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Citywide Inclusive Sanitation (CWIS): Better Projects through Integrity (Integrity Talk 9)

dilapidated housing above dark brown river, with one man on a balcony filling a jerrycan of water from a tank
Photo by Ayman Gamaledeen Gomaa Elmeligi - Mumbai, India - WIN photo competition 2016

The Citywide Inclusive Sanitation (CWIS) framework has been introduced to ensure that sanitation services are provided in a safe, sustainable and reliable way in cities, particularly to vulnerable groups. Contrary to previous approaches that tend to focus on incrementally extending the centralised sewerage network, CWIS puts forward both sewered and non-sewered systems and focuses on sustainable service.

In this integrity talk, we discussed how CWIS is working in practice and how different actors are taking on board the framework. We focused on integrity, responsibilities, regulation and what we can do to enable long-term change.

This is an edited summary of the main discussion points of Integrity Talk 9 on Citywide Inclusive Sanitation, which took place online on November 29, 2023. See other Integrity Talk summaries here.

With special guests: Dr. Christoph Lüthi, EAWAG-SANDEC; Claire Grisaffi, Water & Sanitation for the Urban Poor (WSUP); Bill Twyman, AguaConsult; Tanvir Ahmed, ITN-BUET; Rohini Pradeep, CDD Society. Moderated by Ivan Zupan, Water Integrity Network (WIN).



  • CWIS is a powerful and useful framework – it makes it possible to reframe sanitation in a positive and innovative manner, without stigma. Its flexibility and focus on principles, rather than solutions, make it particularly adaptable.

  • It is however not straightforward to implement. It requires long-term commitment and investment. Above all it requires new ways of thinking and doing sanitation work, along with adequate new capacity and dedicated people working collaboratively across the sector.

  • Integrity is an important component of CWIS work and is embedded in CWIS functions (particularly under accountability, resource planning, and management). It is especially needed to:

    • define clear responsibilities for all stakeholders and build accountability along the entire sanitation value chain;

    • ensure that poor integrity and shadow systems don’t undermine impressive developments in regulatory work;

    • safeguard available resources and attract new ones;

    • build community trust and engagement, ensuring acceptability.




What is Citywide Inclusive Sanitation (CWIS) and why does it matter?

Christoph Lüthi (EAWAG-SANDEC): The global water crisis manifests in different areas as too little water, too much water, or too dirty water. In response, CWIS is the dominant paradigm for achieving safe sanitation for urban context.

CWIS is not new and it’s not a set approach. It’s a framework for solutions where all members of the city have equitable access to adequate and affordable improved sanitation services through, appropriate systems of all scales (sewered and non-sewered), without any contamination to the environment along the entire sanitation value chain.


schema of CWIS service framework showing on top 3 outcomes (Equity, Safety, Sustainability), and below 3 functions (Responsibility, Accountability, Resource Planning and Management)
CWIS service framework: outcomes and functions. Source:

In the last two years, we’ve seen an increasing number of pilot implementations and moves to operationalise CWIS. This includes work on ways to measure progress. For example, to measure progress on equity, indicators can include: percentage of population with access to improved sanitation or shared sanitation, or the percentage of the population living in informal settlements with access to improved sanitation.

None of this is prescriptive. It’s a guide for action that most large funders are aligning with.


What do you see as the main implications of CWIS for utilities? How are service providers taking the framework on board?

Claire Grisaffi (WSUP): We've seen that the CWIS framework is a powerful concept. It has made investment into promotion of non-sewered solutions much more politically palatable and it also embeds the understanding that high quality faecal sludge management can provide safe sanitation and even be prestigious.

For utilities, there are still two major challenges to implementation:

  • The whole new way of working to manage non-networked services and the very different capacities needed to do so. In many cases, service providers are not providing direct services like they are used to, but managing multiple formal and informal service providers. They also have to build trust and manage expectations and social norms around safe sanitation, with limited public funding.

  • The need to balance often conflicting aims for universal access to sanitation and commercial viability. There is an assumption that market mechanisms can work and that low-cost sanitation services can be developed. What we’re seeing is that providing safe sanitation – safe for households, safe for workers, safe for society at large – has a high cost, even more so in lower income areas due to difficult access and poor-quality containment.

As implementing partners, we also must seriously reflect on our own integrity and the approaches we are promoting. Are we overly optimistic about the potential of the private sector? Are we transparent about what financially viable services really mean and how that can imply a sustainable level of subsidy? Are we thinking enough about the weight placed on utilities to reach universal access?

We’ve seen the importance of developing trust, the importance of local management. And in terms of design of services, we’ve seen how important it is to actually demonstrate what safe sanitation service looks like. Because for many people, it’s horrific and shameful. You have to understand how this is viewed by communities. 

-Claire Grisaffi, WSUP


What do we know about regulating for CWIS? What can we learn from Zambia?

Bill Twyman (AguaConsult): Across the continent there is a bias in regulation towards water supply only. Zambia doesn’t entirely escape this trend but is still at the forefront of many developments for regulation of urban sanitation.

Zambia stands out for its independent regulatory agency (National Water Supply and Sanitation Council, NWASCO) and the impressive and wide range of regulatory instruments in place, also for non-sewered sanitation. There are also some regulatory functions that are in a sense shared with the Lusaka Water Sanitation Company, which acts as a bridge to smaller service providers.

This doesn’t mean the Zambian sanitation sector is immune to corruption and poor integrity. In our research, we came across a number of cases – from bribery, nepotism and misuse of per diems to allegations of large-scale corruption in procurement and management of major internationally funded programmes.

Recommendations to improve and strengthen regulation include e-procurement, better data collection, public reporting on integrity and integrity failures.

We need to pay attention and understand this shadow system better. There is no doubt that in countries with no dedicated regulatory actors and weaker regulatory systems, the issues related to poor integrity will be much more perverse and far more widespread.

-Bill Twyman, Aguaconsult

On a broader level, we see many weaknesses in the regulatory environment, in relation to autonomy, capacity coordination, and accountability. We also see weaknesses in the application of integrity mechanisms: standards monitoring, reporting incentive sanctions or more specific mechanisms relating to governance, human resources, or project execution. There’s a lot we could be doing to reduce the opportunities for corruption. Generally, you see better regulator performance when there is a dedicated agency, but that’s not the case in every context.

Tanvir Ahmed (ITN-BUET): In cases where there are a lot of utilities or a lot of private operators, regulation through an agency may be easier but in other cases maybe not. In Bangladesh, an independent regulatory agency is not an option. But CWIS does bring out notions of accountability and responsibility. It has regulation almost built in through the principles.

Claire Grisaffi (WSUP): A good example we see isn’t about passive adaptation to new regulation. That doesn’t work. Utilities have to lean into the discussion on what’s working and what’s not. They see low demand, low profit margins and the need for a long-term change process, meaning it will be typically deprioritised. As a consequence, regulation pushing on-site sanitation just doesn’t get implemented. A good practice is for utilities to have units or dedicated staff or dedicated budget lines, even if they are tiny, just to make sure that you actually have that accountability and visibility of service.



How can we then create an enabling environment for CWIS? What can we learn from Bangladesh for the mainstreaming of CWIS?

Tanvir Ahmed (ITN-BUET): Dhaka has very low coverage for sewerage and a sewerage system that hasn’t expanded over time with the city. Only 1.2% of the households are connected to sewers. The city, with 20 million people, has only one sewerage treatment plant. Faecal Sludge Management (FSM) was never in any city plans. This is the backdrop for the CWIS and how it has to evolve in Bangladesh.

What we see across the country is programmes in small cities that are exemplary in relation to individual CWIS principles. Faridipur City has worked on awareness raising and equity and has women-led treatment operations; Sakhipur has closed the loop on managing the entire sanitation service chain, Khulna has set performance targets with a clear inclusive mandate. These examples have yet to be replicated and scaled up. We are still using traditional approaches to planning and implementation.

For CWIS to work and for the 216+ municipalities that are still unserved or have no Faecal Sludge Treatmpent Plant (FSTP), we need a strong collaborative ecosystem. As a first step, the country developed an institutional regulatory framework for Faecal Sludge Mangement (FSM) which outlines who the sanitation stakeholders are and what their relationship is. We have the ministry on top, the local government institutions to implement, and the agencies to support sanitation investments. The next step is a regulatory mechanism for sanitation.

ITN-BUET focuses on capacity building for all actors. It is especially crucial to prioritise capacity building at the local level. There’s a realisation there that focusing on implementers is not enough. Mayors and city officials have become important stakeholders.

We have to make them realise that citywide inclusive sanitation is a change of mind-set. That it’s not only infrastructure. That it is also means service. People think of a toilet but it’s a combination of everything.

-Tanvir Ahmed, ITN-BUET

Christoph Lüthi (EAWAG-SANDEC): Around the principle of mixed technologies and mixed systems, we are still getting a lot of pushback. And that has a lot to do with old-school engineering thinking about ‘one-size fits all’ or ‘we want sewers for our city’. Many utility managers want sewers. That can actually create delays and issues in project implementation. Political will is central.



How is it working in practice? What can we learn from India about project implementation?

Rohini Pradeep (CDD Society): When looking at CWIS principles, we must think in terms of public service. How do we strengthen service by bringing in responsibility, accountability, and better resource planning, in order to ensure high levels of equity and sustainability.

Integrity is clearly key. It underpins trust-building and community engagement, it encourages equitable access, transparency on the use of funds, better accounting, capacity building, and regulation.

What we see very often in our work is community toilets that are not or poorly maintained, or where usage is very low. There are many factors contributing to this situation. Poor and unintegrated planning and siting is one.

Unclear or clashing responsibilities and insufficient capacity is another. When there are delays because of limited resources or unclear responsibilities and multiple service providers, people will bypass formal solutions, resort to private contractors, or connect themselves however they can. We’ve seen examples where one truck is used for multiple activities in the process of collecting waste then desledging. It created delays and pushed people elsewhere when cooperation between stakeholders could have been beneficial for everyone.

One other big concern is financing. When no provisions are made for operation and maintenance (O&M) upfront, local municipalities will have to put up funds. But sanitation is usually then at the bottom of the list of priorities.

There are a number of interesting initiatives being piloted, for example performance-based contracts for service delivery, subsidy programmes, quotas of low-income users for each providers. Most of these rely on strong community engagement for success. Integrity is key to this, especially the inclusion of all stakeholders in planning. Clearly defining the roles and responsibilities of each party involved and resourcing these adequately is the next crucial step.





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