perspectives from three years experience of regional water services in thames water authority

WATER RESOURCES BULLETIN VOL. 15, NO. 6 AMERICAN WATER RESOURCES ASSOCIATION DECEMBER 1979

PERSPECTIVES FROM THREE YEARS EXPERIENCE OF REGIONAL WATER SERVICES IN

THAMES WATER AUTHORITY'

Peter Black and Alex Momson'

ABSTRACT: Thames Water is one of ten regional Water Authorities established in 1974 to manage all water services in England and Wales. This paper looks back at water reorganization and reviews the achievements and highlights of the last three years. Constitutionally, Water authorities are a combination of a nationalized industry and local authority. This has advant- ages and disadvantages. Freedom of action, particularly in fiincial matters, is constrained by Government and official agencies. A severe pollution of the upper Thames and the drought of 1976 tested Thames Water's ability to deal with emergencies. Thames Water does not have an operational monopoly. Private Water Companies supply one third of the water demand and local authorities manage nearly all the sewers. But Thames Water's control over planning and investment ensures that the river basin is managed in a coordinated fashion. Tariff structure changes have led the Authority to bill all its consumers direct. The Thames is a small but intensively used river and vigilance is needed to maintain water quality. Thames Water is proud of the restoration of the tidal Thames from a typical grossly polluted metropolitan estuary to its present excellent condition. The British Government intends to establish a national water industry strategic planning organization but at the same time they affiim that there can be no departure from the principle of integrated river basin management. (KEY TERMS: Water Authorities; Thames River; England; Wales; water management.)

INTRODUCTION In 1974 there was a major reorganization of the water industry in England and Wales.

Fifteen hundred different organizations, each one responsible for water supply or sewage disposal or river management or some other water service were amalgamated and re- grouped into just ten Regional Water Authorities. For the first time the management of clean and waste water was brought together. From then on only one public authority was to have overall control of the water cycle in each river basin. That upheaval took place three-and-a-half years ago. This paper looks back over that period, considers the performance of the Regional Water Authorities so far, using the Thames Water experience as an example and, with the benefit of hindsight, asks these related questions: Was the reorganization well conceived? Are the Water Authorities fulfilling the promises that

'Paper No. 78046 of the Wafer Resources Bulletin. Discussions are open until August 1, 1980. 'Respectively, Chairman and Chief Executive, Thames Water Authority, New River Head, Rosebery

Avenue, London, EClR 4TP, England (until mid-1979). (Note: This paper was officially givenin 1977 and the New British Government's policies are not the same as some of those referred to herein. The Rice Commission no longer exists.)

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were made for them? Have they coped effectively with the emergencies which are a feature of this industry everywhere - floods, droughts, and accidental pollutions? It suggests that the answer to all these questions is a qualified “yes.”

WATER REORGANIZATION

Before reorganization, the water industry in England and Wales was fragmented. Re- sponsibility for different parts of the water cycle was divided between a variety of bodies. There were nearly 200 water undertakers in England and Wales with a statutory duty to provide piped water to domestic and other consumers. They were either local authorities, joint boards of local authorities, or statutory companies. There were more than 1300 sewage and sewage disposal authorities, which were local authorities operating separately or occasionally through joint boards. In addition, the Water Resources Act, 1963, set up 29 river authorities t o deal with water conservation, land drainage, fisheries, and pollution control. The 1963 Act also established the Water Resources Board as a national planning and advisory body in the water conservation field.

In 1969, the Government asked the Central Advisory Water Committee to look at this situation. The Committee reported in 1971 and drew attention to the shortcomings of the existing structure (Central Advisory Water Committee, 1971). They recommended the establishment of Regional Water Authorities. Within three years, a Water Act (Water Act, 1973, Chapter 37) had been passed and Regional Water Authorities were in business. The Committee accepted the Water Resources Board’s view that water demand could well double by the end of the century. Meeting this demand would be a major problem. There would have to be much more water reuse in nearly all parts of the country. This called for a much greater concern with waste water treatment and for more comprehensive water resources development planning.

There should be a single water management plan for each river basin. As things stood, there were increasing conflicts of interest between the various authorities and inadequate mechanism for resolving them, apart from intervention by central government. Responsi- bility for developing new water sources was divided between river authorities and water supply undertakings. Each looked at this function from their different standpoints. A river authority might prefer to license one source on wider conservation grounds, whereas the water undertaker might prefer another on financial grounds. Again, the river authority might wish the water undertaker to use a source which in his eyes was too polluted or more expensive to treat. Sewage disposal authorities were usually interested only in disposing of their sewage at least cost to their rate payers. It was not their business to consider the wider issues of water reclamation or reuse. There is a basic conflict of interest between those who discharge effluents into a river and those who abstract water from it. Sewage treatment expenditure in many cases was understandably kept t o the minimum the discharger could escape with, since treatment plant investment will probably benefit not those who pay for it, but rather those further downstream.

The technological arguments for combining the whole water cycle under one management, then, were clear and compelling. It would make possible a comprehensive improvement policy for both quantity of supply and river quality. Similarly, by the addition of responsibility for sewage treatment, under the same management, programs could be developed for water reuse for public supply where necessary.

This is what has happened. The Water Act 1973 established nine Regional Water Authorities for England and one for Wales. They each cover one or more river basins.

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They are responsible for water resources and supply; sewerage and sewage disposal; pollution prevention; land drainage and flood protection; fisheries; the recreation and amenity use of their water space; and, in some cases, for inland navigation.

During the passage of the legislation through Parliament, the Government announced the main objectives of reorganization. They are:

“TO secure an ample supply of water of appropriate quality to meet the grow- ing demands of the people, industry, and agriculture - while at the same time ensuring that it is not wasted. To provide adequate sewerage and sewage disposal facilities to cope with the natural increase in water use and with new housing, industrial, and agricultural developments. To ensure that the vital contribution of land drainage and flood protection to both urban and agricultural areas alike is maintained and, where appropriate, expanded. To achieve a massive clean up of the country’s rivers and estuaries by the early 1980’s.

To make the widest use of water space for other purposes including recreation and amenity and, where appropriate, the protection and development of salmon and freshwater fisheries and the provision of water needed for navigation.

To protect the interests of those who may be affected by proposals for the development of water resources in any of these respects.” (Department of the Environment and The Welsh Office, 1973, paragraph 6.)

The Thames Water Authority is by far the largest of the ten in terms of its budget and the population served. Its area is about 5,000 square miles. As the name implies, it covers the River Thames catchment. Nearly 12 million people live in its area, over half of whom are in Greater London. It employs about 12,000 staff (6,800 manual, 5,100 professional and office workers). Its three biggest divisions, Metropolitan Public Health, Metropolitan Water, and Thames Conservancy are each larger in many respects than the smaller Regional Water Authorities. The Authority’s revenue budget for 1977-78 is t245 million ($421 million) and its capital budget is E77 million ($132 million). (The exchange rate used in this p a s r is that current in late July 1977 - 81 = $1.72.)

THAMES WATER CONSTITUTION AND STRUCTURE Regional Water Authorities are set up on a basis which is new in the United Kingdom.

Their function most closely resembles that of public utilities like the gas and electricity boards and other publicly-owned monopoly service industries like the railways but their constitutional position is different. For whereas in common with these other public boards, their chairmen and some members are appointed by central government, a majority of the Water Authority’s members is nominated by local authorities. That is to say, they are primarily elected local politicians whom their Councils appoint to serve on the Water Authority. Constitutionally, Water Authorities are a combination of a nationalized industry and a local authority.

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They are required to establish a system of direct charging for their services as opposed to a form of local taxation which had been used hitherto, except in the special case of land drainage. Their borrowing powers are akin to those of nationalized industries, and government capital expenditure control is exercised in the same way.

In common with other similar monopolies, the water industry has the prime objective of meeting the public demand for its services. There are not so many varied policy choice areas as arise in local government. Nevertheless, the Water Authorities are providing a public service and have a consumer responsibility. Moreover, there are duties on them t o make available public facilities or amenities where only a subjective view of the appropriate standard of provision is possible. This is particularly so for such matters as tidal river water quality objectives, recreational, and sporting facilities, etc.

Against this background it is significant that the initial proposals for the Water Au- thority constitutions envisaged a membership comparable with that of the area electricity and gas boards. The aim was for management bodies, in conjunction with which the Government proposed to establish regional consultative councils to provide a consumer voice to the Authorities.

In the event, the Water Act 1973 provided for local authority nominated membership of the Water Authorities themselves and did not proceed with the regional consultative councils. Thus the concepts of a small executive Water Authority and a representative regional consultative council merged into one large Authority with a substantial locally- appointed membership. This is particularly evident for the Thames Water Authority with its 57 members, of whom 36 are nominated by local authorities. The Chairman and remaining 21 members are appointed by central government.

The only reasonable conclusion to be drawn from this situation is that the Authority in itself combines the executive powers of a nationalized industry and the electoral man- date of the public to represent their interests as consumers. Thames Water’s aim is to get the best of both worlds by managing the day-to-day affairs as a business enterprise like the nationalized industry boards, at the same time securing the advantage of a local authority by providing for democratic control of the major policy and financial decisions and also of matters where the decision must be subjective. Unfortunately, it is sometimes a case of getting the worst of both worlds.

The Authority members determine the policies to be followed. Apart from the Chair- man, the members are unpaid. The executive management of the Authority is exercised by a Board of Directors who are appointed by the Members. This consists of the Chief Executive, four Directors, and the Authority Chairman. They operate as a corporate management team in which each Director has a voice on all matters and is equally bound by its decision.

The Authority must have good local management. It is providing a direct service to every household, commercial, industrial, and public establishing in its area, operating some five hundred significant works and depots and looking after many ten-thousands of miles of sewers, water mains, and rivers. Effective management of such an organization calls for a high degree of decentralization and delegation. Quick response to consumer needs and an awareness of local problems cannot be obtained through a systemofdetailed control by Regional Headquarters. They require a high degree of autonomy to be given to Divisions and indeed to local works. For operations, the Authority is divided into nine divisions. The three largest are single-function divisions providing London’s water supply, sewage, and sewage treatment in London and river management of the Thames, respectively. The remaining six divisions are smaller and multifunctional, managing both water

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and sewage services except for the Lea Division which manages the River Lee and sewage disposal but has no water supply functions.

EXTERNAL CONSTRAINTS ON THAMES WATER

For all functions the ten regional Water Authorities are responsible direct to central government through the Secretary of State for the Environment except for land drainage and fisheries, for which they are responsible to the Minister of Agriculture, Fisheries, and Food. It is primarily in the area of finance that central government exercises control over the industry. The Government controls the national public borrowing level through a system known as the Public Expenditure Survey. This provides Ministers with a regular means of seeing where their existing policies will lead in public expenditure terms and for considering this against the country’s economic prospects and the Government’s social and political priorities.

Each year the Treasury allocates a capital expenditure ceiling to each nationalized industry. Within the total sum allocated to the water industry, individual amounts are a-located to each Water Authority by the Ministry of Agriculture, Fisheries, and Food for land drainage and flood prevention purposes and by the Department of the Environment for all other purposes. These allocations are determined in the light of overall Govern- ment economic policy and specific Government policies on matters relevant to the water industry, such as housing development and public health, and the estimated requirements submissions made by Water Authorities. The allocations made to Water Authorities are limits on capital expenditure irrespective of the means used to raise capital. In addition there are specific controls over the finance source, self-financing, and reserves.

Local authorities throw their doors open to the public once a year when the annual accounts audit takes place. Any elector for the area can appear before the District Audi- tor and question him about the accounts or make objection to them. Water Authorities are also subject to this procedure. This is a fine example of democracy at work in a free society. It is also an opportunity for professional objectors to amuse themselves at the Authority’s expense.

Other nationalized industries are not subject to this form of scrutiny. In their case, public accountability is exercised through Parliament and in particular through the Select Committee on Nationalized Industries. The Select Committee examines the Chairman and Board Members about their annual report and accounts at formal hearings and Water Authorities are also subject to this procedure.

There are two other external checks on the Authority’s activities. Members of the public who consider that they have suffered injustice because of maladministration may have their complaints looked into by an independent local commissioner. This officer is popularly known as the Ombudsman - a Swedish word, since the idea was copied from them. “Maladministration” means unjustifiable delay, incompetence, neglect, or pre- judice. Any organization as large as Thames Water is bound to slip up from time to time and the commissioner has found against the Authority on one occasion.

The Price Commission is an independent statutory body which enforces the Govern- ment’s Price Code. The first aim of the Code is to limit the extent of price increases on account of increased costs and to secure reductions as a result of reduced costs. The Commission requires advance notification of the Authority’s proposed charges for each financial year and have 27 days in which to approve them or not. In 1976-77 Thames

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Water was directed by the Commission to reduce its sewage charges by five percent and put up its water charges by nine percent. The proposed charges for 1977-78 were approved.

OPERATIONAL EXPERIENCES

There has been no shortage of emergencies to test Thames Water’s ability to cope. One afternoon in January 1976, the Superintendent of a disused power station noticed

a green discoloration of the station’s former cooling pond. Analysis showed samples of this water to contain hexavalent chromium, a toxic substance that has been linked in industry with skin ulcers, dermatitis, and other diseases. Water from this pond flows into the river Ray and then into the Thames upstream of the Buscot water treatment works intake. The intake was closed for two days, creating a daily deficiency of about 500,000 gallons which would have emptied the treated water storage reservoirs in 36 hours or less. The owners of a private lake about a mile from the works gave permission for its water to be used and emergency crews worked all night under floodlights installing generators, temporary pumps, and hoses. The water was analyzed overnight, proved suitable for treatment at Buscot, and water tankers were sent from London to supply properties having private supplies. Meanwhile the progress of the pollution slug was monitored as it gradually flowed down river. Polluted water from the pond was pumped into sewers or taken by tanker for treatment at Rodbourne sewage works. Later a second pollution slug passed down the Thames and again Buscot intake was closed. The pollution source was traced to a factory whose owners were successfully prosecuted. This was a major pollution incident which required a great deal of cooperation between divisions, four being directly involved. They were Thames Conservancy for river pollution control, Vales for water supply, Cotswold for sewage treatment, and Metropolitan Water for emergency plant and crews. Before April 1974 these four groups of staff worked for different organizations. It is doubtful if this incident could have been handled so expeditiously in the absence of a unified river basin administration (Reed, 1976).

By far the severest test so far was the Great Drought of 1976. The period May 1975 to August 1976 was the driest 16 months over England and Wales since rainfall records began in 1727 (National Water Council, April 1977, paragraph 2.1). In North Devon about 65,000 people were subjected to rationing by standpipes for up to three weeks in the summer of 1976. In southeast Wales about 1 million people suffered rota-cuts for up to 11 weeks. Neither of these areas is in the Thames region. In Thames Water’s area the use of garden watering hose pipes was banned from July onwards and other nonessential uses such as car washing were banned throughout the country from September onwards. Ground water levels in the aquifers sank to lows hitherto unknown. By August the entire flow of the River Thames was being abstracted and no fresh water was flowing out into the estuary.

The Authority is normally obliged by law to maintain the flow of freshwater into the tideway above a minimum of 170 million gallons per day (mgd). (The gallons used in this paper are Imperial gallons. To convert to U. S. gallons multiply by 1.2.). However, this may be reduced by fmed amounts at certain times of the year and in times of water shortage. These regulations limit the amount of water that may be taken into London’s storage reservoirs. In accordance with these rules, this “residual flow,” as it is called, was reduced to 140 mgd on 7 February and to 50 mgd on 7 May. On 24 July it was reduced to 20 mgd by pumping the water from the lowest nontidal reach of the river up and over

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a weir so that it could be abstracted further upstream at one of the London intakes. This enabled abstraction of the flows of the Rivers Mole and Hogsmill tributaries of the Thames whose waters are normally lost to the sea, because their confluences with the Thames lie downstream of the last intake. On 27 August this reverse pumping was stepped up so that no water at all flowed to the tideway. By this time practically all the flow in the lower reaches of the Thames was treated sewage effluent discharged from Ox- ford and other places upriver. Some back pumping also went on near Oxford to get more water into the storage reservoirs there. Nevertheless the stocks in London’s storage reservoirs were falling fast and if nothing further was done were expected to run out about mid-November. It began to rain hard in September and continued through the autumn and winter to such an extent that there was flooding in February this year (1977), but that is another story.

Among the nonessential users who had to be without water were race courses. Horse- racing is big business, especially if one includes the betting, and employs many thousands of people. The race courses were threatened with closure since the ground was too hard. Treated sewage effluent was therefore made available from the London sewage works which discharge to the tidal Thames reaches and whose water is therefore not available for subsequent use. Thames Water scientists said this water could be used for watering grass without danger to human health. The race course owners could have it in very large quantities free of charge if they would come and collect it with road tankers. Many of them did so and 2,700,000 gallons were supplied in this way. It is interesting to note that such consumers who usually receive unlimited quantities of first-class drinking water delivered to their premises for 45 pence per 1,000 gallons (64c per 1,000 U. S. gallons), were prepared to pay L5 or more per 1,000 gallons (over $7 per 1,OOO U. S. gallons) to convey by tanker sewage effluent which cannot be drunk or even bathed in. This says something for the price of water. Forty-five pence per 1,000 gallons is equivalent to 16p (27c) per ton. What else apart from fresh air can you have delivered for that price?

The drought tested the ingenuity of the Authority’s engineers and scientists as never before. A number of the previously separate distribution systems had already been inter- connected after 1974 to enable water to be moved into areas with supply problems. Many more such connections were made in the drought, some of them temporary. The ability to do this prevented the imposition of more severe restrictions on the consumption of water. The total resources of the catchment remained sufficient throughout this difficult period although there was a much greater degree of water reuse than is normal.

THAMES WATERS HEGEMONY Thames Water does not have an operational monopoly of water services in the region.

There are seven private water companies who together supply 31 percent of the demand to 34 percent of the population. In doing so they act as the Authority’s agents. Com- panies raise their own money and fix their own charges. Their investment programs have to be agreed with the Authority as do their licenses to abstract from surface or ground water sources. Thames Water has excellent working relations with them.

On the sewerage side, it was not thought practical for regional Water Authorities to take over the management of the hundreds of thousands of miles of local sewers so the 93 local authorities whose areas lie wholly or partly in the Thames region act as the Authority’s agents in the operation, maintenance, and improvement of the sewerage systems in their districts. These sewers belong to Thames Water but the Authority does not

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look after them operationally. This arrangement has not been entirely free of difficulties. There have been disputes about reimbursement of costs to the district councils and dis- agreements on other matters. Nevertheless, the Authority continues to support the principle of sewerage agencies and has no desire to do this work itself. It does look after about 900 miles of the larger sewers nearly all of which are in London.

In both these agency arrangements, Thames Water has control over the services’ planning and over new investment. The two principal resources of water and money are in its control. In the Authority’s view this is sufficient to ensure that the river basin is managed in a coordinated fashion to the advantage of the consumers. There is no need for Thames Water to have an operational monopoly.

Nevertheless, there is one activity in which the Authority does seek to take over work from its agents. That is revenue collection. It already collects its own water charges in London and in some areas outside but the charges for sewerage and sewage treatment are mostly collected on its behalf by the local authorities who then pass the money over to Thames Water. This is because sewage disposal was a local government service before 1974 and it was not practical for the Authority to take over the job on reorganization. In any case, sewage charges are still based on the local taxation system which is used to finance other local services. This system is based on property values and the tax is known as a “rate.” It is therefore a simple matter for local authorities to add the Authority’s charges to their own rate demands. Water Authorities, however, are required by law to “ensure that as from a date not later than April 1, 1981, their charges are such as not to show undue preference to or discrimination against any class of persons.”

Thames Water takes this to mean that its charges should be equitable. The present system is convenient but cannot be said to be equitable. Large properties in expensive areas pay higher rates but there is no evidence that their occupants consume more water or impose greater burdens on the sewage disposal service. Since it is neither practical nor economic to meter domestic water supplies some other charging system must be found which will approximate more closely to what the law demands. As a first move, Thames Water expects to introduce a two-part tariff system from next April. This consists of a fixed standing charge plus a variable charge which will, for the time being, still be based on rateable value. This will even out some of the worst inequities of the present system and other changes can be expected to follow later. Discussions have been going on nationally for some years to find a tariff system for water and sewerage charges which will conform to the equity principle and at the same time not be too difficult to ad- minister.

The further the charging base moves away from rateable value, the less easy will it be for local authority computers to handle these charges. This is particularly so in the case of the districts around the perimeter of the Thames Water region whose areas lie partly in a neighboring Water Authority. There are a great many of these since Water Authority boundaries follow the watersheds of river basins, not administrative areas.

Besides these practical difficulties, the Authority holds to the principle that there should be a direct financial relationship between itself and its customers. It is grateful to its agents who have collected its income during these early years but does not think it is right for this activity to be permanent. It has, therefore, decided to embark on the direct billing of all but a few of its customers from April 1978. Some local authorities would like to have continued with this agency but most of them agree to the change.

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WATER QUALITY The freshwater Thames is a small river for the population it supports and is intensively

used. Three-quarters of the region’s water demand is met by abstraction from the Thames itself. The remainder comes from the River Lee, a tributary of the tidalThames,and from ground water. The Thames is also the eventual receiver of effluents discharged from the Authority’s 450 sewage works. Over 22,000 pleasure boats - mostly motor launches - are licensed to navigate the river. Cooling water from two thermal power stations with a total generating capacity of 2,500 Megawatts is discharged. At the London end of the Thames and in the Lee, there is a high degree of water reuse. That is to say, water abstracted for supply contains a significant proportion of sewage effluent. This means special vigilance about water quality must be exercised. Fortunately, the Authority’s pre- decessors had high standards and a generally satisfactory situation was inherited.

Tidal Thames quality is something of which Thames Water is particularly proud. This part of the river is not used for water supply and consequently there has not been the same necessity to keep it clean. Fifteen years ago downstream of central London it was, like other metropolitan estuaries in the United Kingdom and elsewhere, grossly polluted and lifeless. Black and evil-smelling during the summer months, only a few eels were known to inhabit its murky waters. Since then London’a major sewage works have been rebuilt to modern standards so that all sewage flow is given full primary and secondary treatment. In 1964, a few fish were found on the cooling water intakes of riverside power stations (Wheeler, 1970). Now found in great abundance, 91 different species have been recorded so far, including a salmon. Dissolved oxygen rarely falls below 30 percent of saturation and in the autumn of 1976, when the freshwater flow into the tideway was the lowest ever and temperatures were very high, the average minimum dissolved oxygen concentration expressed as percentage saturation remained high at 30 percent off the main London sewage works outfall. This is very satisfactory.

THE FUTURE OF THE UNITED KINGDOM WATER INDUSTRY In 1974 the new Labor Government announced their intention to review the operation

of the water industry established by the previous administration. In July 1977 they pub- lished their conclusions in a “White Paper” (Dept. of the Environment, Ministry of Agriculture and The Welsh Office, 1977, Cmnd 6876). This is a statement of the Govern- ment’s intention to bring legislation before Parliament. The principal change proposed in the White Paper is to establish a new national planning and research organization to be known as the National Water Authority (NWA). The White Paper says:

“One of the main tasks of the NWA will be to prepare on behalf of the industry, and recommend to Government, a national strategy for all water services. The strategy will constitute the essential framework for the regional policies, plans, investment programs and operations of the industry. The Government will define the economic and financial background against which the exercise is to be carried out, will consider and endorse the strategy subject to any modifications needed and will ensure, through the NWA, that it is im- plemented by the water authorities. This will enable the Government to ful- fill in the most effective way their duty to promote and secure the implemen- tation of national policy.

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In future, therefore, there will be three clear tiers of responsibility in Eng- land: the regional water authorities, who will retain their executive responsi- bilities but whose planning will be guided by national strategic objectives; the NWA, which will be responsible for national strategic planning; and the Government, to whom the industry as a whole remains accountable. The proposed position in Wales is set out later.” (Department of the Environment and The Welsh Office, 1977, paragraphs 14-15.)

It is also proposed that the NWA should take over the canal network which remained untouched by the 1974 water reorganization. The canals are a big problem. Built in the eighteenth and nineteenth centuries, these narrow inland waterways were the country’s freight arteries at the time of the industrial revolution. The railways and later the motor- ways deprived them of practically all their commercial traffic, but in recent years more and more people are pleasure cruising on these charming but steadily decaying back- waters. The canals are only prevented from financial collapse by an annual Government subsidy which is now about L12,000,000 ($21,000,000). Some of them do have a land drainage and water supply function but this is not generally so. The White Paper does not say what their long term future is to be.

Despite these proposed changes at national level, the White Paper reaffirms the principle of integrated river basin management in England and Wales. In our small and densely populated country, it works well. I t is not a model that could be copied everywhere. One could hardly imagine a regional Water Authority like Thames Water’s for the Missouri-Mississippi basin, for example. The massive rivers and estuaries clean-up by the early 198O’s, one of the promises at the time of reorganization in 1973, will have to wait a little longer because of national economic difficulties but, in other respects, three-anda- half years have been sufficient to convince Thames Water that the principles on which the Water Authorities were founded were right. The Government thinks so too. The White Paper affirms that:

“There can be no departure from the principle of integrated river basin management; it is essential to the organization of the water industry. The authorities have, despite certain inherent limitations in the structure set up by the 1973 Act and the disruption following reorganization, coped extremely well with the major tasks they have faced, not less the 1976 drought. In this connection, indeed, the flexibility that the new system offered in the transfer of resources from areas of plenty to those in short supply was of considerable importance.” (Department of the Environment and The Welsh Office, 1977, paragraph 9.)

LITERATURE CITED

Central Advisory Water Committee, 1971. The Future Management of Water in England and Wales. Her Majesty’s Stationery Office.

Department of the Environment and The Welsh Office, 1973. A Background to Water Re-organisation in England and Wales. Her Majesty’s Stationery Office.

Department of the Environment, Ministry of Agriculture, Fisheries and Food and The Welsh Office, 1977. The Water industry in England and Wales: The Next Steps. Her Majesty’s Stationery Office.

National Water Council, 1977. The 1975-76 Drought. A Report by the National Water Council to the Rt. Hon. Denis Howell, M. P., Minister of State, Department of the Environment. National Water Council.

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Reed, E. C., 1976. A Brief Report on the Pollution of the Rivers Ray and Thames Thames Water Authority.

Water Act, 1973. Her Majesty's Stationery Office. Chapter 37. Wheeler, Alwyne, 1970. Fish Return to the Thames Science Journal, pp. 28-32.

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