A 'ladder' of regulatory steps for sanitation?
In the conclusions to the WSUP Discussion Paper on 'Responsibilities, regulations and regulating for urban sanitation', reflecting on the fascinating case studies and recognising that each country and sanitation sector is at different stages on their regulatory journey, I suggested a 'Regulations and Regulating ladder'.
Clearly mimicking the JMP service ladders, the sanitation regulating ladder is designed to act as something like a checklist, to understand where a country is in terms of regulating sanitation.
In addition to the need to ensure that responsibilities are clearly defined with respect to FSM the difference is highlighted between passive regulations compliance in what is termed here as a ‘basic regulatory service’ and active regulating, using all the ‘tools of the regulatory trade’ in what is described as ‘safely managed regulatory service’.
We leave it to the reader to judge where each of the cases in the Discussion Paper might lie on this ladder. Several could be seen to be delivering a ‘safely managed regulatory service’ for water (though this not being explored in this document) whilst not yet at that level for sanitation – but all are moving in the right direction.
Running too far beyond my word limit, I had wanted to refer to the many further issues to be explored, questions to be asked, that arise in regulating sanitation – challenges that have not necessarily been made apparent through the selection of cases in the paper. For example, to what extent should surface and storm water drainage be included in a regulator’s sanitation responsibilities? What about grey water? What should sanitation surcharges be spent on? Communal toilets? Emptying & conveyance? Faecal sludge treatment? Household toilets? Substructures (emptiable pit)? What is the priority of priorities?
Though perhaps the greatest challenge is the extent to which regulators (and their governments) are satisfied that the water tariff is adequately cost reflective, as well as being affordable, so as not to be jeopardising willingness and ability to pay to ensure water services sustainability ....... before adding a sanitation surcharge?