On the future of water management in Poland – a conversation with Witold Sumislawski, former president of the Polish Water Authority

gospodarki wodnej

Wody Polskie, the body responsible for water management, is quite an administrative structure, consisting of: National Water Management Board, 11 regional water management boards, 50 basin boards and 330 water supervisors. The administration’s tasks are related to flood and drought protection, the protection of water resources, the exercise of ownership rights over public waters, and the billing and collection of fees for water services.

And we can’t forget the key issues for users – the Water Authority is the regulator of water and wastewater tariffs and issues water permits. In the difficult situation in which Polish water management currently finds itself, every expert opinion matters and should be taken into account. That’s why I invited Witold Sumislawski – a manager with experience in managing the public and private sectors, president of the National Water Management Authority in 2013-2015 (now Wody Polskie) – for a substantive conversation.

Agnieszka Hobot: I would like to start by determining whether you think water management is more about infrastructure or the environment. And let’s not focus here on a specific ministry, but rather on management issues. Should they be in one hand, or is there a better solution?

Witold Sumislawski: Water is still an asset with an unconscious value. It just seems to be there and will be there, everywhere and always, like air you don’t notice. This feeling means that water management does not have its rightful place in both the public consciousness and the political world.

The change of power in Poland is a good time to once again emphasize that it involves all sectors of the country’s economy: from agriculture, which cannot exist without water, to the industrial sector (from construction to the production of ultra-modern batteries for cars), and finally the service sector with municipal management and health care. The special role of water in the energy sector, which is so important for the country’s development, must not be forgotten. Both the traditional, coal-based and nuclear ones do not function without access to ample water resources.

This breadth of impact, the cross-cutting effect on the economy, the multiplicity of sectors and industries it touches, and the ubiquity of its use on a daily basis, by almost all Poles, accounts for the fundamental difficulty of water management. It is the need to constantly reconcile the divergent, and sometimes conflicting, expectations and requirements of each water management stakeholder. This requires knowledge, professionalism and the ability to engage in dialogue in arriving at acceptable solutions.

Water management, in addition to the impacts discussed above, touches on what I believe are the most important areas and challenges facing Europe and Poland, namely. Adaptation to climate change by counteracting the effects of drought and flooding, improving the quality of the environment and quality of life (by, among other things, restoring natural retention, managing rainwater and counteracting urban heat islands), safety and health (by, among other things, protecting water intakes, establishing sanitary protection zones, controlling wastewater discharges, etc.).

We are part of the European community. It is often forgotten that water management is important in shaping international relations. Poland’s borders largely run along rivers and their delineation, maintenance and effective management of resources on border waters, requires coordination between states, respect for agreements and cooperation in emergency situations, and this is already a serious international policy. A separate issue is the relationship with the European Commission, the transposition of the law and the practical application of many EU directives related to water management, the environment or agriculture.

I have listed only some aspects of water management. The answer to your question raises another question. Can such a huge area be managed in one structure? To answer this, in my opinion, it is necessary to distinguish between what is the goal and what is the tool to achieve it. The management system, whether centralized or decentralized, departmental subordination, division of authority and responsibility, single- or two-instance administrative, etc., are all tools for achieving the goals, and it is not from these that work should begin.

The target model of Polish water management should be based on a well-prepared sector strategy, which would be a sub-strategy of the state strategy. It seems high time to arrange water issues in a systematic way, to carry out a diagnosis through in-depth strategic analysis and strategic modeling, to analyze scenarios, to identify the optimal direction of water development for Poland, to generate strategic goals, to arrange them in order of importance, to develop programs that implement the goals and tasks that implement the programs, etc., up to the level of specific projects. Pin the whole thing down in the timeframe of the schedules, and include the expenditures and costs associated with implementation in the material and financial schedules.

A coherent vision and strategy built in this way, “translated” into concrete solutions and actions, will provide answers to most of the questions we face today, including structural, organizational and management ones. I have been asked about such a strategy many times in Brussels.

Sorry for the management slang, but it really can be done, and it works not in theory, but in practice. We have the potential, knowledge and competence. In order to be successful, we need dialogue, cooperation of the entire broader “aquatics” community, going beyond annual budgets and acting in the long term.

A.H.: So, to summarize what you said, the most important thing in water management is the goals derived from the strategy and the selection of courses of action, and only after that is the arrangement of the structure and division of competencies for the various bodies.

W.S.: Definitely yes. At the same time, it should be emphasized that such a coherent, comprehensive strategic plan, combining management and organizational activities with investment programs, correlated with water management plans and flood risk management plans, as well as other planning documents, gives a much higher probability of obtaining external funding sources for implementation than separate investment tasks.

A.H.: It’s just that developing such a strategy takes time, and the problems to be solved are here and now, after all, we can’t wait.

WS: Full agreement. The response to current problems is immediate action from the operational management level, streamlining and facilitating decision-making, delegating authority, removing organizational roadblocks, etc. Another tool is to define key points, hot-spots, that need to be addressed immediately. In this way, it should be possible to resolve the most urgent issues under the current law, which takes time to change. Operational and strategic activities are two parallel but equivalent entities of any organization. With limited time and resources, the response should be to focus on key issues.

A.H.: Will you give an example?

W.S.: An example would be water and sewage tariffs, a very important issue to be resolved immediately at the operational level, but requiring the necessary adjustment of the regulatory function, and in parallel, at the strategic level, the preparation of a target regulatory model in Poland.

A.H.: You also have experience working with local governments, and so the question should be asked, how do local governments see water management and do they have enough competence to meet the challenges they face?

W.S.: I think the basic problem in recent times has been insufficient cooperation between state and local government structures. Let’s leave the causes, but it seems that the dialogue on many levels and levels has died down. And this is a prerequisite for any activity in an area with such a wide socio-economic impact. There are a huge number of points of contact and, unfortunately, most often “gnawed”. The lack of good relations makes it difficult to implement effective solutions, yet the Water Law contains provisions that enable cooperation. So there is a great deal of homework to be done in this field… Regarding the preparation of local governments.

As a general rule, downward delegation of authority is a desirable action and generally results in increased efficiency and effectiveness. However, it should not be forgotten that the delegation of tasks from the central administration to local governments must be followed by adequate funding. Without this, local governments are unable to generate the necessary competence. Competency building is a difficult and lengthy activity, requiring resources and specialized capacity. This should take into account the likely reduction in quality and efficiency at the initial stage. District municipalities will do better, but rural municipalities may face difficulties.

It is necessary to analyze whether it is appropriate for the local government to issue permits or decisions on its own. Water management brings an additional element to this, namely catchment management, which escapes administrative divisions. Even if we delegate some of the authority downward and achieve the goals, some structure will have to look globally at the entire catchment areas, coordinate, standardize the quality of maintenance of watercourses, manage emergencies, balance resources, and so on.

Without resolving the issues raised in the question, I only point out the complexity of the problem and the need for an in-depth analysis to make a proper diagnosis and recommend optimal solutions.

A.H.: In your opinion, as a person with a lot of experience in management as such, but also in leading the National Water Management Authority, what should management in water management consist of?

W.S.: I would say on parallel ongoing and strategic activities. I believe that at the operational level, it is a constant improvement of efficiency and effectiveness in activities related to drought and flood protection, environmental management and water use, it is meeting deadlines, openness to dialogue, cooperation with local governments and representatives of local governments, including economic ones, close cooperation with the world of science and use of competencies and knowledge accumulated there, cooperation with non-governmental organizations and use of their experience, and finally it is reconciling expectations of stakeholders that are difficult to reconcile. I have already talked about management at the strategic level. I would only add active participation in international structures and organizations, as well as looking after the interests of the Polish water industry by forming partnership relations with its neighbors.

If I had to point out key issues, I would start with general principles. Water management is an area in which decisions should be made with extreme caution and after deep thought, because once taken, especially investment actions are hardly reversible or irreversible, and mistakes in this area will result for many decades. This is absolutely key for me – everything should embed strategy.

The second element I would point out is the focus on flood safety. A number of programs and updates to risk management plans have been developed in consultation with the European Commission. Analyses have shown that throughout the previous decades, Poland has not had the best policy in this regard. As a result, the impression was created, as the EC pointed out to us, that we were dropping a flood on the heads of those living below.

This happened, among other things. As a result of the split between local and government rivers. We had well-protected agricultural areas and poorly protected urban and industrial areas. The approach to flood safety should continue to be corrected and take into account the natural retention capacity of non-urbanized areas, and this means focusing more attention on retaining water where it falls. This includes. mountainous areas that experience flash floods, but also metropolitan areas that are subject to urban flooding.

Over the years, we have focused on floods, and I believe that drought is a much bigger problem and threat at the moment. This “opponent” is more insidious and more difficult. Drought mitigation programs are far from sufficient. Still too little is being said and done.

Other key areas are protection of water quality, sludge management, revitalization and restoration of water resources of industrial areas, especially Upper Silesia. The list is impressively long. Indications will be found in the strategy.

A.H.: I asked what is the most important thing in modern Polish water management. Your opinion on the regulator is therefore not to be missed.

W.S.: A central regulator seemed to be a solution to address the key problems of the industry, and the idea had the support of some water companies. It became clear very quickly that the decision was not well prepared. Again, there was a lack of professional management of change and the regulator’s competence was not built beforehand, and over time the goals and functions of regulation began to diverge unfavorably from the conditions of the economic game, leaving many water utilities at or below the break-even point.

I was working on an analysis for the Polish Waterworks Chamber of Commerce related to single and multi-sector regulatory systems in Europe. At the time, we analyzed the impact of water and wastewater tariffs on residents’ disposable income in relation to European countries. Many aspects of tariff regulation have been analyzed, and there is not the slightest doubt what are the key elements that a good regulator should meet. The first that European respondents point to is the neutrality of the regulator, understood as independence from the pressures and influences of central and local politics. And this is the element that, even if it sounds idealistic, we should introduce in Poland.

The other two, i.e., the regulator’s legal guarantee and organizational and budgetary independence, were introduced into the regulation and can be considered, with some adjustments, to have been met.

These three key elements are essential to get the country’s policies on the availability of drinking water and wastewater collection services right. The central regulator was not without flaws, but as we go back in time the local, self-governing one had them as well. For me, restoring the proper functions of regulation, especially economic regulation, is absolutely the number one topic in the area of water management.

A.H.: My impression is that there is now an avalanche of unblocking of tariffs that water companies had requested months earlier. So something has begun to change in this regard.

I would also like to ask you about the long-term perspective – I understand that according to you it is primarily retention and the implementation of procedures and measures that should protect us from drought and its effects.

W.S.: I am a proponent of natural retention and this also applies to open water management infrastructure in cities. I want to point out why it is so important to have a thoughtful state policy in this regard. Rainwater fees are not subject to tariffs. This is a fairly poorly regulated issue and each city operates according to its own rules. The differences in fees are very large. It is important for the state to give impetus to solve problems in a certain way. It can do this by stimulating fee policies or preferentially funding desirable (e.g., green-blue) solutions. Such synergy is also very important because of the need for Poland to adapt to climate change.

The European Commission has these issues well thought out and shows through the priorities of a given funding perspective what it considers important at a given stage. This makes it easier for us to shape the right directions for the development of water management strategies. This is important, because despite the sometimes difficult relationship with the EC, I believe that the questions asked by experts in Brussels have taught us a lot.

A.H.: I would like us to speculate a little bit. Media reports talk about the liquidation of Polish Water, so we have two options. Either Wody Polskie will remain as it is or there will be a liquidation and transfer of powers. And now let’s imagine a situation where water planning remains in one hands, in one of the ministries, and maintenance and all tariff issues return to local governments. This is one solution. In the second one, which we have actually been discussing all this time, Waters of Poland is still operating, but a deep restructuring is taking place. Going back to the former, in your opinion, could such a solution, with all its consequences, work?

W.S.: As I mentioned before, the management system is a tool for achieving water management goals, not an end in itself. In my opinion, it should be derived from the strategy and the preceding diagnosis.

I do not prejudge which solution is better, because we have practice and experience with both models, both centralized and diversified, and we already know their strengths and weaknesses. Based on this, we can conduct analyses and recommend optimal management solutions to decision-makers, taking into account the specifics of Polish water management and its conditions. I am a change manager, and have repeatedly prepared and implemented restructuring strategies in water management. My experience has been that changes should be implemented based on a well-prepared action plan and sound analysis, including risks. However, it is not enough to introduce them, they still need to be professionally managed, adapting to the dynamic environment.

Water management is a network of complex interrelationships that need to be understood, taking into account short- and long-term perspectives and global and local challenges. Through dialogue with the expert community, a broad and comprehensive view of issues and matters can be ensured to guard against mistakes. We have enough potential in Poland. In my opinion, the key to success is just the word: manage.

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