Methodology for collecting data on DWD implementation readiness
The Chamber of Commerce "Polish Waterworks" is the only economic self-government organization in the water and sewage sector in Poland. It was established on September 14, 1992, and today it associates 507 companies representing more than 85% of the water supply services market. The Chamber strives to create favorable conditions for the functioning of the water and sewage sector. Its representatives and experts interpret and evaluate the applicable regulations on an ongoing basis, monitor proposed changes, participate in the creation of law, and introduce solutions to improve the functioning of the sector. Conducting surveys is therefore one of the tools for acquiring knowledge about water services. The survey results are the basis for articles, presentations, and consultations with policy makers.
The Chamber conducted two surveys among its members to gain basic knowledge about the needs of Polish water utilities in the context of the requirements of the new DWD. The surveys contained questions about many aspects related to the new DWD, but a part of the questions related to risk-based management. The questionnaires were prepared in Google Forms, water suppliers were asked to fill them online. Most of the questions were open-ended. The first survey was sent in January 2019 by email to 495 members, 106 of them completed the questionnaire. The second survey was sent in January 2020 to 499 members of the Chamber and 148 responses were received. Members of the Chamber serve about 85% of the inhabitants connected to the water supply network.
For the first survey in 2019 answers were given by persons responsible for drinking water supply, working in lower management positions or specialists working in units responsible for the operation of the water supply infrastructure. Although the final content of the directive was not known at that time, it was certain that risk management in water supply would become the responsibility of companies. IGWP received 106 answers, 90% of them came from commercial law companies (joint stock companies, limited liability companies with 100% of municipal capital). Entities that took part in the survey serve from 1 119 to 2.2 million inhabitants. 60% of them use groundwater, most often with simple treatment (aeration, filtration). Most of the respondents were medium and small suppliers. For example, 27 respondents are entities employing from 5 to 20 people, supplying drinking water to less than 20 000 inhabitants. This is the largest group of respondents, being at the same time in the most difficult organizational and financial situation.
The 2018 and 2019 were years of debate on the details of the new DWD and many controversial issues have been clarified and in January 2020, the Council of the European Union has already identified very detailed changes (Ramm 2019). Then (January 2020), IGWP conducted the second survey, which was based on knowledge of the final content of the directive and its requirements. The questions focused not only on risk management issues but also the requirements related to new water quality analyzes and necessary investments.
The second survey was also sent by email to 499 IGWP members. It was filled by people in the same positions as in the first survey, (although they were not always the same employees). One hundred and forty-eight responses were received, mostly from companies with limited liability from small and medium cities.
It is important to pay attention to the profile of respondents, which reflects the position of the IGWP members, but is not a picture of the entire Polish sector. This is reflected in the analysis of the set of entities that are subject to the Act on collective water supply and submit tariff applications. The applications are submitted every 3 years by approximately 2,700 entities. The 506 largest companies belong to IGWP. They serve over 85% of the population, the remaining over 2,000 entities do not belong to the Chamber. This means that most of the entities are very small, supplying several dozen or several hundred people. According to data on tariff applications submitted to the State Water Holding Polish Waters about 80 entities serve less than 50 people. According to Art.3 of the new DWD (Exemptions) these suppliers may be excluded from the directive. More than 200 entities supply water to groups of 50 to 500 people. Article 9 of the directive (Risk assessment and risk management of the supply system) allows them to be exempted from carrying out a risk assessment. The remaining entities—approximately 2500—will have to implement risk management. However, the majority of IGWP members are larger entities, which means that the smallest suppliers did not complete the survey and knowledge about their readiness to implement risk management is unknown. However, it can be assumed that they are not ready for such a challenge. They are mostly small businesses or private intake owners. The obligation to supply water often results from historical conditions. In the twentieth century, many cities in Poland developed around one, usually state-owned factory that provided jobs, built housing estates for workers, and provided them with the media. After the political change, fragments of the infrastructure went to different owners. They are obliged to continue serving the residents. Some factories have been privatized and their owners continue to supply water to consumers.
During the two surveys, respondents indicated certain aspects which give rise to the particular concern. The main challenge indicated was risk management. Other issues that need support are the new list of parametric values (new tests), reducing leakage, and ensuring access to water for all. These 4 new obligations were indicated as the main challenging.
Surveys’ results related to risk management
Respondents were asked whether they carry out a risk assessment related to the water supply infrastructure. The results of both questionnaires were similar: 45% of respondents answered that they work on it, although admitted that they do it fragmentarily introducing solutions such as ISO or risk analysis for establishing protection zones under Article 133 of the Water Law (Pl 2017b). This article obliges all groundwater intake operators to carry out a risk analysis and if needed (depending on the risk analysis result), to define indirect protection zones. 55% of respondents stated that they did not carry out a risk assessment and did not implement any risk management systems (such as water safety plans). Moreover, only 32% of respondents assumed that they have enough internal resources to start carrying out a risk assessment.
According to the surveys, the implementation of risk management will be a significant obstacle for most, mainly small, utilities. The smallest suppliers expect support in providing knowledge and guidelines on how to manage risk. Moreover, water utilities will have to closely cooperate with the central administration responsible for monitoring the environment and with the administrators of selected buildings, especially priority premises (as indicated in Art. 10 of the new DWD). Risk management is not only about developing an action plan but especially about its implementation, systematic modification, and execution, which will involve the necessary costs, including investment. Each of the 2477 Polish municipalities together with the central entity responsible for coordinating this process will have to be engaged; leaving water utilities without support may cause many problems with the implementation of the directive.
In the second survey, respondents who admitted that they had implemented a part or full risk management system were asked about the cost of this implementation. Knowing the number of people served by them, an approximate cost of implementing risk management tools was obtained, amounting to PLN 1 per capita. The entities will have 6 years for the first implementation, but risk management is a continuous process, so a part of this cost will be repeatable. Obviously, this is a rough estimate of an order of magnitude, not the exact budget needed by every utility. Moreover, it is an average value. Detailed analysis shows that economies of scale are important here: the larger the enterprise, the lower the cost per capita. This shows that relatively higher costs of implementing risk management systems will be incurred by the smallest entities. Moreover, IGWP did not reach most of the smallest suppliers because they are not members of the organization.
Respondents were also asked what competency or staff shortages prevented them from making a reliable risk assessment. Ignorance of the subject turned out to be the biggest problem (Fig. 1). The respondents had a choice of the indicated answers and the possibility to mark the ones they considered the most accurate.
The largest companies—serving over 100 000 consumers—did not identify any problems that would make risk management impossible; they have enough internal resources. They have knowledge of future obligations and are already implementing or developing risk management. However, it is the large utilities that are most exposed to the risk of losing service continuity due to sudden, unexpected cases (Mrozik et al. 2015; Rak and Tchórzewska-Cieślak 2019).
The analysis of the size of the companies’ combined with the replies showed that smaller water utilities do not have sufficient knowledge to start smoothly implementing the requirements of the new Drinking Water Directive. Among the reasons for not implementing risk management, respondents first give organizational and financial constraints as well as lack of time (employees have their tasks and it is difficult for them to do more). There is a lack of competence among staff, especially in smaller entities.
Respondents were asked to indicate what they need most to start or complete the process of implementing risk management. The greatest needs of the Polish water utilities concern the demand for competencies and knowledge (Fig. 2). Small companies have the biggest problems with understanding the essence of risk management. The entities serving difficult rural or urban–rural areas are in a particularly difficult situation. They require extensive substantive support.
Simultaneously with the first questionnaire, IGWP organized trainings and a conference on risk management in the supply system. The members of the Chamber who already undertook certain activities related to risk assessment and management shared their experiences. They presented how they fulfill the obligations resulting from the WHO guidelines and the PN-EN 15975-2 standard. It should be added that companies already have some experience in analyzing health risks related to the creation of protection zones for water intakes (Łyp 2019). This is due to the obligation to carry out a risk analysis for catchment areas, resulting from Article 133 of the Water Law. The deadline for the implementation of this obligation is December 2023. This risk analysis complies with the requirement of Art. 8 DWD (Risk assessment and risk management of the catchment areas for abstraction points of water). Entities usually outsource this service on the market. This is because a variety of competences (e.g., knowledge of local hydrogeological conditions) and time are required to conduct a risk analysis for catchment areas. Entities that have already commissioned this service were asked about the costs incurred.
The cost of such an analysis on average does not exceed PLN 1 per capita. However, there were exceptions up to PLN 15/inhabitant (service cost incurred divided by the number of people served). This analysis is performed every 10 or even 20 years, so the cost should not be too burdensome. However, it should be noted that it is again the smallest entities that may be the most heavily burdened. Water utilities in villages usually have many small intakes, for each of them they must carry out a risk analysis.
After the information campaign, workshops, and conferences, a second study was carried out (January 2020). One of the objectives of the survey was to find out about the actions already taken by the water suppliers. According to the WHO methodology, the first step in building a Water Safety Plan is to appoint an interdisciplinary team. So, in 2020, respondents were asked if they had already formed such a team. Figure 3 reflects the responses of respondents. 47% of utilities did not establish a team which is recommended by the World Health Organization. 25% of them wait for the new obligation which will be transposed to the Polish law. Only 16% have already formed teams, but their effectiveness in action varies. During meetings and workshops organized by IGWP, team leaders admitted that many of them were not active i.e., teams were formed, but there was no progress in implementing risk assessment tools.
The respondents were also asked whether implementation of risk management (e.g., Water Safety Plan) would be problematic for them within the next 6 years as it is indicated in the new DWD (Art. 7). Respondents are divided into three parts (Fig. 4). Only 34% answered that it will not be problematic. Others are aware of their ignorance or are even not aware of it (they replied “I don’t know”), which seems to be an even worse situation. Such a statement suggests that the entities did not acquire minimal knowledge about risk management, they do not know their needs and limitations. The survey therefore shows that 66% of water companies are not ready to implement risk management.
The respondents justified the lack of readiness with the reasons presented in Fig. 5. The causes and problems identified by the water utilities are like those reported in the first study. Relatively, the situation has not changed. In the first study, 67 (63%) out of 106 respondents indicated a lack of knowledge, and in the second, out of 148 respondents, 95 (64%) indicated it. 30% of the respondents to the first questionnaire indicated a lack of adequate human resources. In the second survey, they were already 46%.
The first questionnaire did not ask about funds needed to implement a risk-based management. It turns out that this is a very serious problem indicated by as many as 81% of respondents. The results indicate that most utilities analyzed the need to implement risk management which is a positive trend. 30% of respondents commented that because there are no formal requirements (transposition of the directive) yet, there is no justification for implementing risk management systems.
Water utilities pay attention to the costs related to risk management, e.g., costs of introducing new systems (e.g., Geographic Information System) or data archiving procedures for risk assessment and management (e.g., failure database, priority premises database, complaints, leaks, incident registration). Digital systems require constant updating and improvement. However, most water utilities are aware that they will need to carry out a risk assessment. Of course, a lot depends on the quality of this process and on the maintenance of the system at the appropriate level.