Introduction
I am making this submission to express my support for the bulk of the proposals for the
reorganisation of water supply in Ireland as set out in the “Position Paper” and in the “Irish
Water : Phase 1 Report” prepared by pwc.
I also wish to express my concerns with regard to the proposed introduction of meters, especially
the timing of and the proposed timescale for that introduction. I also question the proposal to
include a “free allowance” as part of the pricing structure.
Existing System
The flaws and shortcomings of the existing system for water supply in Ireland are clearly and
accurately set out in the pwc report and in the position paper. The reasons ( fragmentation, etc.)
are also clearly and accurately set out.
The Dublin water supply system clearly exhibits the national problems set out in the pwc report.
A single water supply system serves approximately 1.2 million people. It has two water
producers, (Dublin City Council 70% and Fingal County Council 30%), and involves one city
council, six county councils and two town councils.
While operational cooperation between these various authorities is excellent it is not possible to
have clear objectives, unity of action/response or efficient use of resources.
The Dublin region did manage to implement Telemetry, GIS and Network Modelling on a unified
basis. However the the fragmented nature of the system did prevent the establishment of optimum
structures to support those systems. The implementation of other systems focused on Water
Services was also hindered/prevented as the scale of the individual authorities was too small to
justify the expenditure on these systems.
The shortcomings set out in the pwc report clearly reflect my experience in water services.
Dealing with the problems and difficulties caused by this flawed structure was, unfortunately, a
necessary part of the job of managing the water supply system for staff in all the local authorities.
Public Utility Model
The proposed Public Utility Model, or similar structure, was discussed on many occasions as a
solution to the many difficulties and inefficiencies being experienced in the day to day running of
the water supply system in Dublin.
I believe that the benefits outlined in the pwc report are realistic and achievable. The benefit of a
single national entity being able to examine a problem, a proposal or an opportunity in a unified
overall manner, taking all aspects into account is, if anything, understated in the report.
Bringing the control of capital investment and the responsibility for operations and quality
together in a single organisation will also bring a huge benefit to the management of water supply
in Ireland.
I therefore concur with the recommendation for the Public Utility Model and with the benefits,
possibilities and opportunities outlined in the pwc report.
The type of structure being proposed was regarded as a utopian dream that would never come to
pass. The need foir reform was obvious, the number of viable solutions was limited, the benefits
that reform would bring to water services were also obvious and yet it has taken an extraordinary
national financial crisis to force us to put forward these reasonable and obviously beneficial
reforms.
Metering Background
Section 3 of the Position Paper deals with the issue of metering, firstly in general terms and then
under specific headings. The comments below are set out in a similar fashion.
Irish Water will be asked within a very short time, to start taking on responsibility for strategy,
capital planning and expenditure along with operational management and expenditure.
Irish Water will also be required to bill all customers, domestic and non-domestic and to collect
the money due. The objective is that Irish Water should become self financing within a
reasonably short period.
An Economic Regulator will be established to oversee and control certain aspects of Irish Water
to ensure that they are providing their customers with a proper service at a reasonable price.
I am in favour of water charges as I believe that they are necessary to secure a sustainable future
for water supply in Ireland. I therefore believe that the changes mentioned above should happen
and believe that they make sense.
Despite the complex nature of the question of metering and despit the huge cost of
implementation the decision to meter appears to have been made in the absence of a
comprehensive study of the question in the Irish context. A decision has been taken to spend
between €500 million and €1,000 millon (Most likely closer to the higher figure) with little or no
technical examination and no clear setting out of the objectives to be achieved by this very
substantial expenditure.
Irish Water will, I have no doubt, draw up a priority list for capital expenditue. In view of the
backlog of required investment and in view of the shortage of funds metering would appear very
low down that list, if it appeared on the list at all. Spending this amount of money, in this way,
now, makes no sense from a water supply point of view.
I cannot see why the question of metering and the possibility of a free allowance is not given to
Irish Water for examination. They will be required to implement and maintain any systems
installed. They will have to deal with any customer issues arising. I believe therefore that if they
are going to have to deal with the consequences of the decisions in this area then they should be
involved in the making of those decisions. Clearly the Economic Regulator would have to
approve any billing system prepared by Irish Water to ensure that it was reasonable, fair and
provided good value for money to ccustomers.
Irish Water should be tasked with examining the whole area of billing, including metering and
the free allowance and to put forward proposals to the Economic Regulator within a very short
period of its establishment. In the meantime a flat rate charge would apply.
Metering General
Despite the bald and definitive statements on the issue on pages 18 and 19 of the Position Paper it
is clear that there are many uncertainties and unanswered questions in this whole area.
In England and Wales where meter penetration istands at around 35% not all the companies have
plans to meter in the short term and some have timescales of ten to twenty years to achieve 90%
meter penetration. The timescale is shortest in areas of severe water stress.
In a paper titled “ Do Water Meters Reduce Domestic Consumption? : a summary of available
literature” Dr. Chad Staddon states;
“ In short, there are too many potentially confounding factors to be confident about the link
between metering and consumption suggested by the National Trials. Similar studies undertaken
in other parts of the UK since the National Trials, in Eastern and Southwestern England, have
returned similar results – it is difficult to distinguish between the effects of better network
knowledge and management, altered consumption behaviours, prevalent economic conditions or
weather and other extereaneous local factors (e.g. Condition of local housing stock, etc.). Thus on
the UK evidence, the true impact of metering needs to be seen in terms of better leak detection,
reduced peak consumption and little difference in average consumption in exchange for higher
cost and complexity in customer billing and management.”1
Many parts of the network consist of old mains and old service pipes. Installing meters in those
areas will be costly and problematic. Many local authorities install boundary boxes, capable of
taking a meter, as part of all repairs/excavations on service pipes. As part of mains rehabilitation
works the service pipe, at least as far as the property boundary is replaced. This includes
replacing the stopcock with a boundary box. In this way the work to facilitate the easy installation
of meters is being carried out without the cost of excavation solely for the purpose of meter
installation being incurred. Everything that can be done to make properties “meter ready” should
be done so that in the future if a decision to meter is made the costs will be minimised.
Mains Rehabilitation
Water mains rehabilitation is not an alternative to metering but it should be a much higher
priority. Dealing with the backlog of mains rehabilitation targeted on the basis of leakage
reduction is more likely to provide a sustainable reduction in water demand than a possible 5 –
10% reduction in domestic consumption that may result from meter installation and volumetric
billing.
In this way a greater return on the expenditure could be achieved even just in terms of water
conservation. There would also be the other benefits from rehabilitation including, improved
water quality, reduced burst rate, reduced supply interruptions, improved fire flows and a
reduction in the number of lead supplies.
All the properties served by the rehabilitated mains would be made meter ready. This would
allow any private side leaks on those properties to be dealt with and minimised or eliminated.
Reduced Consumption and Private Side Leakage
The reduction in consumption in Denmark is, in the pwc report, attributed in part to the price of
water, “One reason for the low consumption is high prices.” It is not clear that a similar “high
price” is proposed for Ireland. The incentive for reduction may not therefore be as great as in
Denmark.
In some of the UK trials initial reductions were observed but these savings reduced over time so
that the sustainable reductions were typically less than 10%. There is the possibilty that the way
the metering trials raised the profile of water usage and consumption affected peoples usage of
water. Education and publicity campaigns may therefore have resulted in some of the reductions
observed.
It may well be true that metering will help reduce consumption and help to reduce private side
leaks. The question is, really, to what extent does this happen and what will be the return, in
terms of water conservation, for the €1,000 million spent on installing meters. This question
needs further examination in an Irish context before an informed decision on the expenditure of
€1,000 installing universal metering can be made.
Providing Water Ireland with the authority to meter would allow private side leaks to be dealt
with much more effectively than at present. If a private side leak was suspected a meter would be
installed. If the leak was confirmed then the property owner would be informed, requested to
arrange for a repair and informed that if after a period of grace the leak was not repaired that the
water leaking would be charged for. This would reduce considerably the problem with private
side leaks by giving the property owner a clear incentive to have the repair carried out while
providing a reasonable period of grace for the work to be organised.
Risk Based Approach
I do not see a benefit in metering specific classes of property unless it was part of a risk based
approach. Meters could be installed on properties where high usage might be expected, properties
with swimming pools or properties with large grounds. Properties with a higher risk of leakage
might also be metered such as properties with long service pipes for example. These measures
might yield some of the successes that the metering of the Group Water schemes achieved for a
fraction of the cost of universal metering.
Metering some areas on a pilot basis might yield some valuable information but it would have to
be carefully thought out in terms of tariffs etc. Balancing the metered charges and the flat charge
so that the costs would be the same for the avarage “user” would avoid/reduce any feelings of
victimisation that metered users (or unmetered users) might have.
Long Lead in for Metering
The long term investment is in making properties meter ready not in the meters themselves as the
meters will last less than ten years with current technologies. Many local authorities have been
installing boundary boxes in replacement for stopcocks for the last five to ten years. I believe that
this should continue. All opportunities to make properties meter ready should be availed of. In
most cases the cost is minimal as the bulk of the work involved is necessary for other purposes –
repairs, rehabilitation, renewals, etc.
If at a future date Irish Water and the Economic Regulator decide that metering is desireable
and/or necessary a large percentage of properties will be meter ready and the cost will be
substantially lower, provided a reasonably long term approach is taken. The problem with a short
timescale for “universal” meter installation is that it forces holes to be dug just to fit meters, this
makes the meter installation expensive. The short timescale also forces surveys and even
excavations to be carried out just to find the supply pipe so that it can be metered. This would be
a very expensive element of a meter installation programme.
There are significant changes happening in meter and meter reading technologies and a slower
move to metering would allow the benefits of these changes to be availed of.
Free Allowance
There is no argument put forward in the documentation in favour of the proposed free allowance.
If the objective is to have Irish Water self financing then this “free” allowance will have to be
paid for either by higher prices for the “non free” usage and/or by increasing the charges to users
with high consumption. The question of affordability for households with payment problems
would be best dealt with via existing support systems from the Department of Social Protection.
The complexity this proposal brings into the charging system appears to make no sense as there
seems little if any benefit. If the objective is to encourage low usage there is no evidence of the
impact of such a proposal on consumption. The level and method of operation of the free
allowance has not been defined so the proposal is impossible to assess. Why is such an unclear
and ill defined proposal being put forward?
It may well be reasonable to ask Irish Water to look at this option as part of an overall review of
the overall pricing/metering issue and to reach a decision along with the Economic Regulator.
Summary
I agree that reform of the water sector in Ireland is necessary. I agree that a single Public Utility,
Irish Water, is the best option. The benefits and opportunities of such an organisation are clearly
and accurately set out in the documentation.
Water charges should be introduced as quickly as possible and shouldinitally, at least, be on a
fixed charge basis. Irish Water should be tasked to examine the whole question of metering,
billing and charging including the option of a “free allowance”. The final arrangements would be
agreed with the Economic Regulator.
References
1. “Do Water Meters Reduce Domestic Consumption?: a summary of available literature.”
Dr. Chad Staddon, University of the West of England, Bristol.
I spent 37 years working in Water Services in the Dublin region, up to my retirement from Dublin
City Council in 2011. This experience consisted of;
Drainage Services
Construction, Design/Planning 11 years Dublin County Council
Water Supply
Operations 7 years Dublin County Council
Leakage Control / Support services 4 years Dublin City Council
Project Engineer Dublin Region
Water Conservation Project 4 years Dublin City Council
Divisional Engineer Water
Services Division 10 years Dublin City Council
My comments above are informed by this experience.
Retired “Water Supply Engineer/Manager”