Graham Setterfield and Matthew Hatchwell have prepared and submitted a response with the support of the Board to the Water Resources South East (WRSE) Consultation - our submission concluded with these points.
The consultation document's strong focus on the environment is very welcome, as is its regional approach. We recognise that this is a huge strategy and more detail needs to be established going forward. In particular:
a). We are concerned that the main driver here seems to be cost-efficiency rather than sustainability, resilience or protection of the natural environment. It must be recognised and accepted that in order to maintain the sustainability of supply and protect the natural environment, there will have to be significant expenditure over an extended period, for example, to expand nature-based solutions whose upfront cost is high but which will lead to savings in the long term.
b). The needs of integrated wastewater planning must also be fully taken into account. Water supply and wastewater treatment should not be considered in isolation from each other.
c). Environmental baselines and monitoring (in particular around chalk streams) need to be improved.
WRSE needs to work with the EA, NE and other actors on this. The consultation document gives scant attention to the issue of pollution which is clearly linked to the amount of water available in the environment.
d). Most critically, the British water industry as a whole needs to incorporate into its thinking the implications of Sir James Bevan’s now famous "jaws of death" speech in 2019, in which he spoke about the point where a future diminishing water supply is outstripped by increasing water demand. Much more needs to be done not only on the demand and supply sides, but also to introduce profound changes to the current planning system and the assumptions underlying it. All utilities must be planned for, delivered, and used through a transformed national spatial strategy that will allow planning to deliver truly sustainable communities and protected natural environments. The current situation, which requires water providers to deliver what they do not have, must be abandoned.
Our submission in full
|Abstraction reduction to protect the environment is likely to be the single biggest driver of investment in water resources over the next 25 years. Do you agree with our approach to establishing the appropriate level of abstraction reduction required across the South East England?|
Please explain your answer.
a) We agree that abstraction reduction to protect the environment should be a very high priority and that major investment is appropriate in cases where significant environmental benefits can be achieved, e.g. in maintaining the flow of chalk streams. b) This is a very complex issue, however, and the question is too simplified. Public water supply of sufficient quality and quantity remains the most important responsibility of private water companies. To achieve this in 2060 is the challenge to be met – by the variety of mechanisms proposed. We question whether abstraction reduction can be the single biggest mechanism for achieving the gains needed by 2040 and beyond – although, given the high level of public concern, it could indeed be the biggest driver of investment. Abstraction reduction from some aquifers as well as from some rivers is essential, but reduction in leakage and consumption per capita are equally important. c) Does this question presuppose that abstraction reduction across the board is essential? Reduced abstraction is most important in the case of chalk aquifers where abstraction may contribute to low flow in chalk streams. In some catchments there is balance between the present abstraction rates and public water supply with no harm being done to the aquatic environment. Winter river abstraction and storage for example cause no harm and summer releases from reservoirs into low-flow rivers enhance the environment. So our answer is a qualified no: abstraction reduction is but one of the most significant drivers where over-abstraction now or in the future will cause environmental harm.
Prioritise upper catchments, because headwater ecologies are the most vulnerable and the benefits to flow should improve the whole catchment.
Prioritise catchments where the impacts on flows are the most severe.
Prioritise catchments where there is the highest degree of certainty that abstraction reduction will restore flows and deliver environmental improvement.
Prioritise catchments where people have the most unrestricted access to rivers and streams.
Prioritise catchments where nature will benefit most, even if public access is restricted.
Focus abstraction reductions on a smaller number of catchments but fully address the issues they face.
Focus on a wider range of catchments and partially address their abstraction issues
Are there any other factors that you think should be considered as we prioritise where abstraction could be reduced in the future?
a) Prioritising abstraction reduction at the expense of other measures is worrying. In some cases, aquifer recharge or treated wastewater recycling via rivers or into groundwater may be the optimal solution, enhancing the effective state of the natural water environment without necessarily reducing abstraction. There are already examples of this approach being used successfully. Subject to wastewater treatment enhancement and consent standards being improved, this can be both more cost effective, more certain of a result and more beneficial for the environment. b) One of the written responses to questions posed during the consultation stated that “through our work with regulators, CaBA and the water companies, we have a comprehensive picture of the chalk streams that might be impacted now and in the future.” That is incorrect: there is a series of streams flowing into the Thames Estuary from the North Kent Chalk aquifer to the west and east of Faversham that are not currently included in the national register of chalk rivers held by Natural England. Work is now underway to rectify that omission. Abstraction from the North Kent Chalk has been responsible for the depletion of those streams since the 1960s when abstraction began. c) We welcome the statement in the same set of written responses that “virtually no new water [for new housing developments] (only 1 per cent of what could be required) will come from new groundwater sources and none of this will be from new chalk abstractions.” That commitment should be specifically stated and substantiated in the final WRSE strategy document.
We have assessed the future water needs of the other sectors that don’t rely on the public water supply provided by water companies. Do you agree with our assessment? Please explain your answer.
Approximately one billion litres of water from the public water supply system are used every year by business in the south east. Clearly industries such as paper making, brewing, farming and many others have their own dedicated sources of water. These cannot be ignored at the expense of the public water supply system. The Environment Agency is the regulator for all abstraction, so we would hope that their assessment is correct and follows the same methodology as for public water supply and that those industries are set the same challenges for becoming more water efficient and abstracting less.
We’ve described our adaptive planning approach and the scenarios we’ve included in our adaptive planning pathways. Do you agree that we have planned for the right scenarios in each of the pathways, with a wide enough range for each of our key challenges, through our adaptive planning approach? Please explain your answer.
We disagree with the straight line to 2040. This is a very binary approach and seems to suggest that this trajectory is certain and the confidence around it high. Our knowledge of water resource planning suggests that the only period that should be shown as binary is to about 2027, thereafter there should be bounds with confidence limits attached and alternative strategies shown.
Do you support our approach to treat each pathway as equally likely and not choose a core pathway beyond 2040? Please explain your answer.
We agree with this assumption post 2040, although would like to see more evaluation of some of the post 2040 solutions and approaches carried out earlier.
Do you have any other comments on our approach to addressing the challenges that are facing South East England?
The scale of development is of concern to us all. It is completely incorrect to think that the Government (now and in the medium-term past) has shown any appetite to force developers to make new homes more water efficient. The present by-laws do not force them to do so, the developers continue to build homes for people moving into the area rather than the affordable smaller homes that are needed, and have no appetite for any genuine water-saving strategies. The water companies and water regulators have no choice but to provide water for any and every house that is built. This system is desperately in need of an overhaul. Water is not an infinite resource, yet WRSE seems unwilling to even contemplate the “black swan” scenario that supplies might run out if development continues unabated, with all the negative environmental consequences that that implies.
Reducing the demand for water through leakage and water efficiency activity contributes to more than half of the total amount of water needed in the first 15 years of the emerging plan. The balance then shifts to include a greater reliance on supply side solutions, particularly in the more challenging future scenarios. Water companies are committed to delivering these reductions, but they are reliant on customers making sustained reductions in their water use over the long-term. Do you think our plan strikes the right balance between demand and supply solutions and the risks associated with delivery of such solutions? Please explain your answer.
No, we disagree with the proposed balance. The risks associated with reductions on the supply side are multiple. In no specific order our view is as follows: • Leakage reduction by the companies is treated in the first 18 years, up to 2040, as a certainty, which is highly risky. The water companies have for the past 20 years - or more in some cases - been spending increasingly large amounts of cash trying to reduce leakage. Different governments, different heads of the Environment Agency, different heads of Ofwat, have all at various times “demanded” that the companies fix leakage. Every water company in WRSE has expended huge efforts in manpower and technical solutions to try to reduce the figure. This is a diminishing returns game. We worry that a “messianic” optimism is in evidence. “Something will turn up…” but what if leakage reduction remains as difficult? The investment in new pipework - which ultimately is the only way to reduce leakage - was until recently less than 1% p.a. which means that the present infrastructure is ageing faster than it is being replaced, which in turn leads to increasing difficulty in detecting leakage. This is not to say there is not huge effort, nor that the effort is misplaced, simply that the risk associated with assuming this to be a certain solution is underestimated.
• Secondly the success of reductions on the customer side might be predicated on the success of the companies. This was suggested by Trevor Bishop during the webinar. If the public feels that companies are not doing their share, why should they as its customers? (See above for the risks). There is also the challenge presented by the existing housing stock not being intrinsically water efficient. The cost and disruption of retrofitting more efficient taps, showers and appliances, let alone more complex systems such as rainwater harvesting, seems to us to make this very risky. Water remains very cheap. Metering has helped and will continue to do so, but unless variable tariffs become the norm, customer side demand will not reduce as quickly as is hoped. • Thirdly, new houses are not yet being built to the highest water efficiency standards. Successive governments have shied away from amending the Building Regulations to force developers to set demanding efficiency targets for new properties. Water companies should encourage central government to “raise the bar” because they are the ones that will bear the brunt of public anger when demand exceeds supply and taps run dry – and because informed lobbying by the private sector may be more effective than pressure from other quarters. If government will not tighten Building Regulations, companies should challenge the current unconditional legal obligation imposed upon them to enable new development. Experience elsewhere shows that unlimited housing growth creates unacceptable impacts in other sectors.
The plan assumes that the Government will introduce new policies that will support more efficient use of water across society - through labelling of water-using products by 2024, introducing a minimum standard for all water using products by 2040 and tightening the water efficiency requirements within the Building Regulations for new homes by 2060. Do you support these interventions and the timing of their introduction? Please explain your answer.
Yes we support these interventions wholeheartedly, but the time scale for change is pathetically and – in the light of climate change – inexcusably slow. In Faversham the number of new houses to be built over the next 5 to 10 years represents a pace of development rarely, if ever, seen in the town since it received its first Charter in 1252. There is no reason why, by 2030, Building Regulations should not be tightened and all water-using products achieve an ambitious minimum standard, except inertia and lack of political will.
Do you think it is appropriate for Temporary Use Bans and Non-Essential Use Bans, that reduce demand for water further during droughts, to be used as options in this regional plan?
No water company would choose to use any form of ban as they each represent a failure to provide what the customer feels they have paid for. Under the scenarios presented there is a real risk that such measures will become more commonplace, if efforts to reduce demand are not successful. There will always be a risk that a combination of weather events leads to such bans, but they should be a last resort.
Do you agree with the mix of options that provide new water supplies for the region within our plan - reservoirs, desalination, water recycling, new transfers, improved abstraction from groundwater storage and ASR schemes? Do you think that some options should feature more or less in our plan to secure future water supplies? Please explain your answer.
a) We fully support these options and the mixed approach. Our view is that they should feature much earlier as they have a lower risk associated with their successful development. The environmental benefits of many of these schemes cannot be overstated. Should they be available earlier and demand reductions are modestly successful, such environmental gains will still be realised. Specifically, we are very disappointed that Broad Oak reservoir has been pushed back by another 10 years: this is a reservoir where the water companies own all the land, where the feasibility assessment has been completed and few serious objections remain. This scheme creates the opportunity to allow reductions in abstraction from the North Kent chalk, in turn leading to the possibility of enhancing the flow of numerous chalk streams in the Faversham area. In addition, the opportunity to develop recycling schemes at new locations such as Faversham WTW would have significant benefits both in recharging the aquifer and removing a polluting wastewater discharge where it is causing serious pollution to Faversham Creek and neighbouring Thorn Creek. b) With rising energy costs, desalination of brackish water may become unaffordable.
Do you support the use of new, potentially long pipelines to move water around the region?
Local solutions are usually preferable. The rising cost of energy and the need to cut carbon militates against pumping water which is energy intensive. However, greater resilience and flexibility will arise from some pipeline interconnections.
We have identified where water companies might investigate a number of new, more innovative nature-based solutions to improve the region’s water catchments. Whilst these options can provide multiple benefits, the fact they are still relatively new can make it more difficult to be certain of the benefits that will be delivered and the return on investment. Do you agree that we should promote new, more innovative nature-based solutions in our plan to develop a better understanding of their future value and role in delivering water supplies and wider environmental improvements?
a) The return on investment elsewhere in the proposed programme is based on assumed success from solutions with a higher risk of non-achievement such as leakage. The possible solutions outlined in Q11 include many nature-based solutions which are worthy of further R&D. Nothing should be discounted, in particular for new installations where the viability of nature-based solutions may be greater since they are free of the additional challenges posed by retro-fitting. b) We support nature-based solutions over technological fixes as a matter of principle because in the long run they are likely to have lower running costs, be more sustainable (e.g. in terms of GHG emissions), and deliver more societal benefits. Liv Garfield, CEO of Severn Trent, told the House of Commons’ Environmental Audit Committee (EAC) recently that ”equipping sewage treatment works with nature-based solutions would be more expensive in the short term but would deliver savings over the long term” (Report on Water Quality in Rivers, January 2022). The same report recommends that “Ofwat incentivise the use of nature-based solutions in wastewater management, including ongoing funding for maintenance and operation.” c) This WRSE consultation should take note of the EAC’s Water Quality in Rivers report more generally, in particular Section 6 on “Restoring rivers to good ecological status.” (The report is weak, however, in failing to make the connection between water quality and quantity. Flow is one of the key determinants of water quality, in chalk streams especially, therefore abstraction should have been included within the purview of the study.)
Do you support our approach to stop using the majority of Drought Orders and Permits - only continuing to use a limited number during droughts until we achieve one in 500-year drought resilience, and stopping their use after 2040, unless we experience a drought more severe than a one in 500-year event?
In principle, yes. There may be ways to use recycled water or reservoir releases to restore flows such that subsequent Drought Orders and Permits are less damaging than presently assumed. There remains the requirement to continue to supply potable water for normal domestic and industrial use under all circumstances.
Overall, do you agree that the emerging plan, which presents the most cost-efficient adaptive planning solution, should be used as the basis to further develop our draft best value regional plan?
a) It is too early to say that the emerging plan presents the most cost-efficient planning solution. Cost-efficient and best value are different measures. We are concerned that short termism remains inherent in the emerging plan as shown in the consultation, despite the intent of this being a medium-term planning exercise. b) There is almost no mention of climate change in any aspect of these questions regarding the plan, yet this was frequently raised during the webinars. Climate change seems to be more certain than several other aspects of this plan. c) There is much of the plan that seems to be omitted from these 15 pre-set questions, on issues such as chalk streams, carbon emissions and climate change. Concerns were raised during webinar sessions about these and other issues but only partially answered due to time constraints. Webinar participants should be given the opportunity to react further to written answers if they feel that their concerns have not been fully or appropriately addressed. d) There is an unquestioning assumption underlying the emerging plan that development will continue unabated with WRSE unwilling to question whether the present system, whereby water supply follows development, is fit for purpose. This is an opportunity to challenge the status quo and ask whether the time has come to limit development because of the severe water shortage that exists in South East England.
Finally, do you have any other comments about our emerging regional plan? If so, please give more details below.
The consultation document's strong focus on the environment is very welcome, as is its regional approach. We recognise that this is a huge strategy and more detail needs to be established going forward. In particular: a). We are concerned that the main driver here seems to be cost-efficiency rather than sustainability, resilience or protection of the natural environment. It must be recognised and accepted that in order to maintain the sustainability of supply and protect the natural environment, there will have to be significant expenditure over an extended period, for example to expand nature-based solutions whose upfront cost is high but which will lead to savings in the long term. b). The needs of integrated wastewater planning must also be fully taken into account. Water supply and wastewater treatment should not be considered in isolation from each another. c). Environmental baselines and monitoring (in particular around chalk streams) need to be improved. WRSE needs to work with the EA, NE and other actors on this. The consultation document gives scant attention to the issue of pollution which is clearly linked to the amount of water available in the environment. d). Most critically, the British water industry as a whole needs to incorporate into its thinking the implications of Sir James Bevan’s now famous "jaws of death" speech in 2019, in which he spoke about the point where a future diminishing water supply is outstripped by increasing water demand. Much more needs to be done not only on the demand and supply sides, but also to introduce profound changes to the current planning system and the assumptions underlying it. All utilities must be planned for, delivered, and used through a transformed national spatial strategy that will allow planning to deliver truly sustainable communities and protected natural environments. The current situation, which requires water providers to deliver what they do not have, must be abandoned.
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