WRSE Regional Plan consultation document

Response on behalf of the Faversham Society

February 17, 2023

Question 1:  Do you think the draft regional plan addresses the scale of the challenge we face in the future through our adaptive planning approach?

Disagree.

Certainly, an adaptive planning approach is an appropriate response to uncertainty around climate change, continued population growth and other factors.  The Faversham Society disagrees, however, with the reliance in all proposed options on desalination to supplement water supplies from other sources to achieve delivery targets.  Desalination is very expensive compared to other options, has unacceptably high environmental impacts because it is so energy-intensive, and provides none of the co-benefits associated with other potential sources, notably increased water recycling.  The carbon impacts of the various pathways proposed (p36) are not described in sufficient detail for their relative merits to be compared. The water industry as a whole – i.e. regulators, water suppliers and wastewater treatment companies together – must take responsibility for tackling environmental impacts along the entire supply chain.  Increasing water recycling and thereby reducing the discharge of partially or wholly untreated wastewater into the environment is essential and would constitute a public good.  The same cannot be said in any way for desalination.

Question 2:  Do you support us continuing to work with other sectors so our regional plan fully embeds their future needs and includes appropriately-funded solutions to meet them?

Agree.

Of course, the water supply sector should work with other industries to reduce overall water consumption and improve performance along the entire supply chain.  The same standards that are increasingly being applied to domestic water supplies must be applied too, however, in other sectors, to ensure for example that water used for agricultural purposes is used as efficiently as possible and that levels of nitrates and phosphates in runoff from agricultural land do not cause problems either for water suppliers or in wastewater.  As flagged elsewhere, the water industry as a whole – regulators, water suppliers and wastewater treatment companies together – must take responsibility for reducing environmental impacts along the entire supply chain. 

Question 3:  Do you think the draft regional plan strikes the right balance between reducing the demand for water and developing schemes to provide new water supplies?

Disagree.

The Faversham Society disagrees with what it believes is an over-reliance on leakage reduction as a strategy to reduce usage and demand.  We are disappointed that our response to your earlier consultation on this point, in March 2022, does not appear to have been heeded.  What we wrote then was as follows: “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 a huge effort, nor that the effort is misplaced, simply that the risk associated with assuming this to be a certain solution is underestimated.”  Much greater investment will be needed to achieve the 51 percent target listed in the draft plan (p26). 

On the supply side, we wholeheartedly support the ambition to reduce abstraction from the chalk aquifer by the 40 to 60 percent cited for this part of north Kent.  We also support the proposed creation of the Broadoak Reservoir, at the latest by 2036.  Indeed, we believe it is a sufficiently high priority that it should be fast-tracked for completion before that.  We oppose desalination as a solution because of its high cost compared to other options and unacceptably high carbon emissions. 

Because of our scepticism about the realism of the leakage reduction targets and opposition to desalination, we believe that water companies in the southeast – specifically South East Water in the case of Faversham – should explore more actively the opportunities for wastewater recycling and for the exploitation of currently untapped sources of water such as the former gravel pits at Oare.  There are precedents for such projects associated with the former papermills and gravel pits in Aylesford and Snodland.  As noted elsewhere, wastewater recycling at the Faversham WTW in partnership with Southern Water would also contribute to improved water quality in Faversham Creek and the Swale as the result of reduced discharges of partially treated wastewater. 

Question 4:  Do you support the increased collaboration between the water companies in the South East and other regions, through the development of shared resources and an enhanced network to transfer water around the region and between regions?

Strongly agree.

The Faversham Society strongly supports increased collaboration between water companies, both for transferring water around the region and between regions, and for other purposes.

In the case of water transfers, it goes without saying that new infrastructure put in place to support transfers using the existing canal and river system will need to incorporate biosafety measures in order to ensure that any alien invasive species, pathogens, etc., present in the source region are not distributed around the country along with the water.

As for other partnerships between companies, the Faversham Society supports an increase in water recycling which would require close collaboration between South East Water and Southern Water in this area of north Kent.  Increased water recycling would reduce dependence on water abstraction from the nearby chalk aquifer, which affects the flow of chalk streams flowing from the aquifer, and contribute to improved water quality in Faversham Creek and the Swale as the result of reduced discharges of partially treated wastewater.  Water recycled from wastewater treatment works could either be fed immediately back into the local supply or else used to recharge the chalk aquifer.