SOUTH STAFFORDSHIRE WATER

FINAL DROUGHT PLAN

FEBRUARY 2013

APPENDICES

Appendix A: Summary of Draft Drought Plan Pre-Consultation

Appendix B: Statement of Response to Representations: April 2012 Overview Statement and November 2012 Addendum

Appendix C: April 2012 Statement of Response: Detailed List of Representations

Appendix D: EA River Severn Drought Order Process

Appendix E: Drought Management Schedule

Appendix F: Demand Management Options

Appendix G: Communication Plan

Appendix H: Supply Management Options

Appendix I: General Specifications for Environmental Monitoring

Appendix J: HRA Severn Estuary

Appendix K: Map of Key Environmental Sites

Appendix L: Company Drought Management Structure

Appendix M: Example of an Appeal for Customer Demand Savings

Appendix N: Example of a Hosepipe Ban Notification

Appendix O: Example of a Hosepipe Ban Cessation Notice

Appendix P: Example of a Notice to Apply for an Ordinary Drought Order

Appendix Q: Detail of Drought Legislation

Appendix R: Drought Plan Summary

South Staffs Water Final Drought Plan February 2013: Appendices

APPENDIX A:

SUMMARY OF PRE DRAFT PLAN CONSULTATION

Organisation Main Comments SSW Response The Environment Agency referred The Company has followed ENVIRONMENT the Company to its Water Company the relevant legislation and AGENCY Drought Plan Guidelines which the Environment Agency were updated in June 2011. Guidelines.

To follow the updated Environment The Company has followed Agency Drought Plan Guidance. the relevant legislation and the Environment Agency Guidelines.

To take account of the widened powers regarding hosepipe bans in preparing their drought plans The widened powers have (Section 76 of the Water Industry been reviewed and the Act 1991 as amended by section 36 relevant sections in the Plan of the Flood and Water updated accordingly Management Act; and the Water DEFRA Use (Temporary Bans) Order 2010).

Consider timing and phasing of drought actions and restrictions, The options for timing and priorities for achieving water phasing of restrictions have savings and any concessions you been reviewed along with might expect to make. To consider potential concessions. carefully how you will engage with Additional communication your customers to communicate material has been included. your plans to them and obtain their views.

Set out clearly what a drought is Drought management steps and what steps will be followed to have been reviewed and manage it. updated.

Set out clearly what levels of service, in terms of restrictions on Levels of service have been use, customers can expect to reviewed to ensure they are receive, and for these to be consistent with FWRMP OFWAT consistent with those funded in your 2009. 2009 Final Determination.

Demonstrate that the proposed drought management actions strike A balance between supply a balance between meeting the and demand management needs of consumers, those of the actions has been environment and shareholders. maintained in the new plan

South Staffs Water Final Drought Plan February 2013: Appendix A Organisation Main Comments SSW Response Set out your company’s liability for payments of compensation Compensation arrange- associated with drought permits, ments have been reviewed ordinary drought orders and and retained emergency drought orders.

Take account of the impact of Bulk import arrangements drought on your bulk imports of have been reviewed and water and exports of water between remain the same zones.

All drought plan documentation continues to published on the Company internet website along with a Be easily accessible to customers. non technical summary and explanatory leaflets to domestic and business customers

Ofwat remains within the Include Ofwat in your company’s Drought Communication communications plan. Plan along with other key stakeholders

Our HRA includes an assessment, alone and in- combination, with other drought plans. As part of the The Drought Plan must be subject in-combination assessment, to a Habitats Regulations we have included the Assessment. combined effects of the drought plan with existing licensed abstractions as well as other drought plans

Preparatory work for an SEA has been carried out NATURAL through the preparation of Consider applicability of the SEA ENGLAND extensive environmental directive to the Drought Plan and assessments of drought carry out a Strategic Environmental schemes. We have Assessment if required. determined that the SEA Directive dos not apply to our current Plan

Take reasonable steps to further These issues were the conservation and enhancement considered in our previous of SSSIs and make clear how review of Drought Scheme protection and enhancement issues options and drove the affecting SSSIs and biodiversity rejection of schemes in the have been taken into account in the Stour Valley. These factors process of reviewing, selecting and have influenced monitoring

South Staffs Water Final Drought Plan February 2013: Appendix A Organisation Main Comments SSW Response assessing drought options. and mitigation plans

Following completion of ongoing ecological surveys would like to see further discussion and agreement These issues will be picked on the exact monitoring required for up in consultation over the Hanch Tunnel Drought Scheme and revised environmental a clear mitigation plan which will be assessment. implemented if monitoring picks up any impact to the SSSI.

Drought Management: demand and Assumptions have been supply assumptions should reflect reviewed in light of the the changes to the 2009 water FWMP 2009 resource management plan.

Increase public awareness of the The Company endorse this environmental impacts of drought objective and will support on the environment to assist in the environmental increasing the effectiveness of regulators in giving this demand management measures message to our customers.

Review communication and A review has been carried application procedures generally for out drought and pre-drought situations

The Company has followed The draft Drought Plan follows the the relevant legislation and Environment Agency guidelines the Environment Agency Guidelines

The non technical summary has been updated and The Drought Plan is customer sections on customer friendly and, in particular, the non- restrictions expanded to technical summary. The reflect the Company consultation to be as wide as response to wider powers CCWATER possible, particularly engaging with under new legislation. those most likely to be affected by Additional explanatory the actions in the plan. customer leaflets have been prepared

The sequence of demand- The plan should set out the various side actions follows demand–side actions which will be Company experience of the implemented to reduce demand 1976 Drought and national and how these actions will be best practice published in prioritised. UKWIR studies

South Staffs Water Final Drought Plan February 2013: Appendix A Organisation Main Comments SSW Response Drought Communication Plan – This should provide for liaison with CCWater so that we can provide CCWater remains within the comment in the media and ensure Drought Communication that our Consumer Relations staff Plan along with other key are briefed to enable them to advise stakeholders customers appropriately.

South Staffs Water Final Drought Plan February 2013: Appendix A

APPENDIX B: RESPONSE TO REPRESENTATIONS

B1 APRIL 2012 OVERVIEW STATEMENT

B2 NOVEMBER 2012 ADDENDUM (this precedes change of Hampton Loade supply option from Drought Permit to Drought Order)

South Staffs Water Final Drought Plan February 2013: Appendix B APPENDIX B1

SOUTH STAFFS WATER RESPONSE TO REPRESENTATIONS ON THE 2012 DRAFT DROUGHT PLAN

1. BACKGROUND

This is South Staffordshire Water’s response to the representations received following the publication of its Draft Drought Plan on 9th of January 2012. South Staffordshire Water is committed to engaging with all of the stakeholders who have an interest in this plan. The Company has undertaken consultation with these stakeholders and the general public. The consultation period ran for 8 weeks from 9th January to 4th March 2012 during which time any comments or questions on the draft plan were sent to the Secretary of State. South Staffs Water is now required to publish (by 22nd April 2012) a response to the points raised during the consultation. Details of Consultation Process The Government guidelines for consultation on the Drought Plan indicate that the following groups must be notified of the consultation: • The Secretary of State for Environment Food and Rural Affairs • The Environment Agency • OFWAT • Relevant water undertakers (Severn Trent Water, Bristol Water and Anglian Water) • The relevant Local Authorities • The Countryside Commission (now Natural England) • English Nature (now Natural England) • The Countryside Council for Wales • The Historic Buildings and Monuments Commission (now English Heritage) • The relevant Regional Development Agencies • British Waterways • The Consumer Council for Water The Company wrote to these groups on 6th January 2012 notifying them of the consultation period, directing them to the website and advising that a paper copy of the plan was available if required. The complete draft plan was published on the Company website (www.south-staffs-water.co.uk) on 9th January 2012 in a prominent location. A summary document was also published on the website.

South Staffs Water Final Drought Plan February 2013: Appendix B1

In addition to meeting these minimum requirements for consultation the Company undertook a number of additional activities listed below:

 A selection of interest groups or individuals were written to informing them of the consultation period.

• Members of Parliament • Members of the European Parliament • The British Horseracing Authority • The British Swimming Pool Federation • The Car Wash Association • The Horticultural Trades Association • The National Council for the Conservation of Plants and Gardens • The Royal Yachting Association • The Racecourse Association • The Turfgrass Growers Association • The National Farmers Union • The Country Land and Business Association Limited • The Drinking Water Inspectorate • The Angling Trust • The Staffordshire Wildlife Trust

 Customer leaflets detailing the possible impact of temporary use bans (hosepipe bans) and drought orders (non-essential use ban) were produced to assist customer understanding and these were published on the website  A document of frequently asked questions was produced to assist customer understanding and published on the website  A simple web-based questionnaire for customers to complete to provide feedback was produced and this was included on the website along with all the other relevant documentation.  The consultation was publicised with a press release – this was picked up by the Burton Mail.  Details of the consultation were included in the recorded message which customers heard when they called the customer contact centre.  Details of the consultation were included in a letter about winter issues sent to approximately 250 domestic and non-domestic customers.

This document summarises the representations received, and it responds to the most significant and/or recurring points that have been raised. The full details of every representation are listed in Appendix A, with a response from the Company on the action it intends to take.

South Staffs Water Final Drought Plan February 2013: Appendix B1 2. SUMMARY OF RESPONSES

The following table summarises the representations received:

Consultee Nature of representation

CC Water No formal response submitted but helpful comments on further improvements to proposed customer literature, further simplification of non-technical summary, and communications were received separately.

South Staffs Council No points raised.

NFU Concern raised over availability of supplies to livestock and irrigation water and communications.

Racecourse Concession for course watering requested. Association

Turfgrass Growers 28 day concession for newly laid turf requested. Association

EA No ‘significant’ issues raised. “Moderate” issues of concern raised: - (1) Stronger emphasis on early demand management required before supply schemes used; (2) more robust monitoring and mitigation plan required for supply schemes; (3) more detailed communication plan with neighbouring water companies, customers and other stakeholders required, and; (4) lead in time for drought order implementation too short. 6 ‘minor’ issues raised e.g. incorporation of 2011 lessons learnt and also compliance with legislation.

Fire Brigade Request to be kept informed during drought.

Project Fire Concern over water wastage by sprinkler systems raised.

English Heritage Concern over use of groundwater drought schemes raised.

Car Wash Association Concessions and improved communications requested.

South Staffs Water Final Drought Plan February 2013: Appendix B1 British Waterways* Acknowledgement of previous liaison over supply schemes and requests for this to continue.

Natural England* Submitted after close of consultation period. Concern over Severn drought permit around timing of implementation of hosepipe bans and inadequate monitoring and mitigation of impacts * These representations were received after the close of the consultation period, however the Company has included them in its response.

There were no completed questionnaires submitted via the website and no responses from individuals. During the period of the consultation the drought plan pages of the Company website were the second most visited pages. There were 12 responses containing 32 specific points raised by the consultees. These are listed in Appendix A, with the Company response. The following key issues have been identified for fuller discussion in this document;

• The Environment Agency’s Representation • The Timing of Temporary Use Bans and Drought Orders (Non- Essential Use Bans) • Concessions for Water Use During Temporary Use Bans • Environmental Monitoring and Assessment • Stakeholder Communication

3. RESPONSE TO KEY ISSUES

3.1 The Environment Agency’s Representation

The Environment Agency provided the most detailed response to the Draft Plan. Three specific recommendations for improvements were made. These recommendations were:

• Recommendation 1: order of drought action implementation (temporary use ban) • Recommendation 2: environmental monitoring • Recommendation 3: drought communications

A detailed evidence report which classified issues raised as either major, moderate or minor was also provided. The Environment Agency used this system of classification for plans published by all water companies. The

South Staffs Water Final Drought Plan February 2013: Appendix B1 evidence report included further detail around the three recommendations above which were all classified as moderate issues. In addition to this a fourth moderate issue was raised and seven minor issues were raised. The Environment Agency also considered whether the Company’s Draft Drought Plan complies with the Drought Plan Direction 2011. The Environment Agency identified three issues in this area. All of these can be linked with the issue of environmental monitoring covered in recommendation 2. In total the Environment Agency raised 14 issues with the Company’s Drought Plan. In general the Company welcomes the Environment Agency comments and has attempted to address all of them. The detail of our responses are contained in the following sections and in Appendix A.

3.2 The Timing of Temporary Use Bans and Non-Essential Use Bans

One of the Environment Agency’s key recommendations relates to the timing of temporary use bans and drought orders (non-essential use bans). The EA commented as follows:

‘In most circumstances, temporary restrictions should be in place before a drought permit application is made. We recommend that the Company allows sufficient time to review demand savings from implementing temporary restrictions before a drought permit is considered. We will not support drought permit applications that do not demonstrate that appropriate demand savings have been made.’

The Draft Plan stated that hosepipe bans would be triggered immediately prior to the implementation of drought permits. The Company believes that the most equitable approach is for customers to be impacted at the same time as the implementation of drought permits. However, the Company recognizes that it is appropriate to implement temporary use restrictions prior to drought permits so that the demand savings can be assessed and the need for a drought permit confirmed.

The Company has therefore reviewed its drought triggers, associated actions and the normal order of escalation. The revised text from section 5.6 of the Drought Plan is as follows:

• Normal operation takes place above the drought monitoring curve. The output from Seedy Mill is only restricted by the capacity of the works or by the abstraction licence.

South Staffs Water Final Drought Plan February 2013: Appendix B1 • When the Drought Monitoring Trigger curve is crossed the Company moves from the normal cost optimisation mode to a resource conservation mode of operation. The range of potential actions that may be implemented at this stage are described in Section 6 of the Drought Plan. These include a range of demand management options, minimising abstraction from Seedy Mill (to help conserve storage at Blithfield), using the Nethertown pumpback, including the Trent recirculation if residual flows are insufficient on the River Blithe and putting surplus potable water into the reservoir to augment levels in the reservoir.

• As the Apply for Drought Permit curve is approached the Company will consider the need for a drought permit to maintain the Trent recirculation and the need for and likely benefits of imposing a temporary use ban. The Environment Agency and Defra expect that demand restrictions will have been implemented before a drought permit is granted unless it can be proven that there will be no savings from a temporary use ban, for example in winter when there is little or no hosepipe use. • Other groundwater drought permits (Hanch Tunnel) may also be considered at this stage. (Note: the proposed drought permit at Hampton Loade is linked to storage at Clywedog).

• As the Apply for Drought Permit curve is further approached the Company will begin preparations for making an application for a drought permit.

• If conditions continue to deteriorate the Company will consider imposing a temporary use ban at this point.

• When the Apply for Drought Permit curve is crossed the Company will consider submitting the application for a drought permit. If an application is to be made a temporary use ban will be in place by this stage unless it can be proven that there will be no demand reduction as a result of it.

• The Implement Drought Permit curve is used to illustrate when the drought permits would be operational.

• If the level in Blithfield continues to fall then the Company will consider the need for and likely benefits of an Ordinary Drought Order to restrict non-essential uses of water at commercial premises. If this is deemed appropriate and beneficial then an application will be made.

• The Emergency Storage Curve is 4% above the dead storage curve. This water will only to be used as a last resort and is a buffer before dead storage is reached. Dead storage (25%) represents the level of storage below which it is extremely difficult to abstract water because of the hydraulics of the system and the quality of the water would be so poor that it will probably be unacceptable to utilise it.

South Staffs Water Final Drought Plan February 2013: Appendix B1

A detailed description of the full list of supply and demand actions that may take place as each trigger curve is crossed is included in Section 6. Throughout this process the Company will liaise with the Environment Agency, Severn Trent Water and CCWater. In particular discussions will take place with Severn Trent Water and CCWater around implementation of any temporary use ban to ensure that the information to customers is clear and there is little potential for confusion.

The control rules are set to align with the Company’s stated level of service of only having hosepipe bans in genuinely exceptional circumstances (once every 40 years on average).

The Company will consider carefully the need for, potential benefit of and the timing of implementation of a temporary use ban. It is possible that where such a ban may be indicated by trigger curves, this may not be appropriate during winter months.

The decision to begin the preparation of any drought permit applications will be made by the Company’s Drought Management Team several weeks before the Apply For Drought Permit line is crossed, and this will depend on the particular drought permit and the specific conditions that are in existence at the time. Section 7 describes the programme of environmental impact assessment that the Company has undertaken to support a range of potential drought permits.

The Company’s triggers and main actions for managing a drought affecting Blithfield are shown on Figure 9. These are colour coded to identify the increasing severity of a drought, as described in Section 5. The supply and demand management options that may be implemented at each trigger are described in more detail in Section 6.

The timing and sequence of the implementation of a temporary use ban, a drought permit and an Ordinary Drought Order will depend on the exact circumstances at the time. However, it is the Company’s view that it would be unacceptable to customers to experience a temporary use ban significantly earlier than just before the implementation of a drought permit. Example timelines are shown below to illustrate the possible sequence of events.

Example Timeline for Imposition of Temporary Use Ban and Implementation of a Drought Permit

Pre-consultation on TUB and Drought Permit Day 1: Advertise TUB giving 2 weeks notice Day 14: Implement TUB Day 16: Apply for Drought Permit Day 28: Implement Drought Permit (the Environment Agency has 12 days to determine the application)

South Staffs Water Final Drought Plan February 2013: Appendix B1 Example Timeline for Imposition of Ordinary Drought Order (Non- Essential Use Ban)

Pre-consultation Day 1: Advertise TUB giving 7 days notice Submit application to Defra Day 28: Implement Drought Permit (Defra has 28 days to determine the application)

Figure 9 referred to above is reproduced in Appendix B

3.3 Concessions for Water Use During Temporary Use Bans and Ordinary Drought Orders

The Racecourse Association, the Turfgrass Growers Association and the Car Wash Association responded requesting concessions for water using activities in the event of the implementation of a temporary use ban or an Ordinary Drought Order. The Company believes that for demand restrictions to be effective concessions must be kept to a minimum. However, the Company also recognises that there are some legitimate circumstances when concessions are appropriate. There are existing statutory concessions covering health, safety and animal welfare which the Company believes will cover most customer concerns. The Turfgrass Growers Association requested a concession for newly laid turf. The Company’s position is that in order for a temporary use ban to be effective then it must be applied uniformly to all domestic customers. It believes that customers who purchase new turf will be prepared and capable of watering it by hand and this will avoid the excessive use of potable water. Therefore the Company does not propose to grant a concession for the watering of newly laid turf. The Racecourse Association requested a concession for watering of racecourses for health and safety, animal welfare and economic reasons. South Staffs Water recognises the importance of large sporting events in the local economy and is prepared to make an exception to the prohibition that a hosepipe may be used to water an area of grass or artificial outdoor surfaces used for sport or recreation, where this is required in connection with a national or international sporting event. This concession will be granted initially during the early phase of implementation of a temporary use ban and the Company reserves the right to remove the concession if drought conditions continue and greater demand savings are required. The Car Wash Association requested a concession for conveyor car washes and rollover car washes under an Ordinary Drought Order. Ordinary Drought Orders will only be used under conditions of an exceptional shortage of rain should other measures to conserve supplies (such as Temporary Use Bans) be inadequate. These powers were first granted to water companies in 1976 as it was recognised that further measures in addition to domestic hosepipe

South Staffs Water Final Drought Plan February 2013: Appendix B1 bans were necessary to limit the requirement for standpipes in a severe drought. As such the Company does not currently propose to change Section 6.3.5 of its Drought Plan. The Company notes however the intention of the car wash industry to move to certification of its capability to limit water usage to less than 30 litres per car. Progress on this initiative will be viewed favourably in the Company’s ongoing reviews of its Drought Plan. In view of the implementation of temporary use bans by other water companies within England in April 2012 the Company believes that there will be lessons to be learned with regards to the granting of appropriate concessions and the impact on the effectiveness of temporary use bans. If drought conditions worsen during 2012 and Ordinary Drought Orders are implemented by other water companies within England there may also be valuable learning to be gained from these experiences. Therefore the Company will keep its position with regards to all concessions under review.

3.4 Environmental Monitoring and Assessment

Both the Environment Agency and Natural England raised concerns over the detail of the environmental monitoring plan contained within the Draft Drought Plan. The Company recognises that the development of an acceptable environmental monitoring plan is work in progress. The Company has agreed a way forward with the Environment Agency and hopes to conclude a robust and comprehensive monitoring plan by the end of summer 2012. The Company accepts that without an accepted monitoring plan any proposals for implementation of drought permits may be difficult to progress and therefore this area of work is a priority for the Company. The Company also accepts that until a suitable monitoring plan is agreed it is not possible to determine what mitigation measures might be necessary or whether the correct permits and approvals that may be needed to implement the mitigation measures have been listed in the plan. Similarly, the identification of any compensation necessary as a result of the implementation of supply-side drought options is not possible until the monitoring plan is completed. However, all of these issues will be addressed as part of the development of the agreed monitoring plan. Initial studies were carried out in 2007/8 to assess the environmental impacts of the proposed drought permits. Reports on the River Blithe/Trent and Hampton Loade Drought Permit Schemes were made available to the Environment Agency during pre consultation for the present Drought Plan in 2008 and are publicly available on application as laid out in the 2008 Final Plan and the present draft Drought Plan 2012 (Appendix I and Appendix J). The Company has acknowledged that these reports do not follow the updated guidance on Drought Permits and Drought Orders (Defra, May 2011), specifically with reference to potential impacts on Water Framework Directive (WFD) classification status; and a revision is underway.

South Staffs Water Final Drought Plan February 2013: Appendix B1 A further report did not fully evaluate the impacts of the Hanch Tunnel Drought Permit and this has led to additional work on the Bourne Brook. Reporting is at early draft stage and further work is required for presentational purposes. Nevertheless this is compliant with the Defra 2011 guidelines and identifies the issues in the current environment and future impacts of the scheme. Each report follows the broad approach as follows: i Description of Drought scheme ii Description of water bodies affected (generally from the point of abstraction to the estuary) iii Characterisation of current environment within water bodies affected iv Analysis of hydrological impact on water bodies affected v Analysis of impacts on current environment within water bodies affected vi For the River Severn and River Trent schemes, impact analysis was additionally considered in combination with drought schemes proposed by Severn Trent Water The reaches where the environmental reports concluded a risk requiring monitoring and/or mitigation are as follows: • The River Blithe/Trent scheme affects the lower Blithe (downstream of Nethertown) and the Trent down to the River Tame confluence. Downstream of this, hydrological impacts are very low / negligible even considering in combination effects. • The Hampton Loade Drought Permit has two options (192Ml/d and 245Ml/d). The assessment concluded negligible impact except for the 245Ml/d option when in combination with Severn Trent Water drought permits. The reaches affected are in the lower tidal reaches of the River Severn (Although the scheme impacts the Bewdley flow it is recognised that this is in place to protect the lower reaches). • The Hanch Tunnel Drought Permit impacts the Bourne Brook. For the purposes of this project it is assumed that the whole reach down to the Trent confluence is considered for monitoring. We have also included Stowe Pool SSSI for consideration as it is also subject to monitoring and mitigation of general drought impacts although the link to the drought scheme is less certain. The further work currently being progressed will include a high level re- assessment of key assumptions for our drought schemes and identify the necessary permissions required in their operation and any protected persons or abstractors requiring compensation. It will include a detailed assessment of the changes in risk presented by the WFD data and a re-assessment of the general requirements for baseline monitoring, additional survey information to resolve uncertainties, and in-drought and post-drought monitoring. The Environment Agency has provided data on its WFD monitoring plans and the Company expects to reach agreement with the Environment Agency on its own monitoring plan, the requirements for in- drought mitigation and protocols for data exchange shortly.

South Staffs Water Final Drought Plan February 2013: Appendix B1

3.5 Stakeholder and Customer Communication

Several of the representations identified where improvements could be made to the section of the Draft Plan dealing with communication. In particular the need to reinforce liaison with stakeholders (such as neighbouring water companies, CCWater, and customers) and to review the responsibilities of the drought management team was raised. The Company has revised the communication section of its Drought Plan. The main changes relate to roles for the Drought Management Team which have been revised and the clarification of the different audiences and type of communications which will be relevant during drought management. Drought management has been more closely integrated with the normal supply management process. The team has been strengthened by the incorporation of the Head of Production to create an Executive of Three which mirrors the Company’s proven successful model for incident management and control. The frequency of meetings has been increased from fortnightly to weekly. The Executive of Three will review the drought conditions on a weekly basis and make decisions regarding the ongoing strategy. These decisions will be communicated to other members of the drought team. A meeting of the full Drought Management Team will take place on a monthly basis. In addition to technical support from other roles the Team will be supported for the duration of the drought by a permanent secondment from the Customer Engagement Department who will act as Drought Communications Co-ordinator and report directly at the weekly drought meeting. The Drought Communications Co-ordinator together with the Drought Strategy Manager will act as a point of contact for all communications with external stakeholders ensuring these are regular and timely. The revised Drought Management Team structure is summarised in the following table.

Drought Team Role Day Job Role Responsibilities

Member of Executive of Three, Board Liaison Overall responsibility for drought Supply Director andHead of Drought management. Management Team

Drought management strategy development. Member of Executive of Head of Water Three and Drought Ensuring consistency with Drought Plan. Strategy Strategy Manager External stakeholder management.

Head of Production Overall responsibility for operation of Executive of Three and Asset Production assets. Maintenance

South Staffs Water Final Drought Plan February 2013: Appendix B1 Control of the supply network. Operational Drought Supply Manager Implementation of the drought strategy. Manager Management of the Drought Team

Water resources technical specialist Water Resources Drought Data Manager providing data relating to drought monitoring Manager and forecasting.

Production Drought Production Implementation of drought strategy at Co-ordinator Co-ordinator Production assets.

Co-ordination of internal and external communications relating to drought.

Drought Communications Creative Resources Liaison with internal stakeholders not on the Co-ordinator Manager Drought Management Team but with an interest in drought issues such as the Media Team and the Head of Customer Engagement.

In addition to this the Final Drought Plan will include an overview of the main communications which will take place during a drought. This is summarised in the following table.

Audience Primary purpose of Possible means of communications communication Environment Agency Exchange of technical Email information. Letter Consultation Telephone Co-ordination of messages Meeting Customers Information Press releases Consultation Website Change in behaviour Adverts in media Letters Leaflets Consumer Council for Water Information Email Consultation Letter Co-ordination of messages Telephone Meeting Severn Trent Water Information Email Co-ordination of messages Letter Telephone Meeting Other water companies Information Email Co-ordination of messages Letter Telephone Other regulators Information Email Letter Telephone Other consumer bodies / Information Email stakeholders e.g NFU and Consultation Letter

South Staffs Water Final Drought Plan February 2013: Appendix B1 Fire Brigade Co-ordination of messages Telephone

The Company has also amended its plan to include the regular review of the effectiveness of its drought communications in order to continually improve and tailor its messages. A number of indicators may be used to do this. The relevance of these indicators will depend on the type of communication and the expected response. Suggested indicators include:

• Scale of demand reduction • The uptake of press releases • The number of contacts received • The number of representations received in response to the advertisement of a temporary use ban

The Company has also amended the Drought Plan to include the Consumer Council for Water as a key stakeholder.

South Staffs Water Final Drought Plan February 2013: Appendix B1 4.0 TIMETABLE FOR FURTHER WORK AND THE PUBLICATION OF THE FINAL PLAN

The Company will continue to focus on developing and agreeing its environmental monitoring plan with the Environment Agency and Natural England. It is hoped that an agreed plan can be included within the Final Drought Plan when it is published. However, due to the complexity around these technical issues this may still be work in progress. The most up to date position will be included within the Final Drought Plan and any outstanding work will continue to be progressed as a matter of urgency. The Company will also keep a watchful eye on how the water industry implements temporary use bans in 2012 and will consider any improvements it should make to its stakeholder communication strategy and proposals with regards to concessions for water using activities as a result of these experiences. Once the Company has completed the development of its new water resources model it will undertake a full review of the control curves and drought action triggers using this new software platform. Additional drought scenarios will be explored. This work will help inform the next drought plan revision in three years time.

South Staffs Water will publish the Final Drought Plan once it has received direction from the Secretary of State to do so and it will publish the Plan in accordance with any dates specified in the direction.

South Staffs Water Final Drought Plan February 2013: Appendix B1

Appendix B: Figure 9 DROUGHT CONTROL RULES: TRIGGERS & MAIN ACTIONS Note: The order of actions is an indication of priority, however the Company reserves the right to change the order as circumstances dictate

Above Trigger 1 Trigger 1 Trigger 2 Trigger 3 Clywedog and Blithfield Clywedog/Blithfield storage falls below Drought Clywedog/Blithfield Clywedog/Blithfield above Drought Monitoring curve storage falls below storage cuts Monitoring curve Apply for Drought Implement Drought Permit curve Permit curve

Action 1 Action 5 Action 9 Action 11 Review resource Put potable water into Normal Operation position and calculate Blithfield Impose temporary use Implement drought refill statistics ban and submit permits application for drought permits Action 12 Action 2 Action 6 Consider application Introduce Nethertown Review bulk supply & for Ordinary Drought and River Trent discuss resource Action 10 Order to restrict non abstraction if optimisation with Drought permit essential use. necessary. Maximise Severn Trent application determined Undertake pre- groundwater within by the Environment consultation. existing licences Agency Action 7 Appeals for Action 13 Action 3 Advertise and apply Maximise Hampton customers to reduce demand. Promotion for Ordinary Drought Loade and reduce Order. Seedy Mill output of water efficiency and demand management Action 14 measures Ordinary Drought Action 4 Order determined by Extra promotion of Defra. water efficiency and Action 8 demand Advertise imposition Action 15 management of temporary use measures Implement Ordinary ban giving two Drought Order. weeks notice

South Staffs Water Final Drought Plan February 2013: Appendix B1

APPENDIX B2

South Staffs Water Final Drought Plan February 2013: Appendix B1 APPENDIX B2 SOUTH STAFFS WATER

ADDENDUM TO RESPONSE TO REPRESENTATIONS ON THE 2012 DRAFT DROUGHT PLAN

November 2012

1 Background

In April 2012 the Company published its statement of response to the consultation on the draft drought plan. It was identified within this document that work to conclude the environmental assessments associated with the Company’s three proposed drought permits was ongoing and in particular that monitoring and mitigation plans could not be determined until this was completed. The statement of response stated that it was hoped this would be concluded in time for inclusion in the final drought plan.

Following a review of the statement of response and the draft drought plan Defra informed the Company that it was unable to recommend to the Secretary of State that the plan should be published as a final plan because material information was missing. Defra instructed the Company to submit a revised draft plan including monitoring and mitigation plans for the drought permits by 9th November.

The Company is happy to report this work is now complete and that a revised plan has been submitted to the Secretary of State.

This addendum to the April 2012 statement of response details the additional changes to the draft drought plan which have been made as a result of the conclusion of the environmental assessments. This addendum supersedes section 3.4 and the first paragraph of section 4 of the April 2012 statement of response. These changes relate to the monitoring and mitigation plans for the Company’s proposed drought permits.

South Staffs Water will publish the Final Drought Plan once it has received direction from the Secretary of State to do so and it will publish the Plan in accordance with any dates specified in the direction.

2 Environmental Monitoring and Assessment

The work that has now been completed includes a high level re-assessment of key assumptions for our drought schemes and identifies the necessary permissions required in their operation and any protected persons or abstractors requiring compensation. It includes a detailed assessment of the general requirements for baseline monitoring, additional survey information to resolve uncertainties, and in-drought and post-drought monitoring.

Appendix B2 Addendum to Statement of Response November 2012 Page 1

Sections 7 and 8 of the draft drought plan published in January 2012 have been replaced with entirely new text and an additional section has been included as section 9. The revised text covers: • the environmental assessments for the three drought permits (section 7), • the proposed mitigation plans and any necessary additional permits and approvals that may be required in order to implement them (section 8). An assessment of impact on downstream abstraction and the need for compensation has also been included in this section. • the proposed monitoring plans and triggers for mitigation measures (section 9).

Sections 9 and 10 from the January 2012 draft plan have become sections 10 and 11 of the revised draft plan. Parts of the text in section 6 describing the drought permits have also been updated.

The content of appendices I and J (Summaries of Blithe / Trent and River Severn Environmental Assessments) of the January 2012 draft drought plan have been incorporated into the new text of section 7. Appendix H (Supply Management Options) has been revised to reflect the monitoring and mitigation plans. New appendices I (General Environmental Monitoring Specifications) and J (Habitats Regulations Assessment of the Severn Estuary) have been inserted into the revised draft plan.

The revised text from Sections 6 (part), 7, 8 and 9 and Appendices I and J are included here.

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6.4.5 Drought Permits Major abstractions for Public Water Supply are controlled by abstraction licences issued by the EA. These constrain the amount of water that may be abstracted under normal conditions and may restrict this further in dry conditions or may place certain mitigating measures on the water company to protect the environment and/or other users. Drought Permits are drought management actions that can allow water companies more flexibility to manage water resources and the effects of drought on public water supply and the environment, for example by changing abstraction licence conditions. The Company has identified three sites where applications for Drought Permits (DP) may be appropriate:

Potential SSW DP Site EA Area

River Severn at Hampton Loade Midlands Region West Area

River Blithe and River Trent Midlands Region Central Area

Hanch Tunnel Midlands Region Central Area

Each site requires an Environmental Assessment Report, which provides details of baseline conditions and assesses the potential impacts on the water environment from implementation of the proposed Drought Permit. The Environmental Assessment reports identify appropriate mitigation measures and set out an Environmental Monitoring Plan (EMP) to determine the effect of the operation of the Drought Permit (DP). Technical detail on the environmental assessment is included in Section 7 of the Drought Plan. Section 8 includes detail of the appropriate mitigation measures to address potentially significant negative impacts which have been identified. Section 9 details the EMP.

6.4.6 Hanch Tunnel Drought Permit

The Hanch Tunnel drought permit is described in detail in Section 7.2. Hanch Tunnel is a man made tunnel which was constructed in the Sherwood Sandstone to the west of Lichfield in the 1850’s. The tunnel connects Hanch Reservoir and Seedy Mill Water Treatment Works (WTW) with Sandfields pumping station, to the south west of Lichfield. Originally, surface water and groundwater from the tunnel gravitated southwards to Sandfields where the water was abstracted and treated before being used to supply Lichfield. The Sandfields pumping station and treatment works are now abandoned and the groundwater table has recovered in this area. The flow of water in the tunnel is now reversed, flowing northwards and discharging at Seedy Mill into the Bourne Brook, a tributary of the River Trent. This has led to the proposal to

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abstract water from the northern end of the tunnel during drought conditions. This raw water will be either pumped to Seedy Mill WTW for treatment and use directly for public water supply; or pumped to Blithfield Reservoir to conserve water levels. In the event that the water is pumped to Blithfield an Environmental Permit may be required to discharge water into the reservoir. During dry years water is abstracted at low rates from the tunnel at its southern end in the centre of Lichfield and is used to maintain lake levels in Stowe Pools SSSI. This use of water has priority over abstraction under the drought permit. A test pumping programme has been undertaken, to investigate the yield, water quality and environmental impact of an abstraction from the northern end of the tunnel. In addition ecological surveys and modelling were carried out to assess the impacts of reduced discharge from the Hanch Tunnel on the river environment in the Bourne Bilson Brook downstream. Modelling of the Company’s water resource system using WRAPSIM indicates that implementation of the Hanch Tunnel drought permit would only provide a small increase in annual average deployable output (<1 Ml/d), given a repeat of the critical drought period (1976). However, as with the Blithe/Trent permit, the annual average deployable output of the permit is constrained by the end of the drought occurring shortly after implementation, in the model run. The peak week deployable output benefit is more clearly demonstrated, as a direct increase of up to 3 Ml/d.

6.4.7 River Blithe and River Trent Drought Permit

The River Blithe and River Trent drought permit is described in detail in Section 7.3. The permit would allow abstraction from the Blithe and Trent at Nethertown, to support reservoir storage at Blithfield, at times when the existing abstraction licences would normally be restricted. The current hands off flow is set at 2,650 Ml/d on the River Trent at North Muskham (near Newark) and effectively means that during drought periods the abstractions cannot be used for large parts of the year. For example, during the 1995/6 drought there were over 100 days in each year when the flow at North Muskham was less than 2,650 Ml/d. Once the Apply For Drought Permit trigger curve has been crossed at Blithfield the Company will consider making an application for a drought permit to allow the Blithe and Trent abstractions to continue regardless of the flow at North Muskham. As with all drought permits or drought orders the Company will need to demonstrate that this is required in response to a period of exceptionally low rainfall, when compared to the available historic data. Consideration will also be given to the application for a drought permit on the Blithe and Trent should storage at Clywedog fall below the Environment Agency’s Apply for Drought Order trigger. However this assessment will take account of storage at Blithfield and it is unlikely that action would be taken by the Company immediately after the Agency’s Apply for Drought Order trigger

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was crossed. Under these circumstances it is likely that the Company would defer a drought permit application until Blithfield storage was closer to the corresponding Blithfield trigger (see Section 4). The permit will allow up to 23 Ml/d to be returned to Blithfield Reservoir and allows an equivalent volume to be safely abstracted for treatment without affecting reservoir levels. Modelling of the Company’s water resource system using WRAPSIM for the critical drought period (1975/76) indicates that operation of the Nethertown pump back and the Trent recirculation under a drought permit would provide an increase in annual average deployable output of 1-2 Ml/d. This gain is small primarily because in the model the key drought (1976) ends shortly after the permit is activated. This is an effect of the modelling scenario, and in reality the timing of the end of any drought is not known, and the benefit of the permit could be significantly higher. The Company has undertaken an environmental assessment to support this drought permit. This environmental assessment is described in more detail in Section 7.3.

6.4.8 Hampton Loade Drought Permit The Hampton Loade drought permit is described in detail in Section 7.4. The Company’s abstraction licence at Hampton Loade is restricted when the River Severn is under River Regulation (when water is being released to support the river), and when the Environment Agency has implemented its own drought order on the River Severn (this requires a 5% reduction in abstraction licences on the river). The Company has included two options for a drought permit at Hampton Loade in this Drought Plan. An application for a drought permit at Hampton Loade would only be considered as a last resort, once all other drought permits had been implemented, and would be in response to genuinely extreme conditions. The need for a drought permit at Hampton Loade could occur if:

• the storage level at Blithfield Reservoir was below the Implement Drought Permit curve, and; • the EA has implemented a Drought Order on the River Severn, one of the consequences being a reduction in abstraction of 5% from Hampton Loade, or • maximum river regulation has been in force and the abstraction licence capacity at Hampton Loade is restricted to 192 Ml/d. A period of at least 6 weeks Maximum Regulation has been identified as a trigger criterion. Under the first option the Company would consider applying for a drought permit which would enable a 5% increase in abstraction licence (i.e. to restore the level of abstraction permitted prior to the Environment Agency drought order). This would restore the output of Hampton Loade to 192 Ml/d. Under the second option the Company would consider applying for a drought permit to increase the level of abstraction of raw river water up to 216 Ml/d.

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This would enable conservation of Chelmarsh Reservoir levels, and allow the Company to utilise the maximum treatment capacity at Hampton Loade during the critical drought period. It is also possible that Option 2 may be required during implementation of an EA Drought Order and this has been used to define the maximum environmental impact case. A drought order may ultimately be required, rather than a drought permit, due to the environmental sensitivity of the river, the likely conflict of interest on behalf of the Environment Agency as a Drought Order applicant, and because of the large number of stakeholders who could be affected. A drought order application would be determined by the Secretary of State or Welsh Ministers. As with the other drought permits in this plan, the modelled annual average deployable output benefit is small reflecting the fact that the 1976 drought scenario ends shortly after the drought permit is initiated in the model. However in reality the timing of the end of any drought is not known and the benefit of the permit could be significantly higher. The potential peak week deployable output benefit of both options is easier to calculate, and ranges between 9.6 Ml/d for option 1 (above) and 24.1 Ml/d for option 2. The Company has undertaken an environmental assessment to support this drought permit. This environmental assessment is described in more detail in Section 7.4. The conflict between a Hampton Loade drought permit and a River Severn drought order imposed by the Environment Agency are discussed in Section 10.2.

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7. Environmental Assessment Of Drought Permits

7.1 The Hanch Tunnel Drought Permit

7.1.1 Background on Hanch Tunnel and Bourne Bilson Brook The Hanch Tunnel is a man-made tunnel that was constructed in the Triassic sandstone to the north and west of Lichfield in the 1850s. When first constructed, the tunnel was connected to Minster and Stowe Pools, which served as storage reservoirs for use during times of water shortage. These connections are now blocked and there is believed to be no remaining connection between the tunnel and the pools. The tunnel was also used to transport groundwater from Hanch Reservoir (now abandoned), and then from Seedy Mill boreholes, to Sandfields, where the water was abstracted and treated before being used to supply Lichfield. The tunnel gained groundwater along its length, and net abstraction was greater than the input from the Seedy Mill boreholes. The Sandfields pumping station and treatment works were shut down in 1997 as part of a scheme to raise groundwater levels in the Lichfield area. Levels have already begun to rise, causing the flow of water in the tunnel to reverse. Water from the tunnel now flows northwards, discharging naturally into the Bourne Bilson Brook at Seedy Mill. Downstream of Seedy Mill, Bourne Bilson Brook passes under the Trent and Mersey Canal (operated by the Canal and Rivers Trust), and adjacent to Kings Bromley Wharf / Marina. It enters the River Trent downstream of the Yoxall gauging station ~2 km upstream of the River Swarbourn confluence and ~5 km upstream of the point where the River Tame enters the River Trent. Under normal circumstances, the Company does not abstract water from Hanch Tunnel for public water supply. Since the closure of Sandfields pumping station and treatment works in 1997, water from the tunnel now flows northwards, discharging naturally into the Bourne Bilson Brook at Seedy Mill. During dry years the Company abstracts at low rates from a shaft near the southern end of the tunnel (near the centre of Lichfield) and discharges the water into the Leamonsley Brook to maintain lake levels in Stowe Pools SSSI/SAC. This use of water has priority over abstraction under the Drought Permit.

7.1.2 Drought Permit Proposal The proposed Drought Permit seeks to abstract 3 Ml/d from Hanch Tunnel within the access shaft at its northern end, and to pump this water to provide additional water after treatment at Seedy Mill WTW for PWS, or indirectly, via Blithfield Reservoir to conserve water levels. A preliminary comparison of the drought permit proposal with Trent flows suggested impacts would be negligible (3 Ml/d vs. Yoxall Q95 410 Ml/d). Consequently only one stretch of waterway has been considered to have reduced flows under the proposed DP:

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• A ~5 km stretch of the Bourne Bilson Brook downstream of Seedy Mill. The Company has not previously applied for an equivalent Drought Permit or Drought Order at this site. Detailed hydrological modelling was carried out using rainfall records for an 84 year period including the most severe drought on record (1976) and the more recent drought in 1995/96. This indicated that hosepipe bans might be required once every 40 years on average. It is not clear how often a Drought Permit might be required, but this would probably occur less frequently.

7.1.3 Analysis of the potential impacts of the Drought Permit The Drought Permit Environmental Assessment Report for Hanch Tunnel is available on written request to the Water Resources Manager. This is largely based on previous hydrologic and environmental surveys and analysis by Schlumberger Water Services for the Company in 2011. It reviews all the available flow, water quality and ecological data for the area in order to define the baseline conditions and, in particular, to analyse the potential response of the water environment to the proposed Drought Permit (DP). This allowed an assessment of the sensitivity of the water environment and associated ecology (macroinvertebrates and fish) to low flow conditions. This information was then combined with the results of the hydrological and water quality assessment to predict the potential impacts of the proposed Drought Permit. As flows in the Bourne –Bilson Brook are not routinely gauged the flow regime under drought permit conditions has been determined by analysis of Company gauging of discharges from the Hanch Tunnel and Seedy Mill WTW in addition to spot flow gauging at five locations during 2011, itself a relatively dry year. Further hydrologic analysis in 2012 used raw gauging data to calculate the response of environmental parameters (stage, wetted perimeter and width, velocity) to the DP. Analysis of water quality data was carried out to evaluate possible impacts on the Bourne-Bilson Brook of flow reductions during a DP; and on Blithfield Reservoir should water be discharged here. The results of the hydrological and water quality assessment have been used to assess the conclusions of the report and new baseline datasets, and also to predict potential impacts for the following receptors:

• Water Quality • River Habitats • Macroinvertebrates • Fish Populations and migration • Amenity, heritage and culture • Abstractions and discharges • Designated sites For all receptors and all reaches in the Bourne-Bilson Brook and the Blithfield Reservoir, only negligible or minor negative impacts were predicted.

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Nevertheless, there are limited data available and uncertainties associated with the assessment and as such an extensive and precautionary monitoring plan with appropriate mitigation measures has been proposed which aims to reduce any unexpected impacts which may be detected during DP implementation.

7.1.4 Monitoring and Mitigation Recommendations Additional monitoring and mitigation measures have been proposed to detect and reduce any unexpected impacts on riverine reaches to a minor negative level of significance. Such measures include temporary reductions in abstraction and habitat restoration (Section 8). Section 9 includes an Environmental Monitoring Plan which focuses on the collection of a robust baseline dataset which can be used to improve future updates of the environmental assessment report. This extends monitoring at five existing riverine sites and one new site as well as investigating water quality and flow in the vicinity of the Hanch Tunnel. Monitoring during Drought Permit implementation will be carried out more frequently and this is targeted at identifying potential impacts for sensitive receptors. Such during- Drought Permit monitoring would also provide the trigger for implementation of appropriate mitigation measures. Post Drought Permit monitoring has been identified to confirm that any impacts would be minor and of a temporary nature.

7.2 The River Blithe and River Trent Drought Permit

7.2.1 Background on River Blithe and River Trent The River Blithe is a tributary of the River Trent, originating to the southeast of Stoke-on-Trent in Staffordshire and joining the Trent near Kings Bromley. It is approximately 30 km in length, draining a largely agricultural catchment. The river is impounded by Blithfield Reservoir, approximately 8 km from its confluence with the River Trent. The River Trent is the second largest river in England by flow volume, providing a source of drinking water to urban areas throughout the Midlands as well as meeting demands for a range of agriculture, industry and navigation purposes. Its middle reaches are dominated by agriculture although the river also flows through several large conurbations including Stoke-on-Trent, Burton-on-Trent, and Nottingham. Sand and gravel quarrying and electricity production are key industries within the catchment. Its major tributaries downstream of the River Blithe are the Rivers Tame, Dove, Derwent, Soar, Devon and Idle. The River Trent meets the River Ouse at Trent Falls, where the two rivers discharge into the Humber Estuary. The Environment Agency operates a regulatory ‘Hands off Flow’ (HoF) of 2650 Ml/d on the River Trent at the North Muskham gauging station (near Newark downstream of the River Devon confluence). Historically the river channel has been modified to aid navigation and for flood risk management.

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Blithfield Seedy Reservoir Mill WTW

PWS mcf = 22.7M/d

River Blithe

mcf = 9.1 Nethertown [or 17] Ml/d R. Blithe abstraction

N. Muskham G.S.

Nethertown Yoxall River Trent R. Trent G.S. abstraction

Figure 10 Schematic of SSW’s Blithfield Reservoir, River Blithe and River Trent operations The Company has three abstraction licences affecting the Rivers Blithe and Trent (Figure 10): 1. Blithfield Reservoir (3/28/6/41/S) – involves abstracting water from Blithfield Reservoir to supply Seedy Mill Water Treatment Works (for public water supply). The maximum allowable abstraction in any one day is 132 Ml/d within an annual maximum of 29,200 Ml (annual average 80 Ml/d). Abstraction is only permitted when the outflow from Blithfield Reservoir is at least 22.7 Ml/d. 2. Blithe (Nethertown 3/28/6/84/S up to the year 2018) – involves abstracting water from the River Blithe at Nethertown for transfer back to Blithfield Reservoir, to supplement public water supply abstractions. Under normal conditions, the maximum allowable abstraction is 50 Ml/d, within an annual maximum of 19,335 Ml (annual average 53 Ml/d). Abstraction can increase to 90 Ml/d in certain emergency situations. Abstraction is only permitted when flow in the River Blithe immediately below the abstraction point is at least 9 Ml/d (or 17 Ml/d between 15th Feb and 15th Mar each year to facilitate fish spawning). SSW must stop abstracting when the daily average flow at North Muskham (located downstream on the River Trent) falls below 2,650 Ml/d. 3. Trent (Nethertown 3/28/7/99/S) – involves abstracting water from the River Trent immediately upstream of the Blithe confluence for transfer to the Blithe to augment river flows downstream of the Blithe abstraction point. The maximum allowable abstraction is 17 Ml/d within an annual maximum of 4,505 Ml (annual average 12.3 Ml/d).

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Abstraction must stop when the daily average flow at North Muskham (located downstream on the River Trent) falls below 2,650 Ml/d.

7.2.2 Drought Permit Proposal In order to assist with recharge of Blithfield Reservoir during times of drought, the proposed Drought Permit seeks to: Maintain abstraction from the Nethertown (River Blithe) and Nethertown (River Trent) intakes under circumstances where both abstractions would ordinarily cease i.e. when flows in the River Trent are below 2,650 Ml/d at North Muskham. This equates to maintaining an abstraction of 23 Ml/d from the Nethertown (River Blithe) intake during periods when otherwise (without a Drought Permit) no abstraction would be permitted. This would allow the Company to maintain augmentation of Blithfield Reservoir (using the Nethertown (River Blithe) abstraction) and continue to transfer water to the lower reaches of the River Blithe (using the Nethertown (River Trent) abstraction). The Company’s environmental assessment in 2007 looked at flow and river level impacts on eight river reaches between Blithfield Reservoir and the River Ouse. It found negligible to very low impacts for those reaches downstream of the River Tame confluence to the River Ouse. Consequently the reaches of river considered likely to have reduced flows under the proposed DP are limited as follows:

• A ~300m stretch of the River Blithe downstream of the Nethertown (Blithe) abstraction to the Trent confluence • A short stretch of the River Trent downstream of the Nethertown (Trent) abstraction to the Blithe confluence • A ~9km stretch of the River Trent downstream of the River Blithe confluence to the River Tame confluence at Alrewas. The Company has not previously applied for an equivalent Drought Permit or Drought Order at this site, although the Blithe at Nethertown abstraction was varied in 1963 under the terms of a Drought Order, and compensation flows from Blithfield Reservoir were reduced in 1976 and 1984: South Staffordshire Water was granted a Drought Order for the Nethertown Intake on the River Blithe on 8 May 1963, allowing abstraction from Nethertown over the summer months. Note this is currently allowed under the terms of the existing licence (subject to restrictions on residual flow in the Blithe downstream, and the flow at North Muskham on the River Trent). South Staffordshire Water was granted a Drought Order for the River Blithe on 1 September 1976, allowing the compensation release from Blithfield Reservoir to be reduced from 22.73 Ml/d to 9.09 Ml/d. South Staffordshire Water was granted a Drought Order for the River Blithe on 30 August 1984, allowing the compensation release from Blithfield Reservoir to be reduced from 22.73 to 13.64 Ml/d.

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Detailed hydrological modelling was carried out using rainfall records for an 84 year period including the most severe drought on record (1976) and the more recent drought in 1995/96. This indicated that hosepipe bans might be required once every 40 years on average. It is not clear how often a Drought Permit might be required, but this would probably occur less frequently.

7.2.3 Analysis of the potential impacts of the Drought Permit The Drought Permit Environmental Assessment Report for the Blithe/Trent is available on written request to the Water Resources Manager. The previous Drought Permit Environmental Assessment Report for Blithe and Trent by Enviros in 2007 reviewed all the available flow, water quality and ecological data for the area in order to define the baseline conditions and, in particular, to analyse the response of the water environment to previous droughts. An updated report in 2012 reviewed data collected since the Enviros report, highlighted any changes in the baseline environment and considered how this could affect the impact assessment and conclusions of the previous report. Potential effects on Water Framework Directive classification status were also considered. This allowed a detailed model of the sensitivity of the water environment and associated ecology (macroinvertebrates and fish) to low flow conditions to be produced. This model was then combined with the results of the hydrological and water quality modelling to predict the potential impacts of the proposed Drought Permit. Potential impacts of the proposed DP have only been considered for the reaches immediately downstream of the Nethertown (Blithe) intake on the River Blithe and for a ~9km reach of the River Trent between the Nethertown (Trent) intake and the River Tame confluence at Alrewas. Beyond this, contributions to river flow from major tributaries such as the Swarbourn and the Tame considerably reduce the effect of the DP on river hydrology. Hydrologic analysis made use of measured flows in previous critical years (1976 and 1996) and river cross section data from the River Blithe and Trent to estimate changes in river stage during a DP. These changes in stage were found to be small, consequently changes in environmentally sensitive parameters such as wetted perimeter and width can be considered negligible. The results of the hydrological and water quality assessment have been used to assess the conclusions of the report and new baseline datasets, and also to predict potential impacts for the following receptors:

• Water Quality • River Habitats • Macroinvertebrates • Fish Populations and migration • Amenity, heritage and culture • Abstractions and discharges • Designated sites For all receptors and all reaches, only negligible or minor negative impacts were predicted. However, barriers to fish passage have been recognised

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associated with operation of the Nethertown weir. A monitoring plan and appropriate mitigation measures have been proposed which aim to reduce any unexpected impacts which may be detected during DP implementation.

7.2.4 Monitoring and Mitigation Recommendations Additional monitoring and mitigation measures have been proposed to detect and reduce any unexpected impacts on riverine reaches to a minor negative level of significance. Such measures include temporary reductions in abstraction and habitat restoration (Section 8). Section 9 includes an Environmental Monitoring Plan which focuses on the collection of a robust baseline dataset which can be used to improve future updates of the environmental assessment report. This extends monitoring at four existing riverine sites and one new site as well as investigating water quality and flow in the vicinity of the river intake. Monitoring during Drought Permit implementation will be carried out more frequently and this is targeted at identifying potential impacts for sensitive receptors. Such during- Drought Permit monitoring would also provide the trigger for implementation of appropriate mitigation measures. Post Drought Permit monitoring has been proposed to confirm that any impacts would be minor and of a temporary nature.

7.3 The Hampton Loade Drought Permit (192 Ml/d and 216 Ml/d Options)

7.3.1 Background on River Severn at Hampton Loade The River Severn originates in mid Wales and is the longest river in Great Britain, extending over 350 km before discharging into the Bristol Channel. It provides a source of drinking water to approximately six million people throughout the Midlands as well as meeting demands for a range of agriculture, industry and navigation purposes. The catchment is largely rural, although a number of urban areas (including the towns of Shrewsbury, Bewdley, Worcester and Gloucester) lie along its banks. The river is recognised for its environmental importance, providing habitats and a migratory corridor for many nationally and internationally important species. The River Severn Estuary is a designated wildlife site under the Habitats and Wild Birds Directive. The River Severn is highly regulated with flows supported by releases from Clywedog and Vyrnwy reservoirs and from the Shropshire Groundwater Scheme (SGS) (Figure 11). The regulation system is designed to meet demands for public water supply, irrigation, industry and navigation as well as maintaining flow levels sufficient to support biodiversity and conservation interests. The Clywedog Reservoir Act (1963) requires that river flow is maintained at 850 Ml/d (over a five day average or 650 Ml/d on any one day) at Bewdley, in order to provide adequate freshwater flow in the estuary and to meet other demands. The EA is responsible for managing this requirement. Clywedog

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Reservoir provides the primary resource for regulation (release volumes typically 18.2 Ml/d to 500 Ml/d), SGS can provide up to 140 Ml/d net and Lake Vyrnwy water bank provides sustainable releases up to 70 Ml/d. There is also an abstraction to support the Gloucester and Sharpness Canal which can affect the distribution of water in the lower reaches of the River Severn around the tidal limit. Water is drawn from the river in Gloucester to feed the canal at times of low flow (typically in summer) with a peak abstraction of up to 350 Ml/d. This water, drawn from the River Severn, is then supplemented by inflows to the canal from tributaries of the Severn (i.e. River Frome, River Cam, Daniels Brook, Sud Brook) that are intercepted. Of this combined flow up to 250 Ml/d can be abstracted by Bristol Water at Purton, but is returned to the estuary, minus any losses due to leakage or consumptive use, via the Bristol Avon. The remainder of flow within the canal will, for the most part, find its way back to the estuary via lockage at Sharpness, lockage at Gloucester, and leakage/seepage from the canal fabric. The flow from the Gloucester and Sharpness Canal back into the Severn Estuary is affected by the abstraction at Purton (up to 250 Ml/d). There is however a compensation requirement of 12.2 Ml/d which must be discharged before any abstraction from the canal at this location can occur. In most winters the inflows into the canal from the small tributary watercourses satisfies the water demand of both the canal and the Purton abstraction. It should however be noted that as the flow entering the canal from the tributary watercourses decreases (with particular reference to the River Frome) there is an increased demand to augment water resources in the Canal by means of abstraction from the River Severn at Gloucester. A Section 20 agreement was introduced in the late 1990s between British Waterways (now Canal and River Trust) and the EA as follows: “No pumping for 3 hours after high water springs in March, April and May when flows are less than 2400 Ml/d at Deerhurst and when tides > 8.5 m at Sharpness.” This measure helps to increase the flow in the river during spring tide conditions.

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Figure 11 Schematic of the River Severn catchment The Company’s abstraction licences (18/54/02/584 &163) for Hampton Loade are complicated, and the amount that can be abstracted is dependant upon the flow in the River Severn at Bewdley, the time of year, the degree of river regulation and, in extreme droughts, by the implementation of an EA Drought Order. In addition, the licence at Hampton Loade is further complicated because Severn Trent Water Limited (STWL) is entitled to part of the licence (18/54/02/163) and furthermore the licence has some joint licence conditions with STWL’s licence downstream on the River Severn at Trimpley. There is no individual daily maximum specified on the licence. The Hampton Loade abstraction is effectively restricted to 192 Ml/d when the river is being regulated by the EA (212 Ml/d total abstraction with 20 Ml/d transferred downstream to be abstracted at Trimpley), and this reduces by a further 5% (182.4 Ml/d) if an EA River Severn Drought Order is put in place. The total abstraction at Hampton Loade and Trimpley must not exceed 400 Ml/d when the river is not under regulation, 272 Ml/d during periods of maximum river regulation or 290 Ml/d as an annual average.

7.3.2 Drought Permit Proposal The proposed Drought Permit seeks to: Option 1 - maintain abstraction at 192 Ml/d under circumstances where the abstraction would ordinarily be reduced by 5% to 182.4 Ml/d (under the terms of an EA River Severn Drought Order), i.e. the proposed Drought Permit would allow the Company to abstract an additional 9.6 Ml/d. Option 2 - increase abstraction to the maximum operational capacity of Hampton Loade WTW of 216 Ml/d, if required. This equates to a net

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abstraction of 207.5 Ml/d (i.e. an increase in abstraction of 15.5 Ml/d compared to Option 1 or an increase in abstraction of 25.1 Ml/d compared to the baseline situation under the terms of an EA River Severn Drought Order. Both options would affect flow in the River Severn downstream of Hampton Loade. The agreement to allow STWL to abstract 20 Ml/d from the joint licence (No.163) at Trimpley WTW is assumed to apply both under normal circumstances and under a Drought Permit. The Company has not previously applied for an equivalent Drought Permit or Drought Order at this site, although compensation flows from Clywedog Reservoir were reduced in 1976. A hosepipe ban was last implemented by the Company in 1976. Detailed hydrological modeling was carried out using rainfall records for a 84 year period including the most severe drought on record (1976) and the more recent drought in 1995/96. This indicated that hosepipe bans might be required once every 40 years on average. It is not clear how often a Drought Permit might be required, but this would probably occur less frequently. This is consistent with the Company not having implemented a hosepipe ban since 1976, and never having implemented a DP at Hampton Loade.

7.3.3 Analysis of the potential impacts of the Drought Permit The Drought Permit Environmental Assessment Report for Hampton Loade is available on written request to the Water Resources Manager. The previous Drought Permit Environmental Assessment Report for Hampton Loade by Enviros in 2007 reviewed all the available flow, water quality and ecological data for the area in order to define the baseline conditions and, in particular, to analyse the response of the water environment to previous droughts. The updated report in 2012 reviewed data collected since the previous report was written, highlighted any changes in the baseline environment and considered how this could affect the impact assessment and conclusions of the previous report. Potential effects on Water Framework Directive classification status were also considered. This allowed a detailed model of the sensitivity of the water environment and associated ecology (macroinvertebrates and fish) to low flow conditions to be produced. This model was then combined with the results of the hydrological and water quality modeling to predict the potential impacts of the proposed Drought Permit (DP). Hydrologic impacts of the DP on river reaches were considered both at Bewdley near Hampton Loade, representative of receptors in the upstream part of the River Severn, and also at Deerhurst on the Lower Severn. Extremely low flows (below 1410 Ml/d) at Deerhurst can have an adverse impact on the Canal and River Trust abstraction at Gloucester Docks if they coincide with high spring tides. Use was made of simulated flows from the Severn Trent Water (STWL) regional Aquator model rather than historic measured flows as water resources management and river regulation has changed significantly since the critical 1976 drought. Baseline flows were

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adjusted to evaluate impacts of both the Hampton DP “in isolation” and “in combination” with the STWL Trimpley DP and the River Severn Drought Order. The results of the hydrological and water quality assessment have been used to assess the conclusions of the report and new baseline datasets, and also to predict potential impacts for the following receptors:

• Water Quality • River Habitats • Macroinvertebrates • Fish Populations and migration • Amenity, heritage and culture • Abstractions and discharges • Designated sites For most receptors, only negligible or minor negative impacts were predicted, particularly for the riverine reaches. The continual improvement in water quality in the River Severn over the last two decades has reduced the sensitivity of certain receptors to low flow events and in general, monitoring data show that river ecology recovers fairly rapidly after droughts. Nevertheless, it is considered that in-combination effects on the Severn Estuary, particularly associated with the Gloucester and Sharpness canal abstraction cannot be ruled out (see Section 7.4.1).

7.3.4 Monitoring and Mitigation Recommendations Additional monitoring and mitigation measures have been proposed to detect and reduce any unexpected impacts on riverine reaches to a minor negative level of significance. Such measures include temporary reductions in abstraction and habitat restoration (Section 8). Given that there are a large number of competing interests for water resources within the Severn catchment, it is not considered that the responsibility for assessment, monitoring or mitigation of such impacts lies solely with any one of the interested parties. Rather, it is proposed that the River Severn Drought Management Group be reformed with an objective of determining drought operating agreements with the Canal and River Trust (formerly British Waterways) which are also acceptable to Natural England, Countryside Council for Wales and other water companies with abstractions and potential DP sites on the River Severn. This should aim to facilitate appropriate management of available water in the Severn catchment during drought conditions. The Company has written to Severn Trent Water and the Environment Agency and has obtained agreement in principle with this approach. Section 9 includes an Environmental Monitoring Plan which focuses on the collection of a robust baseline dataset which can be used to improve future updates of this environmental assessment report. This extends existing monitoring at seven riverine sites as well as the river intake. Monitoring during Drought Permit implementation will be carried out more frequently and this is targeted at identifying potential impacts for sensitive receptors. Such

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during- Drought Permit monitoring would also provide the trigger for implementation of appropriate mitigation measures. Post Drought Permit monitoring has been identified to confirm that any impacts would be minor and of a temporary nature.

7.4 Habitats Regulations Assessment

To meet the requirements of the Conservation of Habitats and Species Regulations 2010 the Company has carried out a Habitats Regulations Assessment (HRA) on the effects of the drought plan on European sites. This assesses the likely or potential effects of our drought plan on European Sites, including Special Areas for Conservation (SACs), candidate SACs (cSACs), Special Protection Areas (SPAs) and Ramsars (Ramsar sites are wetlands of international importance designated under the Ramsar Convention 1971 which provides for the conservation and good use of wetlands). This HRA considers:

• The impact of existing abstraction during a drought at Chilcote PS on the River Mease SAC • The impact of the Hanch Tunnel and River Blithe and River Trent Drought Permit on the Humber Estuary SAC SPA and RAMSAR site • The impact of the Hampton Loade Drought Permits on the Severn Estuary SAC, SPA and RAMSAR site; and on neighbouring designated sites No other links between existing or proposed abstraction by the Company and European sites have been identified. There are no Candidate SACs (cSACs) within or in areas potentially affected by abstraction in the West Midlands. The impact of groundwater abstraction at Chilcote PS was evaluated as part of the AMP4 Low Flow Investigation into the River Mease carried out by consultants ESI jointly appointed by the Company and Severn Trent Water. The existing abstraction at annual average rates was found to have no impact on the River Mease SAC and use of the peak licence was predicted also to have no impact. The impact of the River Blithe and River Trent Drought Permit on the Humber Estuary has been evaluated as part of the environmental assessment of the proposed drought permits. The Humber Estuary European sites were assessed within Reach 9 (tidal Trent). The environmental assessment considers four scenarios which variously assume the River Blithe and Trent Drought Permit is run in isolation or in combination with Severn Trent Water Drought Permits on the River Dove and/or River Derwent. The effects of the scenarios were preliminarily assessed to be of negligible to low impact in Reach 9 and as such were not considered in further detail. The impact of the Hanch Tunnel Drought Permit on Reach 9 of the Trent has not been separately evaluated. However due to the significantly lower

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abstraction rates (3 Ml/d vs. 23 Ml/d), the conclusion of negligible to low impact determined for the Blithe/Trent DP is assumed also to apply here. This HRA concludes that there is no significant impact on European sites from existing abstraction at Chilcote or from the proposed Hanch Tunnel or River Blithe and River Trent Drought Permit. The detail of the HRA for the Hampton Loade DPs is described in section 7.4.1 and in Appendix J.

7.4.1 Hampton Loade Drought Permits

The impact of the Hampton Loade Drought Permits was evaluated as part of the environmental assessment carried out by the Company’s appointed consultants Enviros in 2007 in preparation of the previous drought plan. Their conclusions were validated as part of a review in 2012 (Section 7.3). The 2012 study looked at predicted flows at the upstream Deerhurst gauging station in Reach 6 where it was identified that flows to the Estuary below 1410 Ml/d could have an adverse impact on the Canal and River Trust abstraction at Gloucester Docks. It also compared predicted impacts on the Severn Estuary with those from draft EA studies in 2012 into the Severn Drought Order. It was concluded by Enviros that the small predicted reductions in water level associated with implementation of either of the Hampton Loade DP options would have a “negligible’’ effect upon riparian ecology including riparian wetland habitats. The EA assessed whether there were likely to be “significant effects” of the River Severn Drought Order (alone and in combination with other plans and projects, including the Hampton Loade DP) on European designated sites in hydraulic continuity with the River Severn. The hydrological and habitat analyses carried out for the Company in 2012 predict changes of a similar order of magnitude to those reported by Enviros in 2007 and on this basis it is concluded that the small predicted reductions in riverine water level associated with implementation of the Hampton Loade DP would have a “negligible’’ effect upon the updated list of designated sites, riparian ecology and riparian wetland habitats downstream of Hampton Loade (including Walmore Common SAC and Ramsar). This conclusion also applies to the River Teme, River Clun and Downton Gorge, which are upstream of the Hampton Loade abstraction, but are in hydraulic continuity with the River Severn. On the basis of the hydrological and habitat analyses carried out for the Company in 2012, the predicted changes in water level on the River Severn near the Teme confluence are not considered likely to restrict connectivity between the Severn and the Teme catchment (including the River Clun and Downton Gorge) as a consequence of either Hampton Loade DP option (alone and in-combination with other plans / projects). The Rivers Wye, Usk and Tywi flow into the downstream reaches of the Severn Estuary for which no, negligible or very low magnitude impacts on

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water quantity and quality were predicted by both Enviros and the EA as a consequence of both the Hampton Loade DP options and Severn Drought Order proposals (either alone or in-combination with other plans and proposals). In addition, negligible effects on the interest features of the Wye, Usk and Tywi SACs were predicted by the EA in 2012 in their draft Habitats Regulations Assessment (HRA), both alone and in combination with Hampton Loade and other plans/projects. As such, these rivers and their interest features are not considered to be at risk as a consequence of implementation of either Hampton Loade DP option. The possible exception to these assessments of negligible/very low impacts is the Severn Estuary SAC and Ramsar site. Impacts of the Hampton Loade 192Ml/d DP on the Severn Estuary SAC have been assessed in detail as part of the EA’s in-combination Habitat Regulation Assessment process for the Severn Drought Order. This assessment concluded that a risk of Likely Significant Effect on the Severn Estuary SAC and Ramsar site could not be ruled out. This risk of likely significant effect arose primarily as a consequence of the potential for impacts associated with operation of the Gloucester and Sharpness Canal abstraction. Even so, the predicted impacts were reported by the EA as being restricted to the Lower Tidal Severn (aka upper estuary), and the reach of the estuary above the SAC boundary. The following paragraphs are based on a summary of the EA draft HRA in 2012. The Gloucester and Sharpness canal abstraction was not individually assessed in Stage 3 of the Review of Consents (RoC) in 2009, even though the potential for it to cause adverse effects on the Severn Estuary was recognised. It was omitted from the RoC Appropriate Assessment because the abstraction is not a licensed permission; at present water for navigation is exempt from requiring a licence. Any environmental impacts of the abstraction are managed under a 1998 agreement between the Canal and Rivers Trust and the Environment Agency. Since the RoC in 2009, further modelling has been carried out and additional information from historic drought events has become available, indicating the likely effects of this abstraction on the upper reaches of the estuary. During dry years, over 300 Ml/d may be abstracted between July and September, with potential for abstraction up to 691Ml/d (maximum pump capacity). If a period of high abstraction coincides with a period of low flows, there is historical evidence that the abstraction is capable of significantly reducing flows into the estuary, occasionally almost to zero. This is likely to have an adverse effect alone on the Lower Tidal Severn (aka upper estuary) which means there is also potential for adverse effects on the estuary and migratory fish in-combination with other plans and projects (such as the Severn Drought Order and/or Hampton Loade DP), depending on the timing of the River Severn Drought Order and tidal movements. Therefore, there is also potential for the abstraction to have an adverse effect on the Severn Estuary SAC and some of its interest features either alone or in-combination. The EA determined that it was not possible to conclude “no adverse effect” as a consequence of potential in-combination effects of the Severn Drought Order and other permits/projects on the Severn Estuary SAC, particularly due

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to the potential significance of the Gloucester and Sharpness canal abstraction. It noted that where adverse effects are identified, which cannot be avoided or mitigated, alternative options must be considered, or there must be imperative reasons of overriding public interest for carrying out the activity. The Gloucester and Sharpness canal abstraction is not controlled by the EA and nor is it licensed. Therefore it will be advisable to determine drought operating agreements with the Canal and River Trust (formerly British Waterways) which are also acceptable to Natural England, Countryside Council for Wales and other water companies with abstractions and potential DP sites on the River Severn, to enable appropriate management of available water in the Severn catchment during drought conditions. The EA concluded that there is a requirement to find a solution, and that this should be identified well in advance of a Severn Drought Order being implemented. It is also important to note that the previous Hampton Loade environmental report by Enviros concluded medium (significant) potential effects upon the upper estuary for a Hampton Loade DP permitting abstraction up to 245 Ml/d DP. This DP proposal has since been removed from the Company Drought Plan and replaced by a proposal for gross abstraction up to 216 Ml/d at Hampton Loade. Impacts of the revised Option 2 (216 Ml/d) of the Hampton Loade DP on the Severn Estuary SAC were not assessed by the EA in 2012 or in the previous Enviros report. Therefore, in agreement with the EA, a HRA screening exercise has been undertaken for this (see Appendix J). The assessment was based upon the EA’s Drought Order HRA, which considered the previous DP (Option 2 maximum abstraction = 245 Ml/d) in combination. Based on a minor reduction in maximum abstraction of 24 Ml/d under the current proposal, it is expected that any effects of the current DP proposal would be equivalent to or less than EA’s Drought Order HRA. Potential effects of the DP could include reduced dissolved oxygen concentrations within the estuary as a result of reduced flows, which may result in fish kills or barriers to fish migration (salmon, twaite shad and lamprey) through the estuary into the River Severn. However, the Drought Order HRA concluded no adverse effects upon the estuary as a result of the current Severn regulation (including the previous DP proposal), with the likely exception of the Gloucester and Sharpness canal. Following the screening assessment, no potential impacts from the DP proposals “alone’’ are considered likely upon the Severn Estuary SAC and Ramsar. This is supported by the EA’s previous Drought Order HRA, which concludes no significant effect from “do nothing’’ or “Drought Order’’ proposals “alone’’. However, it is not possible to conclude no effects upon the SAC as a result of the “in-combination’’ effects of the Gloucester and Sharpness Canal. There is uncertainty relating to the significance of this effect, largely due to the unregulated, and therefore variable, abstraction rate. For the purposes of the drought plan, it is concluded that neither of the proposed Hampton Loade DPs alone are likely to cause adverse effects on the Severn SAC or its interest features. Nevertheless, there is potential for in- combination effects, particularly associated with the Gloucester and Sharpness canal abstraction. Given that there are a large number of

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competing interests for water resources within the Severn catchment, it is not considered that the responsibility for assessment, monitoring or mitigation of such impacts lies solely with any one of the interested parties. Rather, it is proposed that the River Severn Drought Management Group be reformed with an objective of determining drought operating agreements with the Canal and River Trust (formerly British Waterways) which are also acceptable to Natural England, Countryside Council for Wales and other water companies with abstractions and potential DP sites on the River Severn. This should aim to facilitate appropriate management of available water in the Severn catchment during drought conditions. The Company has written to the Environment Agency and Severn Trent Water and gained agreement in principle for this proposal.

7.5 Strategic Environmental Assessment (SEA)

The Strategic Environmental Assessment Directive (2001/42/EC) requires a formal environmental assessment of certain categories of plans and programmes which are likely to have significant effects on the environment. Government has transposed the Directive into appropriate Regulations. In England and Wales these are:

• The Environmental Assessment of Plans and Programmes Regulations 2004; and • The Environmental Assessment of Plans and Programmes (Wales) Regulations 2004. The plans and programmes that are subject to the SEA Directive are defined by the Directive and are based on multiple factors. Water companies, as responsible authorities, must determine if their drought plan falls within the scope of the SEA Directive. Responsible authorities that prepare and/or adopt a plan or programme that is subject to the SEA Directive need to prepare a report on the likely significant environmental effects of implementing the plan or programme, and of reasonable alternatives. In common with many water companies South Staffs Water has taken the view that the SEA Directive does not apply to its drought plan as it does not require future development consent and environmental impacts are of temporary short-term nature.

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8. Drought Permit Mitigation Plan

8.1 Introduction Mitigation measures may be proposed in order to avoid, reduce or remedy any potential impacts resulting from the implementation of a drought permit. These measures may be identified in advance and incorporated into the design of the project or may be implemented during the operational phase of the project i.e. during the implementation of a DP, to address unexpected impacts. Although only negligible or minor negative impacts have generally been identified for the riverine reaches in the Environmental Assessment reports for the Company’s three drought permits, appropriate mitigation measures have been proposed which aim to reduce unexpected impacts which may be detected during DP implementation. SSW will discuss any necessary mitigation measures with the EA during the DP application process (i.e. during preparation for DP application), to determine the most appropriate monitoring and mitigation regime and would aim to have measures in place in advance of DP implementation. It should be noted that situations may arise where not all of the mitigation measures described are required or appropriate during every DP. Should this be the case, those measures deemed not necessary or not appropriate will be discussed and agreed with the EA during the DP application process. Where mitigation measures are proposed they will be appropriate for the level of impact predicted and the importance of the receptor. Measures proposed would be designed to minimise the impacts occurring as a result of maintained or increased abstraction during a drought and would therefore only be implemented for the duration of the DPs. Mitigation measures would be implemented to reduce the DP impacts and not the impacts of the drought itself.

8.2 Mitigation Plans for the Hanch Tunnel Drought Permit

8.2.1 Measures to Mitigate Environmental Impacts Identified by Monitoring During Implementation of a Hanch Tunnel DP A number of additional mitigation measures could be implemented should monitoring during a Hanch Tunnel Drought Permit indicate that significant impacts are occurring. Whether such measures are required will depend to a large extent on the time of year at which the DP is implemented, as well as other factors such as prevailing weather conditions. As such it is proposed that the Company discusses potential mitigation measures with the EA fisheries officers on a case-by-case basis during the application process (i.e. during preparation for a Hanch Tunnel DP application), to agree the most appropriate monitoring and mitigation regime. The Company and the EA have discussed the range of potential mitigation options including (depending on the time of year and species and lifestages affected):

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• Provision to reduce or cease abstraction if maintained or increased abstraction is considered to be having serious detrimental environmental consequences on downstream watercourses or licensed abstractors (e.g. to maintain a certain water depth across areas of sensitive riffle habitat); • Funding of appropriate, reasonable measures (e.g. habitat restoration) in the event of ecological damage occurring on watercourses affected by increased abstraction; and • Provision of appropriate assistance and / or funding of reasonable additional measures to protect habitats and sites or species of special ecological interest affected by the DP. It should also be noted that under normal circumstances, SSW does not abstract water from Hanch Tunnel for public water supply. Since the closure of Sandfields pumping station and treatment works in 1997, water from the tunnel now flows northwards, discharging naturally into the Bourne Brook at Seedy Mill. During dry years however water is abstracted at low rates from the tunnel at its southern end in the centre of Lichfield and is used to maintain lake levels in Stowe Pools SSSI/SAC. This use of water has priority over abstraction under the drought permit and as a mitigation measure SSW would intend to top up Stowe Pool from Shaft 20, if required, prior to abstraction from Shaft 1 under a DP. It may not be necessary to implement all these mitigation measures in order to reduce the observed impacts. Implementation of the mitigation measures will take place should monitoring during a DP indicate that significant impacts are being experienced. Where these measures involve work within or adjacent to the river channel, additional approvals will be required (e.g. a Land Drainage Consent) and there will be a need to work closely with other stakeholders (landowners, local authorities and the EA). Monitoring has been identified in order to capture any changes before, during and after the DP implementation (see Section 9). It is proposed that the triggers for implementation of mitigation measures and details of the drought and post-drought monitoring should be discussed with the EA during the DP application process.

8.2.2 Measures to Mitigate Impacts by a Hanch Tunnel DP on Downstream Abstraction The impacts on downstream abstractions are predicted to be medium due to the likely low flows if all abstractors were to operate simultaneously. Measures to reduce abstraction under the DP in order to mitigate the exposure at low flows of sensitive riffle habitats will provide additional and sufficient mitigation and protection to surface water abstractors. No further provisions for compensation are required. Measures to reduce abstraction will not require further approval.

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8.3 Mitigation Plans for the Blithe/Trent Drought Permit

8.3.1 Measures to Mitigate Environmental Impacts Identified by Monitoring during Implementation of a Blithe/Trent Drought Permit It is recognised that as a result of the existing Nethertown weir design and abstraction configuration, the existing fish pass will not function during a DP scenario. The HMWB Stage 3 Options Appraisal for the Blithfield Reservoir/River Blithe system has recommended further investigation of the effectiveness of the fish pass at Nethertown under normal operation. This is likely to be part of the National Environment Programme for AMP6 at which time the requirement for further works will be determined. In order to mitigate the effects of this barrier during DP operation, pro-active measures to ensure upstream and downstream fish passage during low flows would be the most environmentally beneficial option. However, in the absence of major engineering works at the weir and fish pass being planned in the short term, it is recognised that other measures may need to be initiated as an emergency response. Whether such measures are required will depend to a large extent on the time of year at which a Blithe/Trent DP is implemented, as well as other factors such as prevailing weather conditions, presence of fish congregating in the affected reaches, and the operating regime of the Nethertown (River Blithe) abstraction. As such, it is proposed that the Company discuss potential mitigation measures on a case-by-case basis with EA fisheries officers during the application process (i.e. during preparation for Blithe/Trent DP application), to agree the most appropriate monitoring and mitigation regime. The Company and the EA have discussed the range of potential mitigation options including (depending on the time of year and species and lifestages affected):

• fish trapping (either via electric fishing or seine netting) and transport; • screening of the Nethertown (River Blithe) abstraction; and / or • temporary cessations of abstraction (to provide short periods of flow through the existing fish pass). In order to detect situations where such mitigation measures may be required, monitoring of fish populations around the Nethertown abstraction will be necessary during DP implementation. Such monitoring has been included in the Environmental Monitoring Plan (Section 9). It should also be recognised that the mitigation measures described above may not avoid all potential impacts, but they are considered to be the best available options. A number of additional mitigation measures could be implemented should monitoring during a DP indicate that significant impacts are occurring:

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• Provision to reduce abstraction if maintained or increased abstraction is considered to be having serious detrimental environmental consequences on downstream watercourses; • Funding of appropriate reasonable measures (e.g. habitat restoration) in the event of ecological damage occurring on watercourses affected by increased abstraction; and • Provision of appropriate assistance and / or funding of reasonable additional measures to protect habitats and sites or species of special ecological interest affected by the DP. It may not be necessary to implement all these mitigation measures in order to reduce the observed impacts. Implementation of the mitigation measures will take place should monitoring during a DP indicate that significant impacts are being experienced. Where these measures involve work within or adjacent to the river channel, additional approvals will be required (e.g. a Land Drainage Consent) and there will be a need to work closely with other stakeholders (landowners, local authorities and the EA). Where these measures involve trapping and/or relocation of fish, additional approvals will be required (e.g. electric fishing or netting consent) and there will be a need to work closely with the EA. Monitoring has been identified in order to capture any changes before, during and after the DP implementation (see Section 9). It is proposed that the triggers for implementation of mitigation measures and details of the drought and post-drought monitoring should be discussed with the EA during the DP application process.

8.3.2 Measures to Mitigate Impacts by a Blithe/Trent DP on Down-stream Abstraction The impacts on the majority of downstream abstractions are predicted to be negligible. However the certainty of this assessment is at times low (Reach 1b between the Nethertown weir and the Trent Confluence) or medium (Reach 2 between the Nethertown Trent abstraction and the unified channel upstream of the Yoxall gauge). Abstraction from Reach 1b is anticipated to be adequately mitigated by recirculated Trent water which will maintain flows and levels in this reach and there is the facility to increase the recirculation of River Trent water from 9 Ml/d to 17 Ml/d. Flows are anticipated to be adequate in Reach 2 however close liaison will be required with abstractors so provision can be made to lower intakes as a precaution before DP implementation. No further provisions for compensation are required. Measures to reduce abstraction or increase recirculation of Trent water will not require further approval.

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8.4 Mitigation Plans for the Hampton Loade Drought Permit

8.4.1 Measures to Mitigate Environmental Impacts Identified by Monitoring During Implementation of a Hampton Loade DP A number of additional mitigation measures could be implemented should monitoring during a Hampton Loade DP indicate that significant impacts are occurring:

• Provision to reduce abstraction if maintained or increased abstraction is considered to be having serious detrimental environmental consequences on downstream watercourses; • Funding of appropriate reasonable measures (e.g. habitat restoration) in the event of ecological damage occurring on watercourses affected by increased abstraction; and • Provision of appropriate assistance and / or funding of reasonable additional measures to protect habitats and sites or species of special ecological interest affected by the DP. It may not be necessary to implement all these mitigation measures in order to reduce the observed impacts. Implementation of the mitigation measures will take place should monitoring during a DP indicate that significant impacts are being experienced. Where these measures involve work within or adjacent to the river channel, additional approvals will be required (e.g. a Land Drainage Consent) and there will be a need to work closely with other stakeholders (landowners, local authorities and the EA). Measures to reduce abstraction will not require further approval. Monitoring has been identified in order to capture any changes before, during and after the DP implementation (see Section 9). It is proposed that the triggers for implementation of mitigation measures and details of the drought and post-drought monitoring should be discussed with the EA during the DP application process.

8.4.2 Measures to Mitigate Impacts by a Hampton Loade Drought Permit on Downstream Abstraction The impacts on the majority of downstream abstractions are predicted to be negligible with a high degree of certainty. Consequently no mitigation measures are proposed and no provisions for compensation are required. This also applies to the Gloucester and Sharpness canal abstraction where the DP is applied in isolation. Measures required to mitigate in-combination effects are discussed below.

8.4.3 Measures to Mitigate In-Combination Impacts including a Hampton Loade Drought Permit on the Severn Estuary Given that there are a large number of competing interests for water resources within the Severn catchment, it is not considered that the responsibility for assessment, monitoring or mitigation of such impacts lies solely with any one of the interested parties. Rather, it is proposed that the River Severn Drought Management Group be reformed with an objective of determining drought operating agreements with the Canal and River Trust

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(formerly British Waterways) which are also acceptable to Natural England, Countryside Council for Wales and other water companies with abstractions and potential DP sites on the River Severn. This should aim to facilitate appropriate management of available water in the Severn catchment during drought conditions. The Company has written to the Environment Agency and Severn Trent Water to propose that the next review of the various environmental reports is carried out on a joint basis. The Company will continue to progress this approach.

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9. Drought Monitoring Plan

9.1 Overview The amended Water Industry Act (1991) states that water companies shall address in their drought plans how they ‘will monitor the effects of the drought and of the measures taken under the drought plan’. In addition, the Environment Agency’s Drought Planning Guidelines (2011) state: “Adequate data collection is needed so companies can assess the impacts from the implementation of the drought management action and a site’s recovery post implementation. It can also feed back into the assessment of sensitivity and likely impact and inform the management of future drought actions”. This section of the drought plan outlines the hydrometric monitoring undertaken by the Company and by the Environment Agency, to monitor the water resources position, and the severity of a drought. In addition, the section provides details of the baseline and drought environmental monitoring that the Company will undertake to examine the impact of potential drought permits. It is the responsibility of the Company to undertake any additional monitoring which may be required to understand the effects on the environment of specific drought actions which the Company has implemented. Where additional monitoring is necessary, this is identified below. This is restricted to those options where abstraction outside of current licence conditions is proposed (drought permits).

9.2 Baseline Water Resources Monitoring

9.2.1 Baseline Water Resources Monitoring by the Environment Agency The Environment Agency maintains and reports on a comprehensive hydrometric and environmental monitoring network for the purposes of its duties to protect and improve the water environment. This information is made available to water companies by the Agency. This includes hydrometric, water quality and ecological data. This information is essential to South Staffordshire Water in the identification and monitoring of drought conditions, and in the identification of baseline conditions against which any impact assessments are measured. The Company believes that this baseline monitoring should continue to be the responsibility of the Environment Agency. The Environment Agency has identified a number of specific monitoring sites within the Midland Region, which can be used to track the development of a drought and be used as indicators for determining drought status by the Environment Agency. These sites include river flows, groundwater levels, rainfall and reservoir levels. Details of each site relevant to South Staffordshire Water can be found in the Agency’s Midland Region Drought Plan. The Agency monitors these sites weekly during April to October and fortnightly during November to March, unless required weekly earlier or later in the year due to dry conditions. In addition to these sites, the Agency also reports soil moisture deficits (a measure of how dry the soil is) calculated by the Met Office.

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Baseline data is made available to South Staffordshire Water in the form of monthly water situation reports from the EA, and in response to specific data requests. In addition the Agency sends out notification letters to the Company when abstraction licence conditions may be triggered by low river flows or by other triggers. The following key datasets are worthy of separate mention:

• The key river flow data that controls the Company’s surface water abstraction at Hampton Loade is at Bewdley on the River Severn. This information is measured by the Agency and provided by daily automated email to operators at the Hampton Loade treatment works. • River Trent flow at North Muskham (Newark) is a key control on the Nethertown and River Trent abstractions downstream of Blithfield reservoir. When the flow is approaching the trigger (when it reaches a nominal threshold of 3180 Ml/d) the EA send a letter to the Company identifying that river flows are approaching the ‘hands off flow’ limit of 2650 Ml/d. In order to help the Company manage abstraction at Nethertown the Agency provides an automated flow alarm (sent via email) which informs the Company when flow on the River Trent is below 4,000 Ml/d and below 2,800 Ml/d and has the facility to send automated emails with flow data on a daily basis. • Reservoir storage at Clywedog is recorded by Severn Trent Water (who maintain the reservoir) for the Environment Agency. This information is provided to the Company by the Agency as part of the regular water situation reports. Storage at Clywedog is the basis for one set of drought triggers in this plan.

9.2.2 Baseline Water Resources Monitoring by South Staffordshire Water The Company maintains an automated groundwater level monitoring system at many of its groundwater sources, which is linked to telemetry. Information on abstraction rate and pumping water level is recorded, and can be compared to historical records when required. The Company also maintains a network of 14 rain gauges at selected treatment works, groundwater sources, and service reservoirs. This information is also provided to the Environment Agency. Company rainfall statistics are based on the long term data from its gauge at Seedy Mill. In addition 3 new weather stations have been constructed, at Barr Beacon service reservoir, at Outwoods service reservoir, and at Cookley. These stations measure temperature, sunshine hours, and rainfall, and they are connected to the Company’s telemetry system. River flows are measured by the Company on the Blithe at Nethertown, in order to manage the abstraction at Nethertown, and the supporting River Trent abstraction. Compensation releases from Blithfield reservoir are also recorded. This data is recorded by the Company’s telemetry system. The Company has also recently installed a river stage board at Newlands Bridge upstream of the reservoir and is in the process of calibrating a stage

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discharge relationship for the site to estimate the River Blithe inflows at this location. Reservoir storage at Blithfield is measured continuously, and is available via telemetry. Blithfield storage is the main drought trigger within this plan. In addition to the collection of hydrometric data, the Company will also continue to measure abstraction from all of its sources in order to ensure that abstraction licence limits are not exceeded during periods of high drought demand, and that any licence conditions are met. The Company will also continue to measure and report on overall demand and its components as accurately as possible. Accurate measurement of demand is an essential part of drought management, and in the identification of the benefit from any demand saving measures.

9.3 Monitoring the Environmental Effects of Company Drought Management Options

9.3.1 Demand Management Options The environmental impact of the Company’s demand management options is considered to be negligible, therefore no specific environmental monitoring is proposed.

9.3.2 Options Where Abstraction will remain within existing Abstraction Licence Limits The Company is legally entitled to abstract water from the River Severn, Blithfield Reservoir and 27 groundwater sources, up to the quantities defined in its abstraction licences. These licences are issued and regulated by the Environment Agency. The Company is aware that, during a serious drought, abstraction within abstraction licence limits, combined with severe rainfall shortages, could in some cases contribute to short-term environmental impact. The Company is fully committed to the long-term sustainability of water resources and measures have already been taken by the Company, in collaboration with the Environment Agency, to protect long-term average flows in the Leamonsley Brook near Lichfield, and the Blakedown Brook near Kidderminster, by a reduction in abstraction from sources in their vicinity and the provision of facilities to augment surface water levels. The Company is currently investigating another scheme at Checkhill Bogs SSSI in the Stour catchment and is evaluating future requirements for schemes at three sites as part of its contribution to the AMP5 National Environment Programme. Despite these measures, an extreme drought and the associated likelihood of high customer peak demands, may necessitate abstraction levels with some short-term environmental impact. Below (in Table 3) is a list of sites that the Company believes may be at risk under such circumstances, together with an indication of existing monitoring plans. Table 3 identifies the actions that the Company will consider in order to minimise the environmental effect of a drought. Table 4 provides an example of how one of these sites (Leamonsley Brook and Stowe Pools SSSI) is monitored to ensure mitigation measures are put in place in an appropriate manner.

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A map of these sites is shown in Appendix K.

9.3.3 Monitoring the Impact of Abstraction on Amenity and Recreation

No direct monitoring of the impact of licensed or drought permit abstraction on amenity and recreation value is undertaken, or is proposed. These issues are specifically covered in the drought permit environmental reports for the Blithe/Trent and the River Severn, and where necessary measurement of key parameters like flow, level and water quality can be used to assess impact.

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Table 3 Overview of Environmental Monitoring Associated with Existing Abstraction Licences Site/Location Monitoring Potenti Mitigation Action al Impact Chelmarsh Chelmarsh is a man made bank side storage reservoir. Low levels The Company aims to keep Chelmarsh as full as Reservoir (near Levels in Chelmarsh will be drawn down as required to possible, and will consider modifying abstraction regimes Hampton Loade) meet the demand from Hampton Loade. The Company where this will not compromise the operation of Hampton already monitors levels at Chelmarsh. Loade.

Blithfield Reservoir Blithfield is a man made impounding reservoir. The Low levels Levels in Blithfield Reservoir will be drawn down as SSSI Company undertakes water level and water quality required to meet the demand from Seedy Mill. Company monitoring. The frequency of monitoring may be policy is to conserve storage in Blithfield as much as increased in the event of a drought. possible during a drought. Hurcott and The Environment Agency currently undertakes a range Low levels Long-term reductions in average abstraction already Podmore Pools of surface water and groundwater level monitoring in this implemented. SSSI (Blakedown catchment. Increase use of EA and Company compensation Brook catchment) boreholes in the short term. Leamonsley Brook, The Environment Agency currently undertakes a range Low flows, The Company and EA can pump water out of the Hanch Stowe Pool SSSI of surface water and groundwater level monitoring in this Tunnel into the Leamonsley Brook if the levels in Stowe catchment. Pool fall to unacceptable levels. Rising Brook The Company is currently undertaking a range of Low flows The impact of the Company’s abstractions is currently (Cannock Chase) surface water, groundwater and ecological monitoring in being investigated by the EA and by SSW as part of the this catchment. AMP5 National Environment Programme (NEP). Checkhill Bogs The Environment Agency currently undertakes a range Low flows The impact of the Company’s abstractions is currently of surface water and ecological monitoring in this being investigated by the EA and by SSW as part of the catchment. AMP5 (NEP). Crane Brook, The Company is currently undertaking a range of Low flows The impact of the Company’s abstractions is currently Bourne Brook surface water, groundwater and ecological monitoring in being investigated by the EA and by SSW as part of the and Black Brook this catchment.. AMP5 (NEP).

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Table 4 Environmental Monitoring Plan for Leamonsley Brook and Stowe Pools SSSI

Drought Environ Parameters Method Frequen Trigger New or Owner Duration Measure mental Monitored cy Existing? Site/ Catchment Fixed flow Baseline and Hanch Tunnel Overflow measurement Daily N/A Existing SSW Drought device in tunnel. Stowe Pool Level Gauge Board Weekly N/A Existing EA/LDC Baseline Stowe Pool Level Data logger Continuous N/A Existing EA Baseline Spot Stowe Leamonsley Brook gauging/flow Continuous Existing EA Drought Pool level sensor Minster Pool Level Data logger Continuous N/A Existing EA Baseline Leamonsley Beacon Park stream Weir, data logger Continuous N/A Existing EA Baseline Brook flow Existing catchment, Abstraction Hanch Tunnel Transducer at Baseline and Stowe Pool Continuous N/A Existing SSW Groundwater Levels shaft 1. Drought SSSI 11 groundwater Manual dips Weekly N/A Existing EA Baseline observation boreholes Invertebrates Stowe Twice Kick Sampling N/A Existing EA Baseline Pool/Leamonsley Yearly Crayfish Stowe Walkover Adhoc N/A Existing EA/NE Baseline Pool/Leamonsley Surveys Groundwater augmentation flow Stowe Flowmeter Daily Existing SSW & EA Drought Hanch Tunnel (Shaft Pool level 20) & Pipe Green BH

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Appendix B2: Addendum to Statement of Response November 2012 Page 35

9.4 Monitoring Plan for the Hanch Tunnel Drought Permit Following the update of the Environmental Assessment Report in 2012 monitoring plans for baseline, in drought and post drought phases were identified. These are described in the following sections. The general specifications for environmental monitoring accompanying drought permits are covered in Appendix I.

9.4.1 Baseline Monitoring for the Hanch Tunnel DP Baseline monitoring is required to formulate a description of the existing ecological conditions, from which the impacts of DP operations over and above the effects of other pressures, such as natural drought, can be identified. It is proposed that surveying is continued at six riverine sites, corresponding to existing EA and SSW monitoring locations (Table 5). In addition to the site-specific monitoring presented in Table 5 it is proposed that areas of riffle habitat in the Bourne-Bilson Brook are identified (either via a habitat walkover survey or based on EA recommendations) and that transect surveys are carried out across a representative selection of such habitats to allow potential DP water level changes to be predicted. It is also proposed that baseline temperature monitoring and assessment is carried out at Hanch Tunnel and on Bourne Bilson Brook upstream and downstream of the Hanch Tunnel discharge, to allow assessment of the baseline temperature regime and potential DP effects on the brook. Baseline monitoring for the Hanch Tunnel DP has been carried out by the EA and SSW. This is described below. White-clawed crayfish For the Bourne Bilson Brook, because no historical information on the presence of crayfish is available, a higher intensity survey method was recommended. Consequently a hand search survey for white-clawed crayfish was undertaken at Locations 2-6 (as described in table 5) on a single occasion during summer 2011. No further surveys are proposed. Electric-fishing for brown trout and general species diversity Surveys were undertaken at Locations 2-6 on a single occasion during summer 2011. NB at Location 6 a 70 m reach was surveyed as a result of restricted access due to very dense vegetation cover. One further baseline survey is included at Locations 1-6 during summer 2013. Specialist fish surveys – Spined loach and Lamprey Surveys were undertaken at Locations 2-6 on a single occasion during summer 2011. One further set of baseline surveys is included at Locations 1-6 during summer 2013. Macroinvertebrate survey Surveys were undertaken at Locations 2-6 in spring and autumn 2011, and at Locations 1 and 2 in spring and autumn 2012.

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One further year of sampling is planned at Locations 1 and 2 (spring and autumn 2013) and two further years of sampling is planned at Locations 3-6 (spring and autumn 2013 and 2014) to provide a baseline dataset of three years at each site. It should be noted that spring and autumn samples have been planned on the Bourne Bilson Brook (rather than spring, summer and autumn) on the basis of the datasets that have already been collected to date. It should also be noted that at least a three-year continuous dataset would usually be recommended as a baseline. It is therefore proposed that the baseline dataset be reviewed at the start of 2015, to determine the need for any additional sampling. River Habitat Survey Surveys were undertaken at Locations 2 and 6 spring and autumn 2011. One further baseline survey is included at Location 1, to be undertaken during 2013. Macrophyte survey Surveys were undertaken at Locations 2-6 in summer 2011. No further baseline surveys are proposed. Spot gauging Spot gauging was carried out on 8th September 2010, 13th May 2011 and 27th July 2011. The gaugings were carried out using a hand held rotating element current meter sampling at a single point in the vertical and several intervals across the channel, as is appropriate for small channels. One further set of baseline surveys is included at Locations 1-6, to be undertaken during summer 2013. Water Quality It is planned that baseline water quality sampling be undertaken at each sampling location, including measurements of temperature, dissolved oxygen and pH using a multi-parameter hand-held probe, and biochemical oxygen demand (BOD), ammonia, soluble reactive phosphate (SRP), suspended solids, hardness, copper, aluminium and zinc from laboratory analysis of water samples. Water quality samples were collected by SSW from Hanch Tunnel during 2006 and 2011, and from Locations 3 and 6 by the EA on a monthly basis (1990-1992 and 1990-2005 respectively). It is planned that the Company collect one further set of baseline measurements and samples from Locations 1-6 during summer 2013 (at the same time as the baseline spot gauging surveys) to allow comparison of key parameters in Hanch Tunnel (Shaft One and in Lichfield) and Bourne Bilson Brook (as well as Blithfield Reservoir). This is intended to improve understanding of various apparent water quality outliers from the Hanch Tunnel (Shaft One) dataset that could be affected by, for example, mixing of water from Hanch Tunnel and Bourne Bilson Brook at the tunnel mouth during periods of high runoff. The monitoring will also help to understand potential water quality impacts of Hanch Tunnel on Bourne Bilson Brook at the point of discharge. It is also intended that baseline temperature monitoring and assessment is carried out at Hanch Tunnel and on Bourne Bilson Brook upstream and downstream of the

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Hanch Tunnel discharge, to allow assessment of the baseline temperature regime and potential DP effects on the brook. Low DO and high temperatures could occur during low flow periods and these could affect ecology; these parameters are therefore a particularly important component of the during-DP monitoring plan (see Section 9.4.2). The baseline monitoring plan for the Hanch Tunnel Drought Permit is detailed in Table 5.

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Table 5 Baseline Environmental Monitoring Plan for the Hanch Tunnel Drought Permit Receptor / Responsibility / Frequency / Timing Location Macro- Fish White- Macrophytes RHS* Spot gauging Water quality invertebrates Populations clawed (MTR (three-minute kick (single run EF crayfish Method) and one minute with stop (presence- hand search) nets, lamprey absence & spined hand loach) search) SSW SSW Location 1 spring & autumn n/a n/a n/a n/a summer n/a Control Site 2011, 2012 2011 Bourne Bilson SSW unless SSW unless otherwise SSW unless SSW unless Brook U/S Seedy otherwise SSW unless otherwise agreed with the EA otherwise agreed otherwise agreed Mill WTW n/a n/a agreed with agreed with the EA spring & autumn with the EA with the EA (SK 10180 13568) the EA Summer 2013 2013 Summer 2013 Summer 2013 Summer 2013 SSW SSW (from Hanch SSW SSW SSW SSW SSW spring & Tunnel 2006 & spring & autumn Sept 2010, May & July Location 2 summer 2011 summer 2011 summer 2011 autumn 2011 2011, 2012 2011 D/S Hanch Tunnel 2011 plus temperature Discharge data from 2010/12) (SK 10531 13792) SSW unless otherwise SSW unless SSW unless SSW unless otherwise agreed with the EA otherwise agreed otherwise agreed n/a n/a n/a agreed with the EA spring & autumn with the EA with the EA Summer 2013 2013 Summer 2013 Summer 2013 SSW unless EA otherwise agreed with SSW SSW SSW SSW monthly the EA n/a Sept 2010, May & July Location 3 summer 2011 summer 2011 summer 2011 1990-1992 spring & autumn 2011 Shaw Lane (Riley Hill Farm) 2011 (SK 11640 15194) SSW unless otherwise SSW unless SSW unless otherwise SSW unless agreed with the EA otherwise agreed n/a n/a n/a agreed with the EA otherwise agreed spring & autumn with the EA Summer 2013 with the EA

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Receptor / Responsibility / Frequency / Timing Location Macro- Fish White- Macrophytes RHS* Spot gauging Water quality invertebrates Populations clawed (MTR (three-minute kick (single run EF crayfish Method) and one minute with stop (presence- hand search) nets, lamprey absence & spined hand loach) search) 2013, 2014 Summer 2013 Summer 2013

SSW n/a (location 3 SSW SSW SSW n/a (location 3 used as spring & autumn n/a used as summer 2011 summer 2011 summer 2011 surrogate) Location 4 2011 surrogate) A515 SSW unless otherwise SSW unless SSW unless (SK 11893 15510) SSW unless otherwise agreed with the EA otherwise agreed otherwise agreed n/a n/a n/a agreed with the EA spring & autumn with the EA with the EA Summer 2013 2013, 2014 Summer 2013 Summer 2013

SSW n/a (location 6 SSW SSW SSW SSW spring & autumn n/a used as summer 2011 summer 2011 summer 2011 Sept 2010 Location 5 2011 surrogate) Chawley SSW unless otherwise SSW unless SSW unless (SK 12777 15719) SSW unless otherwise agreed with the EA otherwise agreed otherwise agreed n/a n/a n/a agreed with the EA spring & autumn with the EA with the EA Summer 2013 2013, 2014 Summer 2013 Summer 2013 SSW SSW SSW EA SSW SSW SSW spring & spring & autumn Sept 2010, May & July monthly summer 2011 summer 2011 summer 2011 autumn Location 6 2011 2011 1990-2005 2011 Lupin Farm SSW unless otherwise SSW unless SSW unless (SK 14447 16182) SSW unless otherwise agreed with the EA otherwise agreed otherwise agreed n/a n/a n/a agreed with the EA spring & autumn with the EA with the EA Summer 2013 2013, 2014 Summer 2013 Summer 2013 *EA River Habitat Survey in Britain and Ireland: Field Survey Guidance Manual (2003 Version) & RHS Technical Update (April 2006)

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NB The monitoring programme and responsibilities for the following year should be discussed annually at the “light touch” review meeting between SSW and the EA. NB n/a = not applicable Bold text indicates surveys that have already been completed. Italic text indicates proposed surveys that have not yet been carried out.

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9.4.2 During Drought Permit Monitoring for the Hanch Tunnel DP In the event that the DP is implemented, additional environmental monitoring would be required to show that any impacts occurring during this time are as a result of the drought itself and are not caused by the operation of the DP. Monitoring may also allow early response should any unpredicted problems or impacts occur as a result of the DP. The proposed monitoring during a DP is outlined in Table 6. Specific issues relating to this programme are as follows:

• It is planned that during the implementation of a DP, spot gauging is undertaken at all locations to confirm predicted water level changes. It is proposed that cross-sectional profiles be reviewed using spot gauging field data at all locations. • The Company will undertake weekly collection of water quality data (dissolved oxygen, pH, BOD, ammonia, soluble reactive phosphate (SRP), suspended solids, hardness, copper, aluminium and zinc). This will allow comparison against the baseline dataset. • Daily monitoring of a reduced suite of water quality determinands (dissolved oxygen, pH and temperature) is planned at Seedy Mill (downstream of the Hanch Tunnel discharge). It is preferred that the equipment be monitored either by SSW personnel or via telemetry, which would allow early warning of potential low dissolved oxygen and high water temperature events. If dissolved oxygen or water temperature reached specified trigger levels daily site visits will be carried out to look for signs of ecological stress. Visits would be continued until water quality parameters returned to acceptable levels. If signs of stress were observed, mitigation measures would be implemented (Section 8). The recommended trigger levels, in line with Freshwater Fish Directive and Water Framework Directive standards, are: dissolved oxygen concentration of less than 8 mg/l; temperature greater than 20°C. • It is also planned that temperature monitoring and assessment is carried out at Hanch Tunnel and on Bourne Bilson Brook upstream and downstream of the Hanch Tunnel discharge, to allow assessment of potential effects of the proposed DP on the temperature regime of the brook. • Where appropriate, the frequency and locations of ecological monitoring will remain identical to that described in the baseline, with the exception of fish surveys which are not recommended during DP implementation. The consistent approach to monitoring during a DP will allow for a scientifically rigorous and quantifiable assessment to be made of any impacts over and above those of a natural drought. The need for macroinvertebrate surveys during DP implementation will be discussed in advance with the EA; depending on the severity and timing of the drought, such ecological surveys may be inadvisable during DP implementation. • Given the potential, under some circumstances, for impacts on fish populations and migration during a DP, a habitat walkover survey and further detailed site based investigations will be undertaken at key locations with the aim of identifying whether unacceptable impacts are

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actually occurring, and if they are, determining their magnitude and recommending appropriate and effective mitigation measures. This monitoring will be used to target potential “in-combination” effects of the proposed DP with other abstractors, especially during the growing season (May-Sep). Such monitoring may need to include spot gauging and a gauge board at one or more of the riffle habitats identified by the baseline monitoring (the need for this should be reviewed after the baseline data has been analysed, as it may or may not be necessary). • Should the habitat walkover at any site identify that flow depth or velocity are below minimum requirements for key species or life stages at that time of year, daily site visits will be carried out to look for signs of ecological stress. If signs of stress were observed, mitigation measures would be implemented (Section 8). • To monitor the predicted low impact of Hanch Tunnel water discharged into Blithfield Reservoir the water quality of Hanch Tunnel and the Reservoir will be monitored on a monthly basis for the duration of the DP. This will include analysis of a full suite of chemicals including pesticides, herbicides, aluminium, cadmium, cyanide and nitrate. Monthly sampling is preferred to allow sufficient time for lab analysis and interpretation, based on previous evidence that water quality in Hanch Tunnel is likely to remain relatively stable (WMC, 2007).

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Table 6 During DP Environmental Monitoring Plan for Hanch Tunnel Drought Permit Receptor / Responsibility / Frequency / Timing Macro-invertebrates Habitat Walkover (three-minute kick and Fixed point Location, (Amended Hendry- Spot gauging Water quality one minute hand photography Cragg-Hine, 1997) search) Location 1 SSW unless SSW unless Control Site SSW unless otherwise SSW unless otherwise SSW unless otherwise otherwise agreed otherwise agreed agreed with the EA agreed with the EA agreed with the EA Bourne Bilson Brook with the EA with the EA U/S Seedy Mill WTW spring & autumn summer Weekly Weekly Weekly (SK 10180 13568) SSW unless Location 1 SSW unless otherwise agreed SSW unless otherwise SSW unless otherwise SSW unless otherwise otherwise agreed with the EA D/S Hanch Tunnel agreed with the EA agreed with the EA agreed with the EA Discharge with the EA Weekly spring, summer & autumn summer Weekly (SK 10531 13792) Weekly (plus DO, temp and pH daily)

Location 2 SSW unless SSW unless SSW unless otherwise SSW unless otherwise SSW unless otherwise otherwise agreed otherwise agreed D/S Hanch Tunnel agreed with the EA agreed with the EA agreed with the EA Discharge with the EA with the EA spring, summer & autumn summer Weekly (SK 10531 13792) Weekly Weekly SSW unless SSW unless Location 3 SSW unless otherwise SSW unless otherwise SSW unless otherwise otherwise agreed otherwise agreed agreed with the EA agreed with the EA agreed with the EA A515 with the EA with the EA spring, summer & autumn summer Weekly (SK 11893 15510) Weekly Weekly SSW unless SSW unless Location 3 SSW unless otherwise SSW unless otherwise SSW unless otherwise otherwise agreed otherwise agreed agreed with the EA agreed with the EA agreed with the EA Shaw Lane with the EA with the EA spring, summer & autumn summer Weekly (SK 11640 15194) Weekly Weekly

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Receptor / Responsibility / Frequency / Timing Macro-invertebrates Habitat Walkover (three-minute kick and Fixed point Location, (Amended Hendry- Spot gauging Water quality one minute hand photography Cragg-Hine, 1997) search) SSW unless SSW unless Location 5 SSW unless otherwise SSW unless otherwise SSW unless otherwise otherwise agreed otherwise agreed agreed with the EA agreed with the EA agreed with the EA Lupin Farm with the EA with the EA spring, summer & autumn summer Weekly (SK 14447 16182) Weekly Weekly Location 6 SSW Hanch Tunnel n/a n/a n/a n/a monthly Abstraction, Shaft 1 Location 7 SSW Blithfield Raw Water n/a n/a n/a n/a monthly Seedy Mill WTW NB The monitoring programme and responsibilities should be discussed annually at the “light touch” review meeting between SSW and the EA

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9.4.3 Post Drought Permit Monitoring for the Hanch Tunnel DP Monitoring after the DP period will be necessary in order to assess whether the implementation of the DP has any long-term effects on any environmental features (Table 7). Following the cessation of the DP, monitoring will continue in each of the monitoring reaches at the same frequency as employed during the baseline period. The duration of post DP monitoring will depend on the severity of the natural drought, but will cover the period of recovery and will be carried out in consultation with the regulators.

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Table 7 Post DP Environmental Monitoring Plan for the Hanch Tunnel DP

Receptor / Responsibility / Frequency / Timing

Fish Populations Macro-invertebrates (single run EF with stop Location (three-minute kick and Spot gauging Water quality nets, lamprey & spined one-minute sweep) loach) Location 1 SSW unless otherwise agreed SSW unless otherwise agreed SSW unless otherwise SSW unless otherwise Control Site with the EA with the EA agreed with the EA agreed with the EA Bourne Bilson Brook U/S Seedy Mill spring & autumn summer summer quarterly WTW (at least 1 year) (at least 1 year) (1 year) (1 year) (SK 10180 13568) SSW unless otherwise agreed SSW unless otherwise agreed SSW unless otherwise SSW unless otherwise Location 1 with the EA with the EA agreed with the EA agreed with the EA D/S Hanch Tunnel Discharge spring & autumn summer summer quarterly (SK 10531 13792) (at least 1 year) (at least 1 year) (1 year) (1 year) SSW unless otherwise agreed SSW unless otherwise agreed SSW unless otherwise SSW unless otherwise Location 2 with the EA with the EA agreed with the EA agreed with the EA D/S Hanch Tunnel Discharge spring & autumn summer summer quarterly (SK 10531 13792) (at least 1 year) (at least 1 year) (1 year) (1 year) SSW unless otherwise agreed SSW unless otherwise agreed SSW unless otherwise SSW unless otherwise Location 3 with the EA with the EA agreed with the EA agreed with the EA A515 spring & autumn summer summer quarterly (SK 11893 15510) (at least 1 year) (at least 1 year) (1 year) (1 year) Location 3 SSW unless otherwise agreed SSW unless otherwise agreed SSW unless otherwise SSW unless otherwise Shaw Lane with the EA with the EA agreed with the EA agreed with the EA (SK 11640 15194) spring & autumn summer summer quarterly

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(at least 1 year) (at least 1 year) (1 year) (1 year)

SSW unless otherwise agreed SSW unless otherwise agreed SSW unless otherwise SSW unless otherwise Location 5 with the EA with the EA agreed with the EA agreed with the EA Lupin Farm spring & autumn summer summer quarterly (SK 14447 16182) (at least 1 year) (at least 1 year) (1 year) (1 year) NB The monitoring programme and responsibilities for the following year should be discussed annually at the “light touch” review meeting between SSW and the EA

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9.5 Monitoring Plan for the Blithe/Trent Drought Permit Following the update of the Environmental Assessment Report in 2012 monitoring plans for baseline, in drought and post drought phases were identified. These are described in the following sections. The general specifications for environmental monitoring accompanying drought permits are covered in Appendix I.

9.5.1 Baseline Monitoring for the Blithe/Trent DP Baseline monitoring is required to formulate a description of the existing ecological conditions, from which the impacts of DP operations over and above the effects of other pressures, such as natural drought, can be identified. It is proposed that 7 riverine sites be surveyed in total, corresponding to existing EA and SSW monitoring locations (Table 8). The proposed monitoring has been selected in line with the risk-based approach recommended in the latest drought plan guidance EA (2011), on the basis that only negligible or very minor changes in water quality and quantity are predicted in comparison with the baseline, and only over very short reaches. Therefore the baseline monitoring focuses on reducing remaining areas of uncertainty in key reaches and relies on existing baseline datasets collected by the EA (including upstream control sites wherever possible). Baseline monitoring for the Blithe/Trent DP has been carried out by the EA and SSW. This is described below. Macroinvertebrates No baseline surveys have been undertaken to date. Fish populations The routine surveys undertaken by the EA at three locations (Location 2, Location 5 and Location 7) are considered to be sufficient to provide baseline data on fish populations. Cross sectional profiles No baseline surveys specifically for the purposes of DP monitoring have been undertaken to date, although there is existing flow/water level measurement at Newton Bridge, Blithfield Reservoir, Hamstall Ridware, Nethertown Weir and Yoxall. At least one spot gauging and cross sectional survey is planned in Reach 1b to determine the hydraulic parameters of the reach and confirm the predicted impacts. At least one set of spot gauging and cross sectional surveys is also planned in Reach 2 on the single upstream channel and the 2 downstream channels to determine hydraulic parameters and confirm the predicted impacts. If the opportunity arises, it may also be useful to undertake such surveys during a period when the Nethertown (River Blithe and River Trent) abstractions are running. Water quality Baseline water quality sampling is planned at each sampling location, including measurements of temperature, dissolved oxygen and pH using a multi-parameter hand-held probe, and biochemical oxygen demand (BOD), ammonia, soluble reactive phosphate (SRP), suspended solids, hardness, copper, aluminium and zinc from laboratory analysis of water samples.

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Low DO and high temperatures could occur during low flow periods and these could affect ecology; these parameters are therefore a particularly important component of the during-DP monitoring plan below.

The baseline environmental monitoring plan for the Blithe/Trent DP is detailed in Table 8.

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Table 8 Baseline Environmental Monitoring Plan for the Blithe/Trent Drought Permit Receptor / Method / Responsibility / Frequency / Timing Location number and Macro-invertebrates Cross-sectional purpose Fish Populations Water quality (3 minute kick & 1 minute profiles hand search) Location 1 (U/S control) SSW unless otherwise agreed River Blithe U/S Blithfield Reservoir with the EA n/a n/a n/a Newton Bridge spring, summer & autumn SK-048-259 Location 2 (U/S control) SSW unless otherwise agreed SSW unless otherwise agreed River Blithe U/S Reach 1a with the EA with the EA n/a n/a Hamstall Ridware spring, summer & autumn summer SK-109-190 Location 3 (U/S control) River Blithe U/S Reach 1a SSW n/a n/a n/a Nethertown u/s water transfer monthly SK-113-178 Location 4 River Blithe, Reach 1b SSW SSW SSW n/a Nethertown d/s water transfer spring, summer & autumn summer monthly SK-113-178 Location 5 (U/S control) SSW unless otherwise agreed SSW unless otherwise agreed SSW unless otherwise River Trent, Reach 2, U/S Nethertown with the EA with the EA n/a agreed with the EA Handsacre High Bridge spring, summer & autumn summer monthly SK-092-167

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Receptor / Method / Responsibility / Frequency / Timing Location number and Macro-invertebrates Cross-sectional purpose Fish Populations Water quality (3 minute kick & 1 minute profiles hand search) Location 6 SSW River Trent, Reach 2, D/S Nethertown n/a n/a summer n/a D/S Nethertown (ADCP, subject to site visit) SK-113-176 Location 7 SSW unless otherwise agreed SSW unless otherwise agreed EA SSW unless otherwise River Trent, Reach 3, D/S Blithe with the EA with the EA agreed with the EA Confluence rating at Yoxall gauging spring, summer & autumn summer station already available monthly Yoxall Bridge SK-131-177 NB The monitoring programme and responsibilities for the following year should be discussed annually at the “light touch” review meeting between SSW and the EA.

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9.5.2 During Drought Permit Monitoring for the Blithe/Trent DP In the event that the DP is implemented, additional environmental monitoring would be required to show that any impacts occurring during this time are as a result of the drought itself and are not caused by the operation of the DP. Monitoring may also allow early response should any unpredicted problems or impacts occur as a result of the DP. The proposed monitoring during a Blithe/Trent DP is outlined in Table 9. Specific issues relating to this programme are as follows:

• It is intended that during the implementation of a DP, river cross- sectional profiles at locations 4, 6 and 7 be additionally surveyed to confirm water level changes predicted by baseline monitoring. • Collection of routine water quality data by the EA and SSW is planned to remain at monthly frequency (dissolved oxygen, pH, BOD, ammonia, soluble reactive phosphate (SRP), suspended solids, hardness, copper and zinc). This will allow comparison against the baseline dataset. • Daily monitoring of a reduced suite of water quality determinands (dissolved oxygen, pH and temperature) is also planned at Nethertown on the River Blithe (immediately upstream and downstream of the SSW water transfer). It is preferred that the monitoring equipment would be monitored either by SSW personnel or via telemetry, which would allow early warning of potential low dissolved oxygen and high water temperature events. If dissolved oxygen or water temperature reached specified trigger levels daily site visits would be carried out to look for signs of ecological stress. Visits would be continued until water quality parameters returned to acceptable levels. If signs of stress were observed, mitigation measures would be implemented (Section 8). The recommended trigger levels, in line with Freshwater Fish Directive and Water Framework Directive standards, are: dissolved oxygen concentration of less than 8 mg/l; temperature greater than 20°C. • Where appropriate, the frequency and locations of ecological monitoring should remain identical to that described in the baseline, with the exception of fish surveys which are not recommended during DP implementation. This consistent approach to monitoring during a DP will allow for a scientifically rigorous and quantifiable assessment to be made of any impacts over and above those of a natural drought. The need for macroinvertebrate surveys during DP implementation should be discussed in advance with the EA; depending on the severity and timing of the drought, such ecological surveys may be inadvisable during DP implementation. • It is planned that the Company checks for evidence of fish congregating above or below the Nethertown (River Blithe) weir on a daily basis during DP implementation, at the same time that the water quality monitoring described above is carried out. This

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monitoring is intended to trigger implementation of emergency mitigation measures (see Section 8) should evidence of ecological distress be identified. Close liaison should also be maintained with EA fisheries officers.

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Table 9 During DP Environmental Monitoring Plan for the Blithe/Trent Drought Permit Receptor / Method / Responsibility / Frequency / Timing Macro-invertebrates Location number and purpose Fish Cross-sectional Water quality (3 minute kick & 1 minute hand Populations profiles search)

Location 1 (U/S control) SSW unless otherwise agreed with the EA River Blithe U/S Blithfield Reservoir n/a n/a n/a Newton Bridge SK-048-259 spring, summer & autumn Location 2 (U/S control) SSW unless otherwise agreed with the EA River Blithe U/S Reach 1a n/a n/a n/a Hamstall Ridware SK-109-190 spring, summer & autumn Location 3 (U/S control) River Blithe U/S Reach 1a SSW n/a n/a n/a Nethertown u/s water transfer daily SK-113-178 Location 4 River Blithe, Reach 1b SSW SSW n/a SSW Nethertown d/s water transfer daily daily SK-113-178 Location 5 (U/S control) SSW unless otherwise River Trent, Reach 2, U/S Nethertown SSW unless otherwise agreed with the EA n/a n/a agreed with the EA Handsacre High Bridge spring, summer & autumn SK-092-167 monthly Location 6 River Trent, Reach 2, D/S Nethertown n/a n/a SSW n/a SK-113-176 SSW unless otherwise Location 7 SSW unless otherwise agreed with the EA River Trent, Reach 3, D/S Blithe Confluence n/a SSW agreed with the EA spring, summer & autumn Yoxall Bridge SK-131-177 monthly

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9.5.3 Post Drought Permit Monitoring for the Blithe/Trent DP Monitoring after the DP period will be necessary in order to assess whether the implementation of the DP has any long-term effects on any environmental features (Table 10). Following the cessation of a DP, monitoring will continue in each of the monitoring reaches at the same frequency as employed during the baseline period. The duration of post DP monitoring will depend on the severity of the natural drought, but will cover the period of recovery and will be carried out in consultation with the regulators.

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Table 10 Post DP Environmental Monitoring Plan for the Blithe/Trent Drought Permit Receptor / Method / Responsibility / Frequency / Timing Location number and Macro-invertebrates Fish Populations Cross- Water quality purpose (3 minute kick & 1 minute hand sectional search) profiles Location 1 (U/S control) River Blithe U/S Blithfield Reservoir SSW unless otherwise agreed with the EA n/a n/a n/a Newton Bridge spring, summer & autumn SK-048-259 Location 2 (U/S control) SSW unless otherwise River Blithe U/S Reach 1a SSW unless otherwise agreed with the EA agreed with the EA n/a n/a Hamstall Ridware spring, summer & autumn SK-109-190 summer Location 3 (U/S control) River Blithe U/S Reach 1a SSW n/a n/a n/a Nethertown u/s water transfer monthly SK-113-178 Location 4 River Blithe, Reach 1b SSW SSW SSW n/a Nethertown d/s water transfer spring, summer & autumn summer monthly SK-113-178 Location 5 (U/S control) SSW unless otherwise SSW unless River Trent, Reach 2, U/S Nethertown SSW unless otherwise agreed with the EA otherwise agreed agreed with the EA n/a Handsacre High Bridge spring, summer & autumn with the EA SK-092-167 summer monthly Location 6 River Trent, Reach 2, D/S Nethertown SSW n/a n/a n/a D/S Nethertown summer SK-113-176 Location 7 SSW unless otherwise SSW unless River Trent, Reach 3, D/S Blithe SSW unless otherwise agreed with the EA otherwise agreed agreed with the EA n/a Confluence spring, summer & autumn with the EA Yoxall Bridge summer monthly

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Location number and Receptor / Method / Responsibility / Frequency / Timing SKpurpose-131-177

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9.6 Monitoring Plan for the Hampton Loade Drought Permits Following the update of the Environmental Assessment Report in 2012 monitoring plans for baseline, in drought and post drought phases were identified. These are described in the following sections. The general specifications for environmental monitoring accompanying drought permits are covered in Appendix I.

9.6.1 Baseline Monitoring for the Hampton Loade DPs Baseline monitoring is required to formulate a description of the existing ecological conditions, from which the impacts of DP operations over and above the effects of other pressures, such as natural drought, can be identified. It is proposed that 8 riverine sites be surveyed in total, corresponding to existing EA and SSW monitoring locations (Table 11). Some baseline monitoring was carried out by Severn Trent Water Ltd (STWL) in 2011. The Company and STWL are planning to co-ordinate their baseline drought monitoring programmes in future years to avoid duplication of effort. It should be noted that no monitoring points have been recommended downstream of Bewdley because monitoring in these reaches is not considered solely the responsibility of the Company or STWL and any unforeseen impacts of the Hampton Loade or Trimpley DPs alone would be expected to be most evident immediately downstream of these abstractions. However, operation of these drought measures in combination with the River Severn Drought Order may effect the Severn Estuary and therefore it is proposed that the River Severn Drought Management Group be reformed with an objective of determining drought monitoring agreements for the downstream reaches with the EA and the Canal and River Trust (formerly British Waterways) which are also acceptable to Natural England, Countryside Council for Wales and other water companies with abstractions and potential DP sites on the River Severn. The Company has written to the EA and Severn Trent Water and has gained agreement in principle for this approach. Baseline monitoring for the River Severn DP has been carried out by the EA, STWL and SSW. This is described below.

Walkover survey No baseline walkover surveys have been carried out by STWL or SSW. It is intended that one survey is carried out at each site in summer 2013. Fish populations The EA is currently in the process of devising an appropriate WFD- compatible sampling method for the River Severn. As such, it is proposed that baseline DP fish monitoring is undertaken by the EA when appropriate methods have been confirmed. This will avoid collection of non-compatible data and/or duplication of effort.

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Macroinvertebrates Surveys were undertaken at Locations 1-2 and 4-6 (as described in table 11) in spring, summer and autumn 2011 and 2012, and at Locations 7 and 8 in spring, summer and autumn 2012. One further year of sampling is planned at Locations 1-2 and 4-8 (spring, summer and autumn 2013). Severn Estuary It is proposed that baseline physico-chemical monitoring by the EA of the Severn Estuary and transitional water bodies upstream continue. Further monitoring by the EA to better understand salmon movements in the estuary is supported. It is proposed that the baseline and in drought monitoring requirements are further discussed and agreed by the River Severn Drought Management Group.

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Table 11 Baseline Environmental Monitoring Plan for the Hampton Loade Drought Permits Receptor / Method / Responsibility / Frequency / Timing Habitat Macro-invertebrates Fish Populations Location Walkover Cross- (three minute kick and (EA WFD (Amended sectional Water quality one minute hand Classification Hendry-Cragg- profiles search) Method (TBC)) Hine, 1997) STWL EA Location 1 spring, summer & autumn n/a n/a n/a as programmed (U/S Hampton Loade - control) 2011, 2012 Coalport (u/s weak bridge) STWL EA STWL EA spring, summer & autumn as programmed at relevant n/a SJ7006502133 Summer 2013 as programmed 2013 locations STWL EA Location 2 spring, summer & autumn n/a n/a n/a as programmed (U/S Hampton Loade - control) 2011, 2012 Apley Forge (200m d/s of Apley Bridge) STWL EA EA STWL EA spring, summer & autumn as programmed at relevant as programmed SO7085898074 Summer 2013 as programmed 2013 locations (flood mapping)

Location 3 n/a n/a n/a n/a n/a (D/S Hampton Loade & U/S Trimpley) Hampton Loade at Bridge SSW SO7465187011 n/a n/a n/a n/a monthly 2012-2015 STWL Location 4 EA spring, summer & autumn n/a n/a n/a as programmed (D/S Hampton Loade & U/S Trimpley) 2011, 2012

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Receptor / Method / Responsibility / Frequency / Timing Habitat Macro-invertebrates Fish Populations Location Walkover Cross- (three minute kick and (EA WFD (Amended sectional Water quality one minute hand Classification Hendry-Cragg- profiles search) Method (TBC)) Hine, 1997) Highley (1km d/s foot bridge) STWL EA STWL EA SO7520283331 spring, summer & autumn as programmed at relevant n/a Summer 2013 as programmed 2013 locations STWL EA Location 5 spring, summer & autumn n/a n/a n/a as programmed (D/S Hampton Loade & U/S Trimpley) 2011, 2012 Upper Arley (1km U/S car park) STWL EA STWL EA EA SO7575380416 spring, summer & autumn as programmed at relevant summer as programmed as programmed 2013 locations 2013 (flood mapping) STWL EA Location 6 spring, summer & autumn n/a n/a n/a as programmed (D/S Hampton Loade & Trimpley) 2011, 2012 Dowles Brook (D/S B4190 road bridge) STWL EA STWL EA SO7898875218 spring, summer & autumn as programmed at relevant n/a Summer 2013 as programmed 2013 locations STWL EA Location 7 spring, summer & autumn n/a n/a n/a as programmed (D/S Hampton Loade & Trimpley) 2012 U/S Bewdley STWL EA STWL EA SO7798976372 spring, summer & autumn as programmed at relevant n/a Summer 2013 as programmed 2013 locations STWL EA Location 8 spring, summer & autumn n/a n/a n/a as programmed (D/S Hampton Loade & Trimpley) 2012 Bewdley STWL EA EA STWL EA SO7964271581 spring, summer & autumn as programmed at relevant as programmed (at Summer 2013 as programmed 2013 locations gauging stations)

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NB The monitoring programme and responsibilities for the following year should be discussed annually at the “light touch” review meeting between SSW and the EA. NB n/a = not applicable Bold text indicates surveys that have already been completed. Italic text indicates proposed surveys that have not yet been carried out.

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9.6.2 During Drought Permit Monitoring for the Hampton Loade DPs In the event that the DP is implemented, additional environmental monitoring would be required to show that any impacts occurring during this time are as a result of the drought itself and are not caused by the operation of the DP. Monitoring may also allow early response should any unpredicted problems or impacts occur as a result of the DP. The proposed monitoring during a DP is outlined in Table 12. Specific issues relating to this programme are as follows:

• It is planned that during the implementation of a DP, surveys of river cross-sectional profiles be undertaken at locations 2, 5 and 8 to confirm predicted water level changes • Collection of routine water quality data by the EA and SSW should remain at monthly frequency (dissolved oxygen, pH, BOD, ammonia, soluble reactive phosphate (SRP), suspended solids, hardness, copper and zinc). This will allow comparison against the baseline dataset. • Daily monitoring of a reduced suite of water quality determinands (dissolved oxygen, pH and temperature) is also planned at Hampton Loade (immediately downstream of the SSW abstraction). It is preferred that the monitoring equipment would be monitored either by SSW personnel or via telemetry, which would allow early warning of potential low dissolved oxygen and high water temperature events. If dissolved oxygen or water temperature reached specified trigger levels daily site visits would be carried out to look for signs of ecological stress. Visits would be continued until water quality parameters returned to acceptable levels. If signs of stress were observed, mitigation measures would be implemented (Section 8). The recommended trigger levels, in line with Freshwater Fish Directive and Water Framework Directive standards, are: dissolved oxygen concentration of less than 8 mg/l; temperature greater than 20°C. • Where appropriate, the frequency and locations of ecological monitoring should remain identical to that described in the baseline, with the exception of fish surveys which are not recommended during DP implementation. This consistent approach to monitoring during a DP will allow for a scientifically rigorous and quantifiable assessment to be made of any impacts over and above those of a natural drought. The need for macroinvertebrate surveys during DP implementation should be discussed in advance with the EA; depending on the severity and timing of the drought, such ecological surveys may be inadvisable during DP implementation. • Should water quality or river level monitoring during DP implementation give cause for concern, it is planned that a repeat habitat walkover survey be undertaken at key locations with the aim of identifying if unacceptable impacts are actually occurring, and if they are, determining their magnitude and recommending

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appropriate and effective mitigation measures. This will facilitate the identification of temporal minimum flow requirement thresholds for the relevant species and life stages and it is anticipated that these would be used to recommend mitigation measures to prevent, reduce or remedy unacceptable ecological impacts, whilst still maximising the available resource. • Should the repeat habitat walkover at any site identify that flow depth or velocity are below minimum requirements for key species or life stages at that time of year, daily site visits would be carried out to look for signs of ecological stress. If signs of stress were observed, mitigation measures would be implemented (Section 8).

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Table 12 During DP Environmental Monitoring Plan for the Hampton Loade Drought Permits Receptor / Method / Responsibility / Frequency / Timing Location Macro- Fish Habitat Cross- Water quality invertebrates Populations Walkover sectional (three minute kick (EA WFD (Amended profiles and one minute Classific-ation Hendry-Cragg- hand search) Method (TBC)) Hine, 1997) Location 1 SSW (U/S Hampton Loade - control) SSW EA spring, summer & n/a n/a Coalport (u/s weak bridge) summer as programmed SJ7006502133 autumn Location 2 SSW (U/S Hampton Loade - control) SSW SSW EA spring, summer & n/a Apley Forge (200m d/s of Apley Bridge) summer summer as programmed SO7085898074 autumn Location 3 (D/S Hampton Loade & U/S Trimpley) SSW n/a n/a n/a n/a Hampton Loade at Bridge daily SO7465187011 Location 4 SSW (D/S Hampton Loade & U/S Trimpley) SSW EA spring, summer & n/a n/a Highley (1km d/s foot bridge) summer as programmed SO7520283331 autumn Location 5 SSW (D/S Hampton Loade & U/S Trimpley) SSW SSW EA spring, summer & n/a Upper Arley (1km U/S car park) summer summer as programmed SO7575380416 autumn Location 6 SSW (D/S Hampton Loade & Trimpley) SSW EA spring, summer & n/a n/a Dowles Brook (D/S B4190 road bridge) summer as programmed autumn SO7898875218

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Receptor / Method / Responsibility / Frequency / Timing Location Macro- Fish Habitat Cross- Water quality invertebrates Populations Walkover sectional (three minute kick (EA WFD (Amended profiles and one minute Classific-ation Hendry-Cragg- hand search) Method (TBC)) Hine, 1997) Location 7 SSW (D/S Hampton Loade & Trimpley) SSW EA spring, summer & n/a n/a U/S Bewdley summer as programmed autumn SO7798976372 Location 8 SSW (D/S Hampton Loade & Trimpley) SSW SSW EA spring, summer & n/a Bewdley summer summer as programmed autumn SO7964271581

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9.6.2 Post Drought Permit Monitoring for the Hampton Loade DPs Monitoring after the DP period will be necessary in order to assess whether the implementation of the DP has any long-term effects on any environmental features (Table 13). Following the cessation of a DP, monitoring will continue in each of the monitoring reaches at the same frequency as employed during the baseline period. The duration of post DP monitoring will depend on the severity of the natural drought, but will cover the period of recovery and will be carried out in consultation with the regulators.

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Table 13 Post DP Environmental Monitoring Plan for the Hampton Loade Drought Permits Receptor / Method / Responsibility / Frequency / Timing Location, Responsibility, Macro-invertebrates Fish Populations Habitat Walkover Cross- frequency & timing (three minute kick and one (EA WFD Classification (Amended Hendry- sectional Water quality minute hand search) Method (TBC)) Cragg-Hine, 1997) profiles Location 1 STWL EA STWL n/a EA (U/S Hampton Loade - control) spring, summer & autumn as programmed at summer as programmed Coalport (u/s weak bridge) relevant locations SJ7006502133 Location 2 EA EA (U/S Hampton Loade - control) STWL STWL EA as programmed at relevant as programmed Apley Forge (200m d/s of Apley Bridge) spring, summer & autumn summer as programmed locations (flood mapping) SO7085898074 Location 3 (D/S Hampton Loade & U/S Trimpley) SSW n/a n/a n/a n/a Hampton Loade at Bridge as programmed SO7465187011 Location 4 EA (D/S Hampton Loade & U/S Trimpley) STWL STWL EA as programmed at relevant n/a Highley (1km d/s foot bridge) spring, summer & autumn summer as programmed locations SO7520283331 Location 5 STWL EA EA (D/S Hampton Loade & U/S Trimpley) STWL EA spring, summer & autumn as programmed at relevant as programmed Upper Arley (1km U/S car park) summer as programmed 2011-2013 locations (flood mapping) SO7575380416 Location 6 EA (D/S Hampton Loade & Trimpley) STWL STWL EA as programmed at relevant n/a Dowles Brook (D/S B4190 road bridge) spring, summer & autumn summer as programmed locations SO7898875218 Location 7 EA (D/S Hampton Loade & Trimpley) STWL STWL EA as programmed at relevant n/a U/S Bewdley spring, summer & autumn summer as programmed locations SO7798976372

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Receptor / Method / Responsibility / Frequency / Timing Location, Responsibility, Macro-invertebrates Fish Populations Habitat Walkover Cross- frequency & timing (three minute kick and one (EA WFD Classification (Amended Hendry- sectional Water quality minute hand search) Method (TBC)) Cragg-Hine, 1997) profiles Location 8 EA EA (D/S Hampton Loade & Trimpley) STWL STWL as programmed EA as programmed at relevant Bewdley spring, summer & autumn summer (at gauging as programmed locations SO7964271581 stations)

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Appendix I: General Specifications for Environmental Monitoring

Appendix J: HRA Severn Estuary

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Appendix C: Statement of Response: Detailed List of Representations with Company Responses

South Staffs Water - Draft Drought Plan 2012 Appendix A – Representation Details and Company Responses Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan 1 Consumer CCWater submitted comments on the Company’s Draft Council for Drought Plan directly to the Company and copied the Water comments to Defra as they believe that only serious concerns (CCWater) about a company’s plan should be raised directly with Defra.

1. CCWater made a number of helpful comments about the Not part of The Company is grateful for the helpful comments made by CCWater on draft customer leaflets and Frequently Asked Questions formal its draft customer leaflets and Frequently Asked Questions. These do not which the Company included in the consultation to aid Drought form a formal part of the Company’s Drought Plan but the Company will customer understanding. These comments are Plan. make appropriate changes to these. summarised below: Drought leaflet • The drought leaflet should clarify there has been a (household recent change in legislation resulting in the extension customer) of powers for temporary bans on water use. It would and FAQ’s be beneficial to clarify the leaflet text where it is circulated ahead of any temporary restriction to avoid confusion that the ban is already in place. There are a number of areas where it would be beneficial to expand on the Frequently Asked Questions. Specifically more information on what the South Staffs Water public awareness campaign will involve; what the fine would be for using a hosepipe or sprinkler when a ban is in place, and; the extension of powers for temporary bans on water use.

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan 2. CCWater views the non-technical summary (NTS) as the Non The Company will make appropriate changes to the Non-Technical customer-facing version of the Company’s Drought Plan. Technical Summary to improve customer understanding. The summary should include more of the non-technical Summary aspects of the main Plan and Appendices, including customer communication around extra promotion of water efficiency and drought awareness messages and the example notices. The differences in procedures between previous approaches to hosepipe bans and the new powers for temporary bans on water use need to be highlighted. The summary should set out how South Staffs expects to use these powers through possible phasing in of restrictions and possible concessions and exemptions to customers, including a rationale for these concessions/exemptions. In addition to greater clarity the NTS should include more detail on the process for making representations about temporary use bans; information on South Staffs enforcement strategy in cases of non- compliance; volumes saved by these measures, and; some information on how it will communicate with customers as laid out in greater detail in the Main Plan. 3. The Consumer Council Water should be included in the Sect 9.4 The Company recognises the need for enhanced communication during communication section(s) of the NTS and Main Plan a drought. The omission of CCWater in Section 9 of the Drought Plan was an oversight and the Plan has been amended to rectify this. CCWater has been formally included as follows: i Identification of CCWater as a main stakeholder in Section 9.4.1 The Timing and Nature of Communications ii Description of how communications with CCWater will take place iii Description of when CCWater will be contacted as drought measures escalate in Table 6 Communication Plan Overview. 2 South 1. No observations to make No action required Staffordshire Council

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan 3 National Farmers 1. The plan is constructive and well informed No action required Union 2. Farmers and growers need water for livestock, crops and General Public water supplies to farmers for animal welfare would not be affected usual farm operations such as crop spraying and are by any actions proposed in the Company’s Drought Plan. The purpose of aware of, and affected by water shortages. Livestock the Company Drought Plan is to maintain supplies for essential purposes farmers particularly pig and poultry units are especially to all domestic, institutional and commercial customers throughout vulnerable during drought conditions. Animal welfare periods of exceptionally low rainfall. Interruptions of supply are more problems can result from interrupted water supplies. The likely to be associated with mains bursts or other short term emergencies welfare of farmed animals is protected by the Animal and the Company has separate emergency procedures to address and Welfare Act 2006. This Act makes it an offence to cause manage any localised problems. unnecessary suffering to animals. The NFU are therefore keen to assist with the development of South Staffs No changes to the Drought Plan are to be made. Water’s emergency plan for delivery of substantial amounts of water to farmers who may be significant customers, under pressure and vulnerable to drought conditions. 3. The NFU are keen to work with South Staffs Water by co- General The Company welcomes the offer of assistance from the NFU in ordinating and helping with liaison between the water communicating any future appeals to use water wisely and to company, farmers and growers to ensure timely action, communicate any restrictions on non-essential use to its members and Good cooperation and communication. The West will work with the NFU in the event of a drought. Midlands NFU wish to be kept informed of the water resources situation and South Staffs Water’s ability to secure supplies during a drought situation. 4 The Racecourse 1. Racetracks often require to be watered to make sure the 6.3.3 & The Water Use (Temporary Bans) Order 2010 states that using a Association ground is safe, with the possibility of racing being Appendix hosepipe to water a garden for health or safety reasons is not to be abandoned should the turf not meet the strict guidelines Q treated as falling within the category of use of any prohibition. set out by the British Horseracing Authority. The South Staffs recognise the importance of large sporting events in the relationship between serious musculoskeletal injuries and local economy and is prepared to make an exception to the prohibition firmness of ground is near linear. For this reason, firm that a hosepipe may be used to water an area of grass or artificial ground is often a directly contributory factor to small fields outdoor surfaces used for sport or recreation, where this is required in which have a negative impact in racing income. An connection with a national or international sporting event. This exemption is requested from the Temporary Use Ban

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan (watering of a garden e.g. an area of grass used for sport concession will be granted initially during the early phase of or recreation). implementation of a temporary use ban and the Company reserves the right to remove the concession if drought conditions continue and greater demand savings are required. 5 Turfgrass 1. Turf and soft landscaping plays an important part in the 6.3.3 & The Water Use (Temporary Bans) Order 2010 allows the prohibition of Growers environment as a whole, and in particular the water Appendix watering of a garden using a hosepipe, but does not prevent the use of Association environment. It prevents run off compared to hard Q watering cans or buckets. landscaping and, importantly, helps with the replenishment South Staffs believe it is important that the hosepipe ban is applied of aquifers in the future. Established lawns do not require uniformly to all domestic customers. It believes that customers who watering in a time of water shortage and grass that purchase new turf will be prepared and capable of watering it by hand naturally dies back during these periods will almost and this will avoid the excessive use of potable water. certainly recover once there is rainfall. However newly laid turf needs to be kept damp for the first 28 days in order to establish successfully. A 28-day exemption is requested for newly laid turf during the initial stages of any restriction.

6 The Environment The Environment Agency made a number of comments Agency classified as either relating to legislation, being of a moderate

nature or being of a minor nature. The Environment Agency

did not raise any issues which it considered to be of a

significant nature. Compliance with relevant legislation Chapter 8 & Appendix 1. Section 4(e) of the Drought Plan Direction 2011 requires H See Statement of Response Overview Statement section 3.4. description of the measures that may be needed to mitigate any adverse effect on the environment resulting from the implementation of a drought management measure. 2. Section 4(f) of the Drought Plan Direction 2011 requires Chapter 8 description of the permits and approvals that may be & Appendix See Statement of Response Overview Statement section 3.4. needed in order to implement those mitigation measures. H

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan 3. Section 4(g) of the Drought Plan Direction 2011 requires Chapter 8 description of the compensation that may need to be & Appendix See Statement of Response Overview Statement section 3.4. made as a result of the implementation of a drought H management measure. The plan does not include details of what compensation it may be required to provide as a result of adverse effects from implementation of supply- side drought actions. The company should include details of any compensation that would be made available if other abstractors are adversely impacted by supply side drought measures. Moderate Issues The Company has revised and provided more detail on the timing of 1. Order of drought action implementation: The timing of drought management actions. The proposed changes to the plan can be implementation of drought management actions is not Section 5 summarised as: appropriate. The plan states that the company will begin 1. The description of additional actions in the drought monitoring phase its two week representation period for temporary (between Trigger 1 and 2) including the transfer of potable water to restrictions on the day they submit a drought permit Blithfield Reservoir. application. In most circumstances, temporary restrictions 2. The phased implementation of appeals to customers to reduce should be in place before a drought permit application is demands, and; the advertisement of a temporary use ban, made. Demand savings from this action can remove or 3. The implementation between Trigger 2 and Trigger 3 of the action to delay the need for a drought permit if the drought impose a temporary use ban. progresses. Implementing drought permits before 4. The description of additional actions related to the application for and temporary restrictions may present an unnecessary risk to implementation of an Ordinary Drought Order. the environment in a drought. The Environment Agency

will not support drought permit applications that do not The revised text to be included in the Final Drought Plan is reproduced in demonstrate that appropriate demand savings have been the Statement of Response Overview Statement. made. Not being able to demonstrate this could mean that

the company experiences a delay in being able to

implement the drought permit. The company should review its approach to implementing drought actions, following guidance in section 5 of our drought plan guideline. The drought plan should present further information and appropriate reasoning for its preferred approach.

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan 2. Environmental Monitoring Plan: The drought plan does Section 8 The Company recognises that the development of an acceptable not demonstrate that the company will adequately monitor environmental monitoring plan is work in progress. The Company has the environment before, during and after a drought. The agreed a way forward with the Environment Agency and hopes to drought plan references environmental monitoring in its conclude a robust and comprehensive monitoring plan by the end of environmental reports for two of its drought permit summer 2012. The Company accepts that without an accepted options, but these reports are not complete or publicly monitoring plan any proposals for implementation of drought permits may available. The absence of this information means we be difficult to progress and therefore this area of work is a priority for the cannot determine if the proposed monitoring is Company. appropriate or would be effective. The company state they Details of the latest position with regards to the environmental monitoring will use Environment Agency monitoring data but doesn’t plan are included in the Statement of Response Overview Statement state what specific data they will use to meet the needs of section 3.4. specific monitoring sites. We don’t consider that data from our monitoring schedule will be sufficient or appropriate for the company to complete its required environmental monitoring and assessment. We cannot determine if mitigation measures would be needed because the monitoring plan is not sufficient. Mitigation measures are unlikely to be effective without adequate monitoring. This absence of monitoring information is linked with non- compliance of Directions 4 (e) and (f).

3. Communications: The communication plan in the draft Section 9 The Company has revised the communication section of its Drought plan does not include sufficient information or detail to Plan. The main changes relate to roles for the Drought Management demonstrate that the company will effectively Team which have been revised and the clarification of the different communicate with its customers and stakeholders during audiences and type of communications which will be relevant during a drought. The plan focuses on liaison with the drought management. Environment Agency relating to technical and operational Drought management has been more closely integrated with the supply drought communications, but does not properly consider management process. The team has been strengthened by the liaison with neighbouring water companies, customers incorporation of the Head of Production to create an Executive of Three and other stakeholders. which adopts the Company’s proven successful model for incident management and control. The frequency of meetings has been increased from fortnightly to weekly.

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan In addition to technical support from other roles the Team will be supported for the duration of the drought by a permanent secondment from the Customer Engagement Department who will act as Drought Communications Co-ordinator and report directly at the weekly drought meeting. The Drought Communications Co-ordinator together with the Drought Strategy Manager will act as a point of contact for all communications with external stakeholders ensuring these are regular and timely.

4. Ordinary drought order lead-in time: The draft plan states As discussed under EA Moderate Issue 1 further detail has been that the company would allow 2 weeks lead-in time to provided in the plan, particularly on the pre-consultation and application prepare information for an ordinary drought order phases of drought permits and ordinary drought orders. application to restrict demand. We are concerned that the company has not allowed sufficient time for this preparation work, given the information requirements of this type of application and the fact that the company has not been required to apply for a drought order before.

Minor Issues

1. Scenarios and Triggers: The scenarios used in the plan are all two year droughts - based on the droughts of Sections Section 4.1 of the Water Company drought plan guidelines (EA, June 1933/34, 1975/76 & 1995/96. No shorter or longer term 3.4 & 4 2011) states that reservoir levels can be developed into trigger curves scenarios have been assessed. If the company had using water resource system modelling techniques, and/or from historic experienced high summer demand in 2011, we consider reservoir drawdown records, previous drought experience and expert that the company may have needed to apply for a drought knowledge of the water company system response. Section 3.4 of the permit after only one year of drought. Implementing these Company’s Drought Plan discusses how the Company’s water resources actions after one year of drought does not correlate with model (Wrapsim) was further developed and used to revise and improve the triggers and actions proposed in the drought plan - trigger curves, and furthermore evaluated against the 84-year historic which more closely matches the proposed actions for a record including a number of single and 2-year periods of reduced

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan two year drought. In addition, no information is included rainfall, concluding that the Company’s present supply system is with the drought plan on how scenarios have informed the primarily vulnerable to 2-year droughts and should there be a repeat of development of the company's drought triggers. the rainfall sequences observed, only in 1933/34 or 1975/76 would customer restrictions be required, matching operational experience. A number of drought scenarios are tested in Section 4.1 of the Company Plan which the guidelines require “to test how robust its drought triggers are and to demonstrate how drought management actions would be implemented given a range of drought conditions and elevated demands”. This section has not been used to further demonstrate how this has been used to help develop drought triggers because this is inherent in the water resources modelling approach covered in Section 3.4. The Company agrees that it will be informative to undertake a review of 2011 and consider ‘what if’ scenarios based on possible higher summer demands. Until this review is undertaken it is not possible to determine what the possible outcomes would have been. Section 3.4 of the Company’s Drought Plan states the Company’s proposals to develop its water resources model using a new software platform. The work to migrate to a new platform is underway and due to be completed in time to inform the next Water Resources Management Plan for the 2014 Periodic Review. Once development of the new model is complete the Company will investigate additional drought scenarios such as 1-year (like 2011) and 3-year droughts and other events which have not previously been observed in the historic record but may be useful for resilience planning. No changes to the plan are proposed at this point in time. 2. Demand Reductions: No information is included in the Section 6.3 There is no discrepancy between the figures quoted in section 6.3.3 and draft plan on how demand reductions have been table 1 and appendix F. Section 6.3.3 quotes “a nominal saving of calculated. There is also a discrepancy on the demand between 5.0% and 9.5% of demand” whilst Appendix F quotes a demand saving resulting from a temporary use ban, with the text in saving of c.10 – 20 Ml/d. The percentage savings are taken from the

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan s6.3.3 saying 9.5Ml/d and table one and appendix F UKWIR report “Drought and Demand: Modelling the Impact of saying 10-20 Ml/d. Restrictions on Demand during Drought” Report Ref: 07/WR/02/3. The percentage figures have been applied to domestic demand (approx 200Ml/d) and hence the saving of between 10 and 20Ml/d has been calculated. The Company considers that the actual savings from a temporary use ban will be very uncertain and believes that this range is approximately correct. No changes to the plan are proposed.

3. Temporary Restrictions: No reference is made to liaising Section 5.5 The Company recognises the importance and benefit of co-ordinating with neighbouring water companies to coordinate the messages regarding temporary use restrictions and ensuring that the approach to the use of temporary restrictions. potential for customers to be confused is minimised. Liaison with Severn Trent Water has been reinforced within the communication section (section 9) of the Drought Plan. Appendix Q states that we will carry out communication with Severn Trent Water on identification of potential and actual restrictions (e.g. hosepipe bans) and this will be better cross- referenced in Sections 5 and 6. 4. Supply side Options: No information is included in the Appendix H Explanation has been provided in Section 6.4 but further clarification of draft plan on how estimated increases to supply have peak yields and improved cross-referencing of quoted values in all (also been calculated. relevant sections (Section 7, Appendix H, I & J) will be included in the Appendix Final Plan. I&J, Sections 6.4 & 7)

5. End of drought Review: The plan does state that there Section 5 The Company regards “lessons identified” reviews as a vital tool in will be an end of drought review, but does not specify learning from incidents, particularly relatively infrequent ones such as what the areas the review will cover and what reports will droughts where operational experience is rare. Section 3.3 describes a be produced and published as a result. number of strategic investments made by the Company to improve its resilience. Many of these derived from a review of experiences during

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan the 1995/96 drought. A fuller description of the areas that the drought review will consider will be included at the end of Section 5. 6. End of drought Triggers: The plan doesn’t indicate that Section 5 The Company has amended its Plan to indicate that it will discuss the the company will contact the Environment Agency to water situation with the EA before declaring the end of drought discuss and confirm the water situation before declaring conditions. that the drought is over. The plan does outline how the The Company has also revised its triggers for the end of the drought for company will decide if a drought is over for Blithfield the River Severn. Reservoir, but for the Severn it states that this will be when the Environment Agency revokes any Severn drought order. This may not be an appropriate way to determine the end of a drought. 7. Legislation: The company has not referred to a key piece Section 2.1 Footnotes and explanatory notes in Appendix Q provide explanation that of legislation relevant to demand management in section & Appendix The Water Use (Temporary Bans) Order 2010 was enabled by the Flood 2.1 and appendix Q. Reference to the Flood and Water Q and Water Management Act 2010 and our draft customer notices Management Act 2010 is absent in the drought plan. (Appendices N and O) make explicit reference to the Act. Reference to this legislation has also now been included in section 2.1 7 Fire Brigade 1. No observations beyond the request for early consultation General South Staffs Water attend regular liaison meetings with the through normal engagement channels in relation to any representatives of the regional statutory fire and rescue services in our drought response measures that may affect the provision area and will keep them informed of any issues through this route. If for operational fire fighting. communication is required between meetings then specific contact will be made with the Fire Brigade. 8 Project Fire 1. There is the potential to reduce the amount of water used 6.3.2 SSW actively participates in the UK Sprinkler network which is lead by Products Limited in the normal inspection and testing procedures of the members of the differing sprinkler associations. A proposed change automatic fire sprinkler systems through the use of in S57 of the 1991 Water Industry Act has resulted in a Water UK proprietary products. There are similar uses of water headed group who are reviewing the implementation of domestic associated with testing of fire hydrants. sprinklers. The UK sprinkler network group meets on a quarterly basis and its objectives include: i. Managing the way domestic sprinklers are connected to the

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan distribution system ii. Understanding what flow rates are required in accordance with British Standards iii. Adherence to National Guidelines for the Supply of Water to Fire Sprinkler Networks We believe these measures will help limit the use of water during testing whilst ensuring systems are properly maintained in light of British standards; and products are used which meet the necessary water quality (WRAS) standards. The potential for accelerating these actions during a drought is extremely limited and we do not propose to change our drought plan. 9 English Heritage 1. We are keen to ensure that the issuing of drought permits 6.6 The Company’s current drought plan (2012 – 2016) does not include any for groundwater abstraction in wet areas does not harm proposals for drought permits to abstract greater volumes from any of its preserved waterlogged deposits. Water logged deposits groundwater sources than current licensed volumes. are rare and potentially important archaeologically. If this position changes and the Company determines that a groundwater drought permit is a viable part of a future drought plan, the impacts of additional abstraction on archaeological heritage will be included as part of the necessary environmental screening process. No changes to the current plan are to be made. 10 Car Wash 1. Under Section 6.3.5 Ordinary Drought Orders, two 6.3.3 & As stated in Section 6.3.3 of the Company’s draft drought plan the Association categories of water use prohibited are “operating a 6.3.5 intention of temporary water restrictions (i.e. Temporary Use Bans under mechanical car washer” and “Cleaning any vehicle, boat, powers of the Flood and Water Management Act 2010) is not to prevent aircraft or railway rolling stock”. These would prevent any legitimate commercial use or to prevent domestic customers from using of the car washing businesses represented by the Car watering cans or buckets. Wash Association (CWA) from trading. The Company intends to retain the restriction on “cleaning a private CWA believes that exemptions are granted from the motor vehicle using a hosepipe” because experience has shown that Temporary Use Bans for businesses whose commercial householders can use excessive amounts of water cleaning their cars in activity would be duly affected and would recommend that this way. On balance it agrees that car wash businesses on commercial certain businesses should be allowed to continue to trade: premises have the potential to use less water than many car owners

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan i. Conveyor car washes who derive all of their income using hosepipes and it is not our intention at this phase in a drought from car washing have no other source of income. They (implementation of a Temporary Use Ban) to prohibit such commercial have invested in water recycling systems and are thus activities. able to temporarily configure the wash process to use a Section 6.3.5 Ordinary Drought Orders (Bans on Non Essential Use) significantly restricted and verifiable amount per wash. describes plans to prohibit water uses including operating a mechanical The CWA would recommend that the usage of fresh vehicle washer and cleaning any vehicle, boat, aircraft or railway rolling water per wash would be limited to 30 litres. This would stock. These prohibitions draw on powers granted to water companies allow the businesses to continue trading and provide the as part of the Drought Direction 2011 under the Water Resources Act public with an option to legally wash their car in a 1991. Under these powers some vehicle cleaning may continue for location that can be readily monitored for water usage. health and safety purposes and hand washing may continue so long as a ii. Rollover car washes are in the majority located at petrol hosepipe or mechanical washer is not used. filling stations and due to falling margins from fuel sales are now considered to be an essential source of Ordinary Drought Orders will only be used under conditions of an revenue. Some rollovers have recycling systems and exceptional shortage of rain should other measures to conserve supplies could operate under the conditions listed above for (such as Temporary Use Bans) be inadequate. These powers were first conveyor washes. Rollovers without recycling would be granted to water companies in 1976 as it was recognised that further encouraged to invest in recycling systems or cease measures in addition to domestic hosepipe bans were necessary to limit trading during the drought. The car washing industry the requirement for standpipes in a severe drought. As such the could self-certify or undertake a process of Company is not currently prepared to change Section 6.3.5 of its Drought measurement and accreditation through independent Plan. certification from the wash manufacturers to ensure that The Company notes however the intention of the car wash industry to conveyor and rollover washes allowed to operate are move to certification of its capability to limit water usage to less than 30 limiting their water usage to less than 30 litres per car. litres per car. Progress on this initiative will be viewed favourably in the

Company’s ongoing reviews of its Drought Plan. The Company will keep Jet washes are widely used in the car wash industry. its position with regards to concessions under review. Conveyor washes use them to prepare a car before the wash process, petrol stations have “buy time” jet washes for public use and many hand car washes use them as well. Monitoring the usage per wash would be difficult and it is unlikely that a usage of less than 30 litres per car could be managed. Hand car washes, providing jet washes are not being

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan used, can wash a car using less than 30 litres if well managed. The CWA concern is that many hand car washes operate from locations with poor drainage and no meters to monitor the amount of water used per wash. Provided they can demonstrate their water usage this trading should be allowed. Based on previous drought experience in 2006 and 1991, the CWA believe that some car owners will try and wash their car whatever restrictions are imposed. Allowing professional car washes to operate within agreed restrictions would almost certainly assist in efforts to conserve water whilst providing a legally-compliant car washing alternative for car owners who might otherwise be inclined to ignore the ban. 11 British 1. British Waterways has been previously consulted by South 7.2, 7.3 British Waterways (BW) will be consulted over the impacts to navigation Waterways Staffs Water concerning three plans for additional water and 7.4 of any future changes as part of any future review of drought schemes. supplies at: Hanch Tunnel; River Blithe and River Trent, The current communication plan (Appendix G) states that BW will be and; Hampton Loade (two options). British Waterways contacted when drought actions are starting to be planned which may have no significant concerns about the proposals in their affect navigation. present form and appreciate the opportunity to comment No change to the plan required. on the Draft Drought Plan. If there is a need to further develop or modify any of the above schemes, they should be contacted as early as possible. 12 Natural England Balance between environment and demand management actions 1. Overall there does not seem to be an adequate balance Section 5 The Company is confident that its stated level of service is not gained by between impacts on the environment and impacts on exploiting the use of drought permits and thereby leading to a risk to the customer service (demand management actions). environment in this way: It appears that one of the main drivers for the company’s i The level has been determined by the comparison of operational response to drought is based around its commitment to experience with the modelled behaviour of its supply system over an customers of insuring that a hosepipe ban is experienced

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan on average once every 40 years and this target seems to 84-year historic record. control timing of the response of the company to ii The modelling allows customer restrictions (temporary use bans) to impending drought. This has led to a plan where be imposed where the relevant drought trigger (implement drought applications for drought permits are requested before permit) is crossed and this occurs in 1934 and 1976. Consequently a appropriate demand measures have been taken leading to level of service of 1 in 40 years was determined for the imposition of a a risk to the environment. temporary use ban. It appears that a hosepipe ban is likely to provide the iii The modelling does not allow/simulate the use of drought permits company with the greatest saving on water use. The and/or drought orders and these do not influence the calculation of timing of this intervention is therefore critical to the timing levels of service. and the operation of any drought permit. It seems to be The Company has further considered the relative timing of temporary inappropriate that this control mechanism is considered use bans and drought permits (see EA Point 4). only at the same time as the drought permits are exercised and even then only if appropriate. It should be noted that in the case of a winter drought permit (e.g. Natural England’s view is that the order of drought Blithe/Trent and Hanch Tunnel permits) customer demand will already be responses needs to be reviewed here to ensure that more depressed over the winter period and formal restrictions ineffective. demand control activities are carried out in advance of an application for a drought permit on the Severn with this continuing before any permit is exercised. Environment Monitoring and Mitigation 1. There is a lack of a detailed environmental monitoring See answer to Environment Agency Moderate Issue 2 plan. The River Severn has a complex water resources Details of the latest position with regards to the environmental monitoring management system which includes a regulated flow from plan are included in the Statement of Response Overview Statement its headwaters, water company abstractions, borehole section 3.4 augmentation and numerous private abstractions. This is controlled by a flow rate at Bewdley which is designed to meet various ecological requirements including those of the Severn Estuary SAC and SPA. Operations that may impact on the flow at Bewdley, such as drought permits, will therefore require Habitats Regulation Assessments. Of the two (drought permit) options proposed for Hampton Loade the second (245 Ml/d) is shown to have a Likely

South Staffs Water Final Drought Plan February 2013: Appendix C

Organisation Key Points Raised Section SSW Proposed Amendments to the Plan of Plan Significant effect on the Severn Estuary European sites.. The company needs to explore the potential options for mitigation before this option is placed in the plan to allow a clear understanding of what may be required to be done to mitigate for any impact should this option pass the sequential tests of, no available alternative and then overriding public importance. The plan does not give enough information to show clearly that these two tests could be passed. Stakeholder Communication Plan 1. There is a lack of clarity over stakeholder engagement See answer to Environment Agency Moderate Issue 3. during drought periods. Timescale for Drought actions 1. The timescales for actions seem to be optimistic and See answer to Environment Agency Moderate Issue 1. activities are not clearly presented with poor evidence around some issues such as demand management A comprehensive summary of the revised triggers and actions are now impacts. provided by the provision of more detail within Section 5 Figure 9 In general the plan appears detailed and has several (Drought Control Rules: Triggers and Main Actions) and Section 9 Table approaches within it, with timetables scattered throughout 5 (Communication Plan Overview). the document. This makes understanding the full process and the trigger points difficult to follow. We would recommend strongly that the plan contains a brief summary of the actions envisaged to allow an understanding of timings and options clearly to be set out (extending Figure 7). Some of the timings around for instance issuing of drought permits seem to be optimistic and the lead in time between demand management measures and drought permit applications/implementation seems very short.

.

South Staffs Water Final Drought Plan February 2013: Appendix C

APPENDIX D: Environment Agency River Severn Drought Order Process

Drought order preparation: The Environment Agency prepares the drought order application in discussion with stakeholders (including water companies, NFU, CLA, FUW) and considers; • the requirement/nature of a Section 57 ban • Whether to include ‘emergency storage’ drought order conditions as part of the application. • Whether the drought order needs to include varying the Shropshire groundwater licence. The Environment Agency and water companies circulate reservoir refill prospects.

Communications: Alert Curve The Environment Agency organises a meeting with water companies* to discuss the drought situation on the Severn and wider. Further meetings may be required within this drought ‘zone’.

The Environment Agency intensifies its appeals for restraint in the media. The communication plan will be followed in liaison with water companies, to ensure conflicting messages are not delivered.

*This initial meeting will comprise the River Severn Drought Management Group: Environment Agency, Severn Trent Water, South Staffordshire Water, Bristol Water and United Utilities. At this meeting the group will decide the frequency of further meetings and consider liaising with other groups including Eon, British Waterways, NFU and English Nature. Drought order application: The Environment Agency applies for a drought order to the Secretary of State.

Communications: The Environment Agency will seek agreement with United Utilities on opportunities for a Vyrnwy overdraft. Application The Environment Agency will organise a meeting of the River Curve Severn Drought Management Group to discuss: Voluntary reductions in abstraction that could be implemented immediately. Reductions in abstractions that will be applied once the drought order is granted. The Environment Agency will inform other stakeholders of the application and the nature of its proposed conditions. Drought order conditions become live: Prescribed flow @ Bewdley reduced to 730 Ml/d. Max releases @ Clywedog capped to 300 Ml/d. If agreement in place - Vyrnwy overdraft used to support estuary Enforce subject to other needs. Curve 5% daily licence reduction in non-spray irrigation licences. The 5% reduction will be pro rata to the remaining available licence during the first 100 days of regulation. The 5% reduction will on top of daily maximum regulation constraints during maximum regulation.

South Staffs Water Final Drought Plan February 2013: Appendix D

Reduce abstraction @ Gloucester to 195 Ml/d during high tides (>9m). Section 57 ban on surface spray irrigation abstractions.

Timing of Drought Order Conditions: It is anticipated that it will take at least 28 days for the Order to be granted, assuming a public hearing is required. This lead-time is built into the curves. If the drought order is granted sooner, conditions will not become live until the ‘enforced’ curve is crossed.

Shropshire Groundwater Scheme: If the Shropshire Groundwater Scheme annual or five-year rolling licences are expected to be exceeded, the Environment Agency will consider applying to vary the licence as part of the drought order application.

Communications: The Environment Agency will organise a joint meeting with stakeholders2 to discuss the drought situation and drought order conditions. Further meetings may be required within this drought ‘zone’. The meeting should look ahead to possible implementation of emergency storage conditions and amendments to the drought order if not included in original application.

2This meeting should include: Severn Trent Water, South Staffordshire Water, Bristol Water, United Utilities, Eon, British Waterways, English Nature, NFU and Water UK. Options considered to enhance drought order conditions: (will depend on the extent and timing of drought). Prescribed flow @ Bewdley further reduced to 650 Ml/d subject to releases from Clywedog Reservoir capped to 1.5% of remaining storage. Reduction in daily licensed quantities of non-spray irrigation licences Emergency above 5%. Storage

Communications: The Environment Agency organises a meeting with the River Severn Drought Management Group to discuss the drought situation and enhanced drought order conditions. Further meetings, with other groups may be required within this drought ‘zone’. Drought Order Cessation Consider withdrawing drought order application if storage rises above ‘alert’ curve. Consider relaxing drought order conditions once storage rises 10% above ‘enforce’ curve. (Note: Drought order powers are in place for six months after date granted. Conditions could be implemented again without another application if storage subsequently drops below ‘enforce’ curve). Consider Relaxing Emergency Storage Drought Order Once Storage Rises 5% above Emergency Storage.

Note: Drought order powers can be extended within the last 28 days of the agreement. The Environment Agency will discuss with the River Severn Drought Management Group if it intends to apply for an extension to River Severn drought order powers.

South Staffs Water Final Drought Plan February 2013: Appendix D

APPENDIX E: DROUGHT MANAGEMENT SCHEDULE

Stepping Up/ Resultant Effects Comments following (SU) (savings in DO, de-brief session Date Action Taken Reason for Action Standing reduced draw on (e.g. positive action, Down (SD) Blithfield etc) timing good/poor)

South Staffs Water Final Drought Plan February 2013: Appendix E

APPENDIX F:– DEMAND MANAGEMENT OPTIONS (Option 1 - Promotion of Water Efficiency)

Option 1: Extra Promotion of Water Efficiency and Customer Drought Awareness Messages

Triggered by reservoir storage levels falling below the Blithfield Drought Monitoring Curve or EA Clywedog Drought Alert Curve. Triggers or Preceding Actions

Preceded by a forecast of reservoir storage and by a meeting of the Drought Management Team. Estimated Demand Saving c. 3 Ml/d

Implementation Timetable It is expected that this action will take 2-4 weeks to prepare and implement. This is likely to begin at the start of the drought period, probably in late spring, early summer, Preparation, time of year and it will continue throughout the drought. effective, duration.

Permissions Required and The timing and content of messages, and the detailed nature of the increased water Constraints efficiency campaign will be determined by the Drought Management Team. No external approvals required. Including details of liaison with bodies responsible for giving permits or approvals Option Implementation Assessment Implementation Option Risks Associated with Option None

South Staffs Water Final Drought Plan February 2013: Appendix F

APPENDIX F:– DEMAND MANAGEMENT OPTIONS (Option 1 continued - Promotion of Water Efficiency)

Risk to the Environment Low High, medium, low, or unknown

Summary of Possible None

Environmental Impacts

Details of Studies None

ssessment Undertaken or Required

Monitoring Requirements None

Mitigation Actions None Environmental A Environmental

Impact on Other Activities, None Public, industry etc.

South Staffs Water Final Drought Plan February 2013: Appendix F

APPENDIX F:– DEMAND MANAGEMENT OPTIONS (Option 2 Increased Leakage Detection and Repair)

Option 2: Increased Leakage Detection and Repair

Triggered by reservoir storage levels falling below the Blithfield Drought Monitoring Curve or the Clywedog Drought Alert Curve. Triggers or Preceding Actions Preceded by a reservoir storage forecast for Blithfield by SSW, and for Clywedog ( by the EA). Also preceded by a review of available leakage management resources.

Deployable Output of Option c. 1.5 Ml/d

Implementation Timetable Although this action could be initiated within 2-4 weeks, the logistics of procuring staff and delivering benefits will require at least 5 months to deliver addition benefit. Preparation, time of year effective, duration. This action can take place at any time, depending on storage levels at Blithfield and the available water resource on the River Severn, however it is most likely to be initiated in the late spring early summer. This action will continue until Blithfield stocks and or Clywedog stocks increase to 5% or more above the Drought Monitoring/Alert Line. Permissions Required and This action will require the approval of the Drought Management Team and the SSW Board of Constraints Directors. No external approvals are required. Including details of liaison with bodies responsible for giving Option Implementation Assessment Implementation Option permits or approvals Risks Associated with Option The main risk associated with this option is the timescale for delivery of the additional benefit, and in the uncertainty over how much additional saving would be achieved.

South Staffs Water Final Drought Plan February 2013: Appendix F

APPENDIX F:– DEMAND MANAGEMENT OPTIONS (Option 2 continued - Increased Leakage Detection and Repair)

Risk to the Environment Low High, medium, low, or unknown

Summary of Possible None.

Environmental Impacts

Details of Studies A review of available leakage management resources would be required in advance of implementing this action. Undertaken or Required

Monitoring Requirements The Company would continue to monitor and report on leakage, to try to identify any savings achieved.

Mitigation Actions N/A Environmental Assessment Environmental

Impact on Other Activities, There may be some additional disruption to the public and to business with the additional activity. Public, industry etc.

South Staffs Water Final Drought Plan February 2013: Appendix F

APPENDIX F:– DEMAND MANAGEMENT OPTIONS (Option 3 Temporary Use Bans)

Option 3: Temporary Use Bans

Triggered by reservoir storage levels falling below the Apply for Drought Permit trigger curve at Blithfield Drought. Triggers or Preceding Actions Preceded by a reservoir storage forecast for Blithfield by SSW, and for Clywedog ( by the EA) and advertisements notifying the general public. Preceded by appeals to customers to reduce consumption.

Demand Saving c.10-20 Ml/d

Implementation Timetable This action can be implemented within 2 weeks following appropriate advertising and consideration of representations. Preparation, time of year effective, duration. This action can take place at any time, this will depend on storage levels at Blithfield, and Clywedog. This action will continue until Blithfield stocks increase to 5% or more above the Drought Monitoring Line, or Clywedog storage is 5% above the Drought Alert Curve. Consideration will be given to the status of River Regulation on the River Severn, and to weather forecasts and reservoir storage predictions. A hosepipe ban will be implemented immediately prior to the implementation of any drought permit. Permissions Required and This action will require the approval of the Drought Management Team and the SSW Constraints Board of Directors. No external approvals are required. Option Implementation Assessment Implementation Option Including details of liaison with bodies responsible for giving permits or approvals Risks Associated with Option The main risk associated with this option is the uncertainty over how much additional saving would be achieved.

South Staffs Water Final Drought Plan February 2013: Appendix F

APPENDIX F:– DEMAND MANAGEMENT OPTIONS (Option 3 continued - Hosepipe and Sprinkler Bans)

Risk to the Environment Low High, medium, low, or unknown

Summary of Possible None.

Environmental Impacts

Details of Studies N/A Undertaken or Required

Monitoring Requirements N/A

Mitigation Actions N/A Environmental Assessment Environmental

Impact on Other Activities, Domestic customers will no longer be able to use hosepipes and sprinklers. Public, industry etc.

South Staffs Water Final Drought Plan February 2013: Appendix F

APPENDIX F:– DEMAND MANAGEMENT OPTIONS (Option 4 Enhanced Pressure Management)

Option 4: Enhanced Pressure Management

Triggered by reservoir storage levels falling below the Implement Drought Permit\Hosepipe Ban line at Blithfield or Clywedog and following a hosepipe ban. This Triggers or Preceding Actions

is because addition pressure management is likely to cause the Company to fail its level of service for mains water pressure (DG2). Demand Saving c. 1.5 Ml/d

Implementation Timetable Any additional pressure management activity is likely to take 2 months to plan, resource and implement. This could take place at any time of year, however it is most Preparation, time of year likely to take place in the late summer/autumn. effective, duration.

Permissions Required and This action will require the approval of the Drought Management Team and the SSW Constraints Board of Directors. No external approvals are required. Including details of liaison with bodies responsible for giving permits or approvals

Option Implementation Assessment Implementation Option Risks Associated with Option The main risks associated with this option is the uncertainty over how much additional saving would be achieved, and the risk of customer complaints due to low pressure, and DG2 failure.

Risk to the Environment Low

High, medium, low, or unknown

Summary of Possible None Environmental Impacts Environmental Environmental Assessment

South Staffs Water Final Drought Plan February 2013: Appendix F

APPENDIX F:– DEMAND MANAGEMENT OPTIONS (Option 4 continued- Enhanced Pressure Management)

Details of Studies N/A Undertaken or Required

Monitoring Requirements None

Mitigation Actions N/A

Impact on Other Activities, Customers may be affected by low water pressure. Public, industry etc.

South Staffs Water Final Drought Plan February 2013: Appendix F

APPENDIX F:– DEMAND MANAGEMENT OPTIONS (Option 5 Ban on Non Essential Use)

Option 5: Bans on Non Essential Use

Triggered by reservoir storage levels falling below the Implement Drought Permit\Hosepipe Ban line at Blithfield or Clywedog and following a hosepipe ban Triggers or Preceding Actions Preceded by a reservoir storage forecast for Blithfield, and by a forecast for Clywedog (from the EA). Preceded by the preparation of a drought order application (2 weeks) and by the determination period (up to 4 weeks).

Deployable Output of Option Unknown.

Implementation Timetable It is anticipated that it would take 2 weeks to prepare the application to DEFRA and up to 4 weeks for the order to be determined. For the order to come in force shortly after a Preparation, time of year hosepipe ban was implemented would require the preparation of the application to effective, duration. begin approximately 2 weeks before the Apply for Drought Permit trigger line is crossed at Blithfield. The application would be made at the same time of the drought permit application (the Apply for Drought Permit trigger curve). This action could take place at any time during the year. However, it is most likely to take place later on in a drought (late summer/ early autumn). The non essential use ban would remain in force until Blithfield stocks increase to 5% or more above the Drought Monitoring Line, or Clywedog storage is 5% above the Drought Alert Curve. Consideration will be given to the status of River Regulation on the River Severn, and

Option Implementation Assessment Implementation Option to weather forecasts and reservoir storage predictions. Permissions Required and Approval Is required from the Secretary of State (DEFRA). Constraints Including details of liaison with bodies responsible for giving permits or approvals

South Staffs Water Final Drought Plan February 2013: Appendix F

APPENDIX F:– DEMAND MANAGEMENT OPTIONS (Option 5 - continued Ban on Non Essential Use)

Risks Associated with Option The main risk associated with this option is the uncertainty over how much additional saving would be achieved.

Risk to the Environment Low High, medium, low, or unknown

Summary of Possible None.

Environmental Impacts

Details of Studies Undertaken N/A or Required

Monitoring Requirements None

Mitigation Actions N/A Environmental Assessment Environmental

Impact on Other Activities, Some businesses , in particular those offering cleaning services, could be significantly affected by a ban on non essential use. Public, industry etc.

South Staffs Water Final Drought Plan February 2013: Appendix F

APPENDIX G: COMMUNICATION PLAN

Stakeholders SSW and Stakeholder Timing and Frequency of Information Required SSW Coordinator Information Communication Method Interested Contact Communication Provider Parties The timing and frequency SSW's water resources position. of communication will Communication will take place via What actions SSW is taking. depend on which drought the Company Website and through Drought Strategy Water saving messages. Water triggers are crossed (see specific press releases and media General All of SSW Manager / Drought Identification of potential and Strategy Section 4 of this Drought campaigns. Information regarding Public customers Communications actual restrictions (e.g. hosepipe Unit Plan). An increasing customer restrictions will be Co-ordinator bans) and the cessation of intensity of communication advertised in the local and regional restrictions. will take place as a drought press. develops.

SSW's water resources position. What actions SSW is taking. Continuous. The timing What external communications and frequency of are proposed. Identification of communication will depend potential and actual restrictions on which drought triggers (e.g. hosepipe bans). Detailed Regional Water are crossed (see Section 4 Meetings. Situation reports and data Environment communication on drought permit Drought Strategy Drought Strategy of this Drought Plan). In exchanges by email. Drought permit Agency applications, and environmental Manager Coordinator Unit particular, however there applications by post. monitoring. Detailed will need to be close communication required on the dialogue as the Apply for Regulation of the River Severn by Drought Permit trigger is the EA, and of the potential for approached. using Chelmarsh to manage the river flow at Bewdley.

SSW's water resources position. Continuous. The timing What actions SSW is taking. and frequency of Chairman of Water Meetings. Situation reports and data Severn Trent What external communications Drought Strategy communication will depend the Drought Strategy exchanges by email. Drought permit Water are proposed. Identification of Manager on which drought triggers Action Team potential and actual restrictions Unit are crossed (see Section 4 applications by post. (e.g. hosepipe bans). Detailed of this Drought Plan). In communication on the joint particular, however there

South Staffs Water Final Drought Plan February 2013: Appendix G

Stakeholders SSW and Stakeholder Timing and Frequency of Information Required SSW Coordinator Information Communication Method Interested Contact Communication Provider Parties abstraction at Hampton Loade will need to be close and Trimpley. Also on any dialogue as the Apply for drought permit applications, and Drought Permit trigger is environmental monitoring issues approached. with respect to the River Severn. Potential use of STW's water resources model for the River Severn to examine scenarios.

SSW's water resources position. Continuous. The timing What actions SSW is taking. and frequency of Detailed communication on the communication will depend abstraction on the River Severn. on which drought triggers Also on any drought permit Water Water are crossed (see Section 4 Meetings. Situation reports and data applications, and environmental Drought Strategy Bristol Water Resources Strategy of this Drought Plan). In exchanges by email. Drought permit monitoring issues with respect to Manager Manager Unit particular, however there applications by post. the River Severn. Communication will need to be close wrt the potential use of STW's dialogue as the Apply for water resources model for the Drought Permit trigger is River Severn to examine approached. scenarios.

Continuous. The timing Head of Drought Strategy and frequency of Supply SSW's resource position and Water Manager / communication will depend OFWAT Demand actions. Identification of any Strategy By letter and email. Regulation on which drought triggers Balance potential supply restrictions. Unit Manager are crossed (see Section 4 Team of this Drought Plan).

Should it appear possible Relevant Any concerns that SSW may Drinking Drought Strategy Water that drought conditions Inspector have that the drought may impact By letter and email. Subsequently by Water Manager / Director Quality may present concerns to appointed by on the quality of public water meetings if required. Inspectorate of Water Quality Team customers about the the DWI. supplies. quality of their supplies.

South Staffs Water Final Drought Plan February 2013: Appendix G

Stakeholders SSW and Stakeholder Timing and Frequency of Information Required SSW Coordinator Information Communication Method Interested Contact Communication Provider Parties Continuous. The timing and frequency of SSW's water resources position. communication will depend Head of What actions SSW is taking. on which drought triggers Branch, Drought Strategy Identification of potential and Water are crossed (see Section 4 Water Manager / Head of DEFRA actual restrictions (e.g. hosepipe Quality of this Drought Plan). In By letter and email. Supply and Drought bans). Detailed communication Team particular, however there Regulation Management Team on drought permit and order will need to be close Division applications. dialogue as the Apply for Drought Permit trigger is approached.

SSW's water resources position. What actions SSW is taking. In particular what impact there may Drought Strategy be on customers. What additional Manager / Head of Continuous. The timing demand management and Drought Water and frequency of CCWater Regional leakage reductions measures are Management Team Strategy communication will depend By letter and email. Midlands Manager planned. What water saving / Drought Unit on which drought triggers messages have been issued. Communications are crossed Identification of potential and Co-ordinator actual restrictions (e.g. hosepipe bans) and the cessation of restrictions.

Other consumer SSW's water resources position. Continuous. The timing groups & What actions SSW is taking. With Water Drought Strategy and frequency of stakeholders particular emphasis on the Strategy By letter and/or email. Manager communication will depend such as NFU, potential impact on relevant Unit on drought triggers. IOG, Fire issues for each group. Brigade

Water UK Policy SSW's water resources position. Drought Strategy Water Continuous. The timing By email.

South Staffs Water Final Drought Plan February 2013: Appendix G

Stakeholders SSW and Stakeholder Timing and Frequency of Information Required SSW Coordinator Information Communication Method Interested Contact Communication Provider Parties Development What actions SSW is taking. Manager / Head of Strategy and frequency of Advisor Identification of potential and Drought Unit communication will depend actual restrictions (e.g. hosepipe Management Team on which drought triggers bans). Detailed communication / Drought are crossed (see Section 4 on drought permit and order Communications of this Drought Plan). In applications. Co-ordinator particular, however there will need to be close dialogue as the Apply for Drought Permit trigger is approached.

SSW's water resources position. Continuous. The timing Head of What actions SSW is taking. In Water and frequency of British Hydrology particular those actions which Drought Strategy Strategy communication will depend By letter and/or email. Waterways and Water may impact on British Waterways Manager Unit on which drought triggers Management (e.g. drought permits or drought are crossed. orders).

SSW's water resources position. What actions SSW is taking. Continuous. The timing Natural Corporate Detailed communication on Water and frequency of England Manager Drought Strategy drought permit applications and Strategy communication will depend By letter and/or email. (West East Manager environmental monitoring in the Unit on which drought triggers Midlands) Midlands West Midlands, where this is are crossed. associated with designated sites.

SSW's water resources position. What actions SSW is taking. Continuous. The timing Corporate Natural Detailed communication on Water and frequency of Manager Drought Strategy England (East drought permit applications and Strategy communication will depend By letter and/or email. West Manager Midlands) environmental monitoring in the Unit on which drought triggers Midlands East Midlands, where this is are crossed. associated with designated sites.

South Staffs Water Final Drought Plan February 2013: Appendix G

Stakeholders SSW and Stakeholder Timing and Frequency of Information Required SSW Coordinator Information Communication Method Interested Contact Communication Provider Parties SSW's water resources position. Continuous. The timing English What actions SSW is taking. Water and frequency of Heritage Regional Detailed communication on Drought Strategy Strategy communication will depend By letter and/or email. (West Planner drought permit applications and Manager Unit on which drought triggers Midlands) environmental monitoring in the are crossed. West Midlands as required.

SSW's water resources position. Continuous. The timing English What actions SSW is taking. Water and frequency of Heritage Regional Detailed communication on Drought Strategy Strategy communication will depend By letter and/or email. (East Planner drought permit applications and Manager Unit on which drought triggers Midlands) environmental monitoring in the are crossed. East Midlands as required.

SSW's water resources position. Continuous. The timing What actions SSW is taking. With Water and frequency of Head of Drought Strategy Peak District particular emphasis on the Strategy communication will depend By letter and/or email. Conservation Manager National Park potential impact on the Peak Unit on which drought triggers Authority District. are crossed.

SSW's water resources position. Continuous. The timing Countryside What actions SSW is taking. With Water Regional Drought Strategy and frequency of Agency (West particular emphasis on the Strategy By letter and/or email. Director Manager communication will depend Midlands) potential impact on relevant Unit on drought triggers. issues in the West Midlands.

SSW's water resources position. Continuous. The timing Countryside What actions SSW is taking. With Water Regional Drought Strategy and frequency of Agency (East particular emphasis on the Strategy By letter and/or email. Director Manager communication will depend Midlands) potential impact on relevant Unit on drought triggers. issues in the East Midlands.

South Staffs Water Final Drought Plan February 2013: Appendix G

Stakeholders and Stakeholder Information SSW Information Timing and Frequency of SSW Coordinator Communication Method Interested Parties Contact Required Provider Communication Birmingham City Director of Planning Council Bromsgrove Corporate Services District Council Director Cannock Chase Chief Executive District Council Derbyshire County Chief Executive Council Dudley MBC Chief Executive SSW's water resources position. East Staffs Principal Officer What actions SSW Borough Council is taking. Water Leicestershire saving messages. Chief Executive Identification of County Council Continuous. The timing and potential and actual Drought Strategy Water Strategy frequency of communication will Lichfield District restrictions (e.g. By letter and/or email. Corporate Director Manager Unit depend on which drought Council hosepipe bans) and triggers are crossed. North West the cessation of Principal Planning Leicestershire restrictions. Key Officer Council issues of relevance to the local Sandwell MBC Chief Executive authority in question. South Derbyshire Deputy Chief District Council Executive South Staffs Chief Executive Council Staffordshire Chief Executive County Council Walsall MBC Chief Executive Wyre Forest Chief Executive District Council

South Staffs Water Final Drought Plan February 2013: Appendix G APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 1: Ensure Existing Baseline Sources are Fully Operational)

Option 1: Ensure Existing Baseline Sources are Fully Operational

Triggered by reservoir storage levels falling below the Blithfield Drought Monitoring Curve or EA Clywedog Drought Alert Curve. Triggers or Preceding Actions Preceded by a review of operational capacity and planned outages by the weekly

Supply Planning team. The deployable output from these sources is already assumed to be in the Company Deployable Output of Option resource base. It is expected that the majority of sources can be made fully operational in 4 weeks. Implementation Timetable This action will take place early on in the drought management sequence and is most Preparation, time of year likely to occur in the spring or early summer. Fully operational sources will continue in effective, duration. supply throughout the drought. Permissions Required and Constraints No approvals required. These sources would operate under existing abstraction licence Including details of liaison with conditions. bodies responsible for giving permits or approvals Option Implementation Assessment Implementation Option

Risks Associated with Option The normal operational risks would apply, such as unplanned outages.

Risk to the Environment High, medium, low, or unknown Low, sources will abstract within existing licence constraints.

Option 1: Sheet 1 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 1: Ensure Existing Baseline Sources are Fully Operational)

Summary of Possible None. Environmental Impacts

Details of Studies N/A Undertaken or Required The Company undertakes abstraction flow and level monitoring under existing Monitoring Requirements abstraction licence conditions. The EA undertakes routine monitoring in all catchments

The compensation flow releases of 22.7 Ml/d from Blithfield Reservoir to the River Mitigation Actions Blithe and 0.227 Ml/d from Chelmarsh Reservoir apply as part of normal licence

Environmental Assessment Environmental conditions.

Impact on Other Activities, None. Public, industry etc.

Option 1: Sheet 2 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 2 – Increase abstraction from the River Severn and reduce abstraction from Blithfield Reservoir)

Option 2: Increase abstraction from the River Severn and reduce abstraction from Blithfield Reservoir

Triggered by reservoir storage levels falling below the Blithfield Drought Monitoring Curve. As storage continues to fall in Blithfield abstraction will be progressively reduced to preserve storage (see Section 5.3) Triggers or Preceding Actions Preceded by a review of operational capacity and resource availability on the River

Severn at Hampton Loade by the Drought Management Team, and by a reservoir storage forecast for Blithfield. The deployable output from this action is already accounted for in the Company Deployable Output of Option resource base. This action can be implemented immediately. Implementation Timetable This action can take place at any time, depending on storage levels at Blithfield and the Preparation, time of year available water resource on the River Severn. This action will continue until Blithfield effective, duration. stocks increase to 5% or more above the Drought Monitoring Curve. Permissions Required and Constraints No approvals required. These sources would operate under existing abstraction licence Including details of liaison with conditions. bodies responsible for giving Option Implementation Assessment Implementation Option permits or approvals

The normal operational risks would apply, such as unplanned outages, e.g. poor raw Risks Associated with Option water quality.

Option 2: Sheet 1 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 2 – Increase abstraction from the River Severn and reduce abstraction from Blithfield Reservoir)

Risk to the Environment Low, sources will abstract within existing licence constraints. High, medium, low, or unknown

Summary of Possible None. Environmental Impacts

Details of Studies N/A Undertaken or Required

The Company monitors storage levels at Blithfield Reservoir and the inflows from the Monitoring Requirements Upper River Blithe, and receives data on Clywedog storage levels and River Severn flow at Bewdley from the EA.

Mitigation Actions N/A Environmental Assessment Environmental Impact on Other Activities, None. Public, industry etc.

Option 2: Sheet 2 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 3: River Blithe (Nethertown) Pumpback)

Option 3: River Blithe (Nethertown) Pumpback

Triggered by reservoir storage levels falling below the Blithfield Drought Monitoring Curve. Abstraction from the River Blithe is pumped up into Blithfield Reservoir. Triggers or Preceding Actions Preceded by a review of operational readiness and resource availability on the River

Blithe and flow conditions on the River Trent (see below), and by a reservoir storage forecast for Blithfield. The deployable output from this action is already accounted for in the Company Deployable Output of Option resource base. This action can be implemented immediately. Implementation Timetable This action can take place at any time.This will depend on storage levels at Blithfield Preparation, time of year and the flow on the Blithe and Trent. This action will continue until Blithfield stocks effective, duration. increase to 5% or more above the Drought Monitoring Line.

Permissions Required and No approvals required, these sources would operate under existing abstraction licence Constraints conditions. A residual flow (normally 9 Ml/d) must be maintained on the River Blithe at Nethertown. The abstraction from Nethertown (and the supporting River Trent Including details of liaison with abstraction ) is restricted by a flow condition on the abstraction licence. When flow on bodies responsible for giving the River Trent at North Muskham (near Newark) falls below 2,650 Ml/d, abstraction Option Implementation Assessment Implementation Option permits or approvals must cease from the Rivers Blithe and Trent at Nethertown.

The normal operational risks would apply, such as unplanned outages, e.g. pump Risks Associated with Option failure. The main limitation of this option is that it is likely that for long periods in a drought the flow on the Trent at North Muskham will be below 2,650 Ml/d.

Option 3: Sheet 1 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 3: River Blithe (Nethertown) Pumpback)

Risk to the Environment High, medium, low, or unknown Low, sources will abstract within existing licence constraints.

Summary of Possible None

Environmental Impacts

Details of Studies N/A Undertaken or Required

The Company monitors storage levels at Blithfield Reservoir, compensation releases from Blithfield, and flow on the River Blithe at Newton Bridge and Nethertown. The EA Monitoring Requirements monitor river flow at Hamstall Ridware on the River Blithe, at North Muskham on the River Trent, and inform South Staffs when residual flows fall below the 2,650 Ml/d limit. Abstraction from the River Trent is discharged at Nethertown to maintain the residual Mitigation Actions flow on the Blithe at Nethertown at a minimum of 9 Ml/d and 17 Ml/d between 15

Environmental Assessment Environmental February and 15 March each year. Impact on Other Activities, None. Public, industry etc.

Option 3: Sheet 2 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 4– Use Nitrate Treatment Sources)

Option 4: Use Nitrate Treatment Sources

Triggered by reservoir storage levels falling below the Blithfield Drought Monitoring Curve.

Triggers or Preceding Actions Operation of Little Hay and Shenstone are preceded by a 2 week process to get works up and running. Pipe Hill treatment works which is already operational is switched from blend to treatment if abstraction from Blithfield Reservoir is low and provides

insufficient water to the area where the blend normally takes place. The deployable output from this action is already accounted for in the Company Deployable Output of Option resource base. Operation of Little Hay and Shenstone are preceded by a 2 week process to get their nitrate treatment works up and running. Pipe Hill treatment works is already Implementation Timetable operational. ion Assessment Preparation, time of year This action can take place at any time. This will depend on storage levels at Blithfield effective, duration. Reservoir. However it is most likely to take place early on in a drought (spring/early summer) and continue until Blithfield stocks increase to 5% or more above the Drought Monitoring Line. Permissions Required and Constraints No approvals required. These sources would operate under existing abstraction licence Option Implementat Option Including details of liaison with conditions. bodies responsible for giving permits or approvals

The normal operational risks would apply, such as unplanned outages, e.g. pump Risks Associated with Option failure.

Option 4: Sheet 1 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 4– Use Nitrate Treatment Sources)

Risk to the Environment High, medium, low, or unknown Low, sources will abstract within existing licence constraints.

Summary of Possible None Environmental Impacts

Details of Studies N/A Undertaken or Required

Monitoring Requirements None

Mitigation Actions N/A Environmental Assessment Environmental

Impact on Other Activities, None Public, industry etc.

Option 4: Sheet 2 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 5– Transfer of Potable Water to Blithfield Reservoir)

Option 5: Transfer of Potable Water to Blithfield Reservoir

Triggered by reservoir storage levels falling below the Blithfield Drought Monitoring Curve. Surplus water from the potable water mains is transferred via the raw water main between Seedy Mill and Blithfield Reservoir. Triggers or Preceding Actions Preceded by a review of operational capacity and resource availability on the River

Severn at Hampton Loade by the Drought Management Team, and by a reservoir storage forecast for Blithfield. See action to obtain environmental permit below. The deployable output from this action is limited as the purpose of this action is to Deployable Output of Option conserve Blithfield Reservoir levels when there is a surplus on the River Severn. The requirement for an environmental permit will be established with the EA once Drought Monitoring has started. An application will require upto 3 months to determine. Operation of the potable water transfer is preceded by a 2 week process to reduce treatment throughput of Blithfield Reservoir water at Seedy Mill WTW and to perform Implementation Timetable valve operations on potable and raw water mains. Preparation, time of year This action is most likely to take place during periods of low demand (generally October effective, duration. to April) and in droughts where River Severn resources are relatively healthy whilst Blithfield stocks are low. It will continue until demands rise; the Severn resources decline or until Blithfield stocks increase enough to provide reassurance that other drought mitigation options are sufficient. Option Implementation Assessment Implementation Option Permissions Required and Constraints This option would operate under existing abstraction licence conditions. Including details of liaison with An environmental permit may be required from the Environment Agency to discharge bodies responsible for giving potable water into Blithfield Reservoir. permits or approvals

Option 5: Sheet 1 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 5– Transfer of Potable Water to Blithfield Reservoir)

The normal operational risks would apply, such as unplanned outages, e.g. pump Risks Associated with Option failure. In addition the option is dependant on demand and the availability of surplus treated water from Hampton Loade WTW. Environmental Assessment Risk to the Environment High, medium, low, or Unknown (anticipated to be low) unknown

Summary of Possible None Environmental Impacts

Details of Studies Risk assessment will be required for the discharge of potable water into Blithfield Undertaken or Required reservoir

Monitoring Requirements Water quality and other monitoring as imposed under the Environmental Permit

Mitigation Actions Treatment (e.g. de-chlorination) and other measures as imposed under the Environmental Permit

Impact on Other Activities, Public, industry etc. None

Option 5: Sheet 2 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 6– Bulk Supply from Severn Trent Water)

Option 6: Bulk Supply from Severn Trent Water (STW)

Triggered by reservoir storage levels falling below the Apply for Drought Permit curve at Blithfield or Clywedog. Preceded by a reservoir storage forecast for Blithfield, and by a forecast for Clywedog Triggers or Preceding Actions (from the EA and STW), and by a meeting with STW to examine the potential for any bulk supplies. The implementation of this option is unlikely (see Section 5.3.5),

however it has been included for completeness.

The existing emergency bulk supply agreements allow for c. 5 Ml/d, however the Deployable Output of Option duration for which this would be available is unknown as it is likely STW would also be experiencing a drought. It is anticipated that it would take 2-3 weeks to meet with STW and to consider the local Implementation Timetable network issues and detailed feasibility at the time. Preparation, time of year This action could take place at any time during the year. However, it is most likely to effective, duration. take place later on in a drought (late summer/ early autumn). The maximum duration of the emergency bulk supply is likely to be less than 1 month. Permissions Required and Constraints Any increase in bulk supply would require the approval of STW, and this would require

Option Implementation Assessment Implementation Option Including details of liaison with that STW did not have a predicted or actual resource issue (this is a condition in the bodies responsible for giving agreement). This is most unlikely if SSW is experiencing a drought. permits or approvals

The risks are that STW will not have available resources, that the bulk supply requires Risks Associated with Option additional treatment or additional infrastructure or network modifications (as they have never been used).

Option 6: Sheet 1 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 6– Bulk Supply from Severn Trent Water)

Risk to the Environment High, medium, low, or unknown Low

Summary of Possible None Environmental Impacts

Details of Studies N/A Undertaken or Required

Monitoring Requirements None Environmental Assessment Environmental

Mitigation Actions N/A

Impact on Other Activities, None Public, industry etc.

Option 6: Sheet 2 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 7 continued – Hanch Tunnel Drought Permit)

Option 7: Hanch Tunnel Drought Permit

Triggered by reservoir storage levels falling below the Apply for Drought Permit Curve at Blithfield Reservoir. As the Apply for Drought Permit curve is approached the Company will consider the need for drought permits and carry out early consultation with the EA, Natural England and other stakeholders.

Preceded by a reservoir storage forecast for Blithfield, and by a forecast for Clywedog (from the EA and STW), and by a meeting with the EA to discuss the proposed Triggers or Preceding Actions application. In the case of a summer permit the application would most likely be preceded by a temporary use ban. Groundwater abstracted from Shaft 1 of Hanch Tunnel at Seedy Mill Water Treatment Works can be pumped directly into the raw water main and discharged into Blithfield reservoir to augment Blithfield Reservoir levels or it may be pumped direct on to the treatment works to enable minimum abstraction from the Reservoir.

Deployable Output of Option Up to 3 Ml/d

The requirement for an environmental permit to discharge the groundwater into Blithfield Reservoir will be established with the EA once Drought Monitoring has started. An application will require upto 3 months to determine.

Option Implementation Assessment Implementation Option Implementation Timetable It is expected that preparation of the drought permit application and the meeting with Preparation, time of year the EA will begin 3-4 weeks before the trigger line is crossed. This is most likely to take effective, duration. place later on in a drought (late summer/ early autumn), however in certain circumstances a winter permit may be sought. The drought permit is likely to remain in place for 3 months, and until reservoir storage at Blithfield and Clywedog is 5% above the Drought Monitoring/Alert trigger.

Option 7: Sheet 1 of 3 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 7 continued – Hanch Tunnel Drought Permit)

Application would be to the Environment Agency which is responsible for determining drought permit applications. This may then require DEFRA approval if referred by the Permissions Required and EA (and may require a Drought Order). Liaison with the EA would take place 3-4 weeks Constraints prior to the application. Liaison would include Natural England as the Stowe Pool SSSI is within the catchment of the abstraction and the Tunnel is also used to augment the Including details of liaison with site (via Shaft 20). bodies responsible for giving permits or approvals The EA has indicated any award would be limited initially to 3 months. An environmental permit is required from the Environment Agency to discharge abstracted water into Blithfield Reservoir. The risks are that the drought permit application will not be accepted by EA and/or DEFRA, or that a public inquiry is required which would delay implementation. However Risks Associated with Option given the low environmental impact this is unlikely. Operation of Shaft 20 will reduce yields. Risk to the Environment

High, medium, low, or unknown Low to medium

The test pumping and monitoring programme has shown that this permit is very unlikely to have any impact on the Leamonsley Brook or the Stowe Pool. Extended Summary of Possible augmentation from Shaft 20 is available if required. Environmental Impacts Low impacts are predicted for habitats and macro-invertebrates but low to medium impacts for water quality and fish due to reductions in dilution flow and the risk of exposure of spawning riffles. 3 month test pumping in 2006 with environmental monitoring and sampling in he

Environmental Assessment Environmental Details of Studies Undertaken Lichfield area including Leamonsley Brook, Stowe Pool and the Hanch Tunnel. or Required Ecological surveys and flow monitoring along the Bourne Bilson Brook in 2011. Environmental assessment in 2012.

Option 7: Sheet 2 of 3 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 7 continued – Hanch Tunnel Drought Permit)

The Company will monitor the Hanch Tunnel groundwater and six sites along the Bourne Bilson Brook. Additional baseline monitoring will be carried out to clarify environmental impacts and further plan mitigation measures and regular frequent Monitoring Requirements monitoring is scheduled for the in-drought and post-drought phases. Surveys will include macro-invertebrates, RHS, habitat walkover and fixed point photography, fish populations, spot gauging and water quality (including DO and temperature) Augmentation of Stowe Pool SSSI from Shaft 20 of the Hanch Tunnel will continue to take priority. Actions to mitigate environmental impacts include temporary reductions or Mitigation Actions cessations in abstraction, habitat protection and habitat restoration. These will be triggered by events observed in the in-drought monitoring programme. These actions are also anticipated to mitigate impacts on downstream abstractions.

Impact on Other Activities, There is a potential medium impact on downstream surface water spray irrigation Public, industry etc. abstractions in the Bourne-Bilson Brook during the growing season.

Option 7: Sheet 3 of 3 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 8– Blithe/Trent Drought Permit)

Option 8: Drought Permit for River Blithe (Nethertown) and River Trent

Triggered by reservoir storage levels falling below the Apply for Drought Permit trigger curve at Blithfield, and river flows on the Trent at North Muskham falling below 2,650 Ml/d. As the Apply for Drought Permit curve is approached the Company will consider the need for drought permits and carry out early consultation with the EA, Natural England and other stakeholders.

Triggers or Preceding Actions Preceded by a reservoir storage forecast for Blithfield, a forecast for Clywedog (from the EA and STW), and by a meeting with the EA to discuss the proposed application. In the case of a summer permit the application would most likely be preceded by a temporary use ban. An additional 23 Ml/d is available assuming no significant loss of compensation water Deployable Output of Option between Blithfield Reservoir and Nethertown. This is estimated at 1-2 Ml/d annual average from modelling. It is expected that preparation of the drought permit application and the meeting with Implementation Timetable the EA will begin 3-4 weeks before the trigger line is crossed. This is most likely to take place later on in a drought (late summer/ early autumn) but in certain circumstances a Preparation, time of year winter permit will be sought. The drought permit is likely to remain in place for at least effective, duration. 12 weeks, and until reservoir storage at Blithfield and Clywedog is 5% above the Drought Monitoring/Alert trigger. Option Implementation Assessment Implementation Option Permissions Required and Constraints Application would be to the Environment Agency who are responsible for determining drought permit applications. This may then require DEFRA approval if referred by the Including details of liaison with EA (and may require a Drought Order). Liaison with the EA would take place 3-4 weeks bodies responsible for giving prior to the application. permits or approvals

Option 8: Sheet 1 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 8– Blithe/Trent Drought Permit)

The risks are that the drought permit application will not be accepted by EA and/or DEFRA, or that a public inquiry is required which would delay implementation. However Risks Associated with Option given the low level of environmental or other stakeholder impact, this risk is considered to be low.

Risk to the Environment Negligible to Low High, medium, low, or unknown

There are no significant environmental impacts likely from the permit however it is Summary of Possible recognised that as a function of the existing Nethertown weir design and abstraction

Environmental Impacts configuration, the existing fish pass will not function during a DP scenario.

Details of Studies Undertaken or Required A detailed environmental assessment has been completed

The Company will monitor four sites along the River Blithe and three sites on the River Trent. Additional baseline monitoring will be carried out to clarify environmental impacts and further plan mitigation measures and regular frequent monitoring is Monitoring Requirements scheduled for the in-drought and post-drought phases. Surveys will include macro- invertebrates, fish populations, spot gauging/cross sections and water quality (including DO and temperature) Environmental Assessment Environmental Actions to mitigate environmental impacts include temporary reductions or cessations in abstraction, habitat protection and habitat restoration. These will be triggered by events observed in the in-drought monitoring programme. Mitigation Actions Actions to mitigate obstructions to fish passage include fish trapping and transport; screening of the Nethertown (River Blithe) abstraction; and / or temporary cessations of abstraction to provide short periods of flow through the existing fish pass.

Impact on Other Activities, Impacts on downstream surface water abstraction for spray irrigation are predicted to Public, industry etc. be negligible and/or mitigated by River Trent recirculation

Option 8: Sheet 2 of 2 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 9– Drought Order for River Severn at Hampton Loade 192 Ml/d)

Option 9: Drought Order for River Severn at Hampton Loade 192 Ml/d

Triggered by reservoir storage levels falling below the Implement Drought Order trigger curve at Clywedog and Maximum Regulation in place on the River Severn and imposition by the EA of the River Severn Drought Order imposing a 5% reduction in all non spray irrigation abstraction licences. In addition projected

storage levels at Blithfield will be considered before applying for this permit (see Triggers or Preceding Actions additional discussion in Section 4 and 5). It is likely that a drought permit would already be in place on the Blithe before this option was pursued. Preceded by a reservoir storage forecast for Blithfield, and by a forecast for Clywedog (from the EA and STW), and by a meeting with the EA to discuss the proposed application. In the case of a summer permit the application would most likely be preceded by a temporary use ban.

Recovery of the 5% reduction is equivalent to 9.6 Ml/d available for peak week. Deployable Output of Option Modelling scenarios suggest 1-2 Ml/d annual average.

It is expected that preparation of the drought permit application and the meeting

Option Implementation Assessment Implementation Option Implementation Timetable with the EA will begin 3-4 weeks before the trigger line is crossed. This action is likely to be restricted to the late summer/ early autumn. The drought permit is likely Preparation, time of year to remain in place for at least 12 weeks, and until reservoir storage at Clywedog effective, duration. and/or Blithfield is 5% above the Drought Alert/Monitoring trigger and/or EA Severn Drought Order rescinded.

Option 9: Sheet 1 of 3 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 9– Drought Order for River Severn at Hampton Loade 192 Ml/d)

Permissions Required and This is likely to require Secretary of State approval given the conflict of interest with Constraints an EA Drought Order. Liaison with all stakeholders (EA, Defra, Welsh Government) Including details of liaison with would take place 3-4 weeks prior to the application. As the application potentially bodies responsible for giving affects a designated site (Severn Estuary) contact would also be made with Natural permits or approvals England at this time.

The drought order application may require a public enquiry which would delay Risks Associated with Option implementation. Mitigation measures associated with the Severn Estuary may periodically reduce abstraction rates.

Negligible to Low for all reaches under a South Staffordshire Water permit in isolation

Risk to the Environment Unknown for Severn Estuary. High, medium, low, or unknown Impacts for a South Staffs drought order in combination with the EA Severn Drought Order and a Severn Trent drought order at Trimpley cannot be ruled out downstream of Deerhurst (assuming Gloucester & Sharpness abstraction) but are only likely to be critical for short periods.

No impacts are predicted for a South Staffordshire Water drought order in isolation.

Summary of Possible Potential effects of the in-combination drought orders could include periods of Environmental Impacts reduced dissolved oxygen concentrations within the estuary as a result of reduced flows, which may result in fish kills or barriers to fish migration (salmon, twaite shad and lamprey) through the estuary into the River Severn. Environmental Assessment Environmental

Option 9: Sheet 2 of 3 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 9– Drought Order for River Severn at Hampton Loade 192 Ml/d)

Details of Studies Detailed environmental assessment . Undertaken or Required

The Company will monitor eight sites along the River Severn. Additional baseline monitoring will be carried out to clarify environmental impacts and further plan mitigation measures and regular frequent monitoring is scheduled for the in-drought and post-drought phases. Surveys will include macro-invertebrates, fish populations, Monitoring Requirements habitat walkovers, cross sectional profiling and water quality (including DO and temperature) Further monitoring in the Severn Estuary and transitional water bodies may be required by the River Severn Drought Management Group. Actions to mitigate environmental impacts in the Upper Severn include temporary reductions or cessations in abstraction, habitat protection and habitat restoration. These will be triggered by events observed in the in-drought monitoring programme. Mitigation Actions The River Severn Drought Management Group (including South Staffs Water) will facilitate appropriate management of available water in the Severn catchment during drought conditions to mitigate impacts in the Severn Estuary. Impact on Other Activities, Canal and Rivers Trust abstraction Gloucester & Sharpness Canal. Public, industry etc.

Option 9: Sheet 3 of 3 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 10– Drought Order for River Severn at Hampton Loade 216 Ml/d)

Option 10: Drought Order for River Severn at Hampton Loade 216 Ml/d

Triggered by reservoir storage levels falling below the Implement Drought Order trigger curve at Clywedog and Maximum Regulation in place on the River Severn. In addition projected storage levels at Blithfield will be considered before applying for this permit (see additional discussion in Section 4 and 5). It is likely that a drought permit would Triggers or Preceding Actions already be in place on the Blithe before this option was pursued.

Preceded by a reservoir storage forecast for Blithfield, and by a forecast for Clywedog (from the EA and STW), and by a meeting with the EA to discuss the proposed application. See also demand management options. Up to 24 Ml/d additional water can be put into supply based on the difference between Deployable Output of Option abstraction under the Severn Drought Order and the works capacity. It is expected that preparation of the drought permit application and the meeting with Implementation Timetable the EA will begin 3-4 weeks before the trigger line is crossed. This action is likely to be restricted to the late summer/ early autumn. The drought order is likely to remain in Preparation, time of year place for at least 12 weeks, and until reservoir storage at Clywedog and/or Blithfield is effective, duration. 5% above the Drought Alert/Monitoring trigger and/or EA Severn Drought Order rescinded.

Permissions Required and This is likely to require Secretary of State approval given the conflict of interest with an Constraints EA Drought Order. Liaison with all stakeholders (EA, Defra, Welsh Government) would

Option Implementation Assessment Implementation Option Including details of liaison with take place 3-4 weeks prior to the application. As the application potentially affects a bodies responsible for giving designated site ( Severn Estuary) contact would also be made with Natural England at permits or approvals this time.

The drought order application may require a public enquiry which would delay Risks Associated with Option implementation. Mitigation measures associated with the Severn Estuary may periodically reduce abstraction rates.

Option 10 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 10– Drought Order for River Severn at Hampton Loade 216 Ml/d)

Negligible to Low for all reaches under a South Staffordshire Water permit in isolation Risk to the Environment Unknown for Severn Estuary. High, medium, low, or unknown Impacts for a South Staffs drought order in combination with the EA Severn Drought Order and a Severn Trent drought order at Trimpley cannot be ruled out downstream of Deerhurst (assuming Gloucester & Sharpness abstraction) but are only likely to be critical for short periods. No impacts are predicted for a South Staffordshire Water permit in isolation.

Summary of Possible Potential effects of the in-combination drought orders could include periods of Environmental Impacts reduced dissolved oxygen concentrations within the estuary as a result of reduced flows, which may result in fish kills or barriers to fish migration (salmon, twaite shad and lamprey) through the estuary into the River Severn.

Details of Studies Undertaken Detailed environmental assessment or Required

The Company will monitor eight sites along the River Severn. Additional baseline monitoring will be carried out to clarify environmental impacts and further plan mitigation measures and regular frequent monitoring is scheduled for the in-drought and post-drought phases. Surveys will include macro-invertebrates, fish populations, Environmental Assessment Environmental Monitoring Requirements habitat walkovers, cross sectional profiling and water quality (including DO and temperature) Further monitoring in the Severn Estuary and transitional water bodies may be required by the River Severn Drought Management Group. Actions to mitigate environmental impacts in the Upper Severn include temporary reductions or cessations in abstraction, habitat protection and habitat restoration. These will be triggered by events observed in the in-drought monitoring programme. Mitigation Actions The River Severn Drought Management Group (including South Staffs Water) will facilitate appropriate management of available water in the Severn catchment during drought conditions to mitigate impacts in the Severn Estuary. Impact on Other Activities Canal and Rivers Trust abstraction Gloucester & Sharpness Canal.

Option 10 APPENDIX H: DROUGHT OPTIONS – SUPPLY MANAGEMENT OPTIONS (Option 10– Drought Order for River Severn at Hampton Loade 216 Ml/d)

Public, industry etc.

Option 10

APPENDIX I: GENERAL ENVIRONMENTAL MONITORING SPECIFICATIONS

White-clawed crayfish

The sampling technique for white-clawed crayfish involves a hand search at each survey location, which should be undertaken by suitably experienced and licensed crayfish surveyors. The standard methodology for sampling crayfish in SAC rivers is targeted at providing a quantitative assessment (Common Standards Monitoring) of high density populations. Where no historical information on the presence of crayfish is available, a higher intensity survey method is recommended as follows: • •Hand searching and sweep netting operated by two persons simultaneously, for 20 minutes (or less if both species of crayfish are found earlier). • •Any crayfish captured recorded to species, with sex, and carapace length also recorded. • •Records of the number of stones / refuges turned in that period and the area of river covered (patch) made for each site. • •Brief records of substrate, flow, depth, and riparian and in-stream vegetation recorded at each site. Given the risk of transferring crayfish, or crayfish plague fungus to native populations, a number of biosecurity measures should be adopted during the surveys: • •Where possible, surveyors conduct searches from upstream to downstream, thus not risking transfer of non-native crayfish, or plague fungus upstream; and • •Prior to commencing fieldwork, at the end of the survey, and at any occasion where movements of equipment or personnel could conceivably pose such a risk, all equipment, clothing etc. should be disinfected with iodophore solution in accordance with EA guidelines.

Electric-fishing for brown trout and general species diversity

Electric-fishing is recommended for brown trout and to assess the general diversity of species present at the survey locations. The survey locations should cover a broad diversity of habitat types within a 100 m section of river, incorporating areas of optimal habitats for lamprey ammocoetes and spined loach. At each location the selected survey extent is isolated using a stop net at the upstream and downstream boundaries. A single run with a single anode is made while wading in an upstream direction and covering the full width of the stream. All fish captured are held in aerated holding tanks until the sampling run is complete. Individual fish are then identified to species, measured (fork length) and released following the completion of any specialist spined loach / lamprey surveys.

South Staffs Water Final Drought Plan February 2013: Appendix I

Standard electric fishing practice for operators and equipment is followed in accordance with the European Standards Committee (CEN, 2001) and the EA Code of Practice and Electric Fishing Equipment Annex A and B, Issue II regulations.

Specialist fish surveys – Spined loach and Lamprey

To establish the presence / absence of lamprey and spined loach, additional specialist sampling is recommended, focusing on areas of optimal habitat (lamprey ammocoetes require predominantly deep, silty substrates typically within river margins, whilst spined loach have similar requirements for soft sediment habitat, but also use tree roots and marginal vegetation for burrowing). Three specialist surveys are recommended at each sampling location, using an enclosed area as a barrier to fish movement. Following a standard protocol (Harvey and Cowx, 2003), a 1 m2 quadrat is positioned over the selected habitat to fully enclose the sampling area and electric-fishing is then undertaken in such a way as to draw individual lamprey out of the sediment rather than stunning and trapping them in the silt (see image below) This is achieved by energising the anode in short bursts of ten seconds followed by five second gaps, and is carried out over a three minute period. Due to the small size of spined loach and their propensity to burrow into tree roots and marginal vegetation, an anode of reduced size (15 cm diameter) is also used to conduct targeted sampling within optimal habitats at each site.

Sampling within enclosed quadrat (1m2) for lamprey ammocoetes at Site 1

Macroinvertebrate survey

At each sampling location a single three-minute kick/sweep sample is collected following the standard protocol detailed in the EA’s handbook, BT001 and the updated Operational Instruction 018_08 (Environment Agency, 1999; Environment Agency, 2009), which is compatible with the procedure for collecting and analysing macroinvertebrate samples for RIVPACS (Murray-Bligh et al. 1997). Each kick/sweep sample covers all the instream habitats present at the sampling location in proportion to their occurrence, over the three-minutes sampling time. Additionally, a further one-minute hand search of submerged stones, woody debris, plants, tree roots and other structures is performed to capture any animals that might have evaded the kick/sweep sample. It should also be noted that at least a three-year continuous dataset would usually be recommended as a baseline.

Walkover survey

In the first instance a walkover survey is recommended to map flow-sensitive and functional meso-habitats for fish and other receptors, and to identify

South Staffs Water Final Drought Plan February 2013: Appendix I

suitable locations for surveys. At each proposed survey site the walkover should be conducted for 500m along the river in both directions. The walkover data can then be linked with river flow and channel-form data at river cross-sections to allow prediction of habitat changes (depth, wetted width, mean cross-sectional velocity) under DP flow scenarios, which can be used to provide a semi-quantitative assessment of ecological impacts of a DP through changes to functional meso-habitats for fish and crossing key velocity thresholds for macroinvertebrate species (using LIFE Flow Groups), as well as other published hydrological thresholds (depth, velocity) for other key species present in the study area ((e.g. bullhead, Atlantic salmon, river, brook and sea lamprey, Allis and Twaite shad, white-clawed crayfish).

River Habitat Survey

River Habitat Surveys (RHS) are carried out by EA-accredited RHS surveyors according to the methodology laid out in the EA River Habitat Survey in Britain and Ireland: Field Survey Guidance Manual (2003 Version) and the River Habitat Survey Technical Update dated April 2006. In addition to the standard method, the following procedures are also recommended: • Additional photographs should be taken at each spot-check, where access allows • In addition to the representative site photographs, and pictures of any moderate/major artificial structures as required by the v2003 methodology, photographs should be taken of channel modifications and special features, unusual or unfamiliar features with supporting field notes. • Photographs should be taken using a good quality digital camera and all photographs stored electronically as JPEG files. A record of photographs taken at each site should be logged onto a RHS Photographic and NGR record form.

Macrophyte survey

Surveys should follow the standard Mean Trophic Rank (MTR) methodology as described in Holmes et al (1999) and in the EA’s latest Operation Instruction 131_07 (Environment Agency, 2010). The presence/absence, species and relative abundance per square metre for each distinct taxon of macrophyte (not just those with an MTR score) occurring at the site is recorded from a 100m reach of the relevant watercourse. The abundance of all macrophytes is recorded as described in the MTR Manual. The rarity of all the species recorded is established, from which the MTR indices can be calculated for each site. At each specified survey location, macrophytes should be recorded to species level, where possible, over a 100 m length of brook by wading in an upstream direction and following a zig-zag track, recording all plant species occurring in the channel (i.e those that are submerged for 85% of the time), as per standard MTR (Mean Trophic Rank) survey methods (Holmes et al. 1999). Data are recorded both as a percentage cover value of each species

South Staffs Water Final Drought Plan February 2013: Appendix I

for each site and as an SCV score (Species Cover Value), according to the 9- point scale of the MTR methodology.

Spot gauging

Spot gauging surveys should be carried out in accordance with BS EN ISO 748:2007 and all survey locations should be visited on the same day, to ensure that the recorded flows and water levels are comparable. As part of each gauging the channel cross-section and point velocities across the channel are recorded. This information can be used to derive depth-area, depth-wetted width and depth-wetted perimeter relationships for each site and Manning’s equation can be applied to the data to derive depth discharge and discharge velocity relationships for each location. Cross sectional profiles

Cross section surveys and sufficient flow gauging to cover a range of flow conditions can be undertaken as programmed by the EA at gauging stations and for flood mapping purposes. These allow ecology results to be interpreted in the context of hydrological data via a semi-quantitative assessment of ecological impacts through changes to functional meso- habitats and crossing key velocity and other hydrological thresholds.

Water quality

Surface water quality sampling undertaken at each sampling location should typically include; measurements of temperature, dissolved oxygen and pH using a multi-parameter hand-held probe, and biochemical oxygen demand (BOD), ammonia, soluble reactive phosphate (SRP), suspended solids, hardness, copper, aluminium and zinc from laboratory analysis of water samples.

South Staffs Water Final Drought Plan February 2013: Appendix I

APPENDIX J: HABITATS REGULATIONS ASSESSMENT (HRA) SEVERN ESTUARY (this precedes change of Hampton Loade supply option from Drought Permit to Drought Order)

South Staffs Water Final Drought Plan February 2013: Appendix J

Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

Prepared for

South Staffordshire Water plc Green Lane Walsall West Midlands WS2 7PD

Report reference: 60757 R1D2 Appendix B, November 2012 Report status: Final

Confidential Prepared by ESI Ltd New Zealand House,160 Abbey Foregate, Shrewsbury, SY2 6FD, UK Tel +44(0)1743 276100 Fax +44 (0)1743 248600 email [email protected] Registered office: New Zealand House, 160 Abbey Foregate, Shrewsbury, SY2 6FD. Registered in England and Wales, number 3212832

Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

This report has been prepared by ESI Ltd. (ESI) in its professional capacity as soil and groundwater specialists, with reasonable skill, care and diligence within the agreed scope and terms of contract and taking account of the manpower and resources devoted to it by agreement with its client, and is provided by ESI solely for the internal use of its client.

The advice and opinions in this report should be read and relied on only in the context of the report as a whole, taking account of the terms of reference agreed with the client. The findings are based on the information made available to ESI at the date of the report (and will have been assumed to be correct) and on current UK standards, codes, technology and practices as at that time. They do not purport to include any manner of legal advice or opinion. New information or changes in conditions and regulatory requirements may occur in future, which will change the conclusions presented here.

This report is confidential to the client. The client may submit the report to regulatory bodies, where appropriate. Should the client wish to release this report to any other third party for that party’s reliance, ESI may, by prior written agreement, agree to such release, provided that it is acknowledged that ESI accepts no responsibility of any nature to any third party to whom this report or any part thereof is made known. ESI accepts no responsibility for any loss or damage incurred as a result, and the third party does not acquire any rights whatsoever, contractual or otherwise, against ESI except as expressly agreed with ESI in writing.

Principal Author(s) Karensa Lawrie, APEM

Checked by : David Bradley Reviewed by : Mike Streetly

Confidential Prepared by ESI Ltd New Zealand House,160 Abbey Foregate, Shrewsbury, SY2 6FD, UK Tel +44(0)1743 276100 Fax +44 (0)1743 248600 email [email protected] Registered office: New Zealand House, 160 Abbey Foregate, Shrewsbury, SY2 6FD. Registered in England and Wales, number 3212832 Review and Update of Drought Permit Environmental Assessment Report: River Severn at Page i Hampton Loade HRA

CONTENTS

1 INTRODUCTION...... 1

1.1 Background...... 1

1.2 Assessment Methodology ...... 1

1.3 Existing Operations ...... 2

1.4 Proposed Plan...... 3

2 SEVERN ESTUARY SAC AND RAMSAR...... 6

2.1 Site Details...... 6

2.2 Conservation Objectives...... 7

3 DRAFT EA RIVER SEVERN DROUGHT ORDER HABITAT REGULATIONS ASSESSMENT...... 9

3.1 Assessment Method...... 9

3.2 Conclusions...... 10

4 SCREENING MATRIX FOR THE HAMPTON LOADE DP PROPOSALS...... 13

5 CONCLUSIONS...... 0

6 REFERENCES...... 2

FIGURES

Figure 2.1 Location of the Severn Estuary SAC (taken from EA, 2012)

TABLES

Table 1.1 Summary of Hampton Loade & Trimpley existing abstraction licences, excluding water treatment works losses (after Enviros, 2007)...... 3 Table 2.1 Designated features of the Severn Estuary SAC and Ramsar included within the EA’s River Severn Drought Order HRA and current DP screening assessment ...... 7 Table 4.1 Hampton Drought Permit proposals...... 13

APPENDICES

Appendix A Conservation Objectives

Report Reference: 60757 R1D1 Appendix B Report Status: Final Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

1 INTRODUCTION

1.1 Background The European Habitats and Species Directive (92/43/EEC) affords habitats and species of European importance legal protection through its implementation of a network of designated areas known as Natura 2000 sites. Natura 2000 sites consist of two main protected area categories, Special Areas of Conservation (SAC) and Special Protection Areas (SPA). Each Natura 2000 site has a number of qualifying features, for which conservation objectives are to be developed. On designation, the Directive requires measures to be taken to maintain or restore site integrity. Article 6(3) of the Directive states that ‘any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to appropriate assessment of its implications for the site in view of the site’s conservation objectives’. Following a review of assessment requirements for a proposed drought permit (DP) application on the River Severn by South Staffordshire Water (SSW), the Environment Agency agreed that a Habitat Regulations Assessment (HRA) would be required with respect to the potential effects of reduced flows on the Severn Estuary SAC. The previous environmental report (Enviros, 2012) predicted a medium impact upon the Severn Estuary (Maisemore to Sharpness canal) under the highest proposed abstraction rate, yet did not conclude whether ‘no likely effects’ would be expected with respect to the SAC. Based on the potential to impact upon the estuary, the current DP proposal has been updated to incorporate an increase in maximum operational capacity to 216 Ml/d compared to 245 Ml/d in the previous assessment report. The Environment Agency (EA) has recently undertaken an HRA for the proposed River Severn Drought Order (DO HRA) including in-combination effects of DP proposals based on the previous 245 Ml/d maximum abstraction value. An HRA is therefore required to determine: 1. if the Drought Permit would be likely to have significant impacts upon nearby Natura 2000 sites, and if so; 2. whether these significant impacts are likely to adversely affect the integrity of nearby Natura 2000 sites. In particular the assessment will focus upon: 1. Reviewing the EA DO HRA, previous and current DP environmental assessment report to include consideration of Option 2 of the DP proposal: increase abstraction to maximum operational capacity of 216Ml/d. 2. Likely effects upon migratory fish only (all other features were scoped out of the EA DO HRA assessment.

1.2 Assessment Methodology The method used for this HRA has been informed by the European Commission document ‘Assessment of Plans and Projects Significantly Affecting Natura 2000 Sites – Methodological Guidance on the Provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC’. This method recommends a four stage assessment process as follows: • Screening – ‘the process which identifies the likely impacts upon a Natura 2000 site of a project or plan either alone or in combination with other plans or projects, and considers whether it can be objectively concluded that these effects will not be significant’.

Report Reference: 60757 R1D1 Appendix B 1 Report Status: Final

Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

• Appropriate Assessment – ‘consideration of the impact on the integrity of the Natura 2000 site of the project or plan,….with respect to the site’s structure and function and its conservation objectives’. • Assessment of alternative solutions – ‘this stage examines alternative ways of implementing the project or plan that, where possible, avoid any adverse impacts on the integrity of the Natura 2000 site’. • Assessment where no alternative solutions exist and where adverse impacts remain – includes establishing whether there are imperative reasons of overriding public interest, and if there are, the identification of appropriate compensatory measures to maintain the overall coherence of the Natura 2000 network.

Based upon the EA’s DO HRA, it is anticipated that a full HRA is unlikely to be required. A screening assessment will, however, be undertaken and the results of this process will confirm the requirement for Appropriate Assessment. 1.3 Existing Operations SSW’s Hampton Loade abstraction is located on the River Severn upstream of the EA’s river flow gauging station at Bewdley. The abstraction licence for Hampton Loade is complicated, and only the main requirements are summarised below. The amount of water that can be abstracted is dependent upon the flow in the River Severn at Bewdley, the time of year, the degree of river regulation, and in extreme droughts, by the implementation of an EA drought order. In addition, Severn Trent Water Limited (STWL) is entitled to part of the licence and furthermore the licence has some joint licence conditions with STWL’s licence downstream on the River Severn at Trimpley. Water abstracted from the River Severn at Hampton Loade (under licences 18/54/02/584 &163) is pumped into Chelmarsh bankside storage reservoir (capacity 3060 Ml), and then onwards to Hampton Loade Water Treatment Works (WTW) across the river. To account for losses from the treatment process as the water passes through Hampton Loade WTW, SSW abstracts an additional volume from the river which is subsequently returned to the river on site. This “treatment loss” volume varies with the total abstraction volume (recently assessed as 8.5 Ml/d at maximum operational capacity of 216 Ml/d). Thus although some additional water is abstracted to account for water treatment works losses, because it is returned to the river on site it can be assumed to have no hydrological impact. STWL is entitled to take a bulk supply of treated water from Hampton Loade WTW to supply Wolverhampton (22,143 Ml/a or 68 Ml/d peak). There is presently an agreement which allows reallocation of 20Ml/d from the STWL entitlement at Hampton Loade to be abstracted directly by STWL downstream at Trimpley. This reduces the Wolverhamtpon take to 41 Ml/d average (48 Ml/d peak). The Hampton Loade abstraction is effectively restricted to 192Ml/d when the river is being regulated by the EA (212Ml/d total abstraction with 20Ml/d transferred downstream to be abstracted at Trimpley), and this reduces by a further 5% (182.4Ml/d) if the EA enforce the Severn Drought Order. The total abstraction at Hampton Loade and Trimpley must not exceed 400Ml/d when the river is not under regulation, 272Ml/d during periods of maximum river regulation or 290Ml/d as an annual average. A summary of the abstraction licence conditions for Hampton Loade and Trimpley is given in Table 1.1.

Report Reference: 60757 R1D1 Appendix B 2 Report Status: Final

Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

Table 1.1 Summary of Hampton Loade & Trimpley existing abstraction licences, excluding water treatment works losses (after Enviros, 2007)

Volume (as Ml/d) or pro-rata equivalents Hampton Loade (licences 163 & Hampton Loade & 584 combined, Trimpley (110) Trimpley including 20Ml/d combined transfer to Trimpley) Bewdley Daily >1100Ml/d 400 180 400 (Nov.–March) <1100Ml/d 280 180 400 Bewdley Daily >1100Ml/d 320 180 400 (April–Oct.) <1100Ml/d 280 180 400 Maximum Daily 212 60 272 regulation Average over 1 st Seasonal 100 days reg. 212 60 272 (then pro-rata) Annual Average 230 60 290 (Ml/d)

1.4 Proposed Plan SSW has developed two proposed drought permit options for Hampton Loade (Option 1 and Option 2) and these are described below. The agreement to allow STWL to abstract 20 Ml/d from the joint licence (No.163) at Trimpley WTW is assumed to apply both under normal circumstances and under a Hampton Loade drought permit. Option 1 – maintain abstraction at 192 Ml/d SSW will apply for this drought permit at Hampton Loade if it has, or is likely to have, a severe deficiency of supply and the EA applies for a River Severn Drought Order (thereby requiring reduction of all River Severn public water supply abstraction by 5%). It has been assumed that under such circumstances, SSW’s Hampton Loade abstraction would already be limited to 192 Ml/d (net), because maximum regulation would already be in place. The proposed drought permit Option 1 would allow SSW to maintain its abstraction at 192 Ml/d under circumstances where the abstraction would ordinarily be reduced by 5% to 182.4 Ml/d (under the terms of an EA River Severn Drought Order), i.e. the proposed Drought Permit would allow SSW to abstract an additional 9.6 Ml/d. Option 2 – increase abstraction to maximum operational capacity of 216 Ml/d SSW will apply for this drought permit at Hampton Loade if it has, or is likely to have, a severe deficiency of supply and the EA applies for a River Severn Drought Order (thereby requiring reduction of all River Severn public water supply abstraction by 5%). It has been assumed that under such circumstances, SSW’s Hampton Loade abstraction would already be limited to 192 Ml/d (net), because maximum regulation would already be in place. The proposed drought permit Option 2 would allow SSW to increase its abstraction to the maximum operational capacity of Hampton Loade WTW (i.e. a gross abstraction of 216 Ml/d), if required. Given that water treatment works losses of 8.5Ml/d would be returned to the river on site, in practice this would equate to a net abstraction of 207.5 Ml/d (i.e. an increase in abstraction of 15.5 Ml/d compared to Option 1 or an increase in abstraction of 25.1 Ml/d

Report Reference: 60757 R1D1 Appendix B 3 Report Status: Final

Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA compared to the situation under the terms of an EA River Severn Drought Order where net abstraction would otherwise be limited to182.4 Ml/d (net abstraction under maximum regulation is 192 Ml/d, with a further 5% reduction under the terms of an EA Drought Order to 182.4 Ml/d). It should be noted that the Option 2 DP described above is different to the “Option 2” DP reported in the previous environmental report Enviros (2007), which related to a gross abstraction of 245 Ml/d. The Option 2 proposal has been changed because there have been changes to SSW’s maximum treatment capacity at Hampton Loade WTW since the previous report was written, and also because it was considered that the proposal could have significant impacts on a designated site by virtue of its in-combination impact (with other proposed drought permits and orders) on the Severn Estuary SAC and Ramsar site. DP in relation to flow regulation proposals assessed in EA DO HRA The Environment Agency have recently (2012) undertaken an HRA to determine the likelihood of significant effects upon the Severn Estuary SAC as a result of the River Severn DO proposals (EA, 2012). A further HRA of abstractions within the River Severn was also previously undertaken as a requirement of the Review of Consents (RoC) process. The River Severn DO incorporates three main proposals: 1. Cap regulation releases from Clywedog Reservoir at 300 Ml/d and no more than 1.5% of the storage in Llyn Clywedog should be released once the 'drought order in force' curve has been reached. If a drought persists and the storage capacity falls below 17.8% full (Emergency Storage) then releases will be further reduced to 1.5% of remaining active storage. 2. Decrease the maintained flow in the Severn at Bewdley to 730 Ml/d over a 5 day mean (120 Ml/d decrease). 3. Impose a 5% reduction in daily licence quantities on licences from the River Severn.

The HRA assessed the potential in-combination effects of the River Severn DO including the Severn DP. However, the model used within the assessment (Aquator WRMP2010) considered the previous Hampton Loade DP Option 2: increase maximum abstraction to 245 Ml/d in-combination. The current assessment reduces the Option 2 abstraction by 24 Ml/d to 216 Ml/d.

Report Reference: 60757 R1D1 Appendix B 4 Report Status: Final

Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

Report Reference: 60757 R1D1 Appendix B 5 Report Status: Final

Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

2 SEVERN ESTUARY SAC AND RAMSAR

2.1 Site Details The EA screening exercise identified the appropriate sites to take forward to the EA’s DO HRA and the result was that the Severn Estuary Special Area of Conservation (SAC) (Figure 2.1) and Ramsar site was the only site to be assessed within the HRA. This is therefore the only site to be taken forward within the current assessment. The site encompasses an area of 73,715 hectares predominantly comprising mudflats and sandbank habitats with small areas of reef and salt meadow. The estuary provides a migratory conduit for diadromous fish species. A list of the site SAC/RAMSAR features assessed within the EA’s DO HRA and within the presence study are provided in Table 2.1. The tidal range in the Severn Estuary is the second-highest in the world and the scouring of the seabed and strong tidal streams result in natural erosion of the habitats and the presence of high sediment loads.

Figure 2.1 Location of the Severn Estuary SAC (taken from EA, 2012)

Report Reference: 60757 R1D1 Appendix B 6 Report Status: Final

Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

Table 2.1 Designated features of the Severn Estuary SAC and Ramsar included within the EA’s River Severn Drought Order HRA and current DP screening assessment Species Annex II RAMSAR interest features Sea lamprey Petromyzon marinus X X River Lamprey Lampetra fluviatilis X X Allis shad Alosa alosa X X Twaite shad Alosa fallax X X Salmon Salmo salar X Sea Trout Salmo trutta X Eel Anguilla anguilla X

2.2 Conservation Objectives The overriding objective of the Habitats Directive is to ensure that the habitats and species designated under the Directive achieve “favourable conservation status” within protected sites for which they are qualifying or interest features and that their long-term survival is secured across their entire natural range within the European Union (EU Commission 2011). In its broadest sense, favourable conservation status means that an ecological feature is maintained in a satisfactory condition and that this status is likely to continue into the foreseeable future. The Conservation Objectives for migratory fish assemblages are detailed in Appendix I.

Report Reference: 60757 R1D1 Appendix B 7 Report Status: Final

Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

Report Reference: 60757 R1D1 Appendix B 8 Report Status: Final

Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

3 DRAFT EA RIVER SEVERN DROUGHT ORDER HABITAT REGULATIONS ASSESSMENT

3.1 Assessment Method The appropriate assessment was undertaken using flow data recorded from Hawbridge (since 1971), which were modelled to provide three flow scenarios: average flow conditions, chronic and acute drought. The Acute drought scenario represents a theoretical event; a dry winter (1975) followed by a drought summer (1976), which triggers the need for a River Severn DO in September (1976). The Chronic drought scenario represents a theoretical two summer drought event where the EA DO is activated in two subsequent years. It builds on / /extends the acute scenario.. A major abstraction exists within the downstream section of the River Severn in the form of a channel split to the Gloucester and Sharpness Canal, owned by the Canal and Rivers Trust (formerly British Waterways). Historic data were used to model flow scenarios at Deerhurst, U/S Sharpness (just upstream of the canal abstraction point) and Lower Parting (downstream of the canal abstraction point). Lower Parting was used as the main assessment point for inflows to the Severn Estuary SAC. The Aquator model was used and despite some limitations with respect to its ability to simulate a drought it provides the most complete model available for River Severn water resource planning and incorporates water company drought orders and permits. In addition to flow modelling, water quality parameters within the estuary were modelled using SIMCAT. Changes in flow were assessed with respect to ‘Environmental Flow Indicator’ (EFI) targets based on the sensitivity of the system to abstraction against expected natural flows derived from measured data. A Neap tide flow target of 1200 Ml/d and Spring tide flow target of 1800 Ml/d were recommended to prevent saline intrusion and therefore help support the Severn Estuary environment, and protect freshwater abstractions (Hutcherson & Wade investigation 1992) and was used in the assessment as a guide. However, these targets can be considered precautionary. The EA acknowledged the flow targets as site specific recommendations and used them in assessment as a guide (rather than a rule due to their date/age, and more recent WFD guidance) to help quantify any potential flow impacts on the Estuary from River Severn flow changes. The EA also acknowledged that Netheridge STW has been improved since the 1976 drought event, which has subsequently improved the water quality of flows entering the Severn Estuary. The Hutcherson & Wade (1992) flow targets were concluded based on natural tidal ranges and saline intrusion up the Estuary, and the impacts this could have. Poor water quality from Netheridge would have further exacerbated the impacts of this saline intrusion. The potential impacts of low flow upon the actual designated SAC was considered along with Annex II migratory fish species and Atlantic salmon. The potential effects of reduced freshwater flows to the estuary in relation to water quality issues such as dissolved oxygen and saline intrusion was also considered.. . . The estuary wide assemblage of fish species within the Severn Estuary Ramsar site was scoped out at the screening stage. A number of existing fisheries data were considered including Hinkley Point (ST 21155 46107) and Oldbury (ST 60633 94448) entrainment data (see Figure 2.1), catch returns from traditional commercial netting for salmon and fyke and seine survey data from the transitional fish sampling sites within the lower and upper Severn estuary. The 1975/76 drought event resulted in a small number of fish (Atlantic salmon) being found dead or in a distressed condition on a small number of successive days in July 1976, however, this was related to poor water quality in a particular section of the estuary (the Lower Tidal Severn, upstream of the SAC), and water quality has since improved

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Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA considerably due to improvements in . . treatment at Netheridge STW. There were no reports of fish in distress during the low flows of 2011 (EA biodiversity officer, pers. comm.). Water quality improvements have been sufficient to reduce the occurrence and severity of fish kills with an overall reduction in biological oxygen demand by a factor of three. The EA notes that impacts of a drought were likely to be late summer and well past the time that adult shad would be migrating upstream. The juvenile shad move down into the estuary during late summer and these would be more likely to be impacted by a late drought (EA Environmental Monitoring Analysis and Reporting Officer, pers. comm.). 3.2 Conclusions The following conclusions were drawn with regard to effects upon migratory Annex II fish species: The Water Authority Joint Committee on the river Severn Estuary concluded that, apart from saline intrusion at Gloucester, the drought of 1976 had virtually no immediate effect on the estuary (Severn Trent Water 1977). In fact the evidence from the 1976 drought is that moderate increases and decreases in the regulated flow at Bewdley would have little effect on the river or the estuary (Severn Trent Water 1977). The droughts modelled for this report were based on the 1976 drought, but extended. The impacts on fish caused by the different management options are only within the lower tidal Severn and not the Severn SAC. However, migratory fish that are a designated feature of the Severn Estuary SAC and Ramsar site, that might be impacted are: • Atlantic salmon – during a drought adult salmon migrating upstream are likely to reside for longer in the estuary increasing the possibility of them not entering the River Severn to spawn. The main impact is likely to be in the lower tidal Severn where reduced dissolved oxygen concentration could cause fish deaths. In both scenarios the 'do nothing' approach is beneficial up until October. Then this approach causes a crash in freshwater flows to the lower tidal Severn which could cause salmon deaths in this section. Hutcherson and Wade (1992) recommended that a flow of 1800Ml/d at Haw Bridge was required to maintain dissolved oxygen concentrations above 3 mg/l necessary for salmon. During the acute drought scenario this flow is not attained for 19% of the year which would suggest a potential for salmo deaths and they would be particularly vulnerable from October onwards. However, the dramatic improvement of water quality as result of treatment improvements at Netheridge STW indicates that salmon are less vulnerable to low flows and to flows of <1800Ml/d. • Twaite shad – juvenile twaite shad feed at the saline wedge before migrating to sea at winter. The location of this saline wedge is impacted by tides and the quantity of freshwater. Therefore, in the lower tidal Severn, these fish could be vulnerable to reductions in dissolved oxygen concentration, especially with the very low freshwater flows predicted in the 'do nothing' management options. Within the estuary where fresh and saline water meet, there is an abundance of prey species (mysid shrimps) and these are particularly important to the juvenile twaite shad population. The actual position varies according to the state of the tide and volume of freshwater input to the estuary. Therefore, it must be assumed that any activity that affects the salinity regime of the estuary would in turn impact the distribution of these prey species (taken from The Severn Estuary European Marine Site). This might cause the juvenile shad to move further upstream during low freshwater flows as in the acute or chronic drought scenarios. With low freshwater flows, episodes of reduced dissolved oxygen concentration would occur in the Severn and the juvenile shad would be vulnerable. This would be more of an issue in the 'do nothing' management option where flows seriously crash in the late summer. However, as stated previously the improvement in water quality makes this less likely. Also if the Canal and Rivers Trust were to abstract their maximum quantity it is possible that there would be virtually no freshwater flow entering the estuary.

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• Sea lamprey – it is only likely that spawning distribution will decrease with the early implementation of the Severn DO in the chronic scenario. • River lamprey – adults are thought to stay close to coastal areas. Therefore any within the lower tidal Severn could be vulnerable to reductions in dissolved oxygen concentration, especially with the low freshwater flows in the do nothing management options. • The fish assemblage of the estuary (qualifying feature of RAMSAR) are generally unlikely to be impacted by the changes in freshwater flows as modelled in the various management options. • Drought is a natural event and the implementation of the DO has a potential to have an 'adverse effect' on migratory species which will very much depend on its timing. During the 1976 drought and other years fish kills were witnessed as a result of reduced dissolved oxygen concentration. The risk of reductions in dissolved oxygen concentration of this magnitude has been reduced since the improvements that have occurred in the water quality of the River Severn since 1976. Also any potential effects will also be related to the length of the drought and potential for species recovery. • It can also be argued that during droughts rivers naturally experience extremely low flows with stretches drying up and salmon in particular experience stress as witnessed during autumn 2011. By having river flow augmentation systems in place the River Severn is already being protected from the worse effects of a drought. • When the Canal and Rivers Trust abstraction to the Gloucester Sharpness Canal is considered there is a potential for adverse effects to migratory fish both alone and in combination with the River Severn DO. When considered on its own this abstraction can average over 275Ml/d during August and September. It has since been recognised these figures do not reflect the high demands during dry weather or the conditions under which a Drought Order would be applied for. It is a major concern that the maximum abstraction that Canal and Rivers Trust could legally make is approximately 691 Ml/d. This amount is only marginally less than the maintained flow at Bewdley of 730 Ml/d over a 5 day mean. There is potential for abstraction by the Canal and Rivers Trust for the Gloucester Sharpness Canal to cause further damage to fish populations of the lower tidal Severn and even the fish within the SAC. Along with the Severn Estuary SAC there are a number of riverine SACs that flow into the estuary and need to be assessed for any impact caused by a Severn Drought Order. These are the River Wye, River Usk and Afon Tywi. The following migratory fish species are included as designated features for all of these rivers: Atlantic salmon (not Afon Tywi), twaite shad, river and sea lamprey. It has already been discussed that migration to spawning areas for twaite shad, sea and river lamprey should not be impacted by the freshwater flows modelled in the acute and chronic scenarios. However, the Bristol Channel and Severn Estuary support populations of adult salmon returning to their home rivers and they arrive in the estuary in most months of the year. These fish use tidal transport mechanisms to ascend the estuary, stemming the tide in some way to avoid displacement and, once the natal river is recognised, using freshwater cures to enter and ascend that river. The probability of salmon entering their home river is dependent on freshwater discharge: in high flows this might be prompt however in low flows delay within the estuary or sub-estuary will occur and increased natural loss or mortality then occurs. Prolonged estuary residence is possible in extended low flow periods. The adult fish are a mixed stock of fish from different rivers, ranging from the Severn itself to those along the south coast of Wales including the Wye, Usk and Tywi Natura 2000 sites, to the recovering industrial rivers (Rhymney, Taff, Ogmore, Neath and Tawe. There is some evidence for fish derived from even further away.

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Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

The salmon present are in the process of identifying their home rivers and a high level of fidelity to those rivers has been widely documented. However, the fish, whilst resident, will make multiple temporary ascents and descents of the estuary, and may make temporary excursions into sub-estuaries before leaving to locate and enter their own rivers. The droughts being modelled with these scenarios are likely to be not just localised to the River Severn, but will be a national problem. Therefore, freshwater flows from all the watercourses entering the Severn Estuary will be expected to be significantly reduced. This will mean the salmon will be within the estuary for a longer period and may well not make their journey up to spawn. There is a possibility that due to regulation, freshwater flows within the Severn will be higher than other watercourses entering the estuary (dependent on abstractions from the Canal and Rivers Trust). This could lead to a small percentage of salmon entering the Severn over their natal river. This is an exceptional drought situation and the expected percentage of fish entering the Severn instead of their natal river is low. Therefore, the impacts of using a DO and in full combination on Atlantic salmon that are progeny of the Wye and Usk is presumed to be negligible. The EA notes that the most important evidence relating to the impact of very low flows on the SAC comes from the 1976 drought which demonstrated no immediate effect on the designated Severn Estuary. The EA’s appropriate assessment indicates a similar conclusion i.e. that the very low flow conditions associated with a drought will not have an adverse effect on the integrity of the designated Severn Estuary: it is the Lower Tidal Severn that may be impacted. This reflects the fact that the greatest changes in bed levels, tidal range and salinities all occur within this upper part of the estuary and the habitat and species have adapted to accommodate this variation. Whereas water quality related to dilution had been a problem during the 1976 drought, improvements at Gloucester (Netheridge) STW mean that water quality of the designated Severn Estuary and Lower Tidal Severn would now be unlikely to be adversely affected by drought conditions.

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4 SCREENING MATRIX FOR THE HAMPTON LOADE DP PROPOSALS

To identify the likely impacts of the Hamton Loade DP proposals on the Severn Estuary SAC, Table 4.1 outlines the screening assessment in detail. The outcome of this screening assessment allows for a conclusion to be drawn objectively on the likely significance of any potential impacts from the proposed works.

Table 4.1 Hampton Drought Permit proposals Name of Project or Plan Hampton Loade Drought Permit proposals

Name and Location of Severn Estuary Special Area of Conservation (SAC) Natura 2000 Site

Description of the South Staffs Water (SSW) propose a Drought Permit to include: Project or Plan Option 1 – maintain abstraction at 192Ml/d; Option 2 – increase abstraction to maximum operational capacity of 216Ml/d.

Is the project or plan No. directly connected with or necessary to the management of the site?

Are there other projects Yes or plans that together with the project or plan The full suite of river regulation plans were considered within the being assessed could EA’s River Severn DO HRA and where appropriate incorporated affect the site? into the drought order assessment model (including the previous Hampton Loade DP proposal which was). The Gloucester and Sharpness canal was the only abstraction considered likely to have significant adverse effect upon the SAC either alone or in combination under modelled drought scenarios.

Describe how the Potential effects of the DP proposals could include reduced project or plan is likely dissolved oxygen concentrations within the estuary as a result of to affect the Natura reduced flows, which may result in fish kills or barriers to fish 2000 site migration (salmon, twaite shad and lamprey) through the estuary into the River Severn. However, the River Severn DO HRA concluded no adverse effects upon the estuary as a result of the current Severn regulation (including the previous DP proposal), with the likely exception of the Gloucester and Sharpness canal. The current DP proposals would represent minor reductions in abstraction (24 Ml/d) compared to the previous DP and it is therefore considered that the potential effects would be equivalent to those concluded within the EA’s DOHRA. The in-combination effects would be greatest within the Lower Tidal Severn (upstream of the SAC boundary); these effects could also extend into the SAC boundary depending upon rates

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of abstraction from the unregulated Gloucester and Sharpness Canal.

Provide indicators of Modelled flow with respect to WFD Ecological Flow Indicator significance as a result (EFI) targets and the 1800Ml/d flow target at Haw Bridge as of the identification of required to maintain dissolved oxygen concentrations above 3 effects set out above mg/l sufficient for salmon (Hutcherson and Wade, 1992) . However, the improvement of water quality following treatment improvement works at Netheridge STW indicates that fish are much less vulnerable to low flows and flows of <1800Ml/d.

Describe any likely The primary risk is restriction to migration and reduction in impacts on the Natura population size for Annex II species, twaite shad and river 2000 site as a whole lamprey and RAMSAR species salmon and sea trout.

Describe from the Following the screening assessment, no potential impacts from above, those elements, the Hampton Loade DP proposals ‘alone’ are considered likely where the above upon the Severn Estuary SAC and Ramsar. This is supported by impacts are likely to be the EA’s previous DO HRA, which concludes no significant effect significant or where the from ‘do nothing’ or ‘drought order’ proposals ‘alone’. However, it scale of magnitude of is not possible to conclude no adverse effect as a result of the ‘in- impacts is not known combination’ effects of the Gloucester and Sharpness Canal . There is uncertainty relating to the significance of this effect, largely due to the unregulated, and therefore variable, abstraction rate.

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5 CONCLUSIONS

The screening assessment has concluded no significant effects are likely as a result of the Hampton Loade DP proposals ‘alone’; however, it is not possible to conclude no adverse effect ‘in-combination’ as a result of the Gloucester and Sharpness Canal abstraction. Where adverse effects are identified, which cannot be avoided or mitigated for, alternative options must be considered, or there are imperative reasons of overriding public interest for carrying out the activity. It is recommended that an alternative option be considered with respect to the currently unregulated licence. A solution will need to be sought between the Environment Agency and the Canal and River Trust which is also acceptable to Natural England, Countryside Council for Wales other water companies. This requirement was already highlighted in the EA’s DO HRA which concluded that there is a requirement to find a solution, preferably in advance of a DO being implemented.

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Report Reference: 60757 R1D1 Appendix B Report Status: Final 1 Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

6 REFERENCES

Enviros Consulting Limited (2007) Hampton Loade Drought Permit – Environmental Report. London, August 2006. Environment Agency (2012 (Draft)) River Severn Drought Order: Habitats Regulation Assessment (including Appropriate Assessment). Draft report. March 2012.

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APPENDIX A Conservation Objectives

Report Reference: 60757 R1D1 Appendix B Report Status: Final 1 Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

Severn Estuary SAC Site Description The Severn Estuary is the largest example of a coastal plain estuary in the United Kingdom and one or the SAC EU Code: largest estuaries in Europe. The overall area is 73,725.6 ha of which roughly two thirds is composed of UK0013030 subtidal habitats and one third intertidal habitats. Size: 73715.4 (ha) Grid Ref Centroid ST321748 Qualifying Features Annex II species assessed River lamprey Lampetra fluviatilis Sea lamprey Petromyzon marinus Twaite shad Alosa fallax River lamprey Lampetra fluviatilis Conservation Conservation objective for the River Lamprey Lampetra Objectives The feature will be considered to be in favourable condition when, subject to natural processes, each of the following conditions are met:

• the migratory passage of both adult and juvenile river lamprey through the Severn Estuary between the Bristol Channel and any of their spawning rivers is not obstructed or impeded by physical barriers, changes in flows, or poor water quality; • the size of the river lamprey population in the Severn Estuary and the rivers which drain into it, is at least maintained and is at a level that is sustainable in the long term; • the abundance of prey species forming the river lamprey’s food resource within the estuary, is maintained. • toxic contaminants in the water column and sediment are below levels which would pose a risk to the ecological objectives described above. Note : The river lamprey population of the Severn depends on habitat in the adjacent River Usk SAC, River Wye SAC and River Severn. The habitats in these rivers, including spawning and nursery areas, are essential for the fulfilment of the species’ lifecycle and therefore the Severn Estuary river lamprey feature can only be in favourable condition if the conservation objectives pertaining to the River Usk SAC and River Wye SAC river lamprey feature are also met in full and there is a continued recorded presence of this species in the River Severn. Report Reference: 60757 R1D1 Appendix B Report Status: Final 1 Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

Conservation objective for the sea lamprey Petromyzon marinus

The feature will be considered to be in favourable condition when, subject to natural processes, each of the following conditions are met:

• the migratory passage of both adult and juvenile sea lamprey through the Severn Estuary between the Bristol Channel and any of their spawning rivers is not obstructed or impeded by physical barriers, changes in flows, or poor water quality; • the size of the sea lamprey population in the Severn Estuary and the rivers which drain into it, is at least maintained as is at a level that is sustainable in the long term; • the abundance of prey species forming the sea lamprey’s food resource within the • estuary, is maintained. • Toxic contaminants in the water column and sediment are below levels which would pose a risk to the ecological objectives described above.

Note : The sea lamprey population of the Severn depends on habitat in the adjacent River Usk SAC, River Wye SAC and River Severn. The habitats in these rivers, including spawning and nursery areas, are essential for the fulfilment of the species’ lifecycle and therefore the Severn Estuary sea lamprey feature can only be in favourable condition if the conservation objectives pertaining to the River Usk SAC and River Wye SAC sea lamprey shad feature are also met in full and there is a continued recorded presence of this species in the River Severn.

Conservation objective for the twaite Shad Alosa fallax

The feature will be considered to be in favourable condition when, subject to natural processes, each of the following conditions are met:

• the migratory passage of both adult and juvenile twaite shad through the Severn Estuary between the Bristol Channel and their spawning rivers is not obstructed or impeded by physical barriers, changes in flows or poor water quality; • the size of the twaite shad population within the Severn Estuary and the rivers draining into it is at Report Reference: 60757 R1D1 Appendix B Report Status: Final 2 Review and Update of Drought Permit Environmental Assessment Report: River Severn at Hampton Loade HRA

least maintained and is at a level that is sustainable in the long term. • the abundance of prey species forming the twaite shad’s food resource within the • estuary, in particular at the salt wedge, is maintained. • Toxic contaminants in the water column and sediment are below levels which would pose a risk to the ecological objectives described above.

Note : The twaite shad population of the Severn depends on habitat in the adjacent River Usk SAC, River Wye SAC and River Severn. The habitats in these rivers, including spawning and nursery areas, are essential for the fulfilment of the species’ lifecycle and therefore the Severn Estuary twaite shad feature can only be in favourable condition if the conservation objectives pertaining to the River Usk SAC and River Wye SAC twaite shad feature are also met in full and there is a continued recorded presence of this species in the River Severn.

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Ramsar interest feature Attribute Measure Target Comments Ramsar Interest feature 2 : Migratory access Water quality measured Water quality is Significant variation in Migratory fish assemblage (Barriers to regularly throughout the sufficient to support these physio-chemical migration) reporting cycle in the migratory passage. parameters may act as ( migratory passage Bristol Channel, Severn Levels (for barriers to migration. not impeded - sections Estuary, River Wye temperature, salinity, For example, the 4.6.i and 4.7.i of the SAC, River Usk SAC turbidity and pH, and timing, duration and conservation and River Severn. dissolved oxygen) consistency of their objectives) (see also lines A17- A20 should comply with upstream migration are of Table 8 relating to targets established believed to be closely general water quality under the EA Review related to temperature requirements for the of Consents and the changes as well as estuary feature (and Water Framework pheromone triggers dependant sub features) Directive. from the juveniles Baseline is water during periods of high quality sampling data water flow. Peak collected by the migration usually Environment Agency coincides with river temperatures that remain above 10oC and continues until temperatures reach 18oC. Dissolved oxygen can also be significantly reduced in stretches receiving significant BOD inputs, or through the re-suspension of organic rich sediments. Toxic contaminants may act as a barrier to

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Ramsar interest feature Attribute Measure Target Comments migration.

Water flows measured Flows from the rivers regularly throughout the into the estuary must reporting cycle be sufficient to allow (frequency to be migration determined) in the River Baseline is water flow Wye SAC, River Usk sampling data SAC and River Severn collected by the (see also line A3 of Environment Agency Table 8 relating to provides a baseline. general tidal and water Severe low flow flow requirements for the conditions that affect estuary feature (and these species yet to dependant sub features) be defined Physical barriers No artificial barriers Dams, navigation and Mapping and significantly impairing, other weirs may quantification of adults from reaching prevent fish from potential obstructions in existing and historical reaching their spawning relation to height, type spawning grounds, or grounds. In particular, and water depth below juveniles from moving sea lamprey is known obstruction once during downstream. to be poor at ascending the reporting cycle. Baseline is the obstacles. Environment Agency data on structures and flood defences Population sizes Number of returning No decline in number (Note that this attribute (returning adults) adults measured using of returning adults will not be able to be (size of populations - fish counters on the from established measured until the sections 4.6.ii and 4.7.ii feeding rivers (Wye , baseline. technological solutions of the conservation Usk and Severn) during Baseline is yet to be for monitoring some

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Ramsar interest feature Attribute Measure Target Comments objectives) the migratory period. established - fish species (notably counter data may be lampreys and shad) are able to provide a developed.) baseline in future years. River populations Survey through various No decline in Details of methods for (size of populations - methods (Electrofishing, populations of the river and sea lamprey sections 4.6.ii and 4.7.ii seine netting , line Rivers Wye and Usk are outlined in section of the conservation fishing records, licencing Baseline is yet to be 4.1.9, Table 13 and for objectives) returns) at a series of established - fish Twaite shad in Table locations in the Rivers counter data may be 14 - the individual FCT Wye, Usk and Severn able to provide a for these species within baseline in future the SAC section of this years. document Prey species The abundance of key No significant River and sea lamprey (abundance of prey prey species measured reduction in require a variety of species - sections by EA in their routine abundance of key other fish species to act 4.6.iii and 4.7.iii of the monitoring of the rivers prey species against as hosts throughout conservation and estuary an established their lifecycle. Their objectives)) baseline principal host species Baseline is yet to be are part of the established through estuarine fish fish surveys in assemblage which has estuary and rivers measures and targets included within Table 8. Twaite shad require a variety of invertebrates including crustacean, mysids and copepods, small fish and fish eggs particularly in that

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Ramsar interest feature Attribute Measure Target Comments section of the estuary where saline and freshwaters meet. While at sea, salmon feed on a variety of fish (e.g. herring, sprat, sand eel, mackerel, and various gadoids) and crustaceans (e.g. euphausiid shrimps, prawns, gammarid amphipods and various crabs). (Bird, 2008) The diet of sea trout at sea is believed to include a range of fish species including sprat, young herring and sand eels as well as crustaceans such amphipods (e.g. Corophium), gammarids, decapods such as Crangon and mysid shrimps. Eeels feed on a range of benthic organisms that include crustaceans and small fish. (Bird, 2008)

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APPENDIX K: KEY ENVIRONMENTAL SITES

South Staffs Water Final Drought Plan February 2013: Appendix K

APPENDIX L: COMPANY DROUGHT MANAGEMENT STRUCTURE

Head Of Drought Management Drought Strategy Drought Team, Manager Member of Production Drought Management Member of and Drought Data Operational Executive of Drought Communication Team Executive of Member of Manager Drought Manager Three Co-ordinator Co-ordinator Role Three Executive of and Three Board Liaison. Head of Creative Day Job Role Head of Water Production and Water Resources Production Co- Supply Director Supply Manager Resources Strategy Asset Manager ordinator Manager Management Drought Plan Preparation Update plan every Review and sign off Review and sign off Review and sign off 3 years and where Input to review of Input to review of Input to review of Responsibility Plan Plan Plan material changes Plan Plan Plan occur Normal Operation (Reservoir storage above the Drought Monitoring Trigger Curve) Attend weekly Attend weekly Attend weekly Attend weekly Supply Planning Produce Blithfield Responsibility Supply Planning Supply Planning Supply Planning Meetings as refill scenarios Meetings Meetings Meetings required Identify when Identify when reservoir reservoir storage is storage is approaching 1st approaching 1st trigger curve trigger curve

South Staffs Water Final Drought Plan February 2013: Appendix L

Head Of Drought Member of Production Drought Drought Strategy Drought Data Operational Role Management Executive of Drought Communication Manager Manager Drought Manager Team Three Co-ordinator Co-ordinator

Drought Monitoring (Reservoir storage below the Drought Monitoring Trigger Curve at Blithfield or the Drought Alert Curve at Clywedog) Ensure Production Produce Blithfield Set up Drought Liaise with EA assets are refill scenarios / Management Team Regional Responsibility available and seek Clywedog when storage Drought advise on any refill forecast from crosses 1st curve Co-ordinator constraints. EA Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Drought Drought Drought Drought Drought Drought Management Management Team Management Team Management Team Management Team Management Team Team Monthly meeting of Monthly meeting of Monthly meeting of Monthly meeting of Monthly meeting of Monthly meeting of Monthly meeting of Drought Drought Drought Drought Drought Drought Drought Management Management Team Management Team Management Team Management Team Management Team Management Team Team Identify proposed Identify proposed Identify proposed Identify proposed Identify proposed Identify proposed drought mitigation drought mitigation drought mitigation drought mitigation drought mitigation drought mitigation options options options options options options Co-ordinate Confirm proposed internal and drought mitigation external Oversee instigation Co-ordinate options and communication of supply side Instigate drought Instigate drought internal and communications and drought mitigation mitigation actions mitigation actions external with Board of implementation of options communication Directors as demand side required options Identify when Identify when reservoir storage is reservoir storage is

approaching 2nd approaching 2nd trigger curve trigger curve.

South Staffs Water Final Drought Plan February 2013: Appendix L

Head Of Drought Member of Production Drought Drought Strategy Drought Data Operational Role Management Executive of Drought Communication Manager Manager Drought Manager Team Three Co-ordinator Co-ordinator

Drought Monitoring (Approaching Apply for Drought Permit Trigger Curve) Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Drought Drought Drought Drought Drought Drought Drought Management Management Management Team Management Team Management Team Management Team Management Team Team Team Produce Blithfield Review need for Review need for Review need for and refill scenarios / Maintain drought Maintain drought and benefit of and benefit of benefit of temporary seek Clywedog refill mitigation actions mitigation actions Responsibility temporary use ban temporary use ban use ban forecast from EA Prepare Drought Permit Applications Review need and Review need and Review need and and ensure benefit of drought benefit of drought benefit of drought environmental permit permit permit monitoring is in place Confirm need for temporary use ban Liaise with EA and drought permits Regional with Board of Drought Directors as Co-ordinator required Prepare notice for Co-ordinate internal temporary use ban and external and other external communication communication Publish the notice for temporary use ban Implement

temporary use ban

South Staffs Water Final Drought Plan February 2013: Appendix L

Production Drought Head Of Drought Drought Strategy Member of Drought Data Operational Role Drought Communication Management Team Manager Executive of Three Manager Drought Manager Co-ordinator Co-ordinator Drought Management (Reservoir Storage below the Apply for Drought Permit Trigger Curve) Confirm need for Produce Blithfield temporary use ban Liaise with EA refill and drought Regional scenarios / Responsibility permits with Board Drought seek Clywedog of Directors as Coordinator refill forecast required from EA Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Drought Drought Drought Drought Drought Drought Drought Management Management Management Team Management Team Management Team Management Team Management Team Team Team Review need and Review need and Review need and benefit of drought benefit of drought benefit of drought permit permit permit Implement temporary use ban if not already in place and if required Co-ordinate Co-ordinate internal and Submit drought internal and

external permit application external communication communication

Identify when Identify when reservoir storage reservoir storage is

is approaching 3rd approaching 3rd trigger curve trigger curve

South Staffs Water Final Drought Plan February 2013: Appendix L

Head Of Drought Production Drought Drought Strategy Member of Drought Data Operational Role Management Drought Communication Manager Executive of Three Manager Drought Manager Team Co-ordinator Co-ordinator

Severe Drought Management (Reservoir Storage below the Implement Drought Permit Trigger Curve) Ensure environmental Implement drought Implement drought Implement drought monitoring is in permit permit permit place for drought permits Responsibility Produce Blithfield Liaise with EA refill scenarios Regional /seek Clywedog Drought refill forecast from Coordinator EA Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Weekly meeting of Drought Drought Drought Drought Drought Drought Management Management Team Management Team Management Team Management Team Management Team Team Identify additional Identify additional Identify additional Identify additional Identify additional Identify additional drought mitigation drought mitigation drought mitigation drought mitigation drought mitigation drought mitigation options options options options options options Review need and Review need and Review need and benefit of Ordinary benefit of Ordinary benefit of Ordinary Drought Order Drought Order Drought Order Confirm need for Prepare notice for Co-ordinate Ordinary Drought Ordinary Drought internal and Order with Board Order and other external of Directors as external communication required communication

South Staffs Water Final Drought Plan February 2013: Appendix L

Head Of Drought Member of Production Drought Drought Strategy Drought Data Operational Role Management Executive of Drought Communication Manager Manager Drought Manager Team Three Co-ordinator Co-ordinator Implement Instigate drought Instigate drought Ordinary Drought mitigation actions mitigation actions Order Drought Cessation (Reservoir Storage at least 5% above the Drought Monitoring trigger curve) Produce Blithfield Liaise with EA refill scenarios Regional Responsibility /seek Clywedog Drought refill forecast from Coordinator EA Final meeting of Final meeting of Final meeting of Final meeting of Final meeting of Final meeting of Drought Drought Drought Drought Drought Drought Management Team Management Team Management Team Management Team Management Team Management Team Identify proposed Identify proposed Identify proposed Identify proposed Identify proposed Identify proposed Identify proposed drought cessation drought cessation drought cessation drought cessation drought cessation drought cessation drought cessation actions actions actions actions actions actions actions Identify proposed Identify proposed Identify proposed Coordinate residual internal and internal and internal and drought monitoring external external external and reporting. communication communication communication

Review and Report Coordinate drought Restore normal on drought and Restore normal Restore normal Coordinate drought

communication operation amend Drought operation operation communication Plan as required.

South Staffs Water Final Drought Plan February 2013: Appendix L

APPENDIX M: EXAMPLE OF AN APPEAL FOR CUSTOMER DEMAND SAVINGS

South Staffordshire Water asks customers to use water wisely:

The recent hot spell has come at the end of a very dry period and has resulted in unprecedented demand for water throughout the whole of the Company’s area.

Although the Company currently has adequate resources to provide sufficient water for domestic use, we are asking customers not to use hosepipes or sprinklers, but to use a garden watering can instead. We are also asking that non- essential uses of water are postponed, for example car washing and patio pressure-washing.

A spokesperson for the Company said: “With the continuing hot weather and little prospect of prolonged rain, unless customers avoid the unnecessary use of water, reservoirs will be depleted and customers may find themselves without water. Common sense use of water will ensure that all customers will receive an adequate amount of water for their essential domestic use”.

We would like to thank customers in anticipation of their help and co-operation.

Dr Liz Swarbrick Managing Director South Staffordshire Water PLC Green Lane Walsall WS2 7PD

Tel: 01922 638282

South Staffs Water Final Drought Plan February 2013: Appendix M

APPENDIX N: EXAMPLE OF A TEMPORARY USE BAN NOTIFICATION

SOUTH STAFFORDSHIRE WATER PLC WATER INDUSTRY ACT 1991 & FLOOD AND WATER MANAGEMENT ACT 2010

IMPLEMENTATION OF A TEMPORARY USE BAN Notice is hereby given that a serious shortage of water available for distribution by South Staffordshire Water PLC exists or is threatened in the area specified in the Schedule hereto. Under powers conferred by Section 36 of the Flood and Water Management Act 2010, South Staffordshire Water PLC therefore prohibit the use of water supplied by the Company in the area specified in the Schedule below and drawn through hosepipe or similar apparatus for the purpose of: a. watering a garden using a hosepipe; b. cleaning a private motor-vehicle using a hosepipe; c. watering plants on domestic or other non-commercial premises using a d. hosepipe; e. cleaning a private leisure boat using a hosepipe; f. filling or maintaining a domestic swimming or paddling pool; g. drawing water, using a hosepipe, for domestic recreational use; h. filling or maintaining a domestic pond using a hosepipe; i. filling or maintaining an ornamental fountain; j. cleaning walls, or windows, of domestic premises using a hosepipe; k. cleaning paths or patios using a hosepipe; l. cleaning other artificial outdoor surfaces using a hosepipe. This prohibition shall take effect from XXXXX until further notice. Customers wishing to make representations should contact the Managing Director at the address below by YYYY. AREA AFFECTED BY THE PROHIBITION Those customers supplied by South Staffordshire Water PLC in the following areas: East Staffordshire Borough Council (including Burton, Abbots Bromley, Uttoxeter, Mayfield) Cannock Chase District Council (including Rugeley, Cannock) South Staffordshire District Council (including Penkridge, Kinver) Lichfield District Council Tamworth Borough Council Birmingham City Council (Sutton Coldfield) Walsall Metropolitan Borough (including Aldridge) Sandwell Metropolitan Borough (including West Bromwich, Smethwick, Blackheath) Dudley Metropolitan Borough (including Halesowen) Bromsgrove District Council (Romsley) South Derbyshire District Council (Castle Gresley, Overseal) North West Leicestershire District Council (Chilcote)

Dr Liz Swarbrick Managing Director South Staffordshire Water PLC Green Lane Walsall WS2 7PD

South Staffs Water Final Drought Plan February 2013: Appendix N

APPENDIX O: EXAMPLE OF A TEMPORARY USE BAN CESSATION NOTICE

SOUTH STAFFORDSHIRE WATER PLC WATER INDUSTRY ACT 1991 & FLOOD AND WATER MANAGEMENT ACT 2010

REVOCATION OF TEMPORARY USE BAN

Recent weather conditions and a positive response to our appeals have meant a substantial reduction in our peak demand and a significant increase of our reservoir levels. Subsequently, South Staffordshire Water is pleased to announce to our customers the relaxation of the temporary use ban on the use of hosepipes and garden sprinklers.

We would like to take this opportunity to thank customers for their help and co- operation during this difficult time and remind them that if they do operate a garden watering system, such as a sprinkler or hosepipe running unattended, they must have a water meter fitted to their property.

AREA AFFECTED BY THE REVOCATION OF PROHIBITION

Those customers supplied by South Staffordshire Water PLC in the following areas:

East Staffordshire Borough Council (including Burton, Abbots Bromley, Uttoxeter, Mayfield) Cannock Chase District Council (including Rugeley, Cannock) South Staffordshire District Council (including Penkridge, Kinver) Lichfield District Council Tamworth Borough Council Birmingham City Council (Sutton Coldfield) Walsall Metropolitan Borough (including Aldridge) Sandwell Metropolitan Borough (including West Bromwich, Smethwick, Blackheath) Dudley Metropolitan Borough (including Halesowen) Bromsgrove District Council (Romsley) South Derbyshire District Council (Castle Gresley, Overseal) North West Leicestershire District Council (Chilcote)

Dr Liz Swarbrick Managing Director South Staffordshire Water PLC Green Lane Walsall WS2 7PD

South Staffs Water Final Drought Plan February 2013: Appendix O

APPENDIX P: EXAMPLE OF A NOTICE TO APPLY FOR AN ORDINARY DROUGHT ORDER SOUTH STAFFORDSHIRE WATER PLC WATER INDUSTRY ACT 1991 & DROUGHT DIRECTION 2011

PROHIBITION OF NON ESSENTIAL USES OF WATER

Notice is hereby given that, because of exceptional shortage of rain South Staffordshire Water plc are applying to the Secretary of State for Environment, Food and Rural Affairs for an Order under section 74(2)(b) of the Water Resources Act 1991. The general effect of the Order will be to prohibit or limit until XXXX within the area described below supplied with water by the Company the use of water for any or more of the purposes set out below being purposes included within the Direction made by the Secretary of State on 29th March 2011. AREA AFFECTED BY THE PROHIBITION Those customers supplied by South Staffordshire Water PLC in the following areas: East Staffordshire Borough Council (including Burton, Abbots Bromley, Uttoxeter, Mayfield) Cannock Chase District Council (including Rugeley, Cannock) South Staffordshire District Council (including Penkridge, Kinver) Lichfield District Council Tamworth Borough Council Birmingham City Council (Sutton Coldfield) Walsall Metropolitan Borough (including Aldridge) Sandwell Metropolitan Borough (including West Bromwich, Smethwick, Blackheath) Dudley Metropolitan Borough (including Halesowen) Bromsgrove District Council (Romsley) South Derbyshire District Council (Castle Gresley, Overseal) North West Leicestershire District Council (Chilcote) The uses of water it is proposed to prohibit or limit are as follows: a. Watering outdoor plants on commercial premises; b. Filling or maintaining a non-domestic swimming or paddling pool; c. Filling or maintaining a pond; d. Operating a mechanical vehicle-washer; e. Cleaning any vehicle, boat, aircraft or railway rolling stock; f. Cleaning non-domestic premises; g. Cleaning a window of a non-domestic building; h. Cleaning industrial plant; i. Suppressing dust; and j. Operating cisterns. Any objections to the proposed Order may be made in writing to the Secretary of State for Environment, Food and Rural Affairs, Water Supply and Regulation Division, 2nd Floor Area 2C, Ergon House, Horseferry Road, London SW1P 2AL, within the period of 7 days from the date of publication of this notice.

Dr Liz Swarbrick Managing Director South Staffordshire Water PLC Green Lane Walsall, WS2 7PD

South Staffs Water Final Drought Plan February 2013: Appendix P

APPENDIX Q: DETAIL OF DROUGHT LEGISLATION

Q1: Flood and Water Management Act 2010 Section 36 Water use: temporary bans

Q2: The Water Use (Temporary Bans) Order 2010

Q3: The Drought Plan Direction 2011

South Staffs Water Final Drought Plan February 2013: Appendix Q Status: This version of this provision is prospective. Changes to legislation: There are currently no known outstanding effects for the Flood and Water Management Act 2010, Section 36. (See end of Document for details)

ELIZABETH II c. 29

Flood and Water Management Act 2010

2010 CHAPTER 29

PART 2

MISCELLANEOUS

36 Water use: temporary bans For section 76 of the Water Industry Act 1991 (temporary hosepipe bans) substitute—

“76 Temporary bans on use (1) A water undertaker may prohibit one or more specified uses of water supplied by it if it thinks that it is experiencing, or may experience, a serious shortage of water for distribution. (2) Only the following uses of water may be prohibited— (a) watering a garden using a hosepipe; (b) cleaning a private motor-vehicle using a hosepipe; (c) watering plants on domestic or other non-commercial premises using a hosepipe; (d) cleaning a private leisure boat using a hosepipe; (e) filling or maintaining a domestic swimming or paddling pool; (f) drawing water, using a hosepipe, for domestic recreational use; (g) filling or maintaining a domestic pond using a hosepipe; (h) filling or maintaining an ornamental fountain; (i) cleaning walls, or windows, of domestic premises using a hosepipe; (j) cleaning paths or patios using a hosepipe; (k) cleaning other artificial outdoor surfaces using a hosepipe. (3) The Minister may by order— (a) add a non-domestic purpose to the list in subsection (2); 2 Flood and Water Management Act 2010 (c. 29) Part 2 – Miscellaneous Document Printed: 2010-09-06 Status: This version of this provision is prospective. Changes to legislation: There are currently no known outstanding effects for the Flood and Water Management Act 2010, Section 36. (See end of Document for details)

(b) remove a purpose from the list in subsection (2). (4) A prohibition must specify— (a) the date from which it applies, and (b) the area to which it applies (which may be all or part of the undertaker's area). (5) A person who contravenes a prohibition— (a) is guilty of an offence, and (b) is liable on summary conviction to a fine not exceeding level 3 on the standard scale. (6) A water undertaker which issues a prohibition must make arrangements for a reasonable reduction of charges which are made in respect of prohibited uses (including arrangements for repayment or credit where charges are paid in advance). (7) A water undertaker may vary or revoke a prohibition.

76A Temporary bans: supplemental (1) A prohibition may— (a) apply to one or more specified uses of water generally or only in specified cases or circumstances (which may be specified by reference to classes of user, timing or in any other way); (b) be subject to exceptions (which may be absolute or conditional, and may be specified by reference to classes of user, timing or in any other way). (2) The Minister may by order— (a) provide for exceptions to a category of use in section 76(2) (whether or not added under section 76(3)); (b) provide that a specified activity, or an activity undertaken in specified circumstances, is to be or not to be treated as falling within a category of use in section 76(2) (whether or not added under section 76(3)); (c) define a word or phrase used in section 76(2) (whether or not added under section 76(3)). (3) In particular, an order may— (a) restrict a category of use by reference to how water is drawn; (b) frame an exception by reference to ownership of land by a specified person or class of person; (c) provide for a process that involves the use of a hosepipe at any point to be included in the meaning of “using a hosepipe”; (d) provide for a reference to a thing to include a reference to something that is or may be used in connection with it (such as, for example, for a reference to a vehicle to include a reference to a trailer). (4) In this section and section 76 “the Minister” means— (a) the Secretary of State in relation to prohibitions which may be issued by water undertakers whose areas are wholly or mainly in England, and (b) the Welsh Ministers in relation to prohibitions which may be issued by water undertakers whose areas are wholly or mainly in Wales. Flood and Water Management Act 2010 (c. 29) 3 Part 2 – Miscellaneous Document Printed: 2010-09-06 Status: This version of this provision is prospective. Changes to legislation: There are currently no known outstanding effects for the Flood and Water Management Act 2010, Section 36. (See end of Document for details)

(5) Subject to provision under subsection (2), a reference to a hosepipe in section 76 includes a reference to anything designed, adapted or used to serve the same purpose as a hosepipe.

76B Temporary bans: procedure (1) A prohibition takes effect only if this section is complied with. (2) Before the period for which a prohibition is to apply the water undertaker must give notice of the prohibition and its terms— (a) in at least two newspapers circulating in the area to which it is to apply, and (b) on the water undertaker's internet website. (3) The notice must give details of how to make representations about the proposed prohibition. (4) The variation of a prohibition is to be treated as a prohibition for the purposes of this section. (5) A water undertaker must give notice of a revocation of a prohibition— (a) in at least two newspapers circulating in the area to which it is to apply, and (b) on the water undertaker's internet website. (6) The revocation may not take effect until at least one notice under subsection (5) has been given.

76C Orders under sections 76 and 76A (1) Section 213 applies to orders under section 76(3) or 76A(2) as it applies to regulations. (2) But— (a) an order made by the Secretary of State under section 76(3) may not be made unless a draft has been laid before and approved by resolution of each House of Parliament, (b) an order made by the Welsh Ministers under section 76(3) may not be made unless a draft has been laid before and approved by resolution of the National Assembly for Wales, and (c) an order made by the Welsh Ministers under section 76A(2) shall be subject to annulment in pursuance of a resolution of the National Assembly for Wales.” 4 Flood and Water Management Act 2010 (c. 29) Document Printed: 2010-09-06

Status: This version of this provision is prospective.

Changes to legislation: There are currently no known outstanding effects for the Flood and Water Management Act 2010, Section 36. Status: This is the original version (as it was originally made). UK Statutory Instruments are not carried in their revised form on this site.

STATUTORY INSTRUMENTS

2010 No. 2231 WATER INDUSTRY, ENGLAND AND WALES

The Water Use (Temporary Bans) Order 2010

Made - - - - 6th September 2010 Laid before Parliament 9th September 2010 Laid before the National Assembly for Wales - - 9th September 2010 Coming into force - - 1st October 2010

This Order is made in exercise of the powers conferred on the Secretary of State and the Welsh Ministers by section 76A(2) of the Water Industry Act 1991(a). The Secretary of State, in relation to prohibitions which may be issued under section 76(1) of that Act(b) by water undertakers whose areas are wholly or mainly in England, and the Welsh Ministers, in relation to prohibitions which may be issued under that section by water undertakers whose areas are wholly or mainly in Wales, make the following Order.

PART 1 Introduction

Citation and commencement 1. This Order may be cited as the Water Use (Temporary Bans) Order 2010 and comes into force on 1st October 2010.

Interpretation 2. In this Order— “the Act” means the Water Industry Act 1991; “grow” includes cultivate or propagate; “health or safety reasons” includes—

(a) 1991 c. 56; section 76A was inserted by section 36 of the Flood and Water Management Act 2010 (c. 29). See section 76A(4) of the Water Industry Act 1991 for the definition of “the Minister”. (b) Section 76 was substituted by section 36 of the Flood and Water Management Act 2010. Document Printed: 2010-09-10 Status: This is the original version (as it was originally made). UK Statutory Instruments are not carried in their revised form on this site.

(a) removing or minimising any risk to human or animal health or safety; and (b) preventing or controlling the spread of causative agents of disease; “National Plant Collection” means a plant collection which is part of the National Council for the Conservation of Plants and Gardens’ National Plant Collection scheme; “outdoor pot” means a pot or other container that is outdoors or under cover; “temporary garden or flower display” means a garden or flower display that is— (a) at a show or exhibition; and (b) on public display for a period not exceeding 7 days; and “under cover” means in a greenhouse or outbuilding or under a permanent canopy.

PART 2 Categories of use

Definition of “using a hosepipe” 3.—(1) Using a hosepipe, in relation to a purpose in section 76(2) of the Act, includes the following— (a) drawing relevant water through a hosepipe from a container and applying it for the purpose; (b) filling or partly filling a container with relevant water by means of a hosepipe and applying it for the purpose. (2) In paragraph (1), “relevant water” does not include water supplied by a water undertaker before the use of water to which the purpose relates was prohibited under section 76(1) of the Act.

Watering a garden using a hosepipe 4.—(1) Using a hosepipe to water a garden for health or safety reasons is not to be treated as falling within the category of use in section 76(2)(a) of the Act. (2) In that section, “a garden” includes any of the following— (a) a park; (b) gardens open to the public; (c) a lawn; (d) a grass verge; (e) an area of grass used for sport or recreation; (f) an allotment garden, as defined in section 22(1) of the Allotments Act 1922(c); (g) any area of an allotment used for non-commercial purposes; (h) any other green space. (3) But “a garden” does not include— (a) agricultural land, as defined in section 109(1) of the Agriculture Act 1947(d); (b) other land used in the course of a business for the purposes of growing, for sale or commercial use, any crops, fruit, vegetables or other plants; (c) land used for the purposes of a National Plant Collection; (d) a temporary garden or flower display; or

2 Document Printed: 2010-09-10 Status: This is the original version (as it was originally made). UK Statutory Instruments are not carried in their revised form on this site.

(e) plants (including plant organs, seeds, crops and trees) which are in an outdoor pot or in the ground, under cover.

Cleaning a private motor-vehicle using a hosepipe 5. In section 76(2)(b) of the Act, “private motor-vehicle” means— (a) a mechanically propelled vehicle designed, constructed or adapted for use on roads, except — (i) a public service vehicle, as defined in section 1 of the Public Passenger Vehicles Act 1981(e), and (ii) a goods vehicle, as defined in section 192 of the Road Traffic Act 1988(f); or (b) a trailer designed, constructed or adapted for attachment to a vehicle falling within paragraph (a).

Watering plants on domestic or other non-commercial premises using a hosepipe 6.—(1) The category of use in section 76(2)(c) of the Act— (a) applies only to the watering of plants which are in an outdoor pot or in the ground, under cover; and (b) does not include watering plants— (i) grown or kept for sale or commercial use, or (ii) that are part of a National Plant Collection or temporary garden or flower display. (2) In that section— “domestic or other non-commercial premises” means— (a) any land, building or other structure used or enjoyed in connection with the use of any of the following which is used principally as a dwelling— (i) a building or part of a building, (ii) a caravan, (iii) a boat; or (b) any other land or premises which is not used principally for the purposes of a business; and “plants” includes plant organs, seeds, crops and trees.

Cleaning a private leisure boat using a hosepipe 7.—(1) The category of use in section 76(2)(d) of the Act does not include cleaning any area of a private leisure boat which, except for doors or windows, is enclosed by a roof and walls. (2) Using a hosepipe to clean a private leisure boat for health or safety reasons is not to be treated as falling within the category of use in that section. (3) In that section, “private leisure boat” means a vessel or other thing, other than a seaplane, which is designed, constructed or adapted to move through, in, on or over water and which is not— (a) used in the course of a business; or (b) made available or accessible to the public.

3 Document Printed: 2010-09-10 Status: This is the original version (as it was originally made). UK Statutory Instruments are not carried in their revised form on this site.

Filling or maintaining a domestic swimming or paddling pool 8.—(1) The following are not to be treated as falling within the category of use in section 76(2) (e) of the Act— (a) filling or maintaining a pool where necessary in the course of its construction; (b) filling or maintaining a pool using a hand-held container which is filled with water drawn directly from a tap; (c) filling or maintaining a pool that is designed, constructed or adapted for use in the course of a programme of medical treatment; (d) filling or maintaining a pool that is used for the purpose of decontaminating animals from infections or disease; (e) filling or maintaining a pool used in the course of a programme of veterinary treatment; (f) filling or maintaining a pool in which fish or other aquatic animals are being reared or kept in captivity. (2) In that section, “domestic swimming or paddling pool” means a swimming or paddling pool, other than a pool that is being used for the purposes of a business, which is— (a) in a building, or part of a building, used principally as a dwelling; or (b) on any land or in any building that is used or enjoyed in connection with a building, or part of a building, mentioned in sub-paragraph (a).

Drawing water, using a hosepipe, for domestic recreational use 9.—(1) Drawing water, using a hosepipe, to operate water slides or other recreational equipment is to be treated as falling within the category of use in section 76(2)(f) of the Act. (2) In that section, “domestic recreational use” means— (a) recreational use in connection with a domestic swimming or paddling pool within the meaning of section 76(2)(e) of the Act(g); or (b) recreational use on land that is used or enjoyed in connection with a building, or part of a building, used principally as a dwelling, other than for the purposes of a business.

Filling or maintaining a domestic pond using a hosepipe 10.—(1) The category of use in section 76(2)(g) of the Act does not include filling or maintaining a domestic pond in which fish or other aquatic animals are being reared or kept in captivity. (2) In that section, “domestic pond” means a pond, including a swimming pond, on land that— (a) is used or enjoyed in connection with a building, or part of a building, used principally as a dwelling; and (b) is not being used for the purposes of a business.

Filling or maintaining an ornamental fountain 11.—(1) The category of use in section 76(2)(h) of the Act does not include filling or maintaining an ornamental fountain which is in or near a fish-pond and whose purpose is to supply sufficient oxygen to the water in the pond in order to keep the fish healthy. (2) In that section, “ornamental fountain” includes a cascade or any other display of moving water.

4 Document Printed: 2010-09-10 Status: This is the original version (as it was originally made). UK Statutory Instruments are not carried in their revised form on this site.

Cleaning walls, or windows, of domestic premises using a hosepipe 12.—(1) The category of use in section 76(2)(i) of the Act applies only to the cleaning of the external walls or windows of domestic premises. (2) Using a hosepipe to clean the walls or windows of domestic premises for health or safety reasons is not to be treated as falling within the category of use in that section. (3) In that section, “domestic premises” means— (a) a building used principally as a dwelling or dwellings; (b) a garage, shed, outbuilding or other building or structure used or enjoyed in connection with a building mentioned in sub-paragraph (a); or (c) a wall or other means of enclosure within the curtilage of a building mentioned in sub- paragraph (a).

Cleaning paths or patios using a hosepipe 13. Using a hosepipe to clean paths or patios for health or safety reasons is not to be treated as falling within the category of use in section 76(2)(j) of the Act.

Cleaning other artificial outdoor surfaces using a hosepipe 14.—(1) Using a hosepipe to clean an artificial outdoor surface for health or safety reasons is not to be treated as falling within the category of use in section 76(2)(k) of the Act. (2) In that section, “artificial outdoor surface” means any of the following— (a) any area outdoors which is paved or laid with hard or artificial material; (b) timber decking; (c) a quay; (d) a trailer designed, constructed or adapted to launch boats or other vessels or craft into water, other than a private motor-vehicle within the meaning of section 76(2)(b) of the Act(h); (e) the roof of any domestic premises within the meaning of section 76(2)(i) of the Act(i). (3) In paragraph (2), “quay” includes jetty, pontoon, wharf and slipway.

Richard Benyon Parliamentary Under Secretary of State Department for Environment, Food and Rural 2nd September 2010 Affairs Jane Davidson Minister for Environment, Sustainability and Housing, 6th September 2010 one of the Welsh Ministers

5 EXPLANATORY NOTE

(This note is not part of the Order)

Section 76 of the Water Industry Act 1991 (c. 56) (“the Act”), as substituted by section 36 of the Flood and Water Management Act 2010 (c. 29), allows a water undertaker to prohibit one or more specified uses of water supplied by it if it thinks that it is experiencing, or may experience, a shortage of water for distribution. The uses that may be prohibited are set out in section 76(2) of the Act. This Order defines words and phrases used in section 76(2) of the Act, provides for certain exceptions to the categories of use in that section and provides that certain activities are to be or not to be treated as falling within the categories of use in that section. A separate impact assessment has not been prepared in respect of this Order because the impact assessment which was prepared for the Flood and Water Management Act 2010 included assumptions which are reflected in this Order.

6 The Drought Plan Direction 2011

This Direction is made in exercise of the powers conferred by— (a) section 37B(11) of the Water Industry Act 1991(a), as applied by section 39B(5) of that Act; and (b) section 39B(4)(d) and (9) of that Act(b).

The Secretary of State has consulted the Welsh Ministers in relation to Wales(c) and gives the following Direction to water undertakers whose areas are wholly or mainly in England.

The Welsh Ministers have consulted the Secretary of State in relation to England(d) and give the following Direction to water undertakers whose areas are wholly or mainly in Wales.

Citation and commencement 2. This Direction may be cited as the Drought Plan Direction 2011 and comes into force on 17th March 2011.

Interpretation 3.—(1) In this Direction— “the Act” means the Water Industry Act 1991; “drought plan” means the plan which a water undertaker is required to prepare and maintain under section 39B(1) of the Act; “the relevant Minister” means the Secretary of State in relation to a water undertaker whose area is wholly or mainly in England, and the Welsh Ministers in relation to a water undertaker whose area is wholly or mainly in Wales; and “water undertaker” is to be construed in accordance with section 6 of the Act. (2) A reference in this Direction to section 37B(1) of the Act is a reference to that section as applied by section 39B(5) of the Act.

Additional matters to be addressed in drought plans 4.—(1) A water undertaker, in its drought plan, must address the following matters— (a) the management structure that the water undertaker will put in place during a drought; (b) the permits and approvals that the water undertaker may need in order to implement the drought management measures;

(a) 1991 c. 56. (b) Sections 37B and 39B were inserted into the Water Industry Act 1991 by sections 62 and 63 of the Water Act 2003 (c. 37). Functions of the Secretary of State under sections 37B and 39B, in so far as they relate to matters other than the construction or enlargement of reservoirs, were transferred to the National Assembly for Wales in relation to any water undertaker whose area is wholly or mainly in Wales by the National Assembly for Wales (Transfer of Functions) Order 1999 (S.I. 1999/672) (“the Order”), article 2: see the entry in Schedule 1, as amended by section 100(2) of the Water Act 2003, for the Water Industry Act 1991. Those functions were subsequently transferred to the Welsh Ministers by virtue of section 162 of, and paragraph 30 of Schedule 11 to, the Government of Wales Act 2006 (c. 32). (c) The functions of the Secretary of State under sections 37B and 39B of the Water Industry Act 1991 are exercisable in relation to Wales only after consultation with the Welsh Ministers (article 5 of, and Schedule 2 to, the Order and section 162 of, and paragraph 30 of Schedule 11 to, the Government of Wales Act 2006). (d) The functions under sections 37B and 39B of the Water Industry Act 1991 that are exercisable by the Welsh Ministers are exercisable by them in relation to England only after consultation with the Secretary of State (article 2 of, and Schedule 1 to, the Order (as amended by section 100(3) of the Water Act 2003), and section 162 of, and paragraph 30 of Schedule 11 to, the Government of Wales Act 2006). (c) the discussions that have occurred between the water undertaker and the bodies responsible for granting those permits and approvals; (d) the arrangements for discussions with those bodies during a drought; (e) the measures that may be needed to mitigate any adverse effect on the environment resulting from the implementation of a drought management measure; (f) the permits and approvals that may be needed in order to implement those mitigation measures; and (g) the compensation that may need to be made as a result of the implementation of a drought management measure. (2) In this paragraph— “compensation” means compensation within the meaning of Schedule 9 to the Water Resources Act 1991(a); and “drought management measure” means a measure mentioned in section 39B(4)(a) or (b) of the Act and set out in the drought plan.

Responding to representations 5. A water undertaker must produce the statement required by regulation 4 of the Drought Plan Regulations 2005(b) within 15 weeks after the date on which the water undertaker publishes a draft of its drought plan under section 37B(3)(a) of the Act.

Submitting draft drought plans to the relevant Minister 6.—(1) For the purpose of section 37B(1) of the Act, a water undertaker must send a draft of its drought plan to the relevant Minister as follows— (a) for a first drought plan, within 6 months after the date on which the water undertaker is required to prepare that drought plan; (b) for a revised drought plan— (i) if section 39B(6)(a) of the Act applies as a result of a material change of circumstances arising from a new statutory provision, within 12 months after the date on which the change occurs; (ii) if section 39B(6)(a) of the Act applies as a result of a material change of circumstances arising for any other reason, within 6 months after the date on which the change occurs; (iii) if section 39B(6)(c) of the Act applies, within 3 years and 6 months after the date on which its drought plan, or its last revised drought plan, is published. (2) If section 39B(6)(c) of the Act applies and a material change of circumstances occurs before the water undertaker has submitted a draft of its revised drought plan within the period mentioned in sub-paragraph (1)(b)(iii), the date by which the water undertaker must send a draft of its revised drought plan to the relevant Minister is to be determined in accordance with sub- paragraph (1)(b)(i) or (ii). (3) In this paragraph, “a new statutory provision” means a provision of any Act of Parliament, regulations or order coming into force on or after 1st October 2010.

(a) 1991 c. 57. (b) S.I. 2005/1905.

2 Revocation of the Drought Plan Direction 2005 7. The Drought Plan Direction 2005(a) is revoked.

John Bourne Head of Water Supply and Regulation Division, for and on behalf of the 16th March 2011 Secretary of State for Environment, Food and Rural Affairs

Claire Bennett Deputy Director, Climate Change and Water Division, for and on behalf of 16th March 2011 the Welsh Ministers

(a) The Drought Plan Direction 2005 came into force on 1st October 2005.

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APPENDIX R: DROUGHT PLAN NON-TECHNICAL SUMMARY

South Staffs Water Final Drought Plan February 2013: Appendix R