Ofwat has published its response to Defra’s consultation on the implementation of the revised Bathing Water Directive. (rBWD) Ofwat has expressed specific concerns that the current cost benefit analysis used by Defra could give a misleading outcome with costs to customers of the water companies being significantly higher, reflecting the private costs of financing the capital programme. Ofwat has also commented that some costs to the water industry have not been included in the impact assessment's water sector costs.
Commenting on Defra’s question as to whether England and Wales should aim to do more than the minimum that the rBWD requires (scenario 2 ) by 2015, Ofwat said that on the basis of the costs and benefits used , it did not believe that scenario 2 was justified. Ofwat are concerned that poor value investment might be driven by the objective of maintaining excellent water quality at sites which, through chance or favourable weather conditions, happen to have had "a good year".
The regulator also highlighted the fact that the carbon cost of the CO2 emissions has not been factored into the CBA commenting that the adoption of scenario 2 would be at odds with the Government's strategy for the water industry to reduce its CO2 emissions. According to Ofwat,
“under scenario 2, the tertiary treatment required at sewage treatment works (STWs) would result in an annual increase in greenhouse gas emissions of 600 tonnes of carbon dioxide (CO2) compared to an increase of 230 tonnes for scenario 1A/B. This increase in CO2 emissions results only from the energy cost of running the tertiary treatment (ultraviolet radiation) and does not include the energy cost of any additional pumping required either at the STWs or within the sewerage system (for the additional volumes of storm sewage retained within the system before being passed forward for treatment once flows have subsided). “
Ofwat also pointed out that there are examples around the UK of designated bathing waters where, owing largely to diffuse pollution, water quality cannot be reliably improved without taking disproportionately costly measures such as diverting rivers.
The consultation on the implementation of the Directive closed on 4 February, with the Directive due to be brought fully into effect later this year.


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