Chris Shirley-Smith* asks: who will regulate 'alternative' water resources?

Let us consider where we are going with sustainable water in the UK. I believe that it is high time that local government takes responsibility for non-potable (non-drinking or 'green') water as part of its long-term, strategic and regenerational endeavours. Non-potable water forms a minimum of 30 percent usage of domestic consumption and regulation of 'green' water at local and community level is both possible and desirable.

The UKWIR (UK Water Industry Research) report, 'Barriers to Innovation in the Water Sector', proposed holding a convention of stakeholders to 'agree the long- term strategic goals for the sector to which innovation could contribute'. But there was no mention of sustainability.

Through UKWIR's annual monitoring of sustainability issues over a period of seven years it can be seen that there are still significant areas of water companies' activity as yet largely unsullied by the concept of innovation or sustainability.

The House of Lords Science and Technology Committee also produced its conclusions after the consultation it held on its report into 'Water Management' (June 2006), stating: 'We reiterate our disappointment with the Government's response and encourage them to think again about our main recommendations as their water management policies evolve.' So, no mention of sustainability from the Government here either.

One can see that the problems facing the industry and its regulators are sufficiently daunting for them not to concern themselves much with 'alternatives'. Who then is to drive change if the water industry itself is still striving to get a grip on where to begin in post-IPCC days?

Setting the water industry aside for a moment, let us consider the rise of 'alternative' water systems. These we might group as those systems which rely on local input of water, which are by and large collected and consumed locally, and include rainwater harvesting (RWH), 'grey' water recycling, groundwater use, green roof and stormwater recirculation and so on. SUDS (Sustainable Urban Drainage) is already an accepted key feature which some local authorities have begun to explore, especially in regard to local flooding episodes.

To some extent it has become almost fashionable to consider RWH and its storage as one of the green, sustainable elements to be included in modern housing or commercial developments, promoted by BREEAM in its catalogue of building features. Schemes often achieve approval from local authority planners through the fulfilment of this set of criteria and the inclusion of RWH may, indeed, tip the balance in favour of the scheme. But are the long-term implications of such systems taken into account?

If an RWH system is serving a community of consumers from a communal collection and distribution network, it may be deemed to be a private supply and therefore whilst the duty of care may still lie with the development management agents, the responsibility for monitoring the non-potable, 'green' water may well reside with the Environmental Health Department of the local authority whose planning department agreed its installation in the first place. Unfortunately, and in all probability, that same planning department will almost certainly have failed (through a lack of suitable procedure) to notify the Environmental Health Department of the deployment of a RWH system. Nor, it can almost be guaranteed, are the staff of that Environmental Health Department either aware of their responsibilities or have the current skills, facilities or finances to be the rightful guardians of public health in this field. With the numbers of such systems creeping up, sooner or later there will be an 'incident' with the supply of such unregulated water and questions will be asked as to where the buck actually stops. The same situation applies whether it is RWH, grey water recycling or a non-potable 'green' supply derived from any other water source such as storm water.

A recent survey (2007) by BD (formerly Building Design), reports that 'two out of three local authorities are not ready to deliver the green homes promised by the Government', and that planners have called for 'stronger guidance from central Government' in order to be able to achieve this. What clues might we offer to assist the authorities in their mission  to protect the public in at least the water environment?

The first and most urgent step for the Government is to put in place regulation to establish a minimum quality standard for green water use in domestic environments - WWUK has been proselytising such a 'green water standard' for a number of years, along the lines of those adopted in Germany, Japan, Australia and the USA, but with little or begrudging heed from our own government to date - although perhaps some momentum is now gathering pace on this issue.

The next and equally important task is for local authorities to recognise that the inclusion of such 'alternative' green water systems should comprise part of their strategic regeneration plans and the structured deployment of local water saving schemes should form part of that initiative. The use of RWH, water recycling, groundwater abstraction, storm water, SUDS, green roofs and aquifer recharge are all techniques which can be used to treat and store water locally for non-potable use thus saving some 30 percent of highly treated drinking water. This will mostly apply to new build, but with ingenuity retrofitting need not be left out.

Since it would appear from BD's survey that often the very 'hands-on' and practical aspects of innovative energy, water and other utility requirements of green homes are beyond the scope of many traditional planning officers' remit and experience, the obvious repository of such technical knowledge should lie with what were formerly known as 'Borough Engineers'. But, of course, such officers are now almost an extinct breed. The nearest we have are the Building Control Officers who, again, have limited responsibilities.

This, then, is a wake-up call to all local authorities to reappoint and reassemble a new generation of teams of skilled engineering staff who are capable of assessing and handling the 'nitty-gritty' of innovative schemes. One of the foremost tasks this new team of engineers will have to undertake is the strategic and integrated planning and management of local green water projects which complement both the local development plan and the incumbent water company's efforts to reduce leakage, manage demand and create new resources. There is plenty of room for everyone and there is no time to waste.

*Chris Shirley-Smith is Director of Water Works UK Ltd.