Water services: investing in and paying from 2027 - Analysis of Consultation Responses

2. Consultation on Ministerial Objectives

The draft Ministerial Objectives are the basis for the objectives that are set for Scottish Water by Scottish Ministers on the standard of services Scottish Water provides in delivering its core functions, and the type of investment activity it must undertake. This includes to address challenges faced by the water industry, such as ageing assets, climate change adaptation, and population movements and growth, while balancing customer charges.

Full details about the draft Ministerial Objectives are provided in the consultation paper, but in summary, they cover the following areas:

• Standard of services.
• Investment planning.
• Asset maintenance.
• Supporting sustainable economic growth.
• Drinking water quality.
• Drinking water resilience and demand management.
• Cyber, physical and personnel security.
• Environment.
• Wastewater treatment and network performance.
• Management of rainwater and flood resilience.
• Climate change, adaptation and mitigation.
• Circular economy.

The services provided by Scottish Water are funded through customer charges and borrowing from the Scottish Government. The maximum amounts of customer charges for 2027 to 2033 for Scottish Water’s charge scheme will be determined by the Water Industry Commission for Scotland (WICS), Scottish Water’s independent economic regulator.

Scottish Water’s final business plan set out its view of the investment required to fulfil the draft Ministerial Objectives outlined in the Commissioning Letter. WICS’ draft determination sets out its view of the charges required to deliver on these objectives at the lowest reasonable overall cost.

Question 1: To what extent do you agree that the Ministerial Objectives identify the type of investment activity Scottish Water should undertake in 2027-2033?

Among those answering Q1, 69% agreed to some extent that the Ministerial Objectives identify the type of investment activity Scottish Water should undertake in 2027 to 2033; 54% agreed, and 15% strongly agreed. A further 17% were neutral, and 15% disagreed.

Three quarters (77%) of individuals who answered agreed to some extent - 29% strongly agreed, and 48% agreed. While a majority of organisations that answered agreed to some extent (63%), agreement was less strong - 4% strongly agreed, and 59% agreed. Opinions varied considerably by type of organisation. All licensed providers, local authorities and other water sector organisations that answered agreed, as did 67% of special interest groups. Over half (54%) of community organisations that answered agreed, 27% were neutral, and 18% disagreed.

Question 2: Which areas should Scottish Water be investing in that are not covered or are there areas that are not required?

Two thirds of all respondents provided a response to Q2. The most prevalent themes were support for investment in infrastructure, followed by comments expressing support for the draft Ministerial Objectives. Other themes included calls for improved accountability and monitoring, and strengthening climate resilience, while also balancing the affordability of charges.

While the question directed respondents to consider areas for investment, several respondents used the opportunity offered by this first question to outline their thoughts on how Scottish Water operates more generally. These views are summarised below, but are also explored in more detail under relevant questions throughout this report.

Strengthen investment in infrastructure and maintenance

Support for prioritising investment into the maintenance and improvement of water infrastructure was expressed by several respondents, alongside suggestions for where this is most needed and why. There were calls for long-term investment into asset enhancements, with a focus on reducing leakages and spills, preventing disruption, improving drainage systems, and enhancing climate and weather event resilience. Other comments requested clarity on what maintenance and investment into infrastructure will entail, the need to balance infrastructure investments with charge affordability, and the need to ensure investment results in clear improvements in efficiency and resilience.

“Investment should be more explicitly prioritised toward reducing known maintenance backlogs, improving asset condition, and lowering future failure rates, with transparent evidence that proposed works will reduce long-term operating and capital costs.” – Individual

A few respondents commented on the need to strengthen urban water approaches, namely surface water and rainwater management. This included recommendations by one respondent to invest in sustainable approaches to drainage to minimise flooding impacts, such as through catchments and the reduction of surface water in the sewer network. Stronger legislation relating to rainwater management was also suggested by one respondent.

Support for the draft Ministerial Objectives

Several respondents expressed support for the draft Ministerial Objectives and the corresponding areas of investment by Scottish Water. Overall, respondents felt that key areas for future investment were covered in the draft Ministerial Objectives and that they reflected the needs and challenges that will be faced by Scottish Water and wastewater services and systems in the future.

Respondents agreed with approaches relating to asset maintenance, climate change and environmental priorities. Support was also detailed for improvements to service resilience and reliability, the quality of drinking water, wastewater compliance, and promoting behaviour change in relation to sewer use. While these respondents agreed with the draft Ministerial Objectives, some also noted other areas to consider further or strengthen; these are covered in the other themes presented under this question.

Improve accountability and monitoring

A range of measures to enhance the accountability of Scottish Water was detailed by several respondents. These comments included calls for greater transparency through publicly available data and for monitoring of Scottish Water’s performance in relation to discharges, spills, infrastructure upgrades, and drinking water safety. The monitoring of new pollutant types, such as per- and polyfluoroalkyl substances (PFAs), microplastics, and pharmaceuticals, was requested by a few respondents. Other comments made by one or two respondents included calls to introduce water metering to improve households’ understanding of their water usage, school drinking water testing and record keeping, and accountability that value for money is delivered on investments. Support for measures to improve Scottish Water’s accountability, and for their obligation to publish and action an Improving Urban Waters Routemap, was also noted.

Strengthen climate change and environmental resilience

A variety of suggestions to support investments in climate resilience were made by several respondents. Support for Scottish Water’s existing efforts and investments in this area was noted, such as for the net-zero transition. General comments calling for greater climate resilience in infrastructure were also made by a few respondents. These included, from most to least mentioned:

• Forward-focused planning for future weather events within communities, and to reduce flood risks, such as through nature and catchment approaches.
• Having a greater focus on the prevention and impacts of wastewater outfalls and spillages on the natural water environment.
• Investing more in groundwater reserves to reduce the impacts of droughts on river levels.
• Introducing solar power on Scottish Water facilities.
• Considering the resilience of new builds to future climate events, including the run-off of water.
• Considering the impact of farmer abstraction and hydroelectric schemes on river flows during dry summers.
• Encouraging the recycling of greywater and water loss reduction in farming.
• Implementing protection measures for Shellfish Water Protected Areas.
• Greater support for marine and coastal environments.
• Making faster action towards a net-zero transition.
• Having behaviour change programmes to reduce climate impacts in communities.
• Focusing on pollution reduction prior to spillages and runoff, such as through improving infrastructure.
• Prioritising environmental flows and protection of groundwater.
• Investing in nature interventions to support water infrastructure resiliency, biodiversity, economic benefits, and environmental protection.

“Nature based solutions designed to slow the flow in both rural and urban environments can alleviate stress on existing infrastructure and ecosystems (e.g., improving floodplain connectivity, reducing man-made runoff and restoring altered hydrologic and hydromorphic processes) while delivering additional benefits for fish and people.” - Fisheries Management Scotland

Consider the affordability and fairness of charges

Some respondents highlighted the need for the affordability of charges to be considered as part of investment planning, and the need for improvements to be balanced with affordability. The current approach to charging for water through Council Tax bands was felt to be unfair, to have limited awareness among customers and not to support their understanding of charges, and not to support behaviour change to increase water efficiency. This is explored further in the analysis of responses to Q5.

“…affordability needs to be treated as part of the investment plan, not something dealt with afterwards. Any significant change in charges lands hardest in communities already under pressure, and it has knock-on effects for local facilities and services that people rely on day to day.” – Beith Trust

Collaboration

Calls for greater consideration of the impacts of investment decisions on local communities, and for Scottish Water to take a more collaborative approach, were expressed by a few organisations. These organisations urged Scottish Water to work more closely with the third sector, local charities and community organisations to support efforts towards flood resilience, environmental protection, and behaviour change in relation to efficient water use. They also expressed the view that third sector organisations can have a trusted role in local communities and can be a cost-effective way to implement local change, and that Scottish Water could leverage this trust to increase public awareness of improvements they are making. A concern that small and dispersed communities are not considered enough within investment decisions was raised by Beith Trust. Fisheries Management Scotland called for a forum for national engagement to discuss Scottish Water infrastructure challenges beyond this consultation.

Other comments

Two respondents highlighted the need to ensure that the quality of bathing water is considered within the Ministerial Objectives, and one respondent suggested that the quality of local drinking water in their area had changed. One respondent suggested there should be an objective about private water supply management, noting however this may need legislative reform.

Standard of Services

The standards of services that Scottish Water must provide for its customers between 2027 and 2033 are determined by the Ministerial Objectives, namely the draft standard of services Ministerial Objective. This requires the improvement or maintenance of the standard of services by Scottish Water in comparison to the regulatory period ending 31 March 2027.

WICS produces annual reports on Scottish Water’s performance.

Question 3: What do you value most about the water and wastewater services provided by Scottish Water?

Two thirds of all respondents provided a comment on Q3. Respondents expressed a range of views on what they valued most, which largely centred on the importance of high-quality water and wastewater services for communities. The most commonly mentioned themes were the importance of safe, reliable and accessible provision of water and wastewater services, environmental protection, and the value of public ownership of water and wastewater services.

Safe and reliable water and wastewater services

By far the most prevalent theme was the value respondents placed on the provision of clean, high-quality and safe water. Respondents commented on water being potable, fresh, available on tap, and, through its safety, supporting public health in Scotland. They expressed confidence in the high quality of water supplies, and one respondent commented that local bathing water is also kept to a high standard. Continuing to see Scottish Water invest in providing high-quality water was encouraged by respondents.

In addition to the safety of the water, the reliability and consistency of water provision and wastewater services across most of Scotland were valued by several respondents. This included the ease of access and the equal access across communities to safe and clean water and wastewater services. The reliable provision of water was also felt to allow businesses and charities to operate and support people effectively.

“We value the reliability of Scottish Water’s core services. Consistency is something businesses depend on… It is clear that Scottish Water’s reliability and response is appreciated by customers. Customer satisfaction is high, and it is evident that customers trust Scottish Water.” – Clear Business Water Limited

“I value universal access and reliability - clean, safe water and effective wastewater services available to all communities.” - Individual

The provision of wastewater services was valued by several respondents, who highlighted the importance of this being managed effectively to ensure the health of the environment and communities. Conversely, some respondents used this question to express concerns with wastewater services. This included comments on excess amounts of mixed sewage in wastewater, wastewater and sewage discharge not being treated and put into waterways, and the need to address sewer flooding.

Environmental protection and infrastructure resilience

The importance of high-quality and resilient water and wastewater services in enabling environmental and climate protection was expressed by several respondents. The ongoing need to have resilient infrastructure that can cope with future extreme weather events while continuing to provide a reliable service was highlighted. The need to protect bodies of water so that they sustainably remain healthy, and to reduce leakages, pollution, and sewage discharge, was also noted by respondents. Again, future efforts and investment by Scottish Water, which aimed to achieve greater climate resilience, were welcomed.

“We also value Scottish Water’s environmental standards. While we recognise there is always room to improve, Scottish Water’s efforts into protecting rivers, coasts and the wider environment is valued by customers as this often aligns with their own sustainability goals.” – Clear Business Water Limited

“I also value the public ownership model in Scotland, which means the focus can remain on long-term public benefit, environmental protection, and service quality rather than profit. This approach supports the principle that water is a vital public resource that should be managed sustainably for the benefit of current and future generations… Maintaining this reliability, while also responding to challenges such as climate change, ageing infrastructure, and population change, will remain important in ensuring communities continue to have confidence in these essential services.” – Getting Better Together Ltd

While not directly answering the question, some respondents commented on where they would like to see future investment. This was expressed as a need to continually invest in infrastructure with a long-term vision that addresses upcoming challenges as outlined in the consultation paper. It was hoped that this would continue to provide a reliable, safe and environmentally resilient service to communities across Scotland and future generations.

Public ownership and transparency

Several respondents expressed support for the fact that Scottish Water, and the resulting provision of water and wastewater services, is publicly owned, acting as a public service for Scottish communities. A comparison to the privatisation of water services in England and Wales was made, with respondents expressing the view that this had a negative impact on service delivery.

“…delivered through a publicly owned model that prioritises long-term public benefit over shareholder return.” – Individual

“Public ownership and stewardship, which should support long‑term planning in the public interest rather than short‑term profit.” – Individual

“Public ownership means that there is an ability to align service delivery with wider public interest and environmental outcomes” - Fisheries Management Scotland

A small number of respondents valued the steps and communication Scottish Water takes to ensure transparency. This includes performance reporting, compliance with standards for drinking water, providing local information on water standards, and clear communication during unplanned incidents. Two respondents commented specifically on such incidents being responded to in a timely manner.

Affordability

The affordability of charges and the ongoing consideration of whether charges are affordable were valued by some respondents. Positive comments on charges being reasonable and more affordable than other parts of the UK were made, and it was also thought to be helpful to businesses to have a sense of future charges. Other respondents noted the need to ensure that there is a robust cost / benefit analysis to ensure investments are made within Scottish Water’s budget, while also being affordable for customers.

Question 4: Do you have any concerns about the water and wastewater services provided by Scottish Water?

Three fifths of all respondents provided a response to Q4, outlining concerns with water and wastewater service provision by Scottish Water. The most commonly raised themes were concerns about affordability, ageing infrastructure and climate change. As there was an overlap across these themes, they have been presented under one header below. These were followed by comments about Scottish Water’s communication and compliance with regulation, and issues with wastewater and pollution.

Concerns about affordability, ageing infrastructure, and climate change

The most commonly mentioned concern at this question was the affordability and fairness of charges for households, businesses, and charities. Respondents highlighted the need to consider existing financial pressures on customers and the high cost of living when making investment decisions. Respondents also emphasised the need to balance long-term infrastructure improvements with affordability, along with the need for transparency in charges and how they are used. Comments were also made disagreeing with how charities are charged (see the analysis of responses to Q7), and concerns about a perceived increase in the privatisation of service delivery.

“Affordability is another key concern. Even if charges remain lower than elsewhere in the UK, increases still affect households, particularly during periods of wider cost-of-living pressure. Ambition must therefore be carefully balanced against what customers can reasonably afford, and non-essential or policy-driven enhancements should not displace core service reliability and maintenance.” – Individual

The next most common theme, raised by several respondents, was concerns with ageing infrastructure and assets in the water and wastewater system, and the corresponding need for investment. Respondents felt that there had been historic under-investment in infrastructure, leading to ageing assets that will require repairs or replacement now and in the future. The impacts of not doing so were noted, namely the risk that ageing assets may fail, resulting in disruption for service users and possible pollution.

“Recent customer research has highlighted the importance that customers place on asset maintenance, repair and renewal. There is a recognition among customers that, to continue to have high quality water and wastewater services, Scottish Water needs to invest in replacing aging assets. The ICG is however concerned that a number of major assets are coming to the end of their useful lives (including Daldowie and Juniper House), and that this has implications for (i) the level of risk currently being borne by Scottish Water, (ii) the level of investment needed to replace these assets, and (iii) how that investment is funded in a way that is shared by the current and future customers who will benefit from it.” – Scottish Water Independent Customer Group

Concerns about the impact of climate change on the functionality and resilience of water and wastewater systems, and Scotland’s natural environment, were noted by several respondents. The need for a balance of considerations and concerns relating to climate change resilience, ageing infrastructure, and affordability for those paying for services was highlighted. Respondents noted that extreme weather events, such as drought and intense rainfall, are becoming more frequent. This was suggested to lead to sewer flooding, leakages, and pollution without mitigation, negatively impacting the natural environment and marine health. Respondents therefore called for assets to be modernised to meet the challenges of climate change and increasingly extreme weather events.

Scottish Water communication and compliance

Some respondents called for greater communication and more transparency about the running and future decision-making around water and wastewater services delivered by Scottish Water. Calls were also made for greater community engagement, partnership approaches with communities, increased public awareness, and transparency in Scottish Water corporate operations.

Comments regarding regulation, compliance, and the need for greater accountability of services were made by some respondents. Concerns around the lack of reporting, data publication and enforcement of sewer overflows, spills and discharge regulations being broken were raised. Transparency about these issues was felt to be important for customer understanding of how effectively their charges are being used, and for increasing public trust in Scottish Water. The need for more data and monitoring was detailed by a few respondents. This includes monitoring of discharge coverage, improving water metering, measuring improvements made by Scottish Water, and evidence to show the delivery of commitments between 2027 and 2033.

Singular calls were also made for improvements to wastewater permit data, greater alignment with EU water quality reforms, and sufficient resourcing for policing by SEPA (Scottish Environmental Protection Agency) in response to pollution events.

Issues with wastewater and pollution

Concerns around issues with wastewater services were detailed by some respondents. These included, from most to least commonly mentioned, concerns about:

• Sewage overflows, which may increase in frequency due to climate change, to waterways and areas where people are, e.g. urban areas, beaches, leading to public health concerns.
• Farming and agriculture run-off contributing to water pollution.
• Untreated sewage being present within waterways.
• Mixed sewage contributing to flooding events.
• Unresolved issues of the presence of sewage in a harbour area.
• Wastewater and waterways containing PFAs, microplastics and pharmaceuticals, posing risks to public health.

Other comments

A few respondents commented that they are generally happy with the proposed approaches in the consultation paper and current service delivery, as well as providing areas of concern as detailed above.

Comments relating to behaviour change and reducing water usage were made by a few respondents. There were calls to encourage or incentivise behaviour change in both the general public and businesses, noting that water use in Scotland is higher than in the rest of the UK and Europe. However, it was noted that this may be partly due to the high quality of Scottish water, leading to less bottled water use.

Other singular comments were made, including: a call to extend service coverage to more people; to implement the Recast Urban Waste Water Treatment Directive (UWWTD), including Extended Producer Responsibility; concerns about privatisation as a result of Scottish Water using private contractors; and comments on executive pay, debt, and worker treatment at Scottish Water.