Consumer Scotland - energy, post and water - draft workplan 2022 to 2023: consultation

7. Water

Adapting to cope with flooding caused by climate change

What is the issue?

The flooding of homes, businesses and communities has been happening more often in Scotland as a result of climate change. The impact of extreme weather events can be devastating for communities. A challenge for Scotland's water sector is how to remove surface water from sewerage systems and bring it safely above ground.

Blue-green designs offer nature-based solutions, where outdoor areas are re-designed to naturally accommodate water safely, reconnect communities with nature and enhance spaces where people live and work. If delivered well, blue-green infrastructure can prevent flooding and offer multi-functional benefits that include improve community well-being.

Why are we looking at it?

It is predicted that there will be a 25% increase in the intensity of rainfall during this century, alongside longer dry spells in the summer. We know that people in Scotland support action to tackle climate change, but that many consumers do not understand what this will mean for them or their community. We need to step up engagement with people across Scotland as we shape the approach to adapting to increased flooding, and work in partnership with those that live and work in flood risk communities.

We will gather evidence on consumer attitudes and tolerance levels to climate change action to increase knowledge and to test how willing communities are to support and accommodate different types of changes. Alongside this we will seek insight from other nations that are developing community approaches to mitigate against the effects of climate change.

What is the outcome we're looking for?

A clearer understanding of what consumers need in order to adapt to prevent the worst impacts of flooding and to further understand how to engage consumers on specific climate change issues, as well as engage in societal improvements.

Adapting the use of water and wastewater in homes to tackle climate change

What is the issue?

Households in Scotland use more water than in any other part of the UK. The carbon emissions from the water sector are similar to the aviation industry^[7] . Most people are unaware of how much water they use and when asked, around 80% significantly underestimate their usage.

The summer of 2021 was the driest in 160 years and reservoirs across Scotland reached some of their lowest levels, causing water scarcity in many areas. The frequency of dry spells, that are severe enough to put public water supplies at risk, is expected to double this century.

Why are we looking at it?

Household water usage will need to adapt in response to Scotland's changing climate and carbon emission targets. Identifying effective ways of engaging consumers more consciously to engage with water reduction measures in the home and at work is essential. The water sector must meet the challenge of encouraging consumers to value water more.

Changes that consumers will need to make to their behaviour and their homes are not limited to just water use but extend to the appropriate usage of the wastewater system. Scottish Water spends an average of £6M each year unblocking sewers as a result of households disposing of wet wipes, sanitary products, etc. down the toilet, which can often end up on beaches or in our rivers. During periods of heavy rain, the presence of debris in the sewers increases the risk of sewer flooding to homes and businesses. Additionally, money spent unblocking sewers could be spent on improving other essential customer services.

As the consumer representative body, we will gather evidence on consumer attitudes, levels of consumer knowledge, and test how willing communities are to support changes that change how water and wastewater services are used.

What is the outcome we're looking for?

This work will provide a clearer understanding of how best to engage consumers on Net Zero and resilience to change how they view water and wastewater services. This will support the design of services that help reduce overall household usage and carbon emissions, and protect supplies from the impacts of climate change.

Fair and ethical regulation and practice within the non-household sector

What is the issue?

Scotland's water non-household water market now operates to a values-led culture which pushes for behaviours and practices that support ethical principles. This will support a market that encourages openness and transparency through collaborative working across service providers and regulators, and proactively operates in the customer's best interests to drive out harmful practices.

The consumer representative body is viewed as an 'honest broker' by market players. In this role Consumer Scotland will chair the new strategic Senior Stakeholder Group (SSG) for the water retail market in Scotland. The purpose of the group is to promote improvements to the market.

Why are we looking at it?

The application of ethical business regulation and practice (EBR/P) is still relatively new within the non-household market, and we are keen to use lessons learned from the Strategic Review process (2021-27) to support its implementation. EBP/P provides a robust framework to promote and strengthen consumer advocacy and adoption of the consumer principles.

A review of the Measures Working Group found that knowledge of EBR/P within the market, and confidence to put it into practice, remains limited. More is required to support a collective understanding among all market stakeholders, and commitment to champion ethical practices and improved outcomes for service users.

What is the outcome we're looking for?

We want to support embedding a fair and ethical framework of regulation and practice, which delivers better outcomes for non-household customers. Additionally, there is an opportunity for other sectors to learn from the EBR/P journey and the potential it has to deliver benefits for consumers and operatives.

Represent the needs and interests of consumers on Scotland's Hydro Nation Forum

What is the issue?

The Hydro Nation Forum advises Scottish Ministers on the overall direction and focus of Scotland's Hydro Nation agenda^[8] .

Why are we looking at it?

In addition to representation from the industry and academia, each Forum meeting includes a standard item on consumer issues, ensuring their interests are represented within each of the four key and interlinking themes of National, Innovation, International, and Knowledge. This provides an opportunity to share findings from consumer-focused research and discuss areas of interest and emerging themes with Forum members.

What is the outcome we're looking for?

Consumers being central to Hydro Nation concepts during planning, research and delivery. Additionally, that initiatives consider how to help consumers to link their behaviours and values to outcomes impacting upon water and sewerage services and the environment.

The adoption of the new EU recast Drinking Water Directive – to improve the quality of drinking water and access to it for all

What is the issue?

Scotland is adopting the new EU Water Directive. The directive takes a more holistic approach to managing water quality, recognising the need to monitor emerging pollutants and adopt a risk-based approach to protecting our drinking water sources. The Directive also aims to improve access to safe drinking water for all and enhance the availability of clear and transparent information to consumers.

Why are we looking at it?

The Directive will impact consumers both on the public water supply and those on private supply. It will have a direct effect on all households with lead water pipes as it is likely lead pipes will need to be replaced, affecting an estimated 270,000 households. While there are clear health benefits to doing this, there are also significant cost and disruption implications.

A core principle of the Directive is to ensure safe drinking water is available to all. This will require addressing the problems facing private water supplies, many of which have run out of water in recent years due to low rainfall as a result of climate change. The Directive provides an opportunity to improve support for private water supplies, and address some of the underlying issues they face.

What is the outcome we're looking for?

We will work with the Scottish Government and other stakeholders to ensure the Directive delivers positive and longer-term outcomes for consumers. This includes improving the quality and availability of information to consumers and ensuring that adequate measures of consumer protection and affordability are addressed in the drive to remove lead water pipes from homes.

We will also work with the Scottish Government and other organisations to re-assess current private water supply regulations and seek ways to deliver greater access to safe drinking water, financial support and accessible advice for those on a private supply.

Engagement in key industry forums

What is the issue?

Consumer Scotland will be a statutory consultee within the Scottish water sector's price setting process. It has a statutory duty, as part of a multi stakeholder group, to monitor Scottish Water's capital investment delivery. Currently, the sector operates to ethical principles to secure better outcomes for customers, communities, the environment and sector stakeholders through a more open, transparent, proactive and collaborative approach to planning and delivery of Scottish Water's investment priorities.

Why are we looking at it?

Scottish Water is undergoing a transformation process to meet its 25-year strategic plan, which includes a commitment to 'empower customers and communities'. The consumer representative body will continue to support this process, as well as monitor the delivery of its current investment programme, through membership of the Delivery Assurance Group and the Investment Planning and Prioritisation Group.

What is the outcome we're looking for?

Evidence that Scottish Water is embedding a strong customer and community centric culture that proactively and insightfully seeks to identify where and how planning and decision making can empower customers and communities.

Consultation Questions:

7. Are these appropriate water issues to focus on in our work?

8. Would you recommend the addition or removal of any water issues?