Mr. Brian MacDonald:

We have been embracing the risk assessment approach since 2002. We have a quality assurance system which allows us to identify potential hazards and take steps to eliminate them. It is in that regard that we see a weakness in the directive. While it is good in many respects in taking a risk-based approach to drinking water, as stated by Mr. Page, it is overly excessive in monitoring a lot of parameters. For example, there are 180 group water schemes with bore hole supplies, predominantly groundwater. The majority of the remainder use springs which produce very good water. Since 2007, taking account of all of the parametric analyses that have been made, we have been close to a figure of 100% for all of the chemical parameters. If we could use this evidence retrospectively such that we would not have to carry out certain tests, that would be a good starting point for us. One parameter which has not been yet mentioned and that will have a major affect is turbidity - dirt in water that comes from a pipe. The parametric value in that regard is one nephelometric unit. Under the proposal, water suppliers will be asked to produce it at a level of between 0.3 and 0.5. As Mr. Page pointed out, that means that we would not be able to use a slow sand filtration system anymore because in putting it through a slow sand filter it would increase the level upwards. That will require the installation of a filtration system in advance, even in a good spring or bore hole supply. We have not costed the proposal, but it will be very be significant. There is a need for a rethink on this issue. That said, we agree that there is a need for closer monitoring of turbidity as an indicative parameter. The Environmental Protection Agency has been preaching this for years. We are not afraid of monitoring. We believe it is good, but the monitoring proposed is grossly excessive and potentially crippling.