Structure Plan Position Paper

Water network supply and demand in Aberdeen City and Shire

August 2010

1. Purpose

1.1 This position paper presents the findings of a number of discussions between representatives from key stakeholders involved in land use planning and the provision and regulation of water use in the Aberdeen City and Shire area. A full list of agencies and those involved can be found in annexe 1.

1.2 The primary purpose was to explore the medium to long-term provision of water to serve the anticipated levels of development in the structure plan and emerging local development plans. In order to do this, clarification of the current situation was necessary and consideration of any known risks or opportunities that can reasonably be predicted.

1.3 Grateful thanks are given to all who have contributed to this position paper, with acknowledgement that this represents collective understanding of the situation at the present time.

2. Introduction

2.1 The Aberdeen City and Shire Structure Plan was approved by Scottish Ministers in August 2009. This plan is aspirational and promotes a vision for the north-east of Scotland as a thriving, growing region with a diverse economy. To support this vision, a significant amount of growth is allowed for in both Aberdeen City and .

2.2 The precise locations where development will occur will be a matter for the individual councils. However, the structure plan spatial strategy sets out growth areas where 75% of development is due to take place, with the remaining 25% defined as local growth and usually taking place in smaller communities. In total, allocations for 72,000 homes and over 400ha of employment land are required up to 2030. These figures will be subject to five-yearly reviews.

2.3 Table 1 breaks these figures down into the three plan periods, but it should be noted that employment allocations are only for strategic growth areas; no requirement is given for local growth areas. These new allocations are in addition to any previously allocated sites, constrained land, or developments with planning permission at 1 January 2007.

Aberdeen City Aberdeenshire Housing Employment Housing Employment 2007-2016 16,500 10,800 105 150 2017-2023 10,000 12,450 2024-2030 9,500 70 12,750 113 Total 36,000 175 36,000 263 Table 1: Structure plan allocations 2007-2030

2.4 In recognition of the environmental impact of water supply, both in terms of energy consumption and abstraction (particularly given the protected status of the River Dee), the structure plan, in the sustainable development and climate change section sets out two targets relating to water supply. These are:

“To avoid having to increase the amount of water Scottish Water are licensed to take from the River Dee, as a result of new developments proposed in the plan; and

For all new development to use water-saving technology.”

2.5 Progress toward these two targets will be monitored on a regular basis and the structure plan action programme will help determine how to meet the targets in partnership with the organisations highlighted in annexe 1.

3. North-east Scotland water network

3.1 The water supply system serving the structure plan area is a complex and sophisticated network that has evolved over a significant period of time in response to the growth of Aberdeen and the communities of Aberdeenshire and more stringent social and environmental requirements. In some cases infrastructure built at the end of the 19th century is still fully operational and works with much more recently installed assets.

Aberdeen and Central Aberdeenshire

3.2 Aberdeen City and the area along Deeside, south to Stonehaven, north- west to Alford and Gartly and north to Ellon is all served by water abstracted from the River Dee or immediate tributaries. The licensed abstraction from the Dee is 145 megalitres per day (MLD). This abstraction currently takes place at Glen Dye (to be closed in 2011/12), Invercannie and Inchgarth. In total, Scottish Water abstract on average about 110 MLD from the Dee catchment (including the water abstracted at Glendye).

Inchgarth

Invercannie

Glen Dye

3.3 Aberdeen City is served by water treated at Glen Dye, Invercannie and Mannofield water treatment works (WTW). Each of these WTWs has different capacities (measured in MLD) to treat and release water into the network. • Glen Dye (Aberdeenshire) WTW – 4.5 MLD capacity • Invercannie (Banchory) WTW – 49.5 MLD capacity • Mannofield (Aberdeen) WTW – 70 MLD capacity

3.4 The River Dee has specific sensitivities and is designated as a ‘Special Area of Conservation’ (SAC) in recognition of its importance as part of a European network of high quality conservation sites. This status is due to the populations of Atlantic salmon, otter and fresh water pearl mussel that it supports.

North Aberdeenshire

3.5 Two sources of water supply the majority of north Aberdeenshire; the River Ugie supplies , and down the coast to Collieston and the outskirts of Ellon. The River Ugie license allows for 26 MLD, average abstraction is around 18 MLD at present. Once abstracted, water is treated at Forehill (Peterhead) WTW, which has a built capacity of 28.6 MLD.

3.6 In the north-west, water taken from the River Deveron is sent east to Fraserburgh and , south as far as Oldmeldrum and west into Moray. An additional source in the Turriff area is the Delgaty Borehole, which augments the supply from the Deveron. Separate facilities abstract and treat water from the Deveron solely for Huntly and Banff / Macduff.

3.7 From the Deveron, 33 MLD can be abstracted (31 MLD at Turriff and 2 MLD at Huntly). At this time, actual abstraction is around 30 MLD at Turriff and 1.5 MLD at Huntly; bringing them very near capacity. In terms of treatment, the main WTW is at Turriff and has a capacity of 32 MLD.

3.8 The river basin management plan covering north east Scotland highlights that drinking water abstraction is putting pressure on parts of the River Ugie, the Deveron catchment and the Turriff Bedrock groundwater area. It will be important to avoid further deterioration in these areas, and to reduce the impacts of abstraction in the future.

South Aberdeenshire

3.9 Loch Lee at the head of Glen Esk serves all of south Aberdeenshire, including part of Stonehaven and into north Angus. This reservoir effectively stores water from the catchment of part of the southern Grampian mountains that otherwise would flow into the River North Esk. Water collected here is treated at Whitehillocks WTW; this has a capacity of 15 MLD, but commonly operates around 12 MLD.

3.10 At this time there is no capacity issue in terms of the availability of water in south Aberdeenshire. Should this situation arise, the most likely solution would be the supply of north Angus from another WTW in the Angus area

(which is technically possible at present), thus freeing up additional capacity to serve Aberdeenshire.

General

3.11 Following treatment, water is distributed into supply zones via strategic or service reservoirs. These reservoirs are gravity fed or can use pumping stations and are capable of transferring water over considerable distances. There are several factors that govern the efficiency of the network and quality of the water supplied; these include the conditions that water is stored in, distance traveled and the pressure it is distributed under.

3.12 It is important that there is some spare capacity to allow for peak periods of demand and dry spells of weather. Scottish Water continually monitors the supply and demand rates and concludes that Invercannie and Turriff WTWs are operating at or near capacity. Whitehillocks WTW in Angus has limited capacity. In contrast, even allowing for a degree of headroom flexibility, Scottish Water suggest that WTWs on the Dee could supply around 25- 30,000 new homes and Forehill could supply many thousand additional customers.

3.13 Historical data supplied by Scottish Water illustrates that in the years from 1991 to 2009 (no data for some years) the amount of water distributed to customers from Invercannie, Mannofield and Glendye WTWs does not show an increasing trend; this is despite the significant levels of housing and business land developed over this period. This is not strictly a reflection of the amount abstracted due to losses in the treatment process; these are currently estimated at around 5%, but may have varied over the period of time that the graph represents.

120

100

80

60 Distribution (MLD)

40

20

0 1999 Jul-07 Jul-08 Jul-09 Apr-02 Jan-91 Jan-92 Jan-93 Jan-94 Jan-95 Jan-96 Jan-97 Jan-03 Mar-08 Mar-09 Sep-91 Sep-92 Sep-93 Sep-94 Sep-95 Sep-96 Aug-02 Sep-03 Nov-07 Nov-08 Nov-09 May-91 May-92 May-93 May-94 May-95 May-96 May-03 Mannofield WTW Invercannie WTW Glendye WTW 3.14 There are several reasons why a greater increase in levels of abstraction and treatment has not been recorded. Primarily this is as a result of

considerable success in tackling leakage rates, the negligible increase in population despite more households, the closure of some industrial scale water consumers and progress in more efficient water use.

3.15 In terms of leakage, Scottish Water must demonstrate to their regulators that they are managing this lost resource before any request for increasing abstraction levels can be entertained. For example, current leakage in the Don Region is estimated at 26%, but the Scottish average is nearer 36%. For the Grampian south-east region the ‘economic level of leakage’ has been reached, meaning the benefit of sourcing additional leaks is outweighed by the cost of searching for and repairing faults.

3.16 Scottish Water need to consider the role that demand management and water efficiency measures could play in creating capacity for growth. In some instances this may require a change to current regulations and legislation, as well as gathering robust data to evidence any benefits that demand management and water efficiency measures could provide.

3.17 Regulators must not place a disproportionate cost on Scottish Water. No matter what the perceived environmental benefit may be, the cost and carbon impact must be reasonable to Scottish Water customers..

4. Environmental issues

4.1 Due to the protected nature of the River Dee, the structure plan has a target to avoid having to increase the amount of water abstracted to serve new development. Tackling leakage appears to have been a principal reason for allowing abstraction to remain at a near constant level since 1991. Given that achieving further significant gains on leakage may be neither possible nor economical, it is important to be aware of future scenarios.

4.2 One of the most significant factors in future water use is likely to be adaptation to the effects of climate change; more abstraction for industrial cooling or domestic uses. These scenarios may pose additional strains on rivers where flows may already be low. All public bodies have duties under the Climate Change (Scotland) Act 2009 and Scottish Water has specific responsibilities for promoting water conservation and efficiency under s.74 of the Act.

4.3 The structure plan requires the greater use of water saving technology in new development. However, in the longer-term discussions are to be held with Building Standards to understand if any complementary measures are available and the SDPA will liaise with teams in Scottish Water and SEPA working on this issue.

4.4 Scottish Water abstract water under license from SEPA. These ‘controlled activities regulations’ (CAR licenses) describe the authorised activities (i.e. abstraction), as well as the means and rate of abstraction and determine the monitoring and reporting requirements that must be in place.

4.5 Several CAR licenses are in place on the River Dee, the most significant being for Scottish Water at Invercannie and Mannofield. In addition, two small businesses extract less than 5000m³ daily from the river between Banchory

and Aberdeen. SEPA are responsible for periodically reviewing licenses and may recommend changes to Scottish Ministers that it considers necessary or appropriate. Reviews have recently been undertaken and no amendment to either license is proposed in the short-term.

4.6 In deciding to amend a licence, SEPA must consider any request by Scottish Water to increase abstraction or otherwise change its terms. They may also initiate a licence review as part of Scottish Water’s investment programme. This would look at how much water was required for customers compared to that available to abstract if the environmental standards set by SEPA were to be met. If the environmental standards were not able to be met whilst maintaining the abstraction required, Scottish Water and SEPA would need to reach agreement whether a licence was issued that allowed continuation of the required abstraction, or whether Scottish Water should be funded to seek alternative sources to enable customer demand to continue to be met.

4.7 There is a degree of difficulty in relating how much water is being abstracted, the proportion of this to flow rate and the subsequent environmental quality of the River Dee. In terms of the latter, there is a requirement for the production of River Basin Management Plans (RBMPs) and a supplementary north east area management plan (AMP) under the Water Framework Directive. This sets out actions for a range of partner authorities to ensure that ‘good ecological status’ is reached and maintained for all rivers, lochs and coastal waters by 2015 and groundwater within a similar timescale if possible. The plans and an interactive map of data can be found at: www.sepa.org.uk/water/river_basin_planning.aspx.

4.8 The River Dee achieves good ecological status in part, but some sections are affected by pollution, alterations to beds and banks and abstraction; and are classified as moderate, poor or bad as a result. This has a potential impact on the species that inhabit the river and several studies have been and are still being undertaken by Scottish Natural Heritage (SNH), Macaulay Institute and Dee Fishery Board. At present, it is not thought that any recent study will seek changes to current abstraction levels. Scottish Water work closely to manage their operations during periods of low flow or due to any other reasonable request by either agency.

4.9 Across Aberdeen City and Aberdeenshire, the RBMP for the Scotland river basin district highlights that the following issues are pressures on water body ecology status: • Nutrient enrichment, predominantly from agricultural land use and sewage disposal. In the north east this is a particular issue for agricultural catchments in the north and east of Aberdeenshire; • Abstraction and impoundment for drinking water supply, irrigation, hydropower generation and industries such as distilling. In the north east, abstraction pressures are a particular issue for the Deveron catchment and groundwaters; • Alterations to beds, banks and shores, such as barriers to fish passage, culverting, straightening and channelisation. This can be due to agriculture, forestry, urban development and historical activities. These pressures are spread across all catchments in the north east, with fish barriers as a particular issue on the Dee, Don and Deveron catchments.

5. Future infrastructure requirements

5.1 Scottish Water, SEPA and SNH are identified as ‘key agencies’ to be fully engaged in the development planning process. Of these, Scottish Water has the greatest involvement in planning for future infrastructure to serve new development. At a strategic level, Scottish Water have been involved in discussions on ensuring the existing network is capable of supplying the considerable potential growth identified in the structure plan up to 2016.

5.2 At the individual planning authority level, Scottish Water have been a key part of the process of identifying new infrastructure needed to serve the sites going forward into the proposed local development plans. At both the local and strategic level, requirements must be justified on predictions and assumptions based on the latest information known, some of which is supplied by the development industry; such as financial viability and phasing.

5.3 Scottish Water use their own estimates to predict demand based on water usage per house. This currently considers demand of 500 litres per house per day to allow for leakage and buffering; however, this varies significantly depending on number of occupants and an average figure is more likely to be around 386 litres. As a general rule, 2,000 new homes would be expected to consume around 1 MLD; demand from the 72,000 homes allowed for in the structure plan up to 2030 would therefore require an additional 36MLD across the various sources outlined in section 3. Employment will add further to this amount, but will have a less significant effect.

5.4 What has become apparent is the challenge faced in ‘future-proofing’ new infrastructure and difficulty in building in additional capacity to new assets. This is primarily due to obligations placed on Scottish Water by their regulator to ensure investment is proportionate and justified. To satisfy this, Scottish Water adopts five criteria that a developer must meet before a ‘growth project’ can be funded of Part 4 Assets*, these are: • The development is supported by the local [development] plan and has full planning permission; • The developer can confirm land ownership or control through a solicitor’s letter; • The developer can confirm plans are in place to mitigate any network constraints that will be created by the development; • The developer confirms any time remaining on current planning permissions with the local council; and • The developer can demonstrate reasonable proposals in terms of the development’s annual build rate.

Part 4 Asset growth projects are not funded by developer contributions, but through Scottish Water’s capital investment programme, which is approved by the regulator. The investment priorities for 2010-15 have recently been agreed under the name SR10.

* Part 4 Assets are the strategic assets, such as raw water intakes, water impounding reservoirs, aqueducts, water treatment works and waste water treatment works.

5.5 The strict adherence to the criteria above makes planning for new strategic infrastructure difficult at the plan making stage in the process. This is due to the range of unknown variables and complexities of encouraging developers to work together to serve large developments and deliver growth. However, whilst demand is unpredictable in some areas, notwithstanding further significant economic uncertainty, the majority of sites within the Aberdeen Housing Market Area would be expected to be unconstrained and built out within the general period proposed.

5.6 By being fully involved at discussions early in the strategic and local development plan making process, the councils and Scottish Water have the best possible chance to influence future investment programmes; the next being SR15 (2015-20). Scottish Water have also stated a desire to consider wider development proposals when initiating a growth project to accommodate larger scale development, even if only one initial proposal has been able to satisfy the necessary five criteria. Finally, despite the significant sums allocated in the investment programmes and budgetary constraints, Scottish Water has indicated that in some cases, growth projects can come forward outside the planned investment to allow sites to be developed.

6. Conclusion

6.1 Discussions with Scottish Water, SEPA and SNH have allowed both councils and the Strategic Development Planning Authority to understand the numerous issues concerning the supply of water and the influences on decisions taken within the statutory and regulatory framework. Furthermore, these agencies are fully aware of the development allowances coming through the statutory development plan process.

6.2 The current and short-term situation is clear. No constraint is predicted in strategic terms from the River Dee and no significant problem is envisaged until between 25–30,000 new homes are built, thus allowing sufficient time to inform SR15, or subsequent Scottish Water investment programmes. However, the capacity of Turriff WTW is limited and abstraction from some sources in north Aberdeenshire are highlighted in the RBMP as putting pressure on these catchments; this will have to be resolved and potential solutions investigated.

6.3 The responsibilities of all public bodies under the Climate Change (Scotland) Act 2009 will focus activity on adaptation issues, but reduced abstraction from the Dee is only likely to occur through a review of the CAR licenses. This would create a potential issue for serving new development in the short-term. However, this review would have to recommend a significant reduction in licensed abstraction from the current 145MLD level and is not anticipated to occur in the period up to 2014.

6.4 By maintaining a close partnership with the key agencies involved and through the action programmes and monitoring reports associated with the structure and local development plans, early indications of any significant issue with water supply should become known and steps taken to resolve it.

Annexe 1: Key stakeholders

• Aberdeen City and Shire Strategic Development Planning Authority, Bruce Strachan (Senior Planner), Alanna Lyle (Planner) • Aberdeen City Council Local Development Plan Team, Fraser Clyne (Senior Planner) and Toby Coke (Planner) • Aberdeenshire Council Planning Policy Team, Jill Paterson (Senior Planner) and Matthew Watt (Planner) • Scottish Water, Susanne Steer (Development Planner), Andy Hannah (Graduate), Craig Christie (Water Asset Planner – South Grampian), Hamish MacDonald (Water Asset Planner – North Grampian). Ewan Band (Water Asset Planner - Tayside) • Scottish Environment Protection Agency, Zoe Griffin (Senior Planning Officer), Eilidh Johnston (River Basin Planning Co-ordinator) • Scottish Natural Heritage, David Bale (Area Manager - Grampian), Elizabeth Clements (Area Officer)