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Urban Water Journal
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An organisational innovation perspective on change in
water and wastewater systems – the implementation of
the Water Framework Directive in England and Wales
Marc Spiller
a
, Brian S. McIntosh
b
c
, Roger A.F. Seaton
d
e
& Paul J. Jeffrey
d
a
Department of Environmental Technology, Wageningen UR, Bornsesteeg, Wageningen, The
Netherlands
b
International WaterCentre, Brisbane, Australia
c
Smart Water Research Centre, Griffith University, Gold Coast, Australia
d
Centre for Water Science, Cranfield University, Bedfordshire, United Kingdom
e
Seaton Associates, Southwold, Suffolk, United Kingdom
Available online: 07 Mar 2012
To cite this article: Marc Spiller, Brian S. McIntosh, Roger A.F. Seaton & Paul J. Jeffrey (2012): An organisational innovation
perspective on change in water and wastewater systems – the implementation of the Water Framework Directive in England
and Wales, Urban Water Journal, DOI:10.1080/1573062X.2011.652129
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An organisational innovation perspective on change in water and wastewater systems – the
implementation of the Water Framework Directive in England and Wales
Marc Spiller
a
*, Brian S. McIntosh
b,c
, Roger A.F. Seaton
d,e
and Paul J. Jeffrey
d
a
Department of Environmental Technology, Wageningen UR, Bornsesteeg, Wageningen, The Netherlands;
b
International
WaterCentre, Brisbane, Australia;
c
Smart Water Research Centre, Griffith University, Gold Coast, Australia;
d
Centre for Water
Science, Cranfield University, Bedfordshire, United Kingdom;
e
Seaton Associates, Southwold, Suffolk, United Kingdom
(Received 4 March 2010; final version received 19 December 2011)
This paper presents an assessment of how the European Water Framework Directive (WFD) is stimulating change
in water and wastewater management. The paper aims to provide an organisational innovation contribution towards
understanding the processes by which policy and legislation stimulate change in water and wastewater systems.
Results were produced by analysing interviews with environmental managers from all water and sewerage companies
in England and Wales. Results show that integrated water supply approaches are emerging in response to the WFD,
while wastewater approaches are not changing to the same extent. Reasons for this difference are located in a mix of
factors including: economic regulation; conflicting national and EU regulations; uncertainty; lock-in to infra-
structure; the way in which different WaSCs frame business problems and opportunities, and a lack of technological
knowledge. Results are discussed against an international review of water sector change and against government
reviews of the water sector economic regulator.
Keywords: Water Framework Directive; water utilities; innovation; integrated water management; response
Introduction
By 2050 global population is forecast to rise to 9.3
billion with significantly more than 50% of people
living in urban areas (United Nations 2010a, 2010 b).
Such demographic change is placing increasing pres-
sure on water resources through creating additional
demand for drinking water and increasing volumes of
wastewater to be treated (Verstraete and Vlaeminck
2011). Moreover, urbanisation in combination with
climate change will affect the water cycle by altering
infiltration into and run-off from land, therefore
severely compromising the ability of aquifers to
replenish themselves (Jat et al. 2011).
In response to these pressures, scholars and practi-
tioners have argued that current, centralised, treatment
intensive, throughput oriented water and wastewater
management systems typical across the industrialised
world cannot meet the challenge of delivering reliable
service whilst preventing ecological degradation under
growing demographic pressure (Niemczynowicz 1999,
Novotny and Brown 2007, Pah-Wostl et al. 2008, Elster
and Bennett 2011, Verstraete and Vlaeminck 2011).
Instead, a transition towards more sustainable forms of
water management employing pollution source control;
the capture, appropriate treatment and use of multiple
water sources (river, ground, rain, storm and recycled
waters); sustainable urban drainage, and; wider involve-
ment of stakeholders in planning and management is
advocated (Brown et al. 2009). A key question to be
addressed by water professionals and scholars is how to
stimulate and manage the changes involved? What are
the barriers to change? How can they be overcome
through appropriately designed policy and legislation?
Based on a review of 53 studies of innovat ion
process in water and wastewater management Brown
and Farrelly (2009) provide evidence that the primary
barriers to change are socio- institutional rather than
technological in nature e.g. limited community en-
gagement, regulatory framework limitations, fragmen-
ted responsibilities and insufficient resources. Going
further, Brown and Farrelly (2009) argue that whilst
the existence and significance of socio-institutional
barriers is recognised by others (Neimczynowicz 1999,
Wong 2006) there is insufficient understanding of those
barriers and, importantly, how to overcome them.
In the EU, the Water Framework Directive or WFD
(EC 2000) is a significant legislative driver for change in
*Corresponding author. Email: marc.spiller@wur.nl
Urban Water Journal
2012, 1–16, iFirst article
ISSN 1573-062X print/ISSN 1744-9006 online
Ó 2012 Taylor & Francis
http://dx.doi.org/10.1080/1573062X.2011.652129
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water and wastewater management, seeking to tackle
many of the global challenges outlined previously within
the confines of Europe (Van der Brugge and Rotmans
2007). Taking the WFD as a key legislative driver of
change in the European water sector, and viewing water
utilities as central to water sector function and reform,
the aim of this study is twofold.
First of all to contribute generally to understanding
how to be tter stimulate and manage processes of
change in water and wastewater systems (so-called
systems innovation – see Smith et al. 2005), by
revealing the kinds of barriers to change which must
be overcome. Secondly, to contribute to understanding
the specific barriers facing WFD implementation in a
specific national context.
To fulfil these objectives an innovation perspective
similar to that of Rogers (2003) is employed within a
case study approach (Yin 2003). Through this research
design, the ways in which a national population of
water utilities perceive the need for and implement
change in response to the WFD will be analysed.
Thereafter, the kinds of barriers to WFD implementa-
tion will be characterised and critically assessed.
The national case study selected is that of England
and Wales (a part of the UK) where a fully privatised
model of water and wastewater service provision exists.
This study will focus on the ten large (turnover 2007/08
£m 391–1454 each, OFWAT 2008) Water and Sewerage
Companies (WaSCs) who are responsible for all aspects
of water supply and sewerage servicing. The principal
method for data gathering were semi-structured inter-
views with purposefully selected staff; recorded data was
subsequently analysed using thematic analysis. More
information on the structure and regulation of the UK
water sector can be found in DEFRA (2011). England
and Wales was selected as the case study since an
understanding of innovation in privatised water and
sewerage services is relevant, as increasing levels of
private sector involvement in water supply are expected
across the EU in future (Schouten and Van Dijk 2008).
Thus the insights generated by this study into change in
a privatised, regulated water and wastewater sector
should provide insight useful elsewhere.
The influence of institutional barriers has been
argued as important in relation to a lack of change in
water and wastewater infrastructure and management
by UK water utilities (Th omas and Ford 2005, Cave
2009, Spiller 2010). Thomas and Ford (2005) blame
this lack of innovation partly on the way in which the
UK water industry is economically regulated, and
partly on the way in which civil engineering attitudes
dominate the industry and act to privilege the selection
of large, centralised infrastructural approaches. In
response to the situation, two recent UK Government
reviews into the water industry (Cave 2009, DEFRA
2011) have recommended a set of institutional reforms
including some reform of the system of regulation and
in particular the practices of the water utility economic
regulator (Ofwat). The more recent more broadly
constituted review carried out by DEFRA (2011)
identifies the complex set of formal and evolved
behavioural relationships between Ofwat, other reg-
ulators and the utilities as a key element underlying
low innovation rates. We shall critically examine the
conclusions of these reviews in relation to the results
generated by this study. What evidence is there that
evolved behaviours between utilities and regulator are
inhibiting the kinds of WFD responses being consid-
ered by WaSCs?
Structurally the paper follows a traditional format.
First, the research method will be explained, then the
research results will be presented in terms of the
problems related to the WFD as percei ved by WaSCs
and the response options proposed and selected by the
WaSCs. Finally, water utility relevant barriers to the
implementation of the WFD in England and Wales
will be teased out through a critical discussion of the
implications of the finding.
Method
Conceptual framework – description and justification
The importance of understanding the determinants of
individual and organisational receptivity to change
stimuli has been recognised in the context of more
effectively designing and implementing changes to water
and wastewater systems including water policy and
water re-use schemes (Jeffrey and Jefferson 2003, Jeffrey
and Seaton 2004, Clarke and Brown 2006). The notion
of receptivity is based on the idea that response to a
change stimulus depends on how the recipient constitu-
ency perceives and translates the stimulus (a set of issues)
into a need for change (a set of problems to be solved)
and into the eventual change action itself (a set of
responses put into action). These points are conceptually
close to the stages of performance gap recognition,
choice between alternatives and redefining/restructuring
in organisational innovation processes from Rogers’
(2003) model which we employ here (Figure 1).
In Rogers’ model, innovation is defined as the
process of adopting behaviours, practices, objects or
ideas new to the organisation. The first stage of change
in this model is the recognition of a performance gap
by an organisation. This occurs through the identifica-
tion of issues (internal or external) which may require a
response or change, and which are judged against the
performance of the organis ation as defined by an
aspirational or legally mandated level. If performance
falls below the aspirational or mandated level, a
problem is perceived organisationally. The second
2 M. Spiller et al.
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stage involves the organisation generating and choos-
ing amongst possible alternative response options
(Rogers’ ‘Matching’) before redefining them to fit their
specific context/needs, and potentially restructuring
the organisation to better exploit or use the innovation
concerned during the third stage (Rogers’ ‘Clarifying’).
The remaining two stages (diffusion and routinisation)
involve the organisation diffusing the innovation out
to become standard practice more widely, and adjust-
ing the innovation and itself to more routine use in
particular sets of activities.
The details of how each of Roger’s process stages
works will vary from organisation to organisation, and
potentially over time as organisations change the way
they function. Providing an insight into the stages of the
process, their operationalisation and what influences that
operationalisation has across the population of WaSCs
in England and Wales is a major aim of this paper.
In reviewing the literature on innovation manage-
ment, and knowledge transfer, it is apparent that
Rogers’ model rep resents one articulation of what can
be seen as a consensus over the process stages involved
in intra-organisational change. Table 1 collates some
of this literature for the reader who is unfamiliar with
it, showing where similarities and differences in the
characteristics of the stages of the process exist, and
how there is broad agreement on the overall structure,
sequence and outcomes of the process. The stages of
the process identified by each author which are
essentially equivalent in outcome are shown on the
same row in Table 1 e.g. ‘awareness’, ‘acquisition’,
‘search’, ‘gathering information’ and ideas on a
‘problem’ and ‘agenda setting’ stages.
Whilst alternatives exist, Rogers’ model was
deemed most appropriate, because of the robustness
of the model as demonstrated through repeated
application. The model has been successfully used to
represent and understand organisational change pro-
cesses across a wide range of application areas
including over 30 applications to water management
(data from Web of Science ‘cited reference search’
executed on 23/06/11).
Conceptual framework - use
The research reported here elaborates on the barriers
to innovation in relation to the first two stages of
Rogers’ model by, respectively:
(1) Characterising and explaining variations be-
tween WaSCs in relation to WFD issues (the
stimuli for change perceived by each com-
pany) and problems (the perceived perfor-
mance gaps in relation to perceived issues),
and;
(2) Characterising and explaining variation be-
tween WaSCs in terms of the alternative
response options they are using or planning to
use to address those perceived problems.
We focus only on the first two stages of
Rogers’ model as we are concerned with under-
standing the relationships betw een WaSC problem
perception and response selection and with the
influences on response (or option) selection. This is
sufficient to enable an initial assessment of barriers
to change.
Taking organisational receptivity and innovation
as the underlying conceptual framework, the research
reported here employs an interpretive epistemology
Figure 1. The innovation process in organisations and purpose of each stage for this research (adapted from Rogers 2003); for
the purpose of this research the original names of the second (matching) and third (clarifying) process stage of Rogers model have
been altered. The rationale for this is explained in the text.
Urban Water Journal 3
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Table 1. Comparison of innovation management, technology transfer and knowledge transfer models.
(Trott 1993, Trott 2005)(Jeffrey
& Seaton 2004) (Gilbert 1995) (Tidd et al. 2005) (Gallouj et al. 2002) (Rogers 2003)
Awareness
Capability to scan for internal
capabilities and external
information and to match
these to realise business
opportunities
Acquisition
The process of acquiring
knowledge by the
organisation, the ability of
an organisation to learn
from its experience, by
employing individuals with
new knowledge and by
scanning.
Search
Searching and selecting
incoming signals about
potential for change
applying mechanisms for
identification, processing
and selecting information
Gathering information and ideas
on a problem –
Any kind of information
whether internal or external,
collected formally or
informally, ‘‘associated with
the activity of problem
formulation – which may in
itself be a source of
innovation’’
Agenda Setting
General organisational
problems that may create a
perceived need for
innovation.
Association
Internal capabilities and
external information are
linked and an association to
the commercial exploitation
is made.
Communication
‘Diffusion’ of the acquired
knowledge through
communication mechanisms
to encourage the spread of
new knowledge.
Selection
Selection of the of
technological and market
opportunities which fit the
technology base of the firm
(strategy) and develop an
innovation concept that
matches the overall business
Research
Creation of new knowledge
through combining various
stocks of knowledge
Matching
Fitting a problem from the
organisations agenda with
an innovation.
Assimilation
The organisational process of
transforming commercial
associations into a business
opportunity
Application
Adoption of the knowledge
helping the organisation to
store the information and
transform it into routine
procedures
Implementing
Acquiring knowledge resources
A gradual process in which
pieces of knowledge are pulled
together and conceptual
design is generated
Executing the Project –
Integrating various discipline
and backgrounds (incl.
market related) and
redesigning the innovation
Launching the Innovation –
Preparing the market (external)
and the organisation
(internal) for the innovation
Conception and development
Transformation of the ideas
gathered into a solution of
the problem, test and
customise the design
Reinnovation/Restructuring
The innovation is modified and
re-invented to fit the
organisation and
organisational structures are
altered
Application
The ability to apply knowledge
to achieve a benefit as
judged by the recipient
Assimilation of knowledge into
routines, involving the
transformation of
individuals’ perceptions,
attitudes and behaviours
Production of the solution
In services client participates in
the production process
Clarifying
The relationship between the
organisation and the
innovation is defined more
clearly.
Marketing of the solution
Selling the innovation
internally or externally
(external or internal
marketing), can involve the
protection of the innovation
Routinising
The innovation becomes an
ongoing element in the
organisations activities, and
loses its identity as an
innovation
Learn and Reinnovate
Exploit successful innovations
further through
modifications and
redefinition of features;
assess failing innovations to
learn form experience
4 M. Spiller et al.
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which views the understanding of the perceptions of
individuals in significant decision making positions
within organisations as key to unde rstanding the
reasons behind organisational change. Consequently,
the primary data gathered was from a targeted
sample of key managers from WaSC organisations in
England and Wales.
Study design
The evidence presented here is drawn from semi-
structured, recorded interviews of around one to two
hours each. In total 17 interviews were carried within
nine out of the ten English and Welsh WaSCs. One
WaSC could not be accessed for interview despite
several attempts.
Accountability for WFD response planning was a
precondition for interviewee selection and the basis of
our sampling. More specifically, all interviewees were
senior managers involved in preparin g the WFD
aspects of strategic company plans (specifically formal
regulatory requirements in England and Wales includ-
ing - Strategic Direction Statements and Price Review
09 submissions). These individuals played a key role in
influencing their WaSC’s organisational agenda in
relation to recognising, emphasising and de-emphasis-
ing WFD issues, identifying consequent problems to
the WaSC and informing the processes of response
generation and selection. Semi-structured interviews
with open-ended questions were employed deliberately
to enable a flexible, discursive format to the data
collection. Individuals were asked to respond on behalf
of their organisations.
Thematic analysis
Qualitative thematic analysis was employed to char-
acterise and categorise WFD problem perceptions and
response options. Qualitative thematic analysis is a
method to identify patterns or themes in transcribed
interviews. Braun and Clarke (2006, p. 79) argue that
thematic analys is is a widely used but a ‘‘poorly
branded method, in that it does not appear to exist as a
named analysis in the same way as other methods’’ (e.g.
grounded theory). The coding of text is a key
characteristic that thematic analysis shares with these
other approaches (i.e. grounded theory). Strauss and
Corbin (1998, p. 101) define coding as ‘‘the analytical
process through which concepts are identified and their
properties and dimensions are discovered in the data’’.
Miles and Huberman (1994) suggest that coding
begins with descriptive codes. Later in the process,
when the researcher has developed knowledge about
the data, codes become more interpretive and
inferential.
To distinguish problems driven by the WFD from
those driven by other EU directives or WaSC business
concerns, the following criteria were applied:
(1) Problems directly associated with the WFD by
the interviewee (i.e. interviewee refers to the
WFD as a driver for the problem) and;
(2) Problems legislated for in the WFD (e.g.
ecological status, balanced abstraction)
If both criteria were met, the problem was termed a
WFD chan ge problem. Responses were identified
when the interviewees specifically referred to options
being under consideration, a lready planned or
implemented.
Problems and response options were first cate-
gorised through descriptive coding. The distinguishing
feature of descriptive coding is that it stays close to the
language, the concepts and meanings of the social
actors, rather than being derived from pre-selected
frameworks (Blaikie 2000). This ensured that no
problems or responses were excluded by pre-s electing
a structuring or categorisation framework. Later in the
process labels for the coded text were defined either
using concepts suggested by the interviewees or by
other scholars (e.g. Diagnosis; Wait and See). Pro-
blems and response categories were then related
through being classified hierarchically into broader
themes. The validity of coding was checked through
researcher triangulation i.e. the authors discussing and
agreeing on the coding (Robson 2002).
The reader should note that we looked for but did
not find disagreement between managers interviewed
within the same WaSC. Rather, managers confirmed
each other. Where two interviewees from a WaSC
reported complementary, but non-overlapping pro-
blems and responses, we took the sum of both
responses as being representative of the company.
Results - WaSC perceptions of and responses to the
WFD
Interviewees conceptualised WFD problems as falling
under two main thematic categories, ‘Water Supply’
and ‘Wastewater’ (Figure 2). In addition, an extra
category for ‘Other’ problems that were not associated
to this core business of WaSCs was de rived. Water
Supply comprised activities that relate to the delivery
of clean water to the customer, while Wastewater
included activities associated with the collection,
treatment and discharge of effluent. Water Supply
was further distinguished into Raw Water Quality
Management (RWQ) and Water Quantity Manage-
ment (WQ) problem categories, whilst Wastewater was
further distinguished into Nutrient Removal (NR) and
Urban Water Journal 5
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Priority Substances (PS) problem categories through
thematic analysis.
RWQ problems were defined as those concerning
the quality of the water environment in general, and
water quality at the point of abstraction more speci-
fically (relevant to WFD Articles 1a, b and 7). Water
Quantity problems were defined as those concerned
with flows of water in the environm ent, and with
abstraction and demand (relevant to WFD Article 1c).
Nutrient Removal (NR) problems were defined as
those involving efforts to reduce the emission of nutrients
and associated substances (COD, BOD
5
,TSS,NandP-
relevant to Article: 10). Priority Substances (PS) pro-
blems were defined as those involving efforts to phase out
chemicals harmful to human health (relevant to WFD
Article: 16 and Annex X).
WFD problem perception
Raw Water Quality (RWQ) problems
Interviewees perceived the WFD as on opportunity to
improve raw water quality and therefore benefit by
saving operational costs for water treatment and
capital expenditure for water treatment assets (Table
2). Specifically, the water protection zones required
under Article 7 of the WFD were considered an
opportunity to achieve such cost savings, the reason
being that these zones give additional legal rights to the
environmental regulator (Environment Agency) to
enforce the control of pollution at source, resulting
in lower treatment requirements and costs to WaSCs.
Concerns were raised as to whether this new
approach to raw water quality management can be
implemented under the present regulatory framework.
Ofwat was the prime focus of concern. The enforce-
ment of the polluter pays principle was seen to
constrain the opportunity for WaSCs to develop
source control interventions – changes to agricultural
or land management practices to avoid pollution, such
as co-operative agreements between utilities and farm-
ers (Brouwers et al. 2003). Similarly, the present
regulatory regim e was perceived to incentivise capital
intensive asset investment, rather than promoting
solutions based on negotiation between different
actors – solutions based on operating expenditure
only. Some WaSCs did not see RWQ problems as their
responsibility but rather argued that the improvement
of raw water resources should be the responsibility of
the Governmental environmental regulator, the En-
vironment Agency, and its parent Department,
DEFRA.
Uncertainty, associated with the implementation of
WFD Article 7 and the definition of ecological status
(the way in which aquatic ecosystem health is to be
defined under the WFD, and consequently the
indicator to be improved as a result of water manage-
ment changes) was often expressed as a hindrance. The
WFD implementation process was also considered to
be insufficiently transparent and lacking in measurable
targets to which WaSCs could respond (Table 2).
Furthermore, one WaSCs noted that the business
culture of treatment and supply rather than catchment
scale environmental management meant that they
would not be well positioned to tackle raw water
pollution issues effectively at source.
Water Quantity (WQ) problems
Water quantity problems arising as a consequence of
the WFD included the impact of abstraction on
protected sites and the associated reduction of
abstraction licenses (Table 2). However, it was also
argued that the WFD brings the opportunity to
Figure 2. WFD change issues perceived by WaSC representatives.
6 M. Spiller et al.
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improve river flows which will secure water availability
and contribute towards a better water quality in the
future with resulting reduction in treatment cost and
benefits in achieving discharge consents. Exogenous
pressures such as increasing household demand,
demographic change and climate change were viewed
as factors likely to increase water consumption and
hence the need to abstract increasing volume s of water
from the environment, potentially clashing with the
ambitions of the WFD.
Nutrient Removal (NR) problems
Some WaSCs were concerned that more stringent
requirements for nutrient removal are likely to arise as
a result of the WFD objective to achieve ‘good
ecological status’ for water bodies. Some companies
pointed towards the need to invest in technologies for
phosphorous and nitrogen removal (Table 1). Other
companies expressed their concerns about the uncer-
tainty of required standards and treatment technolo-
gies. Some other WaSCs highlighted con cerns that
higher demands for treatment effectiveness will drive
increased CO
2
emissions, thereby clashing with carbon
policies in England and Wales.
Priority Substances (PS) problems
Across the England and Wales, WaSCs indicated that
there was a lack of appropriate technology, and
further, a lack of sufficient underpinning scientific
and engineer ing knowledge about PS detection and
removal. Some WaSCs were of the view that techno-
logical adaptation will significantly drive up capital
and operational costs, and in doing so potentially
increase CO
2
emissions.
Other WFD implementation problems
Interviewees highlighted conflicts arising from the
interplay between the WFD and other EU directives.
The clash between the EU Habitats Directive and the
WFD is a specific case of concern for many. The WFD
requires member states to cond uct a cost assessment of
implementation measures and allows for extension of
deadlines as well as achievement of less stringent
objectives based on disproportionate costs (WFD
Articles 4.4, 4.5 and 4.7). On the contrary, the Habitats
Directive does not include cost considerations, but
leaves the potential for implementation of dispropor-
tionate costly alternatives or severe reduction of
abstraction licenses.
Moreover, the UWWTD (EC 1991) presents a
pressing concern for WaSCs. In the view of the EU
several coastal waters surrounding the British island
Table 2. Problem perception of WaSCs across the WFD change issues (X indicates a problem perception that has been detected; abbreviations: CC ¼ Climate Change;
GW ¼ groundwater).
Water Supply Wastewater
RWQ WQ NR PS
Benefit
Diffuse
pollution
Business
culture
Inadequate
policy Uncertainty
Impact of
abstraction
Increased
demand
CC
water
stress
Benefits from
improved
flows Investment
CO
2
emissions Uncertainty
Discharges
to GW Uncertainty
CO
2
emissions Investment
Inappropriate
technology Overall
AX X XXX 5
BXX X X4
DX XX XXX X7
EX X XXX X6
F XX X X 4
GXX XX4
HX X XX 4
IX XXX X X 6
JX XX XX X X 7
N ¼ 95315 3 3222 423 1 212 6
Urban Water Journal 7
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(i.e. Wash, Humber and Thames estuaries, the North
Coast of Wales, the South Coast of Scotland) should
be designated as nutrient sensitive under the UWWTD
(EC 2007). If the appeal of the UK government against
this decision fails, it would result in the designation of
large river stretches as nutrient sensitive. The invest-
ment to meet the associated treatment and infrastruc-
tural targets could be substantial with current
technology.
Variety of problem perception
The set of WFD pr oblems perceived was heteroge-
neous across the population of WaSCs (Table 2). No
two organisations exhibited the same profile of
problem perceptions. Some WaSCs are more exposed
to the WFD as a change stimulus than others
i.e. WaSCs D, E, I and J mentioned more of the
problem categories than other WaSCs (each mentioned
6/17 or 7/17 problem categories). It can also be seen
that some problems are not perceive d as affecting
some WaSCs at all e.g. WaSC F did not mention
RWQ problems at all, WaSCs B & G did not
mention WQ problems at all, WaSCs E & G did
not mention NR problems at all, and WaSC A did
not mention PS problems at all.
Looking down the columns (problem categories) in
Table 2 the potential benefits of the way in which the
WFD might impact RWQ were widely perceived as
opportunities for change (by 5/9 WaSCs) but the same
set of WaSCs also perceived inadequate policy
surrounding the RWQ aspects of the WFD as a
problem (5/9 WaSCs). The lack of appropriate
technology for treating PS was perceived as a prob lem
by 6/9 WaSCs. Investment concerns were mentioned
by 5/9 WaSCs for Wastewater related problems but
not mentioned for Water, although concerns about
being able to implement operational rather than
capital cost focussed solutions was raised in relation
to Water Supply (RWQ in particular).
Response options
The response options to the WFD were classified as
follows:
. Diagnosis – activities to better understand and
define a problem through investigation of the
properties of a system, and activities to deter-
mine the character of viable response options
(Mintzberg an d Raisinghani 1976). Examples -
monitoring and modelling;
. Process R&D – distinct from the diagnostic
activities, process R&D is not focused on
understanding systems, but rather on improving
or installing technical processes or artefacts.
Examples - development of new treatment
technologies and their installation;
. Management –interventions which may involve a
mixture of technology and process changes to
achieve management goals. Example - metering
to reduce water consumption;
. Change legal framework – activities which aim to
influence and thus change the legal framework
under which WaSCs operate. Examples - lobby-
ing policy, collaboration with policymakers;
. Wait and see - deferral of action (Berkhout et al.
2006). Examples - delay action until legal
requirements are specified.
Raw water quality (RWQ) responses
The findings suggest that for RWQ there are three
response options considered by WaSCs, i.e. ‘‘diagno-
sis’’, ‘‘management’’ and ‘‘change legal framework’’
(Table 3). Management options were predominately,
but not exclusively, about the farming community.
Frequently, these responses focused on liaising with
and providing advice to land managers or farmers to
improve farming practice. The aim was to improve
water quality at the point of abstraction and to
consequently reduce water treatment costs (operational
expenditure and capital expenditure) and potentially to
develop new incomes for farmers through accessing
agri-environment funding schemes and improving on
farm efficiency (Heinz 2008).
Diagnostic response options were being considered
by WaSCs with the aim of identifying sources of
pollution and modelling their impact on the aquatic
environment at a catchment scale. Two WaSCs
explained how they sought to influence policy through
successful implementation of case examples, whilst
others were using lobbying to change the legal frame-
work. Finally, one WaSC indicated they were adopting
a ‘‘wait and see’’ approach to receive more specific
policy and regulatory guidance.
Water Quantity (WQ) responses
The response options considered for WQ problems
were found to be ‘‘diagnosis’’, ‘‘management’’ and
‘‘process R&D’’ (Table 3). Here diagnosis is con-
cerned with modell ing and assessing river flows and
their impact on water quality. Management responses
were concerned with reducing water consumption
through managing demands using education or
metering interventions, or a combination of both.
Another response was to manage the upstream
catchment in order to improve river flows and thereby
raw water quality. Lastly, process R&D was
8 M. Spiller et al.
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considered as a response in the sense of designing
technological options to increase supplies (i.e.
desalination).
Nutrient Removal (NR) responses
NR problem responses focused on influencing the
legal framework either through joint projects with
regulating authorities or negotiation with regu lators
(Table 3). Some WaSCs were specifically lobbying
for a change in trade effluent regulations or for a
ban of Phosphorous in detergents. One WaSC was
considering how best to support and lobby for
catchment consenting, an approach where discharge
limits are set at a catchment level rather than
individual works.
Some WaSCs described strategies to improve
treatment processes (process R&D) to meet tighter
NR standards. An important additional criterion of
these process innovations was to reduced CO
2
emis-
sions and energy costs. Furthermore, two WaSCs
pointed towards diagnostic activities such as modelling
of discharges or investigations into the implementation
of phosphorous source control.
Management activities such as maintenance of
sewage treatment works or management of sewers
(e.g. sustainable urban drainage systems) to improve
treatment efficiency of sewage treatment works were
also being considered as response options. Finally, one
WaSC also proposed taking a ‘‘wait and see’’
approach.
Priority Substances (PS) responses
The major response to PS problems was to seek to
change the legal framework, predominantly in rela-
tion to controlling PS at source (Table 3). Lobbying
was indicated as one response for achieving policy
change. ‘‘Process R&D’’ was being used experimen-
tally, almost like diagnosis, with the aim of under-
standing the fundamentals of PS detection and
removal. ‘‘Diagnosis’’ responses were found in the
form of research that focuses on isolating the origin
and fate of PS in the wastewater system. Education
and new approaches to trade effluent charging were
proposed as managerial responses with the aim of
changing polluter behaviour.
Variety of response
As with the distribution of problem perceptions there
was no obvious grouping of response profiles (Table
3). However it can be seen that there was variation in
the extent to which different WaSCs were engaged in
responding to the WFD, and the range of options
Table 3. Responses of the population of WaSCs across the WFD change issues (X indicates a response option that has been detected).
Water supply Wastewater
RWQ WQ NR PS
Diagnosis
Change
legal
framework Management
Wait
and see Diagnosis
Process
R&D Management Diagnosis
Change
legal
framework
Process
R&D Management
Wait
and see Diagnosis
Change
legal
framework
Process
R&D Management Overall
AX X 2
BX XX X 3
DX X XXX X X 6
EXXX X X X XX 8
FXXXXXXXX8
GX X X XX 5
HX XX 3
IXXX X XXX 7
JX XXX X X 6
N ¼ 95 4 5 131 3 2 5 3 2 22 6 5 1
Urban Water Journal 9
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being considered, planned or used. For example
WaSC A mentioned being exposed to five out of 17
WFD problems but only discussed two types of
response option (management for RWQ and change
legal framework for NR); while other WaSCs, like
D, E, F and J, were considering six to eight response
options. So, the number and consequently diversity
of response options being considered appears to be
positively associated to the number of WFD
problems perceived, but not universally so e.g.
WaSC F mentioned four WFD problems but also
eight response options.
In the columns of Table 3 (the response options)
one can see that the most frequently mentioned
responses are diagnosis and management for RWQ
(five out of nine WaSCs for each), change the legal
framework for NR (five out of nine WaSCs) and for PS
(six out of nine WaSCs), and process R&D for PS (five
out of nine WaSCs). PS is the only problem category
with a significant R&D response.
Discussion
From the results we conclude (i) that the WFD is more
effectively stimulating change in water supply than
wastewater approaches and; (ii) that the system of
national water regulation in England and Wales is
partly constraining change in both water supply and
wastewater, particularly in relation to the way in which
WaSCs and the economic regulator interact. We will
discuss each of these conclusions in turn before
assessing the socio-institutional nature of the kinds of
barriers found to be influencing the WFD implementa-
tion process in England and Wales.
WFD more effectively stimulating change in water
supply
The results suggest that the WFD may be more
successfully stimulating change in approaches to water
supply rather than wastewater management. We
believe this to be the case for a number of reasons.
First the perceived water supply problem categories
RWQ and WQ, contained responses focussed on novel
approaches, particularly in relation to catchment based
rather than end-of-pipe management. For instance,
control of drinking water pollution at source through
improved integration of land and water management
was put forward by a number of organisations as a
response to water supply problems e.g. source control
interventions such as co-operative agreements between
utilities and farmers (Brouwer et al. 2003). It must be
noted that one WaSC was considering a technological
response to RWQ and WQ problems in the form of
desalination.
Contrary to the findings for water supply, there was
almost no reference to decentralised stormwater
harvesting, water sensitive urban design (WSUD) or
wastewater re-use technologies which are standard
practice in some areas of the world including Australia
(e.g. Water by Design 2007, Bligh Tanner 2009). Such
whole of water cycle approaches to different wastewater
streams appear not yet financially attractive for parti-
cular WaSCs, not yet technically understood sufficiently,
simply not associated with the WFD or, perhaps in the
case of WSUD, not seen as the business of WaSCs.
In addition, WaSCs argued that the national
regulatory framework is not well suited to wastewater
management and needs to be altered to stimulate
change. In the few instances where new, more
integrated, wastewater management solutions were
mentioned as attractive (e.g. SUDS and catchment
consenting) a lack of regulation was also perceived to
be a constraining factor in terms of implementation.
Changes in water supply also faced regulatory
constraints which were perceived to be inhibiting
change. Raw water quality improvements and conse-
quently the finan cial benefits to WaSCs likely to arise
from effective land management activities were per-
ceived as not being accountable for in the five year
funding cycle imposed by Ofwat, and also difficult to
justify in the face of Ofwat’s (perceived at least)
adherence to the polluter pays principle. Similar
conclusions were drawn by Andrews (2003) who
suggested that the most significant barrier for im-
plementation of land management approaches is the
system of economic regulation of water utilities in
England and Wales, which does not allow the
associated costs to be passed on to customers. We
will return in the next section to examine the influence
of the UK regulatory system.
Other potential explanations for why the WFD
appears to be more successfully stimulating change in
water supply than wastewater can be offered when
climate change policy and regulation are taken into
account. UK climate change mitigation and CO
2
emissions reduction regulation were often perceived
to be in conflict with the demands of the WFD for
higher, more energy intense wastewater treatment
processes to meet more stringent standards for removal
of priority hazardous substances. On the other hand,
pollution source control for raw water has the
potential to reduce energy demands for pesticide,
nitrate or dissolved organic carbon removal, while
requiring little capital investment. Such pollution
source control can, in specific circumstances, also
assist in meeting WaSC conservation objectives (such
as those driven by the EC Habitats Directive), through
restoring habitats, reducing pollution and ameliorating
summer low flows. The need for a convergence of
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factors including policy perception, legal obligation
and financial interest is supported by our work and has
been argued as essential for the stimulation of change
in large socio-technical systems such as water and
wastewater management (see Berkhout and Green
2002, Smith et al. 2005).
Another explanation can be teased out when
considering the influence of existing capital invest-
ment in the water sector. The Urban Wastewater
Water Treatment Directive (UWWTD) (EC 1991)
required significant wastewater asset investment in
the 1990s and the early 21st century in towns with a
population equivalent of 2000 or more. It is possible
that WaSCs are locked into their investments from
the recent past and are consequently reluctant to
consider change until those assets approach the end
of their useful life.
Finally, there was also evidence in our interviews
that organisational aspects such as the preference for
specific, less risky responses played a role in inhibiting
change. However, there is no immediate evidence that
can explain why this would lead to diff erences between
water supply and wastewater approach. Indeed one
might question why WaSCs would be more risk averse
when it comes to wastewater management change,
although the cost of managing wastewater (particu-
larly the energetic cost) is well recognised as being
more significant than water supply (see for example the
carbon intensity figures from Water UK (2010a) which
show wastewater as roughly double water supply in
specific CO
2
e emission terms, mostly attributable to
grid electricity use).
National regulation re-enforces traditional management
approaches
The desire to ‘‘change the legal framework’’ under
which English and Welsh WaSCs operate was a
recurring response option and ind icates some dissa-
tisfaction with policy and regulatory arrangements. In
the context of the WFD this is congruent with the
findings of Cashman and Lewis (2007) who argue that
the English and Welsh system of water industry
regulation (see DEFRA (2011) for a description), and
in particular the economic regulator, Ofwat, has a
‘‘regressive impact on the promotion and implementation
of sustainable practices by water companies, as they
perceive that there is little space for them to create such
opportunities.’’ Akin to Cashman and Lewis, we found
that WaSCs perceptions were that the focus of the
regulator on efficiency gains and measurable outcomes
embedded within a relatively short term five year cycle
constrained their ability to pursue certain types of
WFD response. In particular and as discussed above,
land management and pollution source control
responses were perceived to be constrained through a
mixture of (i) the enforcement of the polluter pays
principle; (ii) the approach taken by Ofwat whereby
operational cost intensive solutions are not as accep-
table as capital cost intensive solutions (w hich are
easier to control and ensure efficient operation of),
and; (iii) a mismatch of WFD implementation and
national regulatory timings and objectives.
Our findings suggest that the barriers to change
may not lie with WaSCs, but in aspects of regulatory
system itself. The regulatory system in England and
Wales could be un-intentionally reinforcing the tradi-
tional approach to water management. Is this a fair
conclusion?
The economic functioning of the water sector has
been subject to two reviews recently by the UK
Government. The first, the Cave review of competition
andinnovationinwatermarkets(Cave2009),cameto
various conclusions essentially centred on a set of
customer and environmental benefits determined to be
likely to arise as a consequence of introducing greater
competition – in relation to abstraction licences,
discharge consents, provision of raw and treated water
and retail of water services. The Cave (2009) review noted
that characterising the innovative capacity of the industry
was difficult due to a lack of data, but that R&D
investment levels indicate that such capacity is low.
The Cave review did not critique the overall role
and practices of the economic regulator, Ofwat.
Instead, the UK Government Department for the
Environment, Food and Rural Affairs (DEFRA) took
on board this task with a review released in 2011
(DEFRA 2011). Having asses sed submissions from
WaSCs along with a wider set of sector stakeholders
including the other ‘quality’ regulators (the Environ-
ment Agency and the Drinking Water Inspectorate)
the DEFRA review came to various conclusions of
relevance here. Notably the review did not call for a
radical overhaul of the role and responsibilities of
Ofwat, but did call for significant change to the way in
which the regulator conducts its business, interacting
with both WaSCs and other regulators. The review
noted that WaSCs behaviour over time appears to
have been significantly influenced by (i) the level of
detailed analysis that company business plans are
subjected to every five years during the Price Review
process, leading to companies becoming very Ofwat
and data focussed, cautious and conservative and
developing cultures of compliance rather than innova-
tion, and; (ii) the lack of perceived predictability on
behalf of water companies in relation to how Ofwat
will react to proposed solutions to problems, particu-
larly if they are operational cost rather than capital
cost focussed. The findings of the review that the
current regu latory regime does not sufficiently
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incentivise water companies to be imaginative and
flexible in their approaches to problems was noted in
relation to inhibiting catchment management solutions
(DEFRA 2011, p. 47) and agrees with the findings
presented here. The review notes however that Ofwat is
already moving towards outcomes based regulation,
which should rectify this situation.
The DEFRA review argues that a complex set of
regulatory relationships and interactions have, over
time, created a situation wher eby both the behaviours
of Ofwat and the water companies have co-evolved
and now contain certain pathologies. These patholo-
gies are unproductive in promoting the kinds of
changes required to meet the sustainability challenges
facing the UK, and indeed global, water sectors as a
consequence of population growth and clim ate change.
However, when considered together, the Ofwat
review (DEFRA 2011), DEFRA’s ‘‘Future Water’’
policy document (DEFRA 2008) and the long expected
water policy White Paper (to be released later in 2011
or early in 2012) it is clear that the UK water sector,
and in particular the regulatory system is in the process
of significant change. DEFRA (2008) asks Ofwat to
permit WaSCs to work with land owners, offers new
perspectives on sustainable urban drainage systems,
metering and phosphorous in detergents. More re-
cently the objectives of ‘‘Future Water’’ have found
their way into Ofwats’ Price Review process. For
instance, Ofwat granted funding for 100 catchment
management schemes (Ofwat 2009), leading to the
adoption of increasing numbers of source control
interventions by WaSCs (Horton 2009).
Perhaps the efforts of WaSCs to change the
regulatory and legal framework have influenced these
changes. In any case, action is being taken nationally
to both dismantle some of the regulatory barriers to
change perceived by the WaSCs when interviewed for
this study. As DEFRA (2011) notes however, changing
the regulatory system will not be enough, the key will
be to change perceptions and behaviours, on both
water company and regulatory sides. This will be less
easily achieved, particularly with regards the promo-
tion of the kinds of ecologically orient ed changes
demanded by the WFD, which is in essence a piece of
legislation designed to re-orient water management
across Europe towards achieving ecological outcomes
(Steyaert and Ollivi er 2007). Notably, neither the
recent Cave review nor the DEFRA review mention
the WFD or catchm ent based approaches to water
management in any more detail than ackno wledging
their existence. Neither review discusses the centrality
of achieving good ecological outcomes to water
management as envisaged by the WFD, although the
importance of ecology has been recognised by the
water utilities themselves (Water UK 2010b, p. 6).
Barriers to change water and wastewater management –
a comparison with related findings
Following a review of 53 case studies of ‘barriers,
challenges and impediments’ to change in water and
wastewater management from around the world,
Brown and Farrelly (2009) conclude that the majority
of barriers to change ‘reflect impediments related to
community, resources, responsibility, knowledge, vision,
commitment and co-ordination, rather than . . . technical
feasibility . . . ’. In particular they highlight 12 main
socio-institutional barrier types (see Table 4).
The findings of this study broadly agree with the
conclusions of Brown and Farrelly (2009), Brown et al.
(2009) and Wong (2006); namely that the primary
barriers to IWM implementation are socio-institutional
in character. Specifically, in the context of
WFD implementation by WaSCs in England and Wales,
the bulk of the barriers were related to the regulatory
system, particularly economic regulation of WaSCs.
The additional attitudinal barriers (bottom two
rows of Table 4) found to be an influence on the
response of Engl ish and Welsh WaSCs responses to the
WFD are not noted by Brown and Farrelly (2009), but
agree with some of the conclusions of Thomas and
Ford (2005). Namely, that opposition to new techno l-
ogy in the UK water sector may be attitudinally
framed as being inter alia too risky. Whether such risk
aversion on behalf of WaSCs is a result of a lack of
long term vision, particularly with regards wastewater
treatment, or whether, as argued by DEFRA (2011)
risk aversion (which nobody disagrees is present) is a
consequence of the regulatory interactions between
WaSCs and Ofwat, or some other reason is not clear
from the work here. Regulatory barriers, at least
perceived barriers (see discussion in previous section)
were not found to be as prominent by Brown and
Farrelly (2009), or at least were not unpacked to the
same degree, althoug h they were noted as being the
third most frequently encountered kind of barrier.
Not all barriers to change in response to the
WFD were found to be socio-institutional in
character. Importantly, a number of barriers were
found to exist in terms of knowledge about the
performance of new water and wastewater manage-
ment approaches. A lack of knowledge both
generally and specifically for different raw water
quality contexts about the performance of new
approaches such as for exa mple, pollution source
control interventions, represented a barrier to adop-
tion by WaSCs. Whilst this is a knowledge barrier,
and classifiable as socio-institutional if one follows
Scott’s (2008) definition of an institution as including
cognitive aspects, this barrier is also related to
technological performance.
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Further, for some new water and wastewater
management technologies (e.g. land based source
control interventions) it is simply not known scienti-
fically, under what conditions they will perform to
different economic and environmental standards. This
is a lack of knowledge in absolute terms rather than
with respect to a specific organisation (WaSC) and
therefore arguably not socio-institutional in character.
Further still, with regards priority substances, WaSCs
perceived that there was simply a lack of appropriate
technology for detecting and treating the very small
quantities of priority pollutants like heavy metals,
pesticides and pharmaceuticals that the WFD requires.
This is a purely technological barrier.
Conclusions
The findings suggest that the WFD will be more
successful as an instrument for fostering change in
water supply rather than wastewater arrangements.
There is evidence that the style of WFD response for
water supply issues may increasingly show elements of
integration, recycling and an effort to control raw
water pollution at source. The reason for this appears
to be that WaSCs perceive the WFD as an opportunity
to reduce operational cost for water treatment as a
result of better water quality. Moreover, the WFD in
relation to raw water quality is also well aligned with
other, recent , policies such as the CO
2
emission
reduction targets set by the economic regulator, Ofwat,
and conservation targe ts under the EU Habitats
Directive. Contrary to this for wastewater issues there
was no evidence that WaSCs will be stimulated by the
WFD to change the traditional structures of centrali-
sation, conveyance and treatment. The reasons for this
can be located in lock-in to investment into centralised
water and sewerage infrastructure driven by the EU
UWWTD in the 1990s and early 21
st
century. Finally,
the system of national water regulation, particularly
the way in which the behaviours of the economic
Table 4. Comparison of barriers to water and wastewater system change found by Brown and Farrelly (2009) and the current
study.
Barriers found by Brown &Farrelly (2009) Barriers found in the current study
Uncoordinated institutional framework None
Limited community engagement,
empowerment and participation
None
Limits of regulatory framework Implementation of new wastewater approaches hindered by existing regulation
Regulatory enforcement of polluter pays principle hindering investment in
land management / source control
Benefits of land management accrue over longer timescale than regulatory
performance measurement of WaSCs
Passing on costs of land management / source control interventions not
generally allowed by regulator
Clash between national CO
2
emissions regulation and WFD regulations
preventing wastewater change
Focus of regulator on measurable outcomes and efficiency gains found to
inhibit IWM approach selection
5 year economic regulation cycle found to encourage non-IWM investments
which yield benefits in that timescale
Lack of regulatory clarity about the allowed role of SUDS, about metering
and about banning P in detergents perceived to encourage traditional
approaches
WaSCs discouraged from anticipating WFD investment needs
Insufficient resources (capital and human) None
Unclear, fragmented roles and responsibilities None
Poor organisational commitment None
Lack of information, knowledge and
understanding in applying integrated,
adaptive forms of management
Uncertainty about wastewater technology performance
Poor communication None
No long-term vision, strategy Source control interventions are a new vision for managing raw water
resources/ None for Wastewater
Technocratic path dependencies WaSCs could be l ocked in to UWWTD investments from the recent past
Little or no monitoring or evaluation None
Lack of political and public will None
None Lack of appropriate wastewater treatment technology
None Preference for less risky responses encourages similar technologies
None Perception of WFD as a set of opportunities rather than problems found to
lead to more radical and greater changes
Urban Water Journal 13
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regulator Ofwat and WaSCs have co-evolved indicates
that there remain both formal and informal barriers to
change which must be overcome if the UK water sector
is to rise to the challenges of population and
climate change over coming decades. Understanding
how to overcome these barriers is an area ripe for
further, engaged and action oriented research, and will
be pivotal in curing the various pathological beha-
viours which currently hamper effective innovation,
regulation and long-term planning for sustainability in
the sector.
Limitations and validity of study
The primary limitations of the research reported here
are (i) that the conclusi ons are based on a snapshot of
opinion from WaSC WFD response functions taken
over a relatively short period of time in 2007, and; (ii)
that the findings are based on a relatively small number
of interviews, albeit with key individuals across the
WaSCs.
Both points are concerned with the same under-
lying issue – how reliable is the data gathered and how
valid are the inferences drawn from it? To what extent
do the findings remain relevant and true in the context
of England and Wales today as when the data was
gathered, and to what extent can the findings be taken
as having been valid (true) at the time of data
collection and therefore be trusted as contributions
to building a more generalised body of knowledge
about barriers to change in water and wastewater
management.
Taking sampling first of all - purposive sampling
was employed and the selec tion of individuals within
WaSCs (senior environmental regulation managers
with specific WFD strategic planning responsibilities)
was appropriate. One might criticise the study for not
having interviewed as broader cross-section of man-
agers from different functi ons to further guarantee the
completeness of data gathered from each WaSC. There
is some validity in such a criticism but also no
particular reason why the senior managers interviewed
would provide particularly biased opinions. Further,
WFD response planning was, we found, restricted to
being the responsibility typically of the environment
department or unit of each WaSC, or, where one
existed, the catchment management unit. As a con-
sequence the manager interviewed was often the only
senior person responsible. We did take measures to
triangulate within each WaSC by interviewing a
second, usually deputy, manager where possible.
Second, taking the analysis methods involved – we
employed standard qualitative analytical techniques
(see the method section) and utilised standard multiple
researcher coding validation procedures. As a
consequence the results generated should be consid-
ered valid at the time and therefore reliable for use in
contributing to general knowledge.
Third and last comes the question of how currently
relevant and true do the findings remain. One can see
the resonance between the findings of the recent
DEFRA (2011) review, Water UK position paper
(Water UK 2010b) and the research presented here in
relation to the need for change, and the importance of
overcoming regulatory barriers, both formal and
behavioural. Secondly, the conclusion that greater
change is afoot in water supply than in wastewater
management can be seen in the Price Review 09 Final
Determinations (Ofwat 2009). Despite major cuts, raw
water management activities such as catchment man-
agement have not suffered as badly as elsewhere, with
funding for 100 catchment management schemes
having been granted over the period 2010–2015. As a
consequence we believe the findings presented here
remain current within the context of England and
Wales, and in particular add additional insight into
change related to the WFD in particular. No other
study has focussed exclusively on it despite the
potential of the legislation to overhaul the European
water sector.
Acknowledgements
The authors would like to acknowledge the support of the
EC funded ISBP project (NEST-PATHFINDER-CUL
043199, Integrated Systems and the Boundary Problem)
and the kind co-operation of all the interviewees. Dr.
McIntosh would like to acknowledge the financial support
of the International WaterCentre.
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