The five-year market testing programme is one of the plan's most controversial features. The programme will embrace all of the NRA's regulatory functions, and opens up the prospect of private companies issuing discharge and other consents, carrying out sampling and site inspections, and becoming intimately involved in enforcement.
Selected elements of the programme include:
The remarkable thing about this programme is that at no point have the Government or the NRA initiated a public debate about the fundamental principles at stake. Instead, the privatisation of regulatory activity is being contemplated simply as a means of securing "value for money".
Following the public expenditure settlements of the past three years, the NRA has already been forced to contend with reductions in its previously planned spending and Government grant-in-aid (GIA). In 1991, for example, it was told to expect a GIA from the DoE of £82 million in 1994/5. This was cut back to £75 million last year, and the NRA is now planning on a further cut to £69 million in November.
In addition, the NRA was told by the DoE that its initial plan for 1993/4 was inadequate, and was ordered to prepare a revised plan which incorporated a 10% efficiency saving for each of the next three years. This has bitten deeply into its planned spending on its seven core functions.
In last year's corporate plan, the NRA's expenditure in these areas was budgetted to rise from £439 million in 1992/3 to £518 million in 1995/6 - a 6% increase in real terms after a 1.5% per annum efficiency improvement was taken into account. But its revised plan for 1993/4 shows spending on core functions rising to only £446 million by 1995/6 - a freeze in real terms if it is assumed that it can achieve the 10% per year efficiency improvement demanded by the DoE.
Whether the NRA will in fact be able to achieve a 10% saving must be in doubt. The plan says that the target poses a "very significant and difficult management challenge." And it goes on to warn about the consequences of any further cuts in the budget.
"We believe we have struck the right balance and would therefore vigorously resist demands for further savings or suggestions of further reductions in GIA," the NRA says. "Such arbitrary action would, in our judgement, pose a serious threat to the NRA's whole raison d'etre and would lead to a rapid decline in the environmental improvements which have been hard won by the NRA in its four years of existence."
The impact of the revised plan on spending on core functions is shown in the table below. The first column shows budgetted expenditure this year. The three subsequent columns show how the NRA has had to cut back its proposed expenditure for 1995/6 since drawing up last year's corporate plan and this year's original baseline plan. This year's plan assumes an annual inflation rate of 4% which should be taken into account in interpreting the figures along with the 10% per annum efficiency improvement target.
The "efficiency" drive will have a substantial impact on employment levels. Instead of remaining at the present level of 7,950 assumed in the original plan, staff numbers are to be trimmed to 7,390 - including 90 water quality and 78 water resources personnel - over the next three years, excluding the effects of the market testing programme.
Higher "efficiency" will also mean reductions in the NRA's activity. Some examples are given below. In one or two cases the NRA's inability to achieve its earlier objectives is also attributable to Government inaction.
The NRA's preparations for SWQOs have been going well. It now expects to complete management plans which will form the basis of proposed SWQOs for all 189 catchments by 1998, five years ahead of last year's target. The NRA now hopes to introduce at least two pilot SWQOs in each of its eight regions per year.
Likewise, in 1991/2 it had been planning to reduce the length of the most polluted class D estuaries to 40 kilometres by 1994/5. The current length is 83 kilometres, and this year's plan projects no improvement until 1995/6.
The NRA is more optimistic this year about the rate at which the dirtiest class 4 rivers can be eliminated. It hopes to reduce their length from 478 kilometres this year to 416 next year, with a target of 50 kilometres in 2005.
The NRA has responded to the budget cuts by reducing the number of planned inspections, which are now to build up to 19,200 by 1995/6. This is 25% short of the target in last year's plan of 25,500 inspections in 1995/6.
The plan tells a similar story on fisheries, conservation and recreation. Existing targets for ecological surveys and habitat improvement in river corridors have not been met, and monitoring of the status of fisheries is also behind schedule. The latest plan revises targets in these and other areas downwards.