deliver this framework
Once the Government has provided the water sector with clear goals regarding sustainability, Ofwat must then ensure that appropriate incentives are put in place to encourage and support the delivery of these policy objectives.

Mandating a programme of investigation regarding the separation of surface water from the combined sewerage network
Currently much of the UK sewerage system combines surface water and waste water flows which can create problems during times of high rainfall. In order for us to achieve our aspiration of zero pollution incidents and flooding to customer's homes significant investment and innovative solutions will be required. It is a challenge that we are eager to take on, but new incentives offered by the regulator has to be the first step.

Requiring an environmental impact assessment of all existing and all proposed environmental regulations to assess their overall 'green footprint.'
The purpose of this proposal is to encourage the balancing of environmental considerations on both a local and global scale.
Encouraging greater use of low carbon energy for energy intensive processes
On shore wind farms and and energy capture at waste water treatment works offer real potential as renewable energy sources and currently this is not being fully realised. To make the most of these sources of renewable energy the current regulatory framework needs to be revised so that full account is taken of the potential long-term environmental benefits of investing in these sources of energy

Introduce more flexibility into the regulatory environment to facilitate a move to more appropriate standards - freeing up resources for environmental schemes that would deliver greater benefits elsewhere in the region
We recognise that tough standards do need to be in place, however there needs to be a balance struck to ensure that tighter standards do not result in negative effects such as increased energy consumption.

Mitigating climate change - water companies must measure the carbon footprint of all their activities (operation & construction) and set stretching targets for its reduction
In line with other sectors within the economy, water companies must be obliged to measure their carbon impact in line with national greenhouse reductions targets in the
2008 Climate Change Act

Review of existing policy instruments to ensure that they are fit for purpose and are delivering the policy change that was intended
Following a recent change to the structure of the
Carbon Reduction Commitment, we believe that all current instruments need reviewing to ensure that they are delivering the intended outcomes, in a sustainable manner.