Draft Water Resources Management Plan 2020 to 2080 Statement of Response Appendix 2 - Our response to the representations Appendix tables 2A to 2N 2

Appendix 2 - Our response to the representations Appendix tables 2A to 2N

Appendix 2A - Overview

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Hampshire and S10.5 Overview - Protect and restore catchments from source to sea. We strongly believe in the merits of promoting None Isle of Wight Catchment sustainable and resilient water supplies at source Wildlife Trust Management and fully intend to continue to promote and deliver catchment management to improve the quality and reliability of the water sources we rely upon to fulfil our customer’s demand for water. Please refer to our WINEP and Business plan for more information about this. We recognise our role in addressing impacts on raw water quality. As this is a proactive programme, it sits within our future business plan commitments and WINEP, the only elements that relate to an impact in current DO are reflected in the WRMP. Kent Wildlife S12.40 Overview - We commend the efforts of South East Water to date We welcome your commendation of our ongoing None Trust and Catchment having engaged very positively with Catchment Sensitive activities to engage other land and water users within Sussex Wildlife Management Farming. We would however continue to advocate the catchments we operate in. We strongly believe Trust for their playing a greater stewardship role in the in the merits of promoting sustainable and resilient catchments that they and their customers depend on, water supplies at source and fully intend to continue working in partnership with others to address problems to promote and deliver catchment management at their source, rather than end of pipe. to improve the quality and reliability of the water sources we rely upon to fulfil our customer’s demand for water. Please refer to our WINEP and Business plan for more information about this. We recognise our role in addressing impacts on raw water quality. As this is a proactive programme, it sits within our future business plan commitments and WINEP, the only elements that relate to an impact on output from our existing sources is reflected in the WRMP - so essentially we haven’t forgotten it, it is just sitting in another place within South East Water’s long term plans. southeastwater.co.uk 3

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Defra R1.4 Overview - Would like to understand how the plan will help to deliver We have updated rWRMP19 to address this point. Updated Environmental the government’s 25 year plan for the environment. In Section 1.3 Impact particular, how it will deliver net environmental gain in of rWRMP19 your company area. Environment R2.21 Overview - The company must provide in numerical format how We have included this information in our rWRMP19. Updated Agency Environmental much greenhouse gas it estimates it will emit for its Section 9 of Impact ongoing operations, as it has for its feasible options, or rWRMP19 signpost where this information can be found outside of the WRMP. Individual I112.3 Overview - Costs could change significantly in the next few years. There is a statutory requirement for us to develop None Finance Five year review is required. and publish a Water Resources Plan every five years. Therefore, as part of the process, the plan and costs will be reviewed and updated as necessary in five years time. Individual I38.3 Overview - Need reassurances that financially will not be impacted The rWRMP19 will be delivered in a manner that None Finance and this will result in no hosepipe bans. ensures we maintain an efficient service that is affordable, and ensure no deterioration in levels of service that lead to increased risk of hosepipe bans in the future. Individual I91.2 Overview - Use logical costing models for the 60 year forecast. One step of our decision making process is to None Finance generate a number of least cost plans (for different future scenarios) looking over a 60 year period. This approach is outlined in Section 8 and Appendix 8A of our rWRMP19. Each plan is generated using an optimisation model, this model takes into account the capital cost, operating cost, carbon cost and Environmental and Social cost of all our feasible options to solve the supply-demand balance at the lowest possible cost over the 60 year period.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 4

Appendix 2A - Overview continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I117.1 Overview - Inside the front cover of South East Water’s Draft Water We created several versions of this infographic before None Formatting Resources Management Plan – Non-technical Summary settling on this design. The infographic is there to 2020 to 2080, the large ‘drop’ of water figured lacks provide a quick, high level snapshot of the proposal figures. People might like to know, for example, how timetable. In the WRMP report, Figure 6 provides much water reuse there is, how much desalination. further information about the supply demand balance Maybe the data are hidden away in the rest of the and future water needs. Section 9 provides more document (some on p. 41) but this would be the obvious details on levels of water re-use planned and water place to insert them. options in preferred plan. Ofwat R4.9 Overview - The main plan does not summarise all of the key concepts We consider we have got the balance of information None Formatting relating to the plan and there is significant cross in main report and in supporting technical appendices referencing to numerous technical appendices. This right. Otherwise customers will not understand our reduces the transparency and accessibility of the plan. plan. The non-technical summary provides a useful context, though would benefit from a clearer justification of the selected plan with meaningful details of cost. Waterwise S8.2 Overview - We support the innovative approach to behaviour We welcome the feedback and support for our plan. None Innovation economics and proposed step change in water efficiency. Hampshire A6.2 Overview - Leakage remains a key issue of concern. We have updated our leakage strategy for rWRMP19. Updated County Council Leakage Section 8 and Section 9 of rWRMP19 Hampshire and S10.1 Overview - Use water wisely and price water fairly. We welcome this comment and our plan aims to None Isle of Wight Leakage/PCC promote the efficient use of water and fair pricing Wildlife Trust too. Individual I77.1 Overview - The use of meters in homes is good. We agree, comment noted. None Metering

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I116.4 Overview - I am not convinced by the arguments put forward by We have endeavoured to reach and appeal to as None Negative South East Water. It seems that the company is more large an audience as possible with our dWRMP19 concerned about producing a glossy booklet with consultation as possible. One of the ways we sought pictures and diagrams than it is to present data in a way to do this was by presenting our plan in a range of in which its conclusions can be easily verified. formats from a glossy brochure, non-technical report, main technical report and a host of more detailed technical appendices on specific aspects of the Plan and its development. Individual I9.4 Overview - The strategy has too much waffle and not enough Your comment is noted. We tried to make our None Negative practical determinations. dWRMP19 as accessible as possible and to meet the requirements of our customers and stakeholders by producing it in a variety of document styles - technical appendices, the main technical document, a non-technical summary and an A5 overview leaflet. Ash Parish P4.1 Overview - Looking at water consumption for the next 60 years Our decision to adopt a 60 year planning horizon is None Council Negative rather than 25 years is either bold or foolhardy. explained in Section 6.2 of rWRMP. We believe looking over such a long time period has added value to our decision making process. Ash Parish P4.2 Overview - There are lots of unknowns over the 60 year period. We agree, our decision making today has been better None Council Negative Examples given. informed because we have attempted to quantify the unknowns . Edenbridge P5.1 Overview - One is tempted to say “Good so far, but .....!” And the ‘but’ We have updated our forecast and preferred plan to None Town Council Negative is based upon the report of the National Infrastructure align with the National Infrastructure Commissions’ Commission’s entitled ‘Preparing for a drier future - report recommendations. England’s water infrastructure needs’. Edenbridge P5.2 Overview - The consultative document, moves in that direction We have updated our rWRMP19 to deliver a more Updated Town Council Negative to address water supply issues, but is much slower in ambitious twin track, demand management led plan Section 8 and progressing the issues and needs which are already and improved resilience. Section 9 of urgent, let alone their status in a few year’s time. rWRMP19

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Appendix 2A - Overview continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Waterwise S8.1 Overview - We note - and welcome - that South East Water has We welcome this support for our plan. None PCC achieved an average 18 percent reduction through their metering programme and will have 90 percent metering by 2020. Individual I1.1 Overview - Covered all areas for improvement. None Positive Individual I11.1 Overview - Impressed by the plans presented at Aylesford None Positive Community Centre. Individual I2.1 Overview - South East Water are considerate and professional and None (Wokingham Positive applaud actions. District Council) Individual I3.1 Overview - No real concerns and believe it is the right approach. None Positive Individual I34.3 Overview - Keep up with the technology. None Positive Kent County A4.2 Overview - The greater connectivity between WRMPs and Drought The improvements to the WRMP guidelines for the None Council Resilience Plans is welcome. However, with each company using latest round of plans has allowed water companies a different approach and a different planning horizon, to select and choose differing approaches to deliver this too makes it more difficult for stakeholders to make plans that are most relevant to their circumstance, comparisons between companies. but arguably more robust plans overall. We appreciate this might make plans appear more inconsistent. We see a key role of the existing Water Resources in the South East Group in the future, will be to play a stronger role in understanding how individual company plans fit together into a regional strategy. Hampshire and S10.4 Overview In meeting predicted shortfalls, a twin-track approach of We have updated our preferred plan so it includes a Updated Isle of Wight - Supply- increasing water supplies and reducing water demand is truly twin track, demand led strategy with over 50 Section 8 and Wildlife Trust demand advocated, and the current EFRA inquiry into regulation per cent of new water being delivered by demand Section 9 of balance of the water industry asks whether companies are management and the remainder by new supply rWRMP19 adequately delivering this. schemes. southeastwater.co.uk 7

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Ofwat R4.30 Overview - The draft plan makes reference to the Water UK national We have included further information in our Updated Water UK project and the final plan should provide specific rWRMP19. Section 8 national examples of where the outputs have shaped the plan. and 9 of project rWRMP19

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 8

Appendix 2B - Collaboration and engagement

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA South East S7.5 Collaboration Working in Partnership - South East Water needs to We note your comments and can confirm that we None Rivers Trust and better integrate within the network of local Catchment work in many collaborative partnerships. Full details of engagement Partnerships. our current performance can be found in our business - Catchment plan. Moving forward we are looking to expand our Management collaborative and partnership work. Individual I104.4 Collaboration Engage with the people who are in the industry Thank you for your feedback and discussion at the None and “Plumbers”. public exhibition. We welcome your ideas on engaging engagement - with plumbers to assist with devising systems to Engagement reduce water consumption. We recognise plumbers are a valuable and knowledgeable group and will continue to look at ways we can best engage with the plumbing industry. Ashford A8.9 Collaboration Would like to see a wider commitment to partnership We are very keen and committed to work with partner None Borough and so that projects are delivered in a more timely and organisations and agencies to assist in delivering our Council engagement - integrated manner. projects and will ensure this forms part of our delivery Engagement programme. Waterwise S8.6 Collaboration South East Water has been proactive in engaging Engagement with the non-household retailers Updated and retailers and suggesting joint non-household water has been limited, but have committed to work Section 9 of engagement - efficiency options. Waterwise recommends that the closely with retailers to deliver our water efficiency rWRMP19 Engagement impacts of discussions with retailers on the final non- programme set our in Section 9 of our rWRMP19. household demand forecast and on joint options be clearly communicated in the final WRMP. WWF-UK S9.1 Collaboration Your company’s behavioural customer engagement We have update our rWRMP19 to include more Updated and work with Advizzo is seen as very innovative and is to be ambitious targets. Section 8 and engagement - applauded. However, we wonder if the reach and targets Section 9 of Engagement can be extended to deliver greater demand reduction rWRMP19 than identified in the dWRMP.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.99 Collaboration Customer preferences are taken into account when We have used a range of channels to communicate None Agency and developing the best value preferred plan. Water transfers the positive impact of water transfers, such as engagement - are not viewed positively by customers, but may play a through the media, social media as well as stakeholder Engagement role in the future regional water security of the South and community engagement activities. We have East. The company have not outlined how customers will undertaken a number of customer research exercises be informed about the positive regional impact of water during the WRMP19 process and highlighted the transfers. Customer’s opinions on water transfers remain positive aspects of transfer to customers. unchanged at a time when the company are promoting a water transfer. Additional information should be provided on whether this is a long term concern or a not. Ofwat R4.10 Collaboration It needs to be shown that customers are willing to pay for We have included more evidence in Section 9.2.2 Updated and the increase to a one in 200 year level of resilience and it of our SOR in the appendices in Section 2 of our appendices engagement - is unclear if customers were presented with the costs of rWRMP19. To demonstrate customer support and for Section 2 Engagement achieving this. willingness to pay to move to one in 200 year levels of of rWRMP19 resilience.

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Appendix 2B - Collaboration and engagement continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Ofwat R4.11 Collaboration The company states that willingness to pay outputs are We have undertaken a further customer research None and statistically significant for temporary use bans. However, that supports retaining levels of service for hosepipe engagement - despite customers supporting an increased level of bans at their current frequency of one in ten years. Engagement service, the level of service for these restrictions in the More recent WTP work has indicated customers plan remains unchanged. Rationale for this should be would prefer more Temporary use bans rather than provided in the final plan. fewer. This finding is not unique and it has been seen previously in other WTP research for other water companies. It suggests that people who do not use hosepipes themselves would often genuinely prefer other people not to use them either. These other-regarding preferences would appear in the present case to offset the value for fewer hosepipe bans amongst those who do value their use of them. Taking account of the findings across all the customer research we have undertaken, our customers have shown strong support for maintaining hosepipe ban restrictions at the same levels of service as proposed in our dWRMP19. We have updated Appendix 2B with the further customer research we have completed - it provides the evidence required to support maintaining 1 in ten year level of service for hosepipe bans. Ofwat R4.12 Collaboration It is also unclear whether relative drought resilience We can confirm that relative drought resilience levels, None and levels, compared with other companies, were also compared with other companies was discussed with engagement - discussed with customers. For example, the level of customers. This can be found in Appendix 2B. Engagement service for temporary use bans is among the worst (most frequent) in the industry. Ofwat R4.13 Collaboration Customer engagement regarding option selection We have updated our rWRMP19 to include far more None and indicated a strong preference for demand management ambitious levels of demand management These engagement - activities including further leakage reduction. However, changes were tested with customers and with Engagement this does not appear to be reflected in the plan, with stakeholders. relatively unambitious targets set in comparison to other companies.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I60.5 Collaboration Few leaflets produced at cost. Thank you for your feedback. Your comment about None and leaflets has been noted and will be considered when engagement - undertaking future engagement activities. Finance Ofwat R4.14 Collaboration There is no indication of the bill impact of the options We have undertaken further customer research to Updated and presented in the draft plan or evidence that they have test the acceptability and bill impacts of our plan Section 2, engagement - been discussed as part of customer engagement. with customers, including testing of bill impacts to Appendix 2B, Finance deliver more ambitious leakage reductions, per capita Section 8 and consumption reductions, levels of service, levels of Section 9 of resilience and option preferences. Further detail of rWRMP19 the findings of this research is provided in Appendix 2B and how the findings has been incorporated in our revised dWRMP19 preferred plan is included in relevant sections of the main plan.

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Appendix 2B - Collaboration and engagement continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Maidstone A7.2 Collaboration The Council welcomes the opportunity to work with We will continue to work closely with Maidstone None Borough and South East Water as part of the Environment Focus Group Borough Council to ensure our population and Council engagement - to prepare the dWRMP19 and understand what the property forecast reflect the latest projections, which Local Planning future need is. In preparing the Draft Water Resources we believe they presently do. We have input to the Management Plan, South East Water has taken a plan-led existing Infrastructure Development Plan(IDP) and are approach by engaging with local planning authorities maintaining regular dialogue with Maidstone Borough to understand the expected growth in local plans and Council to ensure our respective plans continue to be therefore what the future need is. South East Water well aligned. should work with local planning authorities to identify the infrastructure requirements relating to future needs. The Council welcomes the opportunity to work with South East Water to identify infrastructure requirements and to develop the potential future options to ensure future need is met. This collaborative approach will be useful in reviewing the Maidstone Borough Local Plan and the IDP to understand what infrastructure is required and the timescales for delivery. The Maidstone Borough Local Plan Review is to start shortly and is likely to accommodate additional housing and employment needs. Therefore, consideration should be made for the infrastructure that will be required to support the additional development. The Council welcomes the opportunity to work with South East Water to plan for demand from future development. Individual I46.2 Collaboration Challenges South East Water are facing are clear in the Thank you for your feedback regarding the public None and report but not so clear on the banners. exhibition banners. We have recorded this in our engagement - engagement lessons learnt log so we can ensure Negative this information is made clearer during future consultations. Kent County A4.13 Collaboration This engagement has been informative, timely and well We are please the engagement has been informative, None Council and managed by South East Water. However, the timing of timely and well managed. engagement - this consultation period was subject to unexpected Neutral delays.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Defra R1.7 Collaboration Water companies should be making it easier for people We have included more information in our rWRMP19 Updated and and businesses to make water smart choices by providing about how we will help customers make water smart Section 9 of engagement advice, technology and tools. choices as part of our water efficiency programme. rWRMP19 - Other Options/ Technology I104.2 Collaboration More engagement with public. We continuously review the engagement we None and undertake with customers to ensure we use the most engagement - appropriate method to reach our audiences. We Overview recognise that direct face-to-face engagement is the most successful way to engage with our customers and something that continues to form part of our ongoing work. Individual I105.4 Collaboration Very good displays. Thank you for your comment, we are pleased you liked None and the public exhibition banners. engagement - Positive

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 14

Appendix 2B - Collaboration and engagement continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I20.2 Collaboration Staff at exhibitions impressed us. We welcome the feedback and support for our plan. None and engagement - Positive Individual I27.3 Collaboration Good exhibition. Pleasant informative staff. None and engagement - Positive Individual I32.3 Collaboration Helpful, informative session. Good to be able to take None and literature to read. engagement - Positive Individual I57.2 Collaboration A well staffed event. None and engagement - Positive Individual I99.2 Collaboration All information given clearly and helpfully. None and engagement - Positive Individual I16.2 Collaboration Interested to take part in the upcoming tour of the We are pleased to hear you would like to come on the None and Arlington Treatment Works. next tour of our Arlington WTW. The tours take place engagement twice a year. For details of the next date and how to - Reservoir - register, please visit corporate.southeastwater.co.uk/ Arlington open days.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I46.3 Collaboration More communications to primary and secondary school We have been running our Key Stage 2 World of Water None and age students. education programme for many years and over the engagement - past five years have spoken to 8,295 children. During Students the past academic year experts from across the company have been working with secondary school pupils to inspire them to think about careers in water by applying what they’ve learnt in their science, technology, engineering and maths lessons to real life as part of our Pure Know H2ow Awards. While these programmes have proved successful, we are looking to expand our education programme over the life of this plan. This already forms a key part of our future water efficiency programme. Individual I46.5 Collaboration Present more of this information in South East Water: Information is being provided to staff was briefings, None and Team meetings and Company briefing. on the company’s intranet and within staff exhibitions. engagement We have also recorded this feedback in our - Team engagement lessons learnt log to review for future Meetings consultations. Individual I104.3 Collaboration Encourage people to store or recycle water. We continue to actively promote and deliver the None and efficient use of water in the home, including water engagement butts that enable our customers to store their own - Water rainwater. We continue to monitor and evaluate the Efficiency feasibility of larger storage options e.g. community based or ‘cul de sac’ level storage schemes, but to date these have proven not to be a cost effective or reliable solution. Once they do become more feasible we will be able to take account of any benefits they deliver more explicitly.

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Appendix 2B - Collaboration and engagement continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I18.2 Collaboration South East Water should focus on educating households Thank you for your comment. We updated our Updated and on water efficiency and usage. rWRMP19 water efficiency program to explain how we Section 8 and engagement plan to support households with water efficiency. We Section 9 of - Water will build on our existing water efficiency education rWRMP19 Efficiency and events programme by extending our award winning customer engagement initiative which has been developed using the latest behavioural science.

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Appendix 2C - How our plan has considered resilience

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Defra R1.6 How our Should demonstrate how South East Water have stepped This was specifically a reference to the recent None plan has up preparations for drought. prolonged dry weather. The additional information considered was provided to Defra independently of the resilience - WRMP process. Drought Environment R2.116 How our The company have only partially explained any We have updated Table 10 to provide further Updated Agency plan has contingencies it has for challenging but plausible information requested. Table 10 considered droughts beyond the capabilities of its current supply resilience - system. The plan outlines that the best value plan has Drought been tested against a one in 200, a one in 500 , and a three dry winter drought event, with further analysis in the drought plan. However, more detail should be given on the measures that are required under these scenarios. This should be in the text of the plan and as part of completing Table 10 for each WRZ. The company should provide more detail on the measures required under the one in 200, one in 500 , and three dry winter scenarios. This should be in the text of the plan and as part of completing Table 10 for each WRZ. Environment R2.20 How our The company must provide the methodology and Updated Agency plan has assumptions it has used to calculate the annual Table 10 considered probability of temporary water use restrictions, ordinary updated in resilience - drought orders and emergency drought orders. The rWRMP19 Drought company must include assumptions about the severity of drought it has used and the methodology must refer to both the annual percentage of risk over the 25 years and the changes over the 25 year period.

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Appendix 2C - How our plan has considered resilience continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.115 How our In the company’s drought plan consultation, we raised Our rWRMP19 has been designed to maintain the None Agency plan has concern over the lack of potential drought options that balance between supply and demand to one in 200 considered the company has to drawn upon which do not require year levels of resilience without the need to impose resilience - a long lead in time to develop. We had concerns that drought actions. This means during a drought event Drought Plan the options would only be looked at once drought had all our drought measures will be available to mitigate commenced so would not allow sufficient lead in time a drought. The long lead schemes referred to are for the option to provide additional supply when needed, borehole sources where a drought permit/order potentially leading to a risk to security of supply/need for would be required. Our drought plan confirmed these other emergency measures. We aren’t clear whether the permits will only be triggered after two consecutive company had addressed these concerns but the feasible dry winters and would not be required until the options that were modelled in the WRMP would appear autumn of a third dry winter/summer after a third dry not to include much in the way of drought options, so winter. This means there is adequate time to deliver our concerns still remain. The company should refer the long lead schemes i.e. nine months to 12 months. back to any comments raised as part of its drought plan consultation in the context of this WRMP where there are linkages and make amendments. Any changes made in WRMP will need to be revisited in the company’s drought plan.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I115.1 How our I note that ‘resilience’ is a key theme in the Water Board’s Thank you for your comment. We have assessed None plan has presentation. This should mean that the Water Board options to build water re-use schemes on the River considered is not dependent solely on one means of storing and Ouse, River Medway and River Stour. Desalination resilience - delivering water, i.e.. large reservoirs, but is also actively options have been assessed at several locations Engagement looking at other methods of meeting and educating and we are continuously reviewing the technology public demand such as catchment management, effluent available. We are sorry you did not see the information re-use and desalination. For example, the possibility relating to this at the public exhibition on the 23 of using the Weatherlees indirect waste-water re-use April. The process of modelling and developing our option, rated at 15Ml/d should be considered. To ignore it plan has considered reservoirs schemes such as Broad would be a failure to invest fully in water resilience. More Oak along with all the types of options mentioned in emphasis needs to be placed on dual-flush water-saving your response - both the relative merits of each and toilets, such as are widely used in New Zealand and the also how they can work together in combination to Water Board needs to make the general public aware develop a best value plan. This included consideration of the benefits of such systems, both in terms of saving of resilience, customers and the environment. We feel water and of benefit to the environment. Desalination confident that all schemes have been considered and is frequently only associated with hot countries where that the preferred plan contains the best possible there is little rainfall but in times of climate change combination of options. conditions and falling rainfall, such as we experience in the south-east, it is becoming increasing relevant and more research needs to be done on its feasibility. In your presentation on April 23rd neither re-use nor desalination received any mention. Individual I103.2 How our Increasing capacity of Arlington for example means if There is a benefit of having the proposal to have None plan has that site is unavailable then the whole supply is lost. two reservoirs at this location to improve levels of considered resilience. The treatment of water will be via adjacent resilience treatment streams which provide resilience to the - Reservoir - supply if there are issues in one or other stream. We Arlington believe this scheme will provide greater resilience against supply interruption.

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Appendix 2C - How our plan has considered resilience continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I103.3 How our If a new reservoir is built then it increases resilience We thank you for your positive comment on the None plan has as you have a wider number of sources available to benefit the reservoir brings to increase resilience to considered supply from. our supply. resilience - Reservoirs Swale Borough A5.4 How our Building a resilient supply demand balance, planning for a We welcome your support for our twin track approach None Council plan has range of future scenarios and providing a mix of demand on our mix of supply side options and demand considered management and supply side options. management initiatives. resilience - Resilience Ashford A8.2 How our Pleased that South East Water has tested the resilience We welcome your feedback and support for our plan. None Borough plan has of its plan through a risk-based approach. Council considered resilience - Resilience Canal and River S11.1 How our It is the Trust’s opinion that South East Water have We welcome the feedback provided on our plan. None Trust plan has produced a draft plan that highlights the issues they considered face and how they plan to address them. The Trust will resilience - continue to work with the WRSE group to help develop Resilience strategic options to ensure cost-effective and resilient water supply options that will benefit South East Water and their customers. Defra R1.1 How our Customers and government expect increasing resilience We have addressed in our rWRMP19. Updated plan has to drought and extreme weather. Section 3 considered and 9 of resilience - rWRMP19 Resilience

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.18 How our The company should plan for non-drought hazard, such We have updated our rWMP19 to provide clearer Updated Agency plan has as freeze-thaw, in its WRMP. references and signposting to our resilience appendix Section 3 of considered for our business plan PR19. This appendix provides the rWRMP19 resilience - information requested to demonstrate our resilience Resilience to non-drought hazards like flooding and freeze-thaw events. Ofwat R4.18 How our As noted in Section 1 , the company plans to move from a Detail of the impact on supply is included in Appendix Minor update plan has one in 100 to a one in 200 year level of drought resilience. 4A. We have reviewed the deployable outputs in to supply considered However, the draft plan includes insufficient explanation the Eastbourne Zone and have amended the figures forecast and resilience - on the impact this has on supply and greater clarity is for Arlington reservoir that showed an increase Appendix 4A Resilience required in the final plan. For example the planning tables in deployable output with increasing severity of of rWRMP19 indicate this appears to result in an increase in baseline drought. This was incorrect. supply (deployable output) for Eastbourne zone, which would not be expected. Ofwat R4.7 How our South East Water should provide greater clarity in We have included more evidence in Section 9.2.2 Updated plan has the final plan for the decision to move to a one in 200 of our SOR in the appendices in Section 2 of our appendices considered year level of drought resilience with respect to level 4 rWRMP19. To demonstrate customer support and for Section 2 resilience - restrictions. This should include quantification of the willingness to pay to move to one in 200 year levels of of rWRMP19. Resilience impact in terms of the supply-demand balance and the resilience. scheduling of options and additional costs in comparison with retaining the current one in 100 year level of resilience. Ofwat R4.8 How our South East Water has not referred to non-drought We have updated rWRMP19 to provide clearer New text plan has resilience, such as freeze thaw events, in detail within references and signposting to our resilience appendix added in considered the draft plan, though it is noted this is being developed for our business plan PR19. This appendix provides the Section 3 resilience - for the company business plan. The final plan should information requested to demonstrate our resilience Resilience set out the interaction between the draft plan and the to non-drought hazards like flooding and freeze-thaw company’s wider proposals to manage system resilience events. and supply system efficiency.

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Appendix 2D - Baseline supply forecast

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.105 Baseline The WRMP does not contain information about whether Appendix 1A Water Resource Zone Integrity Updated Agency supply the direction of flow for water transfers can be changed. contains details of the interzonal transfers. Table 10 Appendix 1A forecast - Section 4.1 of Appendix 4A quotes the guidance in Section 5 summaries capacity and possible flow Section 4 Appendix requesting this but there is no information related to this directions. The appendix set out that all external of rWRMP19 in the text. The company should explicitly state whether imports from other water companies outside our the direction of flow for water transfers can be changed, supply area operate in one direction, with exception as stated in the guidance. to the Belmont scheme, where we can also export water back out to SWS. We have updated the text in Appendix 1A Section 4 to explicitly say this and highlighted these changes in the rWRMP document update. Environment R2.122 Baseline The company provides a brief description of how The information requested is included in Appendix 6A None Agency supply climate change uncertainty has been calculated. of rWRMP19. forecast Some assumptions are presented but not a detailed - Climate explanation of their implications. There is no comparison Change of the various uncertainty components. Climate change uncertainty is said to be especially large for Hayward’s Heath. The company should provide a detailed explanation of the implications behind climate change uncertainty. It should also provide a comparison between the various uncertainty components, especially for WRZ2.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.117 Baseline The company has not clearly explained how its We have updated our rWRMP19 demand restrictions Updated Agency supply deployable output will be affected by demand-side are assumed to provide zero benefit to groundwater Table 10 of forecast - drought restrictions. Section 1.7 of the main report deployable outputs. Appendix 4 Deployable identified the LoS associated with TUBs and NEU bans of rWRMP19 output but does not include the estimated benefit to deployable output. Table 10 of Appendix 4A includes benefit of demand restriction on surface water deployable output, but the text states: ‘no work has been done on the benefit of demand restrictions within the other groundwater dominated resource zones’ (p.58). This approach is common to groundwater only WRZs but may not be appropriate in zones that are not solely groundwater sourced (even if groundwater dominated). The company should clearly explain how its deployable output will be affected by demand-side drought restrictions, and how it benefits from TUB’s and NEU bans. It should also take these into account in zones that are not groundwater dominated. Environment R2.24 Baseline The company needs to clearly demonstrate it Source constraints are summarised in Table 1 of None Agency supply understands the current and future constraints and the individual zone WRP tables. This is provided as a forecast - identify which factor(s) constrain deployable output manageable summary of the larger DO assessment Deployable specific to each WRZ. dataset. We have commenced development of output conjunctive use modelling, and will consider further development and deployable for other zones as we move towards WRMP24. Environment R2.25 Baseline The company should provide detail on which drought Table 10 has been updated for the rWRMP19, and Updated Agency supply event planned LoS are triggered in the historic record, a further commentary can be found within the WRP Table 10 of forecast - table showing Los similar to that provided for WRMP14, tables. rWRMP19 Deployable detail the impact these measures have on supply, and output complete Table 10 appropriately.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 24

Appendix 2D - Baseline supply forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.26 Baseline Include list of deployable output derived from the For the majority of our sources, we are using OBHs None Agency supply assessment in Appendix 4B. Some review of robustness which are representative of specific geology/ aquifer. forecast - of using Chalk groundwater signatures for non-Chalk For the river gravel sources a dampening factor Deployable sources. of the regional groundwater level was applied and output considered to be necessary to ensure consistency with all groundwater sources (i.e. the method applied across all groundwater this is considered to be consistent). Environment R2.27 Baseline The company should consider whether the licences it For the revised WRMP, we have revisited our Updated Agency supply currently holds are sustainable (meet the three tests for assessment of TLL in headroom at a zonal level. Appendix 6A forecast - renewal) and include any uncertainty in headroom (S3). Following this review, we are proposing not to of rWRMP19 Deployable change the positon, and TLLs are not included in the output headroom calculation. Further details are available in the updated headroom appendix (Appendix 6A). Environment R2.28 Baseline Correct/clarify closure date as 2023 for Greywell and We have reviewed the closure dates for Greywell and None Agency supply reassess or explain any impacts that closure in 2023 confirm that the dates referenced in the plan and forecast - rather than 2025 would have on the supply demand WRP tables are correct. Deployable balance. output Environment R2.29 Baseline The company should carry out conjunctive use modelling In Appendix 4A; Section 4.2.2, we set out None Agency supply for WRZ4 due to the large surface water abstraction at improvements made in conjunctive use modelling forecast - Bray, and for the potential new supply from the River since WRMP14 for the zones 2 and 3, which contain Deployable Thames. The company should also consider conjunctive company operated reservoirs . Further development output use modelling for WRZ8 due to the new reservoir at and improvement of conjunctive use modelling for Broad Oak, for when this comes online. This will allow the WRZ4 and WRZ5 can be progressed for WRMP24; company to fully explore system constraints and present including the consideration for inclusion of additional a conjunctive use deployable output estimate in its next zones. draft plan. The company should report progress on this action in its Annual Reviews.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.30 Baseline The company should make sure the deployable output Table 10 has been updated for the rWRMP19, and Updated Agency supply for Table 10 matches that in 7FP base year of the tables. further commentary can be found within the WRP Table 10 forecast - tables. of rWRMP19 Deployable output Environment R2.31 Baseline The company be consistent in its account of restricted Agency supply and unrestricted demand in Table 10. forecast - Deployable output Environment R2.32 Baseline The company should fill in the commentary (Section 10.5) Agency supply in Table 10. forecast - Deployable output Environment R2.33 Baseline The company should state the duration of its events in Agency supply Table 10 to enable better understanding of the benefits forecast - demand and supply side measures. Deployable output Environment R2.34 Baseline The company should explain why there is no variation Agency supply in demand across the different scenarios in the forecast - commentary in 10.5, or amend the 10.4 to reflect the Deployable variations in demand for the different scenarios. output Environment R2.35 Baseline The company include demand restrictions in Section 10.3 Agency supply of Table 10. forecast - Deployable output

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 26

Appendix 2D - Baseline supply forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.36 Baseline The company should provide evidence on how it has Table 10 has been updated for the rWRMP19, and Updated Agency supply selected individual drought events from its synthesised further commentary can be found within the WRP Table 10 forecast - dataset. tables. of rWRMP19 Deployable output Environment R2.37 Baseline The company should provide evidence on how it Agency supply has calculated its return periods for the Table 10 forecast - scenarios, including and justifying whether it has used Deployable meteorological events or the corresponding impact on output system response. Environment R2.38 Baseline Clarity should be provided on the resilience of the Deployable output of supply options based on one in None Agency supply selected options, particularly to the third dry winter 200 year level of resilience and will deliver resilience forecast - scenario which is stated as having reduced vulnerability in three dry winter scenario when combined with Deployable from the preferred plan. drought measures included in our draft drought plan, output December 2017. Environment R2.39 Baseline For the drought plan and WRMP to be consistent, the The one in 200 year level of resilience provided by our None Agency supply company should include the two dry winter scenario in rWRMP19 is based on a two dry winter scenario and is forecast - its WRMP. consistent with our drought plan. Deployable output Environment R2.125 Baseline The WRMP does not provide assurance that under the We have a statutory duty to comply with the Drinking Included in Agency supply water treatment regime applied, and the drinking water Water Directive and to supply wholesome water Section 1.1.6. forecast produced, meets the standards of the Drinking Water to our customers. We have added a more explicit in rWRMP19 - Drinking Directive, plus any UK requirements to make sure that statement in our rWRMP19. Water drinking water is safe to drink. This should be explicitly Directive stated. If the Directive and any UK requirements are not complied with, then drinking water could be unsafe to drink. The company should make sure it complies with the Drinking Water Directive, plus any UK requirements, and state this explicitly in its plan.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.124 Baseline The WRMP does not contain information about how it These issues are addressed through WINEP and None Agency supply will support the objectives for drinking water protected comment is relevant to the plan in terms of forecast - areas (DWPAs). DWPAs are not explicitly mentioned. implications for supply. We believe this has been taken DWPAs Objectives for drinking water protected areas may not into account in the supply demand balance. be supported. The company should provide information on how it will support objectives for drinking water protected areas. Environment R2.127 Baseline Information on Drinking Water Protected Area plans is These issues are addressed through WINEP and None Agency supply extremely limited (Section 4.9.3). Whilst the schemes comment is relevant to the plan in terms of forecast - in WINEP seek to address the at risk pesticides and implications for supply. We believe this has been taken DWPAs ensure there is no deterioration or need for additional into account in the supply demand balance. treatment (and therefore minimise impact to supply), it would be good to see additional information about the “at risk” pesticides and associated schemes recognised. Also, it is important that these schemes are highlighted so that the impact of the possible consequences to supply if they are not completed or are not successful is clearly understood. The company should provide further information on any schemes. Environment R2.42 Baseline Appendix 4A, Table 28 gives sustainability reductions by This has been addressed in the WINEP review process None Agency supply zone, but does not provide information on which sites, which has fed into the plan development and the forecast - making it difficult to assess which licences are expecting scenarios. Environmental to have reductions applied within each WRZ, and what Impact implications this may have. Further information of how sustainability reductions to avoid deterioration have been determined for which sources. Include further information on what sustainability reductions are considered for sources in groundwater bodies that are at Poor Status.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 28

Appendix 2D - Baseline supply forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Ofwat R4.17 Baseline The company should additionally revise its forecasts with We have updated the assumptions within our Updated supply reference to the latest WINEP outputs (WINEP3) and rWRMP19 to take account of the latest WINEP Section 4 forecast - explain any variations between these two releases and outputs (WINEP3) that have been released since the of rWRMP19 Forecast how the programme has changed as a consequence. publication of our dWRMP19 for consultation.

Environment R2.40 Baseline We suggest the company clearly explains why its outage We have updated Section 4 of our rWRMP19 to None Agency supply forecast has changed, and provide further assurance provide more information. forecast that the company is able to operate at this lower level of - Outage outage and/or consider whether its outage methodology Allowance is appropriate. WWF-UK S9.12 Baseline Whilst we can see that ten restoring sustainable Full details of our RSA work going forward is contained None supply abstraction (RSA) investigations and options appraisals in our business plan and supporting Environmental forecast - are being delivered in the current WINEP, we cannot see Appendix. In our WRMP we discuss our abstraction at Sustainable any proposals in the preferred plan that link to these Greywell which has been found to be unsustainable, abstraction appraisals and actively seek to reduce unsustainable we are currently developing a new source at on the abstraction. This is unsatisfactory, and if there are links river Thames as an alternative to this source and these should be explained more explicitly in the final plan. are developing infrastructure to move this water We want to see a clear ambition from South East Water to where it is needed at Greywell. Further details to reduce abstraction from environmentally sensitive related to Greywell are included in Section 1.4.6 of the sources and an explicit pathway to achieving that. rWRMP19. WWF-UK S9.13 Baseline We want South East Water to address any RSA We can confirm this has been done. None supply sustainability reduction actions linked to known impacts forecast - on protected conservation sites and WFD water body Sustainable status as soon as possible –within AMP7 where feasible. abstraction Kent County A4.1 Baseline Struggling to understand the figures for baseline WAFU There were transcript errors in both Figure 27 and Updated Council supply in Figure 27 on page 74. The numbers in columns 2, 3, 5 Figure 28. The numbers have been corrected in the Figures 27 forecast - and 6 don’t seem to add up and the bulk supply figures rWRMP19. Thanks were sent to the consultee for and 28 in Tables don’t match those in Figure 28. letting us know these inconsistencies along with an dWRMP19 apology and corrected versions of both tables and an explanation of the errors Corrected figures 27 and figure 28 were inserted into the electronic version of the dWRMP19 online. southeastwater.co.uk 29

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Kent County A4.14 Baseline Plan for 60 year outlook is valuable but appears to make Thank-you for your comments. We are pleased you None Council supply headline costs of the WRMP less meaningful. see value in planning over a 60 year timeframe but are forecast - sorry you think that the headline costs lack meaning Tables as a result. The annualised costs are presented in the Water Resources Planning tables which provide comparable across all water company WRMP19s. Environment R2.107 Baseline The WRMP only partially describes treatment works We have reviewed the process losses Appendix 4D and None Agency supply losses and operational use within each WRZ and does can confirm that the process losses figures match up forecast - not show how these have been calculated. The ‘WRMP19 between tables 4 and the WRP Table 9BL. The detail Tables Process Loss Assessment’ in the last two columns of of how these numbers were calculated is contained in Table 4 (Appendix 4B) do not match the values in the Appendix 4D. equivalently titled columns in the tables on p16-18 of the same Appendix, but the company do match the figures in columns titled ‘Final WRMP Process Loss’ on p16-18. It is therefore not clear what calculation has been carried out to get to the ‘Final WRMP19 Process Loss’ used in Table 4 (Appendix 4B) and the Table 2.9BL of the planning tables. The company should clarify how treatment works losses and operational use within each WRZ has been calculated. It should also ensure that all values are consistent throughout the plan and the Tables. Environment R2.83 Baseline Effluent re-use at Aylesford (SEW-RZ6-EFF-37) comes We have updated our rWRMP19 and Aylesford re-use None Agency supply online in 2038 in the plan and Table 6 (9 Ml/d), but in Table is no longer part of our preferred plan. forecast - 5 it shows ‘gains in WAFU’ of 9 Ml/d start in 2036. This is Tables inconsistent. The company should make sure Tables and the plan report are consistent. Individual I14.2 Baseline Look more at water wastage. We have updated our rWRMP19 to include more Updated supply ambitious leakage reductions and water efficiency. Section 8 and forecast These have been tested with customers and Section 9 - Water stakeholders during the consultation and given of rWRMP19 Efficiency support by them.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 30

Appendix 2D - Baseline supply forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I69.10 Baseline A rapidly developing aspect of energy supplies are We have updated our rWRMP19 to include more Updated supply Community Energy schemes (see: www.gov.uk/guidance/ ambitious demand management forecast and options. Section 8 and forecast community-energy ) which aim to enable communities The revised forecast aligns well with values forecast Section 9 - Water become more resilient and also reduce energy use and by Artesia by 2065. Our water efficiency programme of rWRMP19 Efficiency save money as well as increasing community spirit. This includes smart metering technology as well. The idea has also been suggested in the water industry for more ambitious levels of demand management we example, Artesia Consulting referred to ‘Community have included in our rWRMP19 have been tested with rainwater harvesting’, and its Figure 16 shows that it is customers and stakeholders who have supported their achievable within a decade and potentially yields over adoption. 80 litres/property/day (The-long-term-potential-for- deep-reductions-in-household-water-demand-report- by-Artesia-Consulting 26/4/2018). It also identifies this as a ‘Short-term, no-regret option’ and with the scaling-up of other activities that the sector is currently delivering, such as smart home retrofit visits, such measures could be implemented more widely in the near future without significant innovation (Paragraph 6.1). Community schemes could use Photovoltaic panels on roofs for pumping or desalination, and reed beds could improve reuse in the local environment. The biggest problem is the need for some initial support and the water companies could have key role to play here, for example

using South East Water’s KnowH2ow. Environment R2.106 Baseline The WRMP does not contain any information about the For the avoidance of doubt, all of the transfers we None Agency supply water quality of water being transferred and the impacts have proposed as part of the plan are treated water forecast - on the receiving area water quality (even within a WR transfers that means there is not an impact on the Water Quality zones).The company should provide information in its receiving area water quality. The inter-zone transfers plan on the water quality of water being transferred included tend to be reinforcements to existing between zones or between companies. interconnected areas, leading to little change overall in treated water quality.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.80 Baseline The plan does not contain a consistent approach to For water quality purposes, our whole supply area is None Agency supply drinking water quality across all the company WR split into 72 water supply zones, which are a subset forecast - zones. The plan should state the company’s approach to of the company’s eight water resource zones. Each Water Quality drinking water quality in all zones. water supply zone is based on the area supplied by water from a specific treatment works or a group of comparable treatment works. From a water quality perspective, we have a consistent approach to assessing water quality across the whole company area using the drinking water safety plan (DWSP) approach in line with WHO guidelines and the Water Supply (Water Quality) regulations. The approach considers the risks across all stages of our supply chain, from source to tap assessing risks in the catchment, treatment, storage, distribution and on the customer’s side. Raw water bulk supplies will be considered as part of our catchment risk assessments alongside any other raw waters and where we receive a treated water bulk supply, the risks associated with this supply will be assessed by the supplying water company and incorporated into our assessments for the area. Within South East Water our DWSP are based around the supply systems associated with each of our water treatment works. There will be a variation in the risks evident within each DWSP, which will be dependent on the risks associated with each specific supply system, clearly there will be very different catchment risks associated with a surface water abstraction when compared with a deep greensand aquifer abstraction, for example. As each water resource zone is made up of a number of discrete supply systems, it is acknowledged that there will be a variation in the specific risks identified across the different water resource zones, however there is complete consistency in the company’s approach to drinking water quality across the whole supply area.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 32

Appendix 2D - Baseline supply forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.126 Baseline The company have not assessed the impact of These issues are addressed through WINEP. None Agency supply metaldehyde on its sources, specifically Ardingly and Metaldehyde does not affect our supply demand forecast Arlington reservoirs, as well as shared/bulk supply balance. - Water reservoirs controlled by Southern Water (Weirwood Quality - and Bewl). The company should address whether its Metaldehydes sources are impacted by Metaldehyde, and any actions the company intends to take to mitigate against it. The company should adequately assess the impact of metaldehyde on its sources, especially Ardingly and Arlington, as well as Southern Water controlled sources, and state any mitigation measures the company expects to take (linked to Issue 2.5 above). Environment R2.81 Baseline The plan does not refer to further guidance from the None Agency supply Drinking Water Inspectorate, including the guidance forecast about metaldehyde (and other pesticides), WRMP’s and - Water new sources of supply. The plan should reference the Quality - guidance provided by the Drinking Water Inspectorate. Metaldehydes

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Appendix 2E - Baseline demand forecast

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Maidstone A7.1 Baseline The Local Plan outlines the required housing and We will continue to work closely with Maidstone None Borough demand economic development targets over the plan period 2011 Borough Council to ensure our population and Council forecast to 2031. A total of 17,660 dwellings are required, with property forecast reflect the latest projections, which - Demand 14, 394 jobs forecast over the plan period. This level of we believe they presently do. We have input to the Management growth will impact on the demand for water in Maidstone existing Infrastructure Development Plan(IDP) and are Borough. The Infrastructure Delivery Plan (IDP) outlines maintaining regular dialogue with Maidstone Borough the infrastructure schemes required to support the Council to ensure our respective plans continue to be development in the Local Plan. Among the schemes well aligned. are measures to improve the capacity and connectivity of the water supply. In developing the Local Plan and the IDP, the Council has engaged with infrastructure providers including South East Water. WWF-UK S9.4 Baseline The up-front focus on demand management options in We have updated our rWRMP19 to include more Updated demand the first ten years of the plan is welcome, but the role of ambitious levels of demand management. Section 8 and forecast demand management beyond this is unclear (with the Section 9 - Demand post- 2025 emphasis firmly on supply-side measures). We of rWRMP19 Management would hence like South East Water to consider demand management much more in the longer term. Kent Wildlife S12.9 Baseline We commend the innovation demonstrated by South Thank-you for your response to our dWRMP19. Your None Trust and demand East Water’s behavioural economics trial/future work comments are noted. Sussex Wildlife forecast with Advizzo on demand management based on nudge Trust - Demand theory and social morning. We would also like to again Management highlight that, like many Wildlife Trusts, we have pledged our support to encouraging community water resource reduction and there are many opportunities to collaborate that are not currently being explored.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 34

Appendix 2E - Baseline demand forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I101.4 Baseline Concerns supplying the vast increase in housing within The population and property forecasts that support None demand this area. our plan have been prepared by Experian in liaison forecast with local planning authorities. The forecast that - Housing have been prepared to comply fully with the WRMP Developments guideline requirements and enable us to meet our existing statutory duty to supply all new homes. Individual I32.2 Baseline More houses are surely on their way in this area. Operating in a water stressed region, we work closely demand with local planning authorities so they are well forecast informed of where the challenges of meeting new - Housing housing and population growth is greatest, and we Developments engage proactively with local planning authorities on Individual I34.2 Baseline The extra water needed to provide for extra home their local plan, design policies, water cycle strategies demand being built. and infrastructure development plans to seek to forecast minimise the impact new housing might have as far as - Housing is practicable. Developments Individual I48.2 Baseline Are we able to influence housing developments based on demand water availability. forecast - Housing Developments Individual I69.4 Baseline Charge building developers less for new connections if Our approach continues to be to work with local None demand water management is built in and is checked to show it is planning authorities to ensure new housing is forecast operating. constructed to high standards of water management. - Housing In our current forecast it is already assumed that Developments new properties are more water efficient than existing housing stock. We encourage local planning authorities to have planning policies that deliver higher standards of water management. We will continue to review our changes as a means to incentivise develops to deliver water efficiency.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I7.1 Baseline Comment on whether South East Water should object to The population and property forecasts that support None demand new housing developments and encourage development our plan have been prepared by Experian in liaison forecast to be made in less water stressed areas. with local planning authorities. The forecast that - Housing have been prepared to comply fully with the WRMP Developments guideline requirements and enable us to meet our existing statutory duty to supply all new homes. Operating in a water stressed region, we work closely with local planning authorities so they are well informed of where the challenges of meeting new housing and population growth is greatest, and we engage proactively with local planning authorities on their local plan, design policies, water cycle strategies and infrastructure development plans to seek to minimise the impact new housing might have as far as is practicable. Individual I88.4 Baseline Work with housing developers to develop solutions. We are working closely with housing developers, None demand with local planning authorities and with Government forecast to ensure high standards of water efficiency are - Housing delivered in new homes. Developments Kent County A4.5 Baseline Would be helpful for all local planning authorities if an The forecast prepared by Experian provides detail to None Council demand appendix could be provided to present both the district Output Area. This information is available on request. forecast total figures that have been used as well as share of the This should make it easier to compare with local - Housing totals that fall within South East Water’s WRZs. planning authority forecast. We already work closely Developments with local planning authorities by inputting to their local plans, water cycle strategies, infrastructure develop plans etc. This ensures our respective plans are based on the best information available.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 36

Appendix 2E - Baseline demand forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Kent Wildlife S12.10 Baseline South East Water should also work closely with South East Water is responsible for the supply None Trust and demand developers and town planners to ensure there is a (wholly or partly) for 33 Local Planning Authorities Sussex Wildlife forecast reduction of the use of water resources and innovative and over 450 Town and Parish Councils. We liaise Trust - Housing ways to manage demand should be sought and with local authorities and councils regularly to Developments implemented if existing measures are unsuccessful. discuss: updates to local plan forecast population and property forecast; review of policies (e.g. on water, environment, climate change, water efficiency standards and promotion etc.); participate in water cycle strategies used to test water availability and need with different growth strategies; input to infrastructure development plans so that new developments and water resources planning are joined up. We will continue to promote and advocate for greater levels of demand management. Individual I116.3 Baseline The lack of change in the leakage level - The page early We have updated our rWRMP19. As a result have now Updated demand in the report that states that “We are on track to reduce included much more ambitious targets in our plan Section 9 forecast - leakage by 11 percent from 2010/2011 to 2019/2020” with a 15 percent leakage reduction over the first five of rWRMP19 Leakage is simplistic and not backed up with data. How many years increasing 50 percent by 2050. litres were lost each day in 2010/2011 and how many litres will be lost in 2019/2020? That time period is incapable of verification, since the leakage for 2010/2011 is presumably an actual number, whereas that for 2019/2020 must inevitably be an estimate. To establish a trend that is meaningful, data at the beginning of a series must be comparable with that at the end. An actual number cannot be said to be comparable with an estimated number! From Figure 20 of the dWRMP: This suggests that after 2025, South East Water ceases to focus on leakage and virtually gives up by 2044. However, by 2075 it is back on track doing something about leakage. South East Water should be encouraged to make more effort in all years to reduce leakage.

southeastwater.co.uk 37

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I60.3 Baseline The leakage position need much more detail and We have updated the section on leakage in the Updated demand transparency. main plan. Appendix 5D contains a comprehensive Sections 1.4.3 forecast - description of leakage levels, calculations and plans Section 8 and Leakage for reductions. Appendix 5D of rWRMP19 Kent County A4.10 Baseline Figure 39 would also benefit from further explanation as This figure is part of discussion on consistency Improve Council demand it is counterintuitive that “Leakage reduced by 10Ml/d” reporting for leakage. It shows what would happen explanation forecast - only results in a demand reduction of 1.7Ml/d. to the zonal leakage and total distribution input if for Fig 39 in Leakage the reported leakage increased or decreased by 10 rWRMP19 Mld. The figures are the results of the water balance calculation which includes MLE (Maximum Likelihood Estimation ). We have updated the description to explain this better. Kent County A4.11 Baseline We believe it would be more helpful to also present the Reporting in Ml/d is required by our regulators and None Council demand level of leakage in m3 per km of main so that comparisons is standard across the industry. However, Figure 3 in forecast - can also be made with other companies. Appendix 5D presents industry leakage levels in m3/ Leakage km of main as well as l/prop/d. It clearly shows the comparisons across the whole of the industry. Kent Wildlife S12.11 Baseline The current targets for leakage reduction represent As part of the consultation process we have reviewed Updated Trust and demand a low level of ambition. We would like to see more both our short term and long term strategies for Section 8 and Sussex Wildlife forecast - ambitious targets for leakage reduction than those demand management. As a result we are now Section 9 Trust Leakage currently detailed, especially given the feedback from including much more ambitious targets in our plan of rWRMP19 South East Water’s customers that of all the options with a 15 percent leakage reduction over the first five available, they would be most willing to pay for this. years (increasing to 50 percent by 2050). South East S7.4 Baseline Reduction in Demand and Leakage - welcomes the As part of the consultation process we have reviewed Updated Rivers Trust demand proposals to reduce leakage, but believes South East both our short term and long term strategies for Section 8 and forecast - Water should be more ambitious. demand management. As a result we are now Section 9 Leakage including much more ambitious targets in our plan of rWRMP19 with a 15 percent leakage reduction over the first five years (increasing to 50 percent by 2050) and significantly lower levels of customer water usage over the planning period.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 38

Appendix 2E - Baseline demand forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA WWF-UK S9.7 Baseline We applaud South East Water on being in the upper As part of the consultation process we have reviewed Updated demand performance quartile of companies for leakage reduction both our short term and long term strategies for Section 8 and forecast - and for exceeding leakage targets in recent years. demand management. As a result we are now Section 9 Leakage However, the leakage reduction planned in AMP7 and including much more ambitious targets in our plan of rWRMP19 beyond does not appear to be anywhere near Ofwat’s with a 15 percent leakage reduction over the first five challenge of reducing leakage by 15 percent during years increasing to 50 percent by 2050. AMP7, so we would like to see much more challenging targets in the final WRMP. Edenbridge P5.4 Baseline The apparent daily loss of somewhere in the region of We have updated our rWRMP19. As a result have now Updated Town Council demand one fifth of the national water supply through leakage included much more ambitious targets in our plan Section 9 forecast - can only be considered as a national disgrace, given with a 15 percent leakage reduction over the first five of rWRMP19 Leakage that all of the water companies have been aware of the years increasing 50 percent by 2050. leakage problem from the outset since privatisation some 30 years ago, a situation which finds the various water companies culpable for the failure to eradicate such a loss from the national water supply. Environment R2.10 Baseline We recommend the company sets a more ambitious We have updated our rWRMP19. As a result we are Updated Agency demand leakage reduction programme for its final plan, exploring have included much more ambitious targets in our Section 8 forecast - how it can use innovative approaches to achieve leakage plan with a 15 per cent leakage reduction over the and Section Leakage reductions in line with leading companies and the first five increasing rising to 50 percent by 2050. 9 for leakage findings of the recent NIC report on England’s Water reduction Infrastructure Needs. Where the proposed level of targets in leakage is changed, the company should show the impact rWRMP19 on the supply-demand balance and the options in its final plan.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.11 Baseline Companywide, leakage is lower when compared to The differences are due to improvements in our None Agency demand WRMP14. But when assessed at a zonal level, there are understanding of zonal flows. Our water resource forecast - four zones (WRZ’s 1, 5, 6, and 8) where leakage is much zones are arranged in three areas as follows: • Sussex Leakage higher. We recommend the company provides further (zones 1, 2, 3) • West (zones 4,5) • Kent (zones 6, 7, clarification on why leakage forecasts for these zones 8) The zones within these areas are connected by have increased, and ensures it considers how these internal transfers. Additionally, there is a transfer increases may affect the company’s ability to meet from WRZ 7 (Kent) to 1 (Sussex). We have made Ofwat’s 15 percent reduction challenge. changes to calculations of zonal leakage levels to reflect our improved understanding of zonal inflows and outflows, particularly following our extensive DMA reorganisation programme . This resulted in changes to forecast leakage at water resource zone levels. At an area level, the only increase has been in Kent where water from WRZ 7 is transferred to WRZ 1 in Sussex. These changes reflect our improved understanding of zonal flows and therefore improve our confidence in our data and ability to manage future reductions.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 40

Appendix 2E - Baseline demand forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.13 Baseline Further information is required on whether leakage Leakage management costs could indeed be affected None Agency demand management costs would be affected by future policy by changes in future policy mix, and we have adjusted forecast - mix affecting the AIC cost curve. For example, with use of our future policy minimum levels of leakage within Leakage calm networks potentially reducing the NRR. the model to account for the impact of new policy options. The scale of these changes is given in Table 1 of Section 2.2.1 of Appendix 5D and represent a change in policy minimum of 87 percent of the leakage reduction delivered in AMP7, and 92 percent of all reductions delivered by 2079. The relative changes in NRR are likely to be subtle and offset against the increasing cost of detection and repair activities, because the underlying condition of the network will remain broadly unchanged and its rate of deterioration will continue to increase with age. The likely changes due to the new policy options will be a reduction in the customer reported component of NRR, as we find and fix a greater number of leaks earlier in their growth cycle, preventing them from becoming visible to customers. This will require a higher level of annual investment in operational activities to enable leaks with smaller flow rates to be identified and repaired to maintain leakage in a steady state. Environment R2.67 Baseline No clarification of leakage impact of non-supply demand No significant leakage benefits are anticipated from None Agency demand activities. It is not stated whether the company included any non-supply-demand activities, therefore we have forecast - any existing policies and the impacts of any planned non- not included them in modelling. Leakage supply demand balance actions that may reduce leakage (e.g. mains relining for drinking water quality purposes). Clarify if any benefit from non-supply-demand balance activities is anticipated and integrated into the baseline for leakage.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.68 Baseline No information provided on the method used to estimate The policy minimum value in each DMA was derived Updated Agency demand the policy minimum level of leakage. The method by from daily minimum night flow data for the period Appendix 5D forecast - which the policy minimum has been calculated is not 01/04/2015 to 30/03/2017 (taken from validated of rWRMP19 Leakage provided. Reference is made to relevant guidance Aquanet data). This represents a best achieved value documents, but it would be useful for this to be during the latest available period, during which confirmed. As the policy minimum is such a significant leakage level have been at their lowest ever reported proportion of total leakage, additional information levels. This DMA data is then combined for each should be requested, and reviewed. The policy minimum resource zone to give the values used in modelling is discussed in Appendix 5D, Section 2.2.1 - Policy activities. Section 2.2.1 of Appendix 5 D has been minimum level of leakage. The company also say it has updated to give a clearer understanding. modelled reducing the policy minimum over subsequent AMP periods, reflecting ‘the impact that our leakage policy improvements will have on the minim levels of leakage achievable’. It is not possible to confirm if best practice has been followed. Provide clarification on the method used to estimate the policy minimum level of leakage, and the sensitivity of the SELL to changes in this.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 42

Appendix 2E - Baseline demand forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.70 Baseline The evidence for increased repair costs to maintain It is correct that the number of leaks required to be Undated Agency demand lower levels of leakage is unclear. The company states repaired within the NRR model does not change over Leakage forecast - that the ALC curves have been developed using DMA- time. More leaks repairs in the detected component Appendices Leakage level relationships from assessed data, although it is not of NRR (Natural Rate of Rise) will be required, and 5A and 7H possible to verify this within the text. However, Appendix these are demonstrably more expensive as more of rWRMP19 5D, Section 2.2.3 - Active Leakage Control Cost Curves resources are deployed in the detection activity. - goes on to say ‘as we drive leakage down, the cost The graph in Fig 6 of Appendix 5D illustrates how of maintaining the lower levels of leakage continually individual DMAs costs to maintain leakage increases increases... this is because more effort is require to as we reduce their level of leakage above the assessed identify and repair leaks earlier in their development, and policy minimum. The cost is lower in DMAs with high at lower flow rates... ‘. The company has based the cost leakage levels while DMAs with higher level of leakage curves on DMA level evidence, and provides a cost curve reduction activity incur significantly higher costs. split into detection and repair as given in Figure 7 (page We have updated the text to clarify this. ALC curves 21). However, it would be useful to confirm from the NRR were developed utilising DMA-level relationships analysis that there is specific evidence that in DMAs with from assessed data and applied across the company. lower leakage levels (closer to policy minimum), the size Our current ALC is effective at maintaining leakage of leaks breaking out is smaller and that, hence, more levels. ALC operations are efficient and repair times repairs are needed to be carried out to hold leakage are short once leaks have been identified. As we drive steady than in DMAs with higher leakage. This link is not leakage down, the cost of maintaining the lower levels clear within the report. The assumption would normally of leakage continually increases. This is because more be made that to maintain leakage at a lower level has a effort is required to identify and repair leaks earlier higher cost associated due to finding leaks (as there are, in their development, and at lower flow rates. As the in aggregate fewer leaks available to find), however the level of leakage is reduced, we rely on finding more number of leaks will be the same as the NRR is constant. of the smaller leaks; this means more resources are Confirm that to maintain leakage at lower levels an required for leakage detection to survey the network increased number of leaks are required to be repaired more frequently. In other words, to achieve the (not just in transition). required saving to offset NRR, we need to find and fix a higher proportion of leaks before they become visible leaks. This is illustrated in Figure 6 where the leakage level in individual DMAs is plotted against the cost of leak detection and repair activity.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.94 Baseline The company have not outlined how it will move away We have effectively already moved away from the Updated Agency demand from SELL for WRMP2024 and to innovate to help reduce SELL as a method for establishing leakage targets Sections forecast - leakage beyond the current levels. The company should and have been managing leakage levels below our 1.4.3, 5.5 and Leakage confirm its intentions for post WRMP2024 leakage current SELL since APR 2002. In WRMP19, our SELL is Appendices review. an output of options modelling , therefore is already 5D and 7H of fully integrated with the current WRMP. Our rWRMP rWRMP19 includes substantial reductions in leakage that rely on innovation and efficiency. We review the progress of our leakage strategy annually. Our next major review of WRMP strategy will be undertaken as part of WRMP24. We continue to support leakage reporting and target setting methodologies through active involvement in Water UK and UKWIR-led projects. Ofwat R4.24 Baseline The narrative indicates that a 15 percent leakage We have updated our rWRMP19 to include far greater Updated demand reduction could not be realistically achieved by 2025. levels of demand management ambition. this includes Section 8 and forecast - Greater evidence is required for this, for example through 15 per cent leakage reductions by 2025. Further detail Section 9 of Leakage testing a 15 percent reduction scenario. is included in Section 9 of our plan. rWRMP19 Ofwat R4.25 Baseline South East Water have identified a leakage reduction of demand 12 percent as the maximum it could achieve by 2025. It forecast - intends to propose a performance commitment relating Leakage to this in its business plan and greater clarity is required in the final plan on how this interacts with the preferred scenario. Ofwat R4.3 Baseline South East Water has selected a significantly lower level We have updated our rWRMP19 to include far greater Updated demand of leakage reduction than other companies; four percent levels of demand management ambition which as had Section 8 and forecast - by 2025 rising to eight percent by 2045. While it is noted the effect of removing, or as a minimum significantly Section 9 of Leakage this could be increased as part of the business plan, to 12 deferring many of the supply schemes included in rWRMP19 percent by 2025, greater clarity is required in the final the latter part of our dWRMP19, and provides a more plan on how this reduction was tested and selected. balance twin track plan. Further detail is included in Section 9 of our plan.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 44

Appendix 2E - Baseline demand forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.23 Baseline The company must include details of the cost of the We have updated our plan to comply with directions. Updated Agency demand planned metering programme. We have completed a compulsory metering Section 5 of forecast - programme, as such the cost of completing that rWRMP19 Metering metering programme is zero. Ofwat R4.26 Baseline South East Water has a compulsory metering programme Thank-you for your response to our dWRMP19. None demand and, except for new builds and a small percentage of Your comments are noted. We will continue to liaise forecast - optants, no further metering is included in the draft plan. with unmeasured households as part of our water Metering The level of metering penetration rises from 86 percent efficiency programme (see Section 9 of rWRMP19) to to 89 percent across the planning period. encourage greater uptake of metering if and when effective to do so. Kent County A4.8 Baseline Comments about farmers using new water storage We will continue to liaise with farmers and the NFU None Council demand reservoirs - potentially leading to a significant upturn in to ensure our demand forecast assumptions for forecast their demand for mains water in the period 2020 to 2025. agriculture remain robust. We received a separate - Non- representation from the NFU on our dWRMP19, and Household following discussion with them we have agreed our Use response to their representation (see response to S 5.1).

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA NFU South S5.1 Baseline Various comments relating to water for farming - The Understanding agricultural water use is important for Updated Eastern demand farming and growing sector is particularly interested us, especially given that agriculture and horticulture is Section 5.4 of forecast in future challenges related to water scarcity and the one of our top three non-household sources of water rWRMP19 - Non- relationship between water security and food security, demand and is focused during times of peak demand Household particularly during dry and drought conditions. The NFU for water. We have a longstanding record of working Use believes that it will be important to find ways of allowing to understand agricultural water use and engage with public water companies to develop new water resources; the sector to encourage water efficient practices. and aligned with additional storage capacity it will be The experiences during 2018 of both the freeze-thaw important to use surplus capacity in ways that could and heatwave events have both given us a better benefit farmers and other businesses. understanding of the needs and requirements of NFU South S5.2 Baseline A forward look for farming - Defra has identified that agricultural and livestock farmers. There need for a Eastern demand direct payments to farmers will be phased out over the resilient water supply should benefit from the work forecast coming years. In the South East region these payments detailed in our business plan to reduce single sources - Non- accounted for 78 percent of farm business income during of supply in our network. Household the period 2014-172 so the withdrawal is likely to have a We understand that there is significant uncertainty Use substantial impact. around the future of farming and some big policy decisions currently being discussed that have the NFU South S5.4 Baseline We do not agree with the forecasts set out in Table 18 potential to impact the way the industry uses water. Eastern demand of Appendix five in the draft WRMP. These results were Our WRMP is reviewed annually and revised every forecast not explained in detail at the Kent Water Task Group, five years. In addition to this, we will continue to work - Non- nor any other direct engagement with our organisation. with the NFU to understand the demand for water in Household We recognise that the overall level of agricultural and the farming sector and how this changes over time to Use horticultural consumption has declined over recent ensure we provide a resilient and secure water supply. years, largely related to the introduction of efficiency measures, greater levels of self-supply and general industry modernisation, however there is no evidence to suggest this trend will continue throughout the next twenty five years. Further work needs to be done to clarify future agricultural demand with more certainty.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 46

Appendix 2E - Baseline demand forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Ofwat R4.16 Baseline South East Water demonstrated good practice in sharing Thank-you for your response to our dWRMP19. None demand its non-household demand forecast with retailers in Your comments are noted. forecast the pre-consultation phase to obtain their views and - Non- feedback. The company indicated that it has not received Household any responses that affect its draft plan and intends to Use ensure it develops and builds on dialogue during the public consultation which we welcome. Individual I91.3 Baseline Thinks there is still an underestimate of the demand in The population and property forecasts that support None demand 10-20 years with current developments. our plan have been prepared by Experian in liaison forecast - with local planning authorities. The forecast that Overview have been prepared to comply fully with the WRMP guideline requirements and enable us to meet our existing statutory duty to supply all new homes. Operating in a water stressed region, we work closely with local planning authorities so they are well informed of where the challenges of meeting new housing and population growth is greatest, and we engage proactively with local planning authorities on their local plan, design policies, water cycle strategies and infrastructure development plans to seek to minimise the impact new housing might have as far as is practicable. We have also adopted more ambitious levels of demand management in our rWRMP19 that will reduce demand further. Hampshire A6.1 Baseline Every effort should be taken to seek to reduce demand. Thank-you for your representation to our dWRMP19. Updated County Council demand As part of the consultation process we have reviewed Section 8 and forecast - PCC both our short term and long term strategies for Section 9 demand management. As a result we are now including much more ambitious targets in our plan with a 15 percent leakage reduction over the first five years (rising to 50 percent by 2050) and a more ambitious water efficiency programme to significantly lower levels of customer water usage over the planning period. southeastwater.co.uk 47

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Kent Wildlife S12.8 Baseline We welcome the intention within the plan to increase Thank-you for your representation to our dWRMP19. Updated Trust and demand water efficiency measures; however we are disappointed As part of the consultation process we have reviewed Section 8 and Sussex Wildlife forecast - PCC that despite relatively high PCC, both their short and both our short term and long term strategies for Section 9 Trust long-term ambition is low (only 2.1 percent reduction in demand management. As a result we are now PCC in AMP7 and a 6.1 percent reduction in PCC over the including much more ambitious pcc targets in our plan life of the plan). to achieve significantly lower levels of customer water usage over the planning period. In the first five years Waterwise S8.3 Baseline This step change isn’t reflected in an ambitious reduction of our plan we will work to achieve 14Ml/d by 2025, demand in per capita consumption, forecast to only reduce to 140 56Ml/d by 2045 and 150Ml/d by 2080. This equates to forecast - PCC l/p/d by 2044/45. We suggest that by 2045 the per capita the following PCC figures: 139l/h/d by 2025, 118l/h/d consumption target should be around 100l/p/d, with by 2045 and 90l/h/d by 2080. We tested levels of milestones towards this set out at intervals and reflected ambition with customers and stakeholders during the in the business plan for PR19. consultation and received support for our proposals. WWF-UK S9.2 Baseline We acknowledge that South East Water has taken big demand steps in the last five to ten years to reduce PCC – down forecast - PCC to around 145 litres/ person/day currently in metered properties. We acknowledge the PCC targets set by South East Water continue to seek demand reductions, but do not feel a PCC target of around 130 litres by 2080 is anywhere near challenging enough. This message was also given to you by your Environment Focus Group (EFG) at their last meeting.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 48

Appendix 2E - Baseline demand forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA WWF-UK S9.3 Baseline Especially as you serve one of the most water-stressed Thank-you for your representation to our dWRMP19. Updated demand parts of England in the southeast, we want to see more As part of the consultation process we have reviewed Section 8 and forecast - PCC ambitious targets on PCC: at least echoing those of your both our short term and long term strategies for Section 9 neighbour, Southern Water, and ideally of 100 litres by demand management. As a result we are now 2025, and 75 litres by 2050. Only with serious targets can including much more ambitious pcc targets in our plan the water industry drive forward with serious ambition, to achieve significantly lower levels of customer water searching out innovative solutions and breaking from usage over the planning period. In the first five years ‘business as usual’ planning. of our plan we will work to achieve 14Ml/d by 2025, 56Ml/d by 2045 and 150Ml/d by 2080. This equates to Ofwat R4.15 Baseline South East Water’s average company baseline PCC is 147 the following PCC figures: 139l/h/d by 2025, 118l/h/d demand l/h/d which is one of the highest across all companies. by 2045 and 90l/h/d by 2080. We tested levels of forecast - PCC The company appears to indicate the high level of PCC ambition with customers and stakeholders during the is driven by affluence and geography but greater clarity consultation and received support for our proposals. is required on the rationale for the underlying baseline trend in the final plan. Ofwat R4.2 Baseline South East Water has a high per capita consumption demand (PCC) in comparison with other companies, 147 l/h/d, and forecast - PCC the lack of ambition in proposed reductions leads to the company’s relative performance deteriorating across the planning period. Individual I105.2 Baseline Query Basingstoke 1/4M by 2050 included in 53 percent The WRP data tables that support our plan can be None demand 3.34M 2080? found on our website. Basingstoke is located in Water forecast - Resource Zone 4. WRP Table 3 includes a further Population breakdown of the property and population forecast Forecast for this area (lines 45BL through to Line 53BL). The forecast prepared by Experian provided detail to Output Area and is available on request. Swale Borough A5.1 Baseline Population/Housing Growth Forecasting - specifically The forecast prepared by Experian provides detail to None Council demand related to Swale Borough Council areas. Output Area. This should make it easier to compare forecast - with local planning authority forecast. We already Population work closely with local planning authorities by Forecast inputting to their local plans, water cycle strategies, infrastructure develop plans etc. This ensures our forecast is based on the best information available to us. southeastwater.co.uk 49

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Ashford A8.3 Baseline The Council is currently undergoing Examination in Public Thank-you for your response to our dWRMP19. Your None Borough demand of its Local Plan to 2030. The plan establishes quanta of comments are noted. We welcome the opportunity to Council forecast - housing and employment land allocations in the period continue work with Ashford Borough Council. Population of 2030. Numbers can feed into South East Water’s Forecast projections. Ashford A8.4 Baseline Appendix 5A - not clear whether the higher figure from We believe our demand forecast assumptions to None Borough demand Ashford Strategic Housing Market Assessment has been accommodate the Ashford Strategic Housing Market Council forecast - included. Assessment figures. Population Forecast Ashford A8.5 Baseline The Council is concerned about the timely delivery of We confirm that the rWRMP delivers water resources None Borough demand water resources supporting the borough’s growth. necessary to support the borough’s growth. Council forecast - Population Forecast

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 50

Appendix 2E - Baseline demand forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA NFU South S5.3 Baseline Population growth and water sustainability - We note In our Responsible Business appendix to our 2020-25 None Eastern demand that the WRMP forecasts a 24 percent population business plan we propose that we will participate forecast - increase over the next 25 years, approximately 500,000 in community partnership projects on water use Population additional people living and working within the South and vulnerability. One of the measures we will look Forecast East Water supply area. This will translate into an uplift of at (as well as working with universities and local approximately 1.5 million meals consumed every day over charities) is to develop a partnership project to the same period, a factor that is not taken into account look at water footprint to begin in 2020. This was a by any company WRMP’s. At the present time it will new idea developed at the stakeholder workshop. not be possible for water companies to quantify wider As it’s something new to us we need to give it time scale sustainability implications within their WRMP’s, to understand, review and discuss further. But we however in the long term they may need to consider wanted to include it as this is an innovative route the macro-level implications if UK farmers and growers we should be taking if we want to be leaders in cannot respond to growth in consumer demand. Indeed sustainable use of water. It may expand to focus on the most sustainable long term option may include a supply chain and communities as well as company and degree of import substitution by facilitating an increase customer water footprint. We would be keen to work in irrigated agriculture within the UK. If this is recognised with the NFU to look at collaborating to explore this as an appropriate sustainability measure then the possibility further. water resource planning system may need to respond accordingly. Horsmonden P2.1 Baseline Very aware of the likely impact on our local infrastructure The population and property forecasts that support None Parish Council demand of future development and population growth in our our plan have been prepared by Experian in liaison forecast - area. with local planning authorities. The forecast that Population have been prepared to comply fully with the WRMP Forecast guideline requirements and enable us to meet our existing statutory duty to supply all new homes. Operating in a water stressed region, we work closely with local planning authorities so they are well informed of where the challenges of meeting new housing and population growth is greatest. We engage proactively with local planning authorities on their local plan, design policies, water cycle strategies and infrastructure development plans to seek to minimise the impact new housing might have as far as is practicable. southeastwater.co.uk 51

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Horsmonden P2.2 Baseline Welcome the statement in this water resource plan that Thank-you for your response to our dWRMP19. Your None Parish Council demand the plan has used independent and robust household comments are noted. forecast - and population projections when assessing future water Population supply need. Forecast Horsmonden P2.3 Baseline Believe it is essential that these projections are updated The water resources management plan process None Parish Council demand regularly as implementation of the plan progresses. is carried out on a five year cycle and in doing so forecast - all assumptions and projections are updated and Population refreshed using the most appropriate data and Forecast methodologies. In addition to this, South East Water carry out an annual review of performance against water resources management plan. This allows us to compare our forecast with actual annual figures.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 52

Appendix 2E - Baseline demand forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.109 Baseline The company does not mention that it has considered As you rightly say the WRMP concentrates on None Agency demand plans for localised housing developments within ensuring we have sufficient resources at a Water forecast - Local Authority areas and how they might affect the Resource Zone (WRZ) level. We also carry out further Population location of growth. There may be localised significant detailed work as part of our five year business plan Forecast developments (hotspots) that should be allocated to a to assess how we will distribute water we have made specific WRZ rather than spread across WRZs to ensure available within each zone to local areas of growth. adequately accurate calculations. There is potential concern that, if the locations of planned development hotspots have not been fully considered, property and population growth in some WRZs may have been either under or over estimated. The calculations that have been undertaken may be appropriate, but there is insufficient evidence that the location of growth hotspots and its allocation to specific WRZs has been considered. Provide further explanation that the approach taken in preparing the plan-based property and population forecasts has adequately accounted for growth hotspots. The company should demonstrate that it has adjusted or considered adjusting property and population forecasts, for those localised planned developments which have a significant effect on the allocation of population to individual WRZs. If no adjustments are considered necessary, the company should provide explanation. Environment R2.73 Baseline The Company does not explain how forecasts were We have updated the demand forecast Appendix 5 to Updated text Agency demand extrapolated from 2044/45 to 2079/80.Provide details explain how this was undertaken. in Appendix 5 forecast - of how the property and population forecasts were Population extrapolated from 2044/45 to 2079/80. Forecast Environment R2.74 Baseline No information is provided on the level of the Agency demand adjustments made to reconcile the property forecasts forecast - to the Base year data. Explain the extent of adjustments Population made to reconcile the property forecasts to Base year Forecast data.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.75 Baseline There are statements in Appendix 5 that the Company We have updated the demand forecast Appendix 5 to Updated text Agency demand followed the UKWIR/Environment Agency guidance explain how all six tasks were applied. in Appendix 5 forecast - in preparing its forecasts. But it is not clear from the Population text that all six of the tasks have been applied. For Forecast example, it is not clear how problem characterisation has influenced the use of Output Area (OA) census geography and digital boundaries to match OAs to WRZs. Provide confirmation that the six tasks described in the UKWIR/ Environment Agency methodology have been addressed and completed. Provide explicit statements of how the Company’s problem characterisation classification has influenced its forecasting approach and choice of census area geography. Environment R2.76 Baseline No assumptions are presented concerning the population We have updated the demand forecast Appendix 5 to Updated text Agency demand residing in void properties. Provide an explicit statement clarify population in void properties is zero. in Appendix 5 forecast - and explanation on the assumptions made concerning Population any population in void properties. Forecast Environment R2.88 Baseline It is clear that the information on population growth The forecast prepared by Experian provides detail to None Agency demand has been very thorough and drawn on the local plan Output Area. This should make it easier to compare forecast - documents produced by local councils. However, it would with local planning authority forecast. We already Population have been useful to see the data behind this (e.g. XXXX work closely with local planning authorities by Forecast number of new homes in XXXX District council over the inputting to their local plans, water cycle strategies, next XXX years) so that it would be possible to sense infrastructure develop plans etc. This ensures our check and ensure nothing has been missed. As it is, it is forecast is based on the best information available to hard to verify that the most up-to-date information has us. The output area information can be made available been used. Show break-down of expected new homes to view on request. that have been used for each district – then we can easily verify that the most up-to-date information has been used by comparing this with Local Authority Local Plans – since these change regularly. Also if/when these forecasts and ambitions for growth change, it will easier be able to identify areas of increased risk.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 54

Appendix 2E - Baseline demand forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.92 Baseline Most LPA plans do not extend beyond 10-20 years. We have updated the demand forecast Appendix 5 to Updated text Agency demand Experian (employed by the company) extrapolated explain how this was undertaken. in Appendix 5 forecast - the dwelling targets in the local plans to 2044/45. Population The Company does not explain how forecasts were Forecast extrapolated from 2044/45 to 2079/80. The company should explain how it has extrapolated the data from 2044/45 to 2079/80. Environment R2.93 Baseline Average property numbers in the Base year (2016/17) Agency demand were extracted from the Company’s customer database forecast - system. Occupied and void properties are also clearly Population identifiable. These data were used to derive the Base Forecast year property numbers from which the forecasts were projected. Experian used the ONS data for LSOAs to build up estimates of Base year (2016/17) population in each WRZ. Population forecasts for each property type were calculated using Experian’s population forecasts and the Company’s occupancy trends and are shown in Table 9 of Appendix 5. Although the above processes are well explained, no information is provided on the level of the adjustments made to reconcile the property forecasts to the Base year data. The company should show the level of the adjustments made to reconcile the property forecasts to the Base year data.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.69 Baseline No information on how pressure management has Our approach to pressure management in rWRMP19 None Agency demand been integrated. The company reflect in Appendix 5D, is focused on the stabilisation of pressures across the forecast Section 2.2 - Assessment of sustainable economic level of network. We are already at the forefront of pressure - Pressure leakage (SELL), the wording from the guidance regarding management across the distribution network, with Management integrating pressure management, however there is significant pressure reduction schemes implemented not information outlining how this has specifically been over the last 25 years, including 150 i2O advanced considered. It is not possible to confirm if best practice pressure management installations. To continue with has been followed. Confirm how pressure management this we have included the Calm Network option in our has been integrated. plan, as described in Appendix 5D Section 3.3.4. SELL impact has been modelled through the lowering of the policy minimum level of leakage (policy minimum) in subsequent modelling periods, lowering the cost of maintaining leakage in future years. Environment R2.5 Baseline SES Water at Outwood to Whitely Hill: The company We can confirm that we have removed the Outwood Updated Agency demand should reassess its supply demand balance to ensure to Whitely Hill transfer from our baseline supply Section 4, forecast there is not a risk to security of supply. forecast and have remodelled our rWRMP19 on this 6 and 9 of - Regional basis to generate a new preferred plan without this rWRMP19 Transfers transfer. Kent County A4.12 Baseline KCC will seek to understand the implications of this We will continue working closely with KCC and other None Council demand for water resilience within the County, with specific stakeholders to ensure our long term plans contribute forecast - references to RZ8. by the best means they can to resilience across the Resilience county of Kent. Individual I77.2 Baseline Public amenities need to catch up on water reduction. Thank-you for your response to our dWRMP19. Your None demand comments are noted. forecast - Water Efficiency

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 56

Appendix 2E - Baseline demand forecast continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Defra R1.3 Baseline Per capita consumption is projected to be high at 138.5 Thank-you for your representation to our dWRMP19. Updated demand l/h/d by 2044/45. Strategy on per capita consumption As part of the consultation process we have reviewed Section 8 and forecast should be explored further. both our short term and long term strategies for Section 9 of - Water demand management. As a result we are now rWRMP19 Efficiency including much more ambitious pcc targets in our plan to achieve significantly lower levels of customer water usage over the planning period. In the first five years of our plan we will work to achieve 14Ml/d by 2025, 56Ml/d by 2045 and 150Ml/d by 2080. This equates to the following PCC figures: 139l/h/d by 2025, 118l/h/d by 2045 and 90l/h/d by 2080. We tested levels of ambition with customers and stakeholders during the consultation and received support for our proposals.

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Appendix 2F - Supply demand balance

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.110 Supply The dominant source of uncertainty is the demand Figure 56 does not represent ranges of uncertainty to None Agency demand forecast. Figure 56, page 136, and Appendix 8B, Figure 5, be incorporated into target headroom. It represent balance - page 21 shows three separate branches/scenario plumes a range of future supply demand scenarios that we Demand of assumptions around demand, splitting in 2044/45. have used to test our preferred plan in terms of Forecast The WRMP would benefit from more information on the resilience and adaptability. The target headroom tipping points. The plan would also benefit from more values included to construct each of the different granularity between these plumes to work out where the future scenario was the same in each case, and were plan would materially change. The uncertainty around developed using existing UKWIR methodology and the demand forecast is likely to be driving the high level WRMP guidelines. Target headroom does not drive of target headroom. The company’s target headroom the changes in deficits observed in later years of is an industry outlier at over ten percent of total WAFU the planning period. The scenarios represented in by 2045. This potentially risk adverse approach may Figure 56 are not driving levels of investment, but are be driving the deficits later in the period and as such, informing investment decisions and the adoption of potentially driving inappropriate investment. The different portfolios of options to best meet the wide company should explore, and provide more information range of alternative futures. Further detail of how our on, the tipping points in the assumptions around demand. plan would change under different plans is included in The company should also provide more granularity Section 8 and Appendix 8. between the three plumes to work out where the plan would materially change. This may then lead to a lower target headroom, and so drive less of a deficit in the future. Environment R2.123 Supply A succinct description of the approach to the climate For our rWRMP19, we have revisited our assessment Updated Agency demand change component of headroom is presented in both of climate change components of target headroom Appendix 6A balance - the main plan and Appendix 6A. There are also some at a zonal level. Following this review, we have made of rWRMP19 Headroom comments on climate change uncertainty in Appendix alterations to the distributions for forecast wetter 4B. Whilst acceptable, given the size of the supply- futures, which were found to be introducing negative demand deficit, it would be beneficial to have a more values. These changes ensure that the wetter developed explanation of headroom in either the main periods will neither increase or reduce uncertainty plan or Appendix 6A (see Improvement 4.1).The company in the calculation. Further details are available in the should provide a more detailed explanation of headroom, updated headroom appendix (Appendix 6A). in particular the climate change component, in the plan or Appendix 6A.

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Appendix 2F - Supply demand balance continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.65 Supply The company should reassess the climate change For the revised WRMP, we have revisited our Updated Agency demand component of its target headroom. assessment of Climate Change at a zonal level. Appendix 6A balance - Following this review, we have made alterations to of rWRMP19 Headroom the distributions for forecast wetter futures, which were found to be introducing negative values. These changes ensure that the wetter periods will neither increase or reduce uncertainty in the calculation. Further details are available in the updated headroom appendix (Appendix 6A). Ofwat R4.19 Supply The target headroom for South East Water as a We are confident that we have only included Updated demand percentage of demand at 2045 is 11 percent and is legitimate areas of uncertainty, and that the chosen Appendix 6A balance - significantly higher than the industry average of eight level of headroom well evidenced and is appropriate Headroom percent. to meet the needs of the company and our customers. Further details are available in the updated headroom appendix (Appendix 6A). It is also unclear on what basis comparison across the industry have been made or are appropriate to individual company circumstances. Ofwat R4.20 Supply The draft plan notes that some of the changes are due For the revised WRMP, we have revisited our Updated demand to pre-consultation feedback from the Environment assessment of Climate Change at a zonal level. Appendix 6A balance - Agency that the previous plan levels were too low. Following this review, we have made alterations to Headroom However, this is not the only element that has changed the distributions for forecast wetter futures, which and the corresponding change in decision making could were found to be introducing negative values. These result in double counting uncertainty. The company changes ensure that the wetter periods will neither should therefore clarify how the duplication of potential increase or reduce uncertainty in the calculation. uncertainties is avoided. Further details are available in the updated headroom appendix (Appendix 6A).

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Ofwat R4.21 Supply South East Water indicate the climate change For the revised WRMP, we have revisited our Updated demand component of headroom is negative, however, reasons assessment of Climate Change at a zonal level. Appendix 6A balance - for this are not clearly articulated within the draft plan. Following this review, we have made alterations to Headroom the distributions for forecast wetter futures, which were found to be introducing negative values. These changes ensure that the wetter periods will neither increase or reduce uncertainty in the calculation. Further details are available in the updated headroom appendix (Appendix 6A). Ash Parish P4.7 Supply Future planning for demand should be at two levels - for Our approach to demand forecasting is effectively None Council demand the first 25 years as proposed and the next 35 years the same as that proposed. We have applied more balance - allowing for greater use of regional transfers, financial certainty concerning the first 25 years and less so for Overview investment, possible forecasting errors and a more the latter 35 years. But there is real benefit looking countrywide analysis. out over a 60 year period, because it allows us to understand the widest range of different futures that may exists in the long term, ensuring the decisions we make in the near term are better informed and represent the lowest risk of regret and greatest scope for adaptation in the longer term. Our plan takes account of the findings from The Water UK National Water Resources Long Term Planning Framework study and the Water Resources in the South East (WRSE) modelling group, which used regional and national data sets and considered water supply options feeding into our region from as far afield as Wales, the west country, the midlands and the north of England. Ashford A8.1 Supply Recognise the regional context across South East Water’s Thank-you for your response to our dWRMP19. Your None Borough demand network, within which population increase is expected to comments are noted. Council balance - be significant henceforth. Therefore welcome the longer Planning view taken in dWRMP, acknowledge limitations of such Horizon an approach in that this timeframe extends significantly beyond that for other plans and strategies.

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Appendix 2F - Supply demand balance continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.77 Supply A 60 year planning horizon is modelled, rather than Thank-you for your representation to our dWRMP19. None Agency demand the minimum 25 years. The advantage of this is not Our approach and reasons behind the adoption of a balance - explicitly referenced. Unlikely to have any impact on the 60 year planning horizon are outlined in Section 2.5 Planning dWRMP, but will increase clarity of the approach taken. of our Decision Making Approach Appendix 8A. A key Horizon Clarification should be provided. advantage being the opportunity to test our plan to a wider range of futures to ensure our decisions in short to medium term are adaptive and better informed. Environment R2.22 Supply The company must provide in numerical format how We have updated our rWRMP19 to include a new Section 1.17 Agency demand much greenhouse gas it estimates it will emit for its Section 1.17 which addresses this query. balance - ongoing operations, as it has for its feasible options, or Supply and signpost where this information can be found outside of Demand the WRMP. Forecasts Individual I103.5 Supply We should be having sufficient capacity to cope with The plan already includes allowances for outages of None demand sites being out of action rather than running near our sources. balance maximum which gives no headroom for maintenance to take place or to cope with unexpected weather events.

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Appendix 2G - Options

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I105.3 Options - Investigate desalination at seaside towns. We have investigated the opportunity for new None Desalination desalination schemes at a number of seaside towns throughout Kent and Sussex, these include Reculver, Newhaven and Bexhill as well as a scheme on the tidal reach of the River Medway. Individual I38.4 Options - What about more desalination. Considered as an option in rWRMP19 but the need None Desalination for them was not evident at this time. More generally, there is uncertainty regarding risks to marine ecology or aquatic ecology associated with the brine waste generated from desalination options. Desalination options also require very high levels of energy to treat the water and therefore have a very high carbon impact compared to more conventional surface water or groundwater abstraction or transfer sources. But technology is improving and we with continue to consider desalination in future plans. Kent Wildlife S12.35 Options - A range of alternatives for developing new and sharing As part of the consultation process we have reviewed Updated Trust and Desalination existing resources were considered in the development both our short term and long term strategies for Section 9 of Sussex Wildlife of the plan, we believe that further improvements in demand management. As a result we are now rWRMP19 Trust demand management and water efficiency must also including much more ambitious targets in our plan be considered alternatives to any proposals that cause with a 15 percent leakage reduction over the first five significant harm to the natural environment. years (rising to 50 percent by 2050) and significantly lower levels of customer water usage over the planning period,14Ml/d by 2025, 56Ml/d by 2045 and 150Ml/d by 2080. This equates to the following PCC figures: 139l/h/d by 2025, 118l/h/d by 2045 and 90l/h/d by 2080. These more ambitious levels of demand management were tested with customers and stakeholders during the preparation of our rWRMP19 and received their support.

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Appendix 2G - Options continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I69.6 Options - Water is not expensive – it is cheaper than sewerage We agree different tariff structures may play a very Updated Finance services, and electricity for example, but using the important role in the delivery of longer term levels of Section 9.3.2 forward price of water based on future scarcity, or the water efficiency. We propose to explore the longer of rWRMP19 Long Range Marginal Cost (LRMC) would help drive term scope and role of tariffs further as part of our change. This would help drive water efficiency and forward programme of work. would be equitable because it would be highlighting the damage caused by excessive abstractions. Individual I69.7 Options - Currently the only incentive for most customers to We are supportive of the comments received. Many Updated Finance reduce water use is to save on the water and sewerage of the proposals form part of ongoing activities Section 9.3.2 bill. Unfortunately tariffs are crude, and the Standing and plans and we have made more explicit in our of rWRMP19 Charge reduces the incentive to save water, because it rWRMP19. As example: we are providing support dilutes the charge per cubic metre signal. For example we and advice to high consumption households; we are use about 56 cubic metres. per annum, pay £31 for the installing smart meters in 200,000 households by Standing Charge, and £91 for the water, total £122, so the 2025. Our water efficiency programme is set out in Standing charge is 25 percent of the whole bill. Without Section 9 and is geared towards raising awareness the separate Standing charge, the volumetric charge of water use and offering smarter information and would be 25 percent higher so any change in use would be comparative advice. 25 percent more noticeable, but water companies would have no loss of income from the change. So a more direct incentive would be for there to be no standing charge. It is particularly important to send clear messages to users with high Per Capita Consumption, unless use is essential such as for medical reasons, dialysis for example, for which allowance can be made. So the cost per cubic metre should be on rising block basis.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Surrey County A2.3 Options - Possibility of using hydro-electricity schemes to provide We have undertook a number of feasibility studies None Council Finance funding. to determine hydro-electricity opportunities. The simple answer is that our surface reservoirs provide insufficient head to generate electricity, i.e. there is insufficient fall of water from height in our operational area. We have also reviewed the possibility of introducing hydro technology within our pipe infrastructure - again no significant opportunities were identified, without interference to pressure levels for customers and at the detriment of increase energy costs that would offset any hydro benefit. Environment R2.133 Options - From the cost comparator tool it can be seen that Since WRMP14, we have updated all of our option None Agency Finance there have been some significant changes in AIC and costs using the latest version of our “unit cost AISC values by option type between WRMP14 and database” (UCDB) costing tool. This update in option WRMP19. For example variations in values for new costs has since changed some of our previous AISC reservoirs, aquifer recharge and desalination. There is values. We have checked the costs of options where no explanation in the plan as to why these costs have AISC costs appear to be different from WRMP14 and increased. Lack of transparency in cost changes between can confirm that following: WRMP periods. Provide commentary on why option type 1) In Table 5 of the WRP tables, the AISC cost for a values are significantly higher or lower than previously DYAA scenario is calculated using the average yield of reported. an option. For ASR and RES schemes the DYAA yield of an option is lower than the DYCP yield of an option, this can generate a high AISC cost in the DYAA WRP tables. 2) Our UCDB tool has been updated and benchmarked using the final outturn costs of schemes delivered since the final WRMP14 was issued. Although this may have generated costs different from WRMP14, we now have more certainty around the cost being used continues for WRMP19. opposite

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Appendix 2G - Options continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.133 Options - From the cost comparator tool it can be seen that 3) Our UCDB tool now includes cost functions for None Agency Finance there have been some significant changes in AIC and the treatment plant required for desalination and continued AISC values by option type between WRMP14 and effluent re-use schemes. Again, although this may WRMP19. For example variations in values for new have generated costs different from WRMP14, we reservoirs, aquifer recharge and desalination. There is now have more certainty around the cost being used no explanation in the plan as to why these costs have for WRMP19 for these types of schemes. increased. Lack of transparency in cost changes between 4) During WRMP14 the zonal network improvements WRMP periods. Provide commentary on why option type where included within resource scheme costs. For values are significantly higher or lower than previously WRMP19, for transparency and to improve our reported. modelling process, we have split these costs out of the resource scheme costs and generated separate zonal schemes with costs that are linked to the associated resource schemes. This will have an impact to reduce some of the AISC costs for WRMP19. Although AISC costs provide a good indication of the financial performance of an option, it is the EBSD optimisation model that is being used to generate the least cost solution of options in combination to generate the overall least cost best value plan.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Surrey County A2.1 Options - Believes there has been a missed opportunity to provide Your proposal of the holistic and joined up None Council Flooding joint solution to increased water supply for planned management of water resources also incorporating population growth and fluvial flooding. hydro-electric power generation sounds eminently sensible. We work closely with catchment Surrey County A2.2 Options Propose a new raw water reservoir close to the Thames. partnerships across our supply area to ensure a joined Council - Other up view of water and land use in the catchments we Options/ operate. As part of this, and as our ongoing business Technology activities we work closely with the Environment Agency who also have a role modelling and managing flooding. We also look to minimise our energy use. The challenge of finding joint solutions for flooding and water resources is that the events of each happen at fundamentally different periods of time and the solution serve different purposes and are in conflict i.e. a reservoir for water resource needs to be kept full, but for flooding need to be kept empty. Flooding obviously happens at times of much higher than usual rainfall whereas we plan water resources to be resilient to a one in 200 year drought event which is one that is worse than a historic drought previously recorded across our supply area - for us this is likely to be after two dry winters and significantly lower than average rainfall during which time river flows would be lower than in normal years and flood alleviation schemes dry.

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Appendix 2G - Options continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.86 Options - The groundwater option “Oakhanger-Oaklands- All drought options have now been classified as DMP Updated Agency Formatting Southlands - Drought Option” has a different code in options. Therefore, some options that were previously Unconstrained the feasible options list (DMP-6) to its original code of ground water options are now drought options (DMP). and NGW-43 in the Unconstrained and Constrained options All option lists (including the unconstrained and Constrained lists. This makes it difficult to follow the option through. constrained options list) have been updated to reflect Option List in It is also very unclear from the option description exactly this change. Also, additional option details for DMP-6 Appendix 7B what this option is proposing. The groundwater option has been added. and 7C “Oakhanger-Oaklands-Southlands - Drought Option” has a different code in the feasible options list (DMP-6) to its original code of NGW-43 in the Unconstrained and Constrained options lists. This makes it difficult to follow the option through. It is also very unclear from the option description exactly what this option is proposing. Apply consistency to naming of schemes and provide more detail on this option. Individual I116.2 Options - The lack of innovation - Section 7 talks about the success We consider that our water efficiency programme None Innovation of asking customers to compare their water usage with included in Section 9 includes more innovative their neighbours. I am not in the slightest impacted by approaches to water efficiency and further discovering that my neighbours use different quantities consideration of new tariffs. of water than me. I might start thinking more about my water usage if my usage this year was compared with my usage last year. But a far simpler and more effective method of getting anyone to focus on consumption is to change the basis of payment. The standing charge should be abolished with the amount paid for water being related directly to consumption. To ensure that people are not overcharged for their water usage, a fixed level of usage per person in a house could be established and that quantity would be purchased at a price per litre that would generate a realistic charge for the water supplied. Usage over that level would be charged at a premium price thus creating a financial incentive for people to continues focus on consumption. overleaf

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I116.2 Options - This should ensure that garden watering and swimming None continued Innovation pool activities are charged at a premium rate; more likely, consumption for such activities would reduce! Similarly, water usage per house is established by an South East Water employee coming to read the meter. Perhaps the phrase”-smart technology to reduce leakage both on the customers and company pipework” shows an intention to introduce some form of electronic water monitoring. But this possibility is not clearly expressed. It should be relatively easy to install meters on the company’s pipes that could be read in real time and thus enable those controlling the network to identify when usage in a particular area is at a greater than expected level and leaks appear likely. Proactive management of leaks is more sensible than the current reactive approach that requires people who observe a leak actually reporting it.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 68

Appendix 2G - Options continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.14 Options - Clarify and provide additional information on the We are not the asset owner of the supply pipe; None Agency Leakage approaches being taken to controlling supply pipe however, we our baseline operation already include leakage. activities aimed at reducing supply pipe leakage. Our billing system contains a high consumption flags that help with leak identification. All new customer meter installations include technology that generates a specific leak flag that is available when the meter is read. Around 300,000 meters of this type are deployed in the network. We currently offer a supported repair process to all of our customers across six of our eight resource zones and are trialling the roll out of this approach to the remaining two. We envisage that this activity will continue into the future. We also plan to increase our communications activity as a part of our plan to reduce per capita consumption to focus on both supply pipe and internal plumbing losses. Our planned initiatives of Smart Networks, Calm Networks, New Technology are not explicitly limited to the distribution network and all include supply pipe leakage identification within their scope. The combination of innovation supported by a policy of assisted repair will lead to an improvement in this area of leakage reduction. Environment R2.15 Options - Request clarity on how supply pipe leakage policies have Burst rates and asset and mains renewal form a part of None Agency Leakage been considered within the options. our Capital Maintenance activity that contributes to maintaining baseline level of leakage. Our leakage options are focused on leakage reduction activities over and above those required to maintain baseline leakage.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.16 Options - Clarify assumptions relating to burst rates, asset and The development of our leakage options was None Agency Leakage mains renewal options. undertaken with a cross section of engineering and operational staff supported by external experts - a true bottom-up approach utilising operational knowledge and wide leakage and distribution expertise. It was based on a “roadmap to achieve vision) framework we applied in previous AMP period. This is described in Section 3.1 of Appendix 5D. Options deemed to be of disproportionately high cost/little benefit were not taken forward beyond the initial development phase. Once all leakage options were developed, they were included in the pool of unconstrained options. All of these options were then taken through to feasible options with no further screening. Targeted capital investments such cathodic protection and mains renewal forms part of the package of works that deliver our baseline level of performance, and we rely on mains replacement to reduce leakage further later in the plan’s lifetime.

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Appendix 2G - Options continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.66 Options - There is a lack of clarity in how constrained options The development of our leakage options was None Agency Leakage were screened or combined to result in feasible leakage undertaken with a cross section of engineering and options. A description of assumptions around the operational staff supported by external experts - a potential impact of innovation and new technologies true bottom-up approach utilising operational is provided in the option descriptions in Appendix 5D - knowledge and wide leakage and distribution Section 3.3 - Options to reduce leakage levels. A number expertise. It was based on a roadmap to achieve of the proposed options appear to be quite ambitious, vision framework we applied in previous AMP period. e.g. to implement the latest technologies and smart This is described in Section 3.1 of Appendix 5D. networks systems across the entire network. There Options deemed to be of disproportionately high is no additional information provided. A full list of the cost/little benefit were not taken forward beyond unconstrained options for leakage considered is provided the initial development phase. Once all leakage in Appendix 7B - unconstrained options report, however options were developed, they were included in the Appendix 7C - WRMP19 Coarse Screening Decisions pool of unconstrained options. All of these options does not step through the short-listing of the leakage were then taken through to feasible options with no options to arrive at the final feasible options list that is further screening. Targeted capital investments such outlined in Appendix 7H. This means it is not possible to cathodic protection and mains renewal forms part of ascertain why certain options, such as leakage-driven the package of works that deliver our baseline level mains renewal or cathodic protection were not taken of performance, and we rely on mains replacement to forward. We would recommend improving the clarity on reduce leakage further later in the plan’s lifetime. how the constrained options were reviewed or combined to form the final feasible leakage options. Improve clarity in transition from constrained options through to feasible options for leakage.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.71 Options - It is not clear what the impact of any new options will SELL is an output from our modelling, therefore it is None Agency Leakage be on the level of SELL, i.e. whether SELL has been recalculated following the options appraisal. recalculated after options appraisal. Request information Leakage management costs could indeed be affected on whether leakage management costs would be by changes in future policy mix, and we have adjusted affected by future policy mix affecting the ALC cost our future policy minimum levels of leakage within curve. E.g. with use of calm networks potentially reducing the model to account for the impact of new policy the NRR etc. options. The scale of these changes is given in Table 1 of Section 2.2.1 of Appendix 5D . The relative changes in NRR are likely to be subtle and offset against the increasing cost of detection and repair activities, because the underlying condition of the network will remain broadly unchanged and its rate of deterioration will continue to increase with age. The likely changes due to the new policy options will be a reduction in the customer reported component of NRR, as we find and fix a greater number of leaks earlier in their growth cycle, preventing them from becoming visible to customers. This will require a higher level of annual investment in operational activities to enable leaks with smaller flow rates to be identified and repaired to maintain leakage in a steady state.

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Appendix 2G - Options continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.100 Options No explicit information on how the 108 possible future At the outset of the decision making process, 432 was Updated Agency - Option scenarios were generated. A range of demand forecast the total number of scenarios that could be generated Appendix 8A Selection component values were provided, but it not readily by a combination of different assumptions for the full of rWRMP19 apparent that this equates to a combination of 108 list of uncertainty components. Drought, demand, scenarios. There is a clear contradiction between the climate change, sustainability reductions, drought technical appendices where 432 scenarios are described, permits/orders and water quality. During the process, and the main dWRMP report where 108 possible futures it was determined that we did not have any reductions are reported. The range of possible futures is too narrow, to implement due to water quality - this reduced the or an even distribution of component variability has not total number of scenarios by a factor of 3. We also been achieved. Reduced clarity of reporting and as a implemented a rule within the modelling process such result stakeholders cannot follow the narrative and the that drought permits and orders could not be used for source of possible future scenarios considered. Additional WRMP14 and Worst Historic drought conditions - this information should be provided. Reporting of possible reduced the total number of scenarios to 108. We will future scenario to be consistent throughout the main ensure that Appendix 8A is updated to reflect this report and appendices. Justification on the reduction within our revised plan. from 432 to 108 scenarios to be provided.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.118 Options At the constrained to feasible stage, there are a number We have updated our rWRMP19 Section 7, regarding Updated Agency - Option of smaller options that were rejected with limited small options. Our preferred plan in our rWRMP19 has Section 7 of Selection narrative on the rejection criteria. A large quantity of been revised following the representation received, rWRMP19 larger scale engineering options were progressed to we have undertaken further customer research the feasible stage despite there being some significant to inform those changes too. As a consequence of risks associated with these. The company also do not those changes we have removed many of the larger necessarily reflect the results of Willingness to Pay schemes and included an alternative schemes list surveys. In our review of the drought plan, we highlighted too. The rWRMP19 has been aligned to the most the company has very few drought options. Those that recent customer research findings as summarised in are available potentially have long lead in times or in rWRMP19. Because we more closely integrated our some cases are not licenced. We suggest these smaller drought plan and WRMP19 processes we have already options, rejected at the feasible stage, be reconsidered considered schemes for our drought plan. But will as potential drought options. The company should ensure these are kept under review in future updates reconsider feasibility of packages of smaller options if of both/either plan. there is significant opposition to the options selected within preferred plan. Reasons for rejection of some options is not always clear and the company should provide more narrative around this. The company may wish to reconsider whether these could be developed as drought options to increase the company’s resilience to long duration droughts. Environment R2.84 Options There are a number options that do not have any detail We note that there are some options in our feasible Updated Agency - Option as to why it has been removed at the fine screening list (Appendix 7D) that do not contain a narrative as to Appendix 7D Selection stage. We do not necessarily expect to see these options why they have been screened out. We have updated of rWRMP19 included, but a narrative should be provided as to why the rWRMP19 appendix with this a narrative provided - provide a they weren’t taken through to feasible/preferred stage. for all fine screening decisions within our revised plan. screening Provide more clarity on why options have been screened narrative for out at the fine screening stage. all options.

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Appendix 2G - Options continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.85 Options SEW-RZ5-LIC-1 MoD Bordon Garrison Boreholes. This The reason that this option was screened out is Updated Agency - Option option should be classed as a New Groundwater option that there is no licence available to trade due to the Feasible Selection as the MOD site is currently exempt from requiring previous exemption of the licence. We Appendix 7D Options List an abstraction licence meaning there is no licence to with narrative provided for this decision within our in Appendix trade. There is also no reason given why this licence rWRMP19. We will also include a new groundwater 7D of was screened out at fine screening. Reclassify as a new option into our unconstrained option list for WRMP24 rWRMP19 licence rather than a licence trade. Provide more clarity to ensure that it is consider and investigated further on why this option has been screened out at the fine as a potential new licence option. screening stage. Environment R2.95 Options Not all preferred options link back to a feasible option, The preferred options are consistent with the Updated Agency - Option this often happens when an intra-company transfer descriptions of the feasible options in Appendix 7D. Appendix 7B, Selection between WRZ has been identified. The company should However, some of the intra-company options have 7C and D, ensure all preferred options link back to a feasible option. been revised since our draft plan submission and the Fig 62 of new descriptions will have been used in post draft rWRMP19 issue planning tables. We have updated Appendix 7D and other text with the revised intra-company descriptions for the rWRMP19. Individual I112.2 Options Alternative water sources and treatment processes need Our options appraisal process has considered a full None - Other to be considered. range of alternative water service and treatment Options/ process. We started with a long list of unconstrained Technology options (510), this list included feasible options from our WRMP14, exploring opportunities with third parties and looking at other ways to benefit from new sources of water and technologies. In line with the WRMP guidelines, we have integrated our extensive list of options with a Multi-Criteria Assessment (MCA) and SEA process and screened out options at multiple stages to arrive at our feasible list from which we have determined our preferred plan.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I19.1 Options Add bulk flow meter at any new development for leakage. We currently install bulk flow meters at all new None - Other Could we do a discount for the developers that do this. developments that are greater than 1,000 properties Options/ and all other existing and new properties are Technology assigned to District Metered Areas i.e. define groups of households we can monitor on a bulk metre. We do not charge the developer for this. We are reviewing the 1,000 property threshold to enable us to meter more smaller developments directly. All new developments are integrated into our current network metering system which captures flow data every hour for leakage monitoring and control purposes. Individually metering all new developments would not be cost effective. Individual I46.4 Options Solar energy on our sites. We are currently undertaking a number of feasibility None - Other studies regarding solar energy being used on, or Options/ near, our sites. We are keen to minimise our impact Technology to the environment and are developing a number of challenging performance metrics to monitor our carbon footprint going forward, and the use of renewable energy will be key to reducing our environment impact. Individual I9.1 Options Consider graphene technology for desalination. We are monitoring the advances in graphene None - Other treatment technology for the desalination of water Options/ as we see the potential benefits it can offer in terms Technology of lower energy usage. However, the technology is still under development for use in a desalination application and so is not currently at a stage where we have sufficient confidence to include in our plans. It is likely however, that as the technology develops and is proven we may find a role to include as a solution for desalination treatment in future WRMP’s.

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Appendix 2G - Options continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I9.3 Options Use of UV technology should be considered. We currently use UV technology as an effective None - Other treatment for the disinfection of water as Options/ appropriate. Technology Individual I91.4 Options Consider two percent annual replacement of mains & We replace mains on a risk basis to optimise how None - Other sewage on rolling programme. they perform we don’t replace on age as older mains Options/ often perform better, typically this results in a rate of Technology around one percent, this optimises performance and affordability. WWF-UK S9.5 Options We cannot see smart metering mentioned in your plan as The implementation of a smart metering programme None - Other a mechanism to explore to drive down demand and feel is included within our Smart Networks leakage option Options/ this option could be explored. which will be delivered starting in AMP7. We are about Technology to embark on an innovative smart metering pilot programme involving 200,000 households, the results of which will guide our full option roll out from 2020 onwards. Please see our water efficiency programme in Section 9 or rWRMP19. WWF-UK S9.6 Options We can see no mention of home visits and specialist-led Our traditional household water efficiency options None - Other customer water audits in the Plan and question if this can such as water butts, audits, leaking toilets, discount Options/ be an area that can be explored to drive down domestic vouchers etc. are in our plan, but are wrapped up Technology usage. within our overall behavioural change water efficiency programme. We have developed technical option dossiers for each of our water efficiency initiatives and would be happy to share these for further discussion and clarification. We have included more detail of what is included in our water efficiency programme in Section 8 of rWRMP19.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.17 Options - PCC We recommend the company should review its demand As part of the consultation process we have reviewed Updated Agency management options and ensure cost beneficial both our short term and long term strategies for Section 8 and measures can be identified to do more to reduce demand management. As a result our rWRMP19 Section 9 of household consumption. It should work more closely includes much more ambitious demand management rWRMP19 with customers to promote options that will tackle the targets over the planning period. In the first five years long standing issues of high pcc, and consider bringing of our plan we will work to achieve 14Ml/d by 2025, forward some of its customer side demand saving 56Ml/d by 2045 and 150Ml/d by 2080. This equates to options. It should provide further information around the following PCC figures: 139l/h/d by 2025, 118l/h/d customer side demand options included in the baseline by 2045 and 90l/h/d by 2080.We have tested our forecast and compare these to the preferred final plan. levels of ambition with customer and stakeholders who have confirmed their support. Environment R2.72 Options - There is no information on how pressure management Our approach to pressure management in our None Agency Pressure has been integrated with the ALC curve. The method by rWRMP19 is focused on the stabilisation of pressures Management which pressure has been integrated into modelling is across the network. We are already at the forefront not clear. Confirm how pressure management has been of pressure management across the distribution integrated. network, with significant pressure reduction schemes implemented over the last 25 years, including 150 i2O advanced pressure management installations. To continue with this we have included the Calm Network option in our plan, as described in Appendix 5D Section 3.3.4. SELL impact has been modelled through the lowering of the policy minimum level of leakage (policy minimum) in subsequent modelling periods, lowering the cost of maintaining leakage in future years. Ash Parish P4.4 Options - A UK wide transfer system has been derided as too costly, Our plan has not been constrained to movement None Council Regional some water movement from north and west to south and of water from one area or region to another. Our Transfers east should be planned for in the longer term. plan takes account of the findings from the Water Resources in the South East (WRSE) modelling group, Ash Parish P4.6 Options - Sales of water from Wales and Northern areas to which considered water supply options feeding Council Regional Southern areas would help to balance wealth. into the region from as far afield as Wales, the west Transfers country, the midlands and the north of England.

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Appendix 2G - Options continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Ash Parish P4.5 Options - Transfers from north to south also cause pH problems, During our recent assessment pH has not emerged None Council Regional the new ground water source at Farnborough could as a potential issue or concern, but we will ensure it is Transfers compensate for this. considered fully in ongoing future assessments. The proposed Farnborough Source is a scheme that may be required in the very long term, but is no longer required in rWRMP19. Individual I8.4 Options - More water reservoirs are needed. We welcome this support of our plan and the inclusion None Reservoirs of new reservoirs in this. We acknowledge the value and benefit to providing a resilient water supply and scope for environmental improvements too. We shall continue in future plans to include new reservoirs in our feasible options set. Individual I69.5 Options The dWRMP recognises that “one of the key drivers for Different tariffs for different sizes of connection None - Water water use is new developments,” and part of that is new already exist. We are supportive of proposals set Efficiency or expanded water connections. out in Waterwise report “Water Efficiency Strategy for the UK” December 2017 and will look to explore and develop some of the proposal included in the Waterwise report to be considered for dWRMP24. Individual I69.8 Options Although the public consultation events had people As part of our water efficiency programme set out in None - Water providing advice and some add-on water saving gadgets, Section 9 of our rWRMP19 we will explore initiatives Efficiency and I appreciate that South East Water is working on to address toilet system performance and efficiency. how to ‘nudge’ customers into reducing water use, more proactive measures are needed. There has already been research of the prospective cost-benefits of water companies actually providing low water use devices, such as WCs, because there are still thousands of old ones with nine litre flushes.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Individual I69.9 Options All new developments should include rainwater As part of our ongoing engagement with local None - Water harvesting and storage because this contributes to planning authorities, we are looking to promote more Efficiency Sustainable Urban Drainage Systems (SUDS) as well as consideration of community based solutions for new reducing water use and costs. If larger storage volumes developments, involving high levels of water re-use are provided then even greater resilience and water that can reduce the demand for potable water. We savings can be made as well as further improving SUDS will seek to engage with planners and developers performance. to target new housing developments where such solutions could be implemented. Individual I84.3 Options Work with developers of large new estates to include - Water separate grey-water and potable supplies. Efficiency Individual I88.3 Options - More use of grey water. Water Re-use Individual I69.3 Options - Reuse and more demand management to be proposed as As part of the consultation process we have reviewed Updated Water Re-use solutions. both our short term and long term strategies for Section 8 and demand management. As a result we are now Section 9 of including much more ambitious targets in our plan rWRMP19 with a 15 percent leakage reduction over the first five years (rising to 50 percent by 2050) and significantly lower levels of customer water usage over the planning period,14Ml/d by 2025, 56Ml/d by 2045 and 150Ml/d by 2080. This equates to the following PCC figures: 139l/h/d by 2025, 118l/h/d by 2045 and 90l/h/d by 2080. These more ambitious levels of demand management were tested with customers and stakeholders during the preparation of our rWRMP19 and received their support. Individual I84.2 Options - Use of reused effluent for greywater supplies, e.g. We consider this to be a valid and important option None Water Re-use industry, agriculture, separate supplies to large new that we will look at more carefully ahead of our next residential blocks for cleaner potable uses. plan dWRMP24. Changes made in our rWRMP19 mean we no longer need effluent re-use schemes at the present time, but will keep option under review in the future.

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Appendix 2G - Options continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Kent Wildlife S12.29 Options - A range of alternatives for developing new and sharing We agree. As part of the consultation process we Updated Trust and Water Re-use existing resources were considered in the development have reviewed both our short term and long term Section 8 and Sussex Wildlife of the plan, we believe that further improvements in strategies for demand management. As a result we Section 9 of Trust demand management and water efficiency must also are now including much more ambitious targets in rWRMP19 be considered alternatives to any proposals that cause our plan with a 15 percent leakage reduction over significant harm to the natural environment. the first five years (rising to 50 percent by 2050) and significantly lower levels of customer water usage over the planning period, 14Ml/d by 2025, 56Ml/d by 2045 and 150Ml/d by 2080. This equates to the following PCC figures: 139l/h/d by 2025, 118l/h/d by 2045 and 90l/h/d by 2080. These more ambitious levels of demand management were tested with customers and stakeholders during the preparation of our rWRMP19 and received their support.

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Appendix 2H - Decision making

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.78 Decision The benefits of an aggregated approach, or reasoning Our approach has been clearly set and reasoned None Agency making - behind the selection of this approach, are not provided. in Section 2.4.2 of our Decision Making Approach Aggregated Unlikely to have a significant impact on the dWRMP, Appendix 8A. Approach but would increase stakeholder clarity on the approach undertaken. Clarification should be provided. Environment R2.19 Decision The company must provide detail of how the annual We have updated Table 10 and Section 1.7 to provide Updated Agency making - risk of temporary use restrictions, ordinary drought further information requested. Table 10 and Annual Risk orders and emergency drought orders changes over the Section 1.7 planning period as a result of implementation of the of rWRMP19 options in its preferred plan, or provide a statement that it will not. Environment R2.120 Decision The level of detail presented in the plan and Appendices We consider Appendix 4B to offer a sufficient None Agency making - is not always commensurate with the vulnerability level of detail to explain how the climate change Climate and the complexity of the climate change modelling methodology was applied. There is no explanation of Change methodology applied – some key elements missing. The what is ‘missing’ so it is difficult to respond further. company should provide more detail in the plan. Environment R2.64 Decision The company should provide detail of steps it will take WINEP 3 changes have been reflected in the Updated Agency making - to update the draft plan with water industry national rWRMP19. Sections 4, Environmental environment programme 3 (WINEP3) details. 6, 8 and 9 of Impact rWRMP19 Individual I60.4 Decision Solutions need to be service and consumer orientated During the consultation process we have tested our None making - rather than profit and shareholder. plan with customers and stakeholders and their input Finance has influenced the final shape of the plan, to ensure it is consumer orientated and informed. The level of profit a water company can make is determined by Ofwat, our economic regulator as part of the business plan and Price Review process. Although the WRMP19 is a key input to this process, it does not determine the outcomes of either company profit or stakeholder benefit.

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Appendix 2H - Decision making continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Ashford A8.8 Decision dWRMP should include South East Water’s infrastructure Infrastructure funding will be supported by a None Borough making - funding assumptions. combination of developer contributions and water Council Finance charges to existing and future customers. The cost and delivery of water infrastructure will be managed by South East Water. Environment R2.114 Decision The best value plan is based on the one in 200 year level We have included more evidence in Section 9.2.2 Updated Agency making - of service. The cost implication of this level of service of our SOR in the appendices in Section 2 of our Section 8.3.3 Finance within the best value plan has not been compared with rWRMP19. To demonstrate customer support and customer a one in 100 year best value plan. Customers have not willingness to pay to move to one in 200 year levels of preferences expressed a strong willingness to pay to increase levels resilience. and of service. The cost implication of meeting the reference willingness level of service within the best value plan is not given. to pay with Provide clarity on the cost implication of meeting further the reference level of service within the best value customer (preferred) plan. research conducted during public consultation to test customer acceptability of the plan.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.101 Decision There is conflicting reporting on which stage of the MCA was applied throughout the options appraisal None Agency making modelling process MCA was applied, as part of the EBSD process and the decision making process. During fine - Option modelling or in the advanced decision making method. screening, the four criteria of resilience, deliverability, Selection As per Figure 52, in this assessment it has been assumed promotability and environmental/social acceptability to occur in the latter, this however required clarification were qualitatively assessed (taking into account in the dWRMP19 report. It is not clear how the opinions stakeholder opinions) for each option and used to of stakeholders were reflected in the assessment of define the feasible options list. These assessment qualitative performance metrics. Reduced transparency decisions were then translated into quantitative MCA in the reporting of the decision making methods applied. scores for each criteria and for each option and were Clarification should be provided. inputted into the EBSD modelling as described in Section 5 of Appendix 8A. Although the MCA scores were not used for optimisation within the EBSD modelling, they were an output from the model and provided us with a view of performance metrics for each programme/portfolio that was generated. After running the model to generate programmes/ portfolios for the 108 future scenarios, the performance metrics were used (with our visualisation tool) to guide our decision in the selection of the best performing programmes/portfolios. This is described on pages 35-36 of the Sub-appendix B in Appendix 8B.

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Appendix 2H - Decision making continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.102 Decision It is not readily apparent how qualitative metrics The qualitative fine screening assessment decisions None Agency making (promotability and deliverability) were compared to were translated into quantitative MCA scores for each - Option the quantitative metric of cost to assess the best value criteria (resilience, deliverability, promotability and Selection preferred plan has an acceptable balance between environmental/social acceptability) as described in cost and risk. The stages of modelling outlined in the Section 5 of Appendix 8A. Along with the quantitative main report differ slightly from the stages outlined cost metric, these were used within our visualisation in Appendix 8A. The results of the stress testing are tool to filter and guide our decision around the not clearly reported. Potential implication that the selection of the best performing programme/ comparison has not been carried out in an appropriate portfolios across all criteria. This is described on pages manner at worst, at least the reporting is not clear. 35-36 of the Sub-appendix B in Appendix 8B. Clarity of reporting is reduced and it is not possible to assess which are the most common failure criterion. Additional information and clarification should be provided. Environment R2.103 Decision The stages of modelling outlined in the main report differ The results of the stress testing are described on None Agency making from the stages outlined in Appendix 8A. The results pages 37-41 of the Sub-appendix B in Appendix - Option of the stress testing are not clearly reported. Clarity of 8B. This sets out to test the robustness of the six Selection reporting is reduced and it is not possible to assess which shortlisted programmes/portfolios and provides are the most common failure criterion. Clarification summary outputs to describe the size and type of should be provided. failure for each step. Environment R2.104 Decision There is no visualisation on how the best value preferred The performance criteria scores for each modelled Updated Agency making plan sits relative to other plans modelled, or analysed plan are provided at the bottom of the model run Appendix - Option through sensitivity testing. The status of this information output sheets in Appendix 8C. However, to assist in 8B (Sub- Selection in the dWRMP19 is difficult to ascertain. The impact the visualisation of these metrics we have developed appendix A) of uncertainty or sensitivity of the system is not clear. an additional table and parallel axis plot in Appendix of rWRMP19 Additional information should be provided. 8B (Sub-appendix A) to better demonstrate how are preferred plan sits relative to other modelled plans.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.108 Decision SEW-RZ4-LIC-36 Coors Brewery in Alton (WRZ4) is Although this option was represented as a feasible Updated Agency making included in the “WRMP19 Feasible Option Dossiers option, it was de-selected from our modelling to Appendix - Option - License Trading (Feasible)” document (not in the prevent selection due to it high environmental impact 7D feasible Selection preferred). This will impact flows for the Wey at Alton status. To ensure clarity we will re-assess our fine options (a serious damage Band 3 waterbody) and is currently screening decisions on this option and remove from list, SEA being reviewed this AMP. This option is unlikely to be our feasible options list as appropriate for future and dossier acceptable. The feasible dossier does not fully reflect reference. accordingly the significance of the Band 3 failure of the North Wey at Alton water body. Wey Springs is referred to, but this is not a WFD water body, and the Wey Springs source was closed following previous AMP investigations. In Table 9 of the WFD assessment, the company do seem to acknowledge that the site is in an area currently under a licence investigation but do not in attach sufficient risk to this new/traded source, suggesting that it may compensate for any restrictions on their current licence under investigation. The current AMP investigation that will be completed in AMP7 is on the Lasham source. We consider the Turk Street Coors licence to be unsustainable due to the surface water impacts, therefore if this licence was varied we would look to put a short-time limit on the licence and it would be required to be investigated in future WINEPs. This should be considered a ‘feasible’ option given the sustainability issues in the impacted area, and should have been ruled out at the coarse or fine screening stage under Environmental and Social Acceptability. Screen out before the ‘feasible options’ stage, so this option does not appear in the feasible options list with a ‘pass’ allocated to it. This will prevent it becoming a possible preferred option in the next round of plans.

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Appendix 2H - Decision making continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.112 Decision Reporting of IGDT as an advanced decision making The advanced info-gap approach that we have Updated Agency making method is not clear. The performance metrics applied, adopted decision making process is set out in Section Section 8, - Option their method of calculation, their thresholds of 8.4 of our WRMP and the outputs summarised in Appendix Selection acceptability, and which failure criterion were not Appendix 8E. The key performance metrics that we 8D and 8E of reported. As part of a peer review for the company, have applied during this process are around the timing rWRMP19 Atkins made a number of recommendations how results and frequency of selection of each option across the should be tabulated and visualised (Appendix 10D), but 108 scenarios that we modelled. The results of this these do not appear to have been taken into account. process are tabulated in Figure 57 of the rWRMP19. The company should provide more information (as The recommendations outlined by Atkins as part suggested in the peer review) to enable us to assess using of the peer review led to the development of the IGDT as an advanced decision-making method. Additional outputs provided in Appendix 8C and 8E information (including metrics applied, method of Within our revised plan we have now included the calculation, thresholds of acceptability, and the failure scores for the MCA analysis within the info-gap results criterion) on the use of IGDT as an advanced decision- in Appendix 8E, this provides details of how each of making method should be provided. the 108 scenarios that we modelled performed in terms of MCA. We have also included within Appendix 8D, the MCA scores and a visualisation graphic for how each of our 13 shortlisted programmes performed in terms of MCA.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.134 Decision It is important for a company to show how it would All drought options (where appropriate) have been None Agency making manage supplies in a drought worse than its design screened and costed in the same manner as all the - Option event. In its plan, the company has set out plausible other supply side options and are included within the Selection droughts and the [supply and/or drought] options that it feasible option list. The drought options have been would take to manage them. However the company has included within the modelling as “drought options not shown how it has appraised these options against and permits” from which the model can utilise them each other and therefore not demonstrated whether to generate an optimal solution with and without these options are the best set of options, economically, these options being available to it. For our best value socially or environmentally. All of these options should be preferred plan, we have opted not to utilise “drought assessed against other feasible options ensuring proper options and permit” and as such our plan is resilient assessment of their costs and benefits relative to other to 1:200 year drought severity without the need for options. The company should assess all the supply and these options. Further resilience is provided by virtue demand options against other feasible options ensuring of our best value preferred plan solution not including proper assessment of their costs and benefits relative to for the benefits of TUBs and NEUBs either. Therefore other options. demand restrictions and existing drought plan options remain available to employ during a drought event worse that the one in 200 year design drought event we have adopted in our rWRMP19. Environment R2.96 Decision No information is provided on how the complexity of Appendix 1B sets out our problem characteristics and None Agency making factors faced by the company was assessed or quantified. assessment of complexity factors that influenced out - Option Potential implications are not likely to affect the approach to plan. Selection characterisation as this is a largely qualitative process, however stakeholder confidence in the approach would be improved with additional information. Additional information should be provided. Environment R2.97 Decision There is not enough evidence provided on the data input The input data that feeds the EBSD+ model is a None Agency making to the EBSD+ model. As assessment on whether the data single workbook that comprises multiple areas of - Option is appropriate for purpose is not possible. Additional data including options costs, yields, supply and Selection information should be provided. demand forecasts and the components that derive the uncertainty factors. Due to its complexity, this workbook has not been included in our published documents, however, this can be provided and explained on request.

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Appendix 2H - Decision making continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.98 Decision It is not readily apparent what performance metrics The five performance criteria used within the decision None Agency making were used, how they were calculated, and what the making process are cost, resilience, deliverability, - Option acceptability criteria were. Reduced transparency in promotability and environmental/social acceptability. Selection the reporting of the decision making methods applied. Quantitative scores for each performance criteria and Additional information should be provided. for each option were generated and used within EBSD modelling as described in Section 5 of Appendix 8A. Although the metrics were not used for optimisation within the EBSD modelling, they were an output from the model and provided us with a view of averaged scores for each of the five performance criteria across all programme/portfolio that were generated. Ofwat R4.1 Decision Considering the challenge faced by South East Water, We have revised our preferred plan to include far Updated making the draft plan has not demonstrated that there is an greater levels of demand management ambition Section 8 and - Option appropriate balance between supply and demand type which has had the effect of a more balanced twin Section 9 of Selection options, consistent with a twin track approach. There track plan. Further detail is included in Section 9 of rWRMP19 is a focus upon demand reduction in the initial five year our plan. period but in the medium to long term the plan is reliant on supply option expenditure. South East Water should clarify why this blend of options represents the best outcome for customers and how the decision making process led to this outcome. Ofwat R4.29 Decision It is stated that a best value plan has been developed We have provided more explanation in Section 8 of Updated text making alongside a least cost plan for its base scenario. However, our rWRMP19 concerning the EBSD/Info Gap results in Section 8 - Option greater clarity is required for the drivers behind the best screening criteria, customer preferences and WTP of rWRMP19 Selection value plan and how they influence the options selection. and the SEA process helped to derive a best value plan Individual I103.1 Decision It makes sense to have sources more diversified rather Your comments are noted. Improving resilience of None making than concentrated in one place. water supply is a key objective of our rWRMP19. - Other Options/ Technology

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/SEA/ HRA Environment R2.79 Decision The six portfolios are not readily apparent. Separate The six portfolios that were used for stress testing None Agency making - reporting in Appendix 8E, or explicit distinction from have now been identified within the full set of Portfolios other portfolios would increase transparency. Reduced portfolios in Appendix 8E. An additional row to transparency in the reporting of the portfolios selected. confirm (Yes/No) if a portfolio was used in the stress Clarification should be provided. testing has been added, they are also shown in bold font with an outer border to distinguish them from others. Individual I27.2 Decision Good mix of solutions will give resilience. We welcome this support for our plan. None making - Positive Environment R2.113 Decision It is unclear how individual options resilience is scored The resilience criteria is used to assess an individual None Agency making - within the EBSD modelling (both for deployable output options level of vulnerability to the following: outages, Resilience and non- deployable output modelled options). Clarity financial and regulatory uncertainty and climate should be provided on how non- deployable output and change/drought. This is explained in more detail in deployable output modelled option resilience has been Section 4.2 of Appendix 7A. Each of these sub-criteria taken into account within EBSD modelling. are scored and averaged to provide an option level resilience score for each options. This is explained in more detail in Section 5 of Appendix 8A. Although this metrics was not used for optimisation within the EBSD modelling, it was an output from the model and provided us with a view of averaged score for the resilience criteria across all programme/ portfolio that were generated.

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Appendix 2I - Our preferred plan

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Kent Wildlife S12.39 Our preferred We are pleased to see catchment management options Thank-you for your response to our dWRMP19. Your None Trust and plan - feature within the preferred plan, the benefits of this comments are noted. Sussex Wildlife Catchment approach to the long-term sustainability of water Trust Management resources is well-recognised. Kent Wildlife S12.41 Our preferred The proposed catchment management programme We have a very ambitious wider catchment None Trust and plan - within this WRMP is targeted to Woodgarston and management programme for 2020 to 2025. Details Sussex Wildlife Catchment Pembury, and we would seek clarification as to whether related to this are to be found in our business Trust Management additional schemes would also be investigated across the plan Appendix 10 and associated performance wider supply area within the plan period. We would like commitments. to see a commitment to upscaling catchment initiatives. We would also like to see the two proposed schemes widened out to consider water quantity in addition to water quality. South East S7.3 Our preferred Sustainable and Resilient Water Supply - welcome the We can confirm that we have a very ambitious None Rivers Trust plan - catchment management activities mentioned in the plan wider catchment management programme for Catchment and encourage South East Water to be more ambitious in 2020 to 2025. Details related to this are to be found Management this area. in our business plan Appendix 10 and associated performance commitments. WWF-UK S9.16 Our preferred We are pleased that South East Water currently Your comments are noted. We strongly believe in None plan - undertakes catchment management and that 2 schemes the merits of promoting sustainable and resilient Catchment are proposed from 2025 to increase deployable output. water supplies at source and fully intend to continue Management to promote and deliver catchment management to improve the quality and reliability of the water sources we rely upon to fulfil our customer’s demand for water. Please refer to our WINEP and Business plan for more information about this. We recognise our role in addressing impacts on raw water quality. As this is a proactive programme, it sits within our future business plan commitments and WINEP, the only elements that relate to an impact in current DO are reflected in the WRMP.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA WWF-UK S9.17 Our preferred The links between current and future management Our future catchment management programme None plan - are unclear and we would expect to see an expansion is contained within our business plan, Appendix 10 Catchment of catchment management work, which is not evident. Environmental Resilience provides the detail behind Management We would also like South East Water to ensure they are an extensive programme of catchment management taking a holistic approach to catchment management, work. rather than focussing on just one chemical or issue. Environment R2.82 Our preferred The plan does not consider catchment options to We have included text in Section 1.1.5. to make clear Updated Agency plan - reduce treatment process while still complying with the that our plan complies fully with drinking water 1.1.5 Catchment requirements of any drinking water regulations. The plan regulations. Management should explicitly state that options will still comply with drinking water regulations. Individual I1.2 Our preferred Disappointment that desalination projects are not due in Desalination no longer features in our preferred plan, None plan - the plan for a number of years. but remains a feasible option we could consider if Desalination required in future. There is uncertainty regarding risks to marine ecology or aquatic ecology associated with Individual I47.2 Our preferred Bring Desalination options forward. the brine waste generated from desalination options. plan - Desalination options also require very high levels of Desalination energy to treat the water and therefore have a very Individual I47.3 Our preferred More Desalination locations. high carbon impact compared to more conventional plan - surface water or groundwater abstraction or transfer Desalination sources. Individual I83.2 Our preferred Need desalination because of the number of new housing plan - developments. Desalination Kent Wildlife S12.36 Our preferred Desalination - SEW would need to demonstrate that Trust and plan - there were no less damaging alternatives to this Sussex Wildlife Desalination development, including better management of existing Trust water resources. Individual I15.3 Our preferred Desalination is not a serious option due to the energy Thank-you for your representation to our dWRMP19. None plan - required and environmental impact. Your comments are noted. Desalination

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Appendix 2I - Our preferred plan continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Ashford A8.7 Our preferred Risks should be fully assessed before reliance is placed on Thank-you for your representation to our dWRMP19, Updated in Borough plan - the scheme. we welcome this support for our plan. Section 8 and Council Desalination We fully agree and this assessment will form part of Section 9 our future work. Kent Wildlife S12.34 Our preferred We welcome the recognition that long lead times are Thank-you for your representation to our dWRMP19, None Trust and plan - needed for the development of many of the new future we welcome this support for our plan. Sussex Wildlife Desalination new resource options to ensure flexibility to bring Trust forward alternative options should any of these prove unfeasible. Ash Parish P4.8 Our preferred Desalination is an expensive option, when as a country we This option is no longer part of the rWRMP19 None Council plan - have excess water supply. preferred plan. However your comments are noted for Desalination future reference. Kent Wildlife S12.31 Our preferred The development of any desalination schemes must Trust and plan - be accompanied by stringent assessment of the Sussex Wildlife Desalination environmental and energy impacts. Trust Ash Parish P4.9 Our preferred Desalination is a failure to plan and distribute water Council plan - properly. Desalination

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.62 Our preferred Reculver Desalination: The spread and impact of This option is no longer part of the rWRMP19 None Agency plan - hypersaline brine discharge to the marine environment, preferred plan. However your comments are noted for Desalination particularly benthic sub-tidal and intertidal communities future reference. - Reculver needs to be investigated in detail. This should include modelling of the dispersal (or accumulation) of such a plume of high density, hypersaline water. Alternative solutions. Environment R2.63 Our preferred Reculver Desalination: Clarification is required on Agency plan - where the abstraction will be sited, and whether it Desalination is from the coastal deposits or the deeper confined - Reculver chalk. Before licensing, more thorough testing with associated monitoring is required. Extensive testing was not undertaken and whist limited data relating to the boreholes’ performance established yields, sustainable yields were never established. Testing was limited, and was not sufficient to establish the wider implications associated with abstracting at this source, and especially given the salinity concerns/ uncertainties. Canterbury A1.3 Our preferred Proposals for significant new infrastructure at Reculver, City Council plan - and any development within the District to facilitate the Desalination Weatherlees scheme, would require detailed assessment - Reculver / and adequate justification. Water Re-use - Weatherlees Environment R2.55 Our preferred The company should amend its comments on pages 22 The text on these pages has now been updated Updated text Agency plan - and 136 so that customers and stakeholders are not to reflect the timing and selection of these more previously Environmental misled over when ‘less environmentally friendly’ schemes challenging schemes within our rWRMP19. referred Impact are planned for. The company should also ensure there is to in our sufficient time to plan and prepare for these options to rWRMP19 be acceptable. The company should report progress on this action in its Annual Reviews.

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Appendix 2I - Our preferred plan continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.59 Our preferred The company should explain its role in mitigating for This option is no longer part of our rWRMP19 None Agency plan - increase abstraction in the Lower Thames, and how preferred plan. Environmental agreements with Thames Water and Affinity will work, Impact especially in low flows/dry weather. Individual I100.3 Our preferred It shouldn’t be using money from customers. Our shareholders have invested hundreds of millions None plan - Finance Shareholders should pay. in the business to support the investment needed to sustain our assets that deliver performance, it is reasonable as per all other investment types that they earn a suitable return on this original investment. This return is regulated by an independent regulator Ofwat who ensures returns are in line with the market and reflect the low risk inherent in a monopoly service provider. Environment R2.130 Our preferred Information is provided on the methodology used for All option costs within our plan (other than the water None Agency plan - Finance assessment of financial costs for each option. However, efficiency options) have been generated using our there is no commentary to explain the variation in “unit cost database” costing tool. This allows us financial costs per option type. Lack of transparency in to build up the cost for each scheme individually generation of financial cost values. Add commentary on (regardless of option type) using benchmarked costs financial cost values to highlight significance to each for each scope item. option type. Although there are similarities in terms of the general scope of scheme within a particular option type, each scheme is different in terms of its size, treatment requirements, length of required water mains etc. For this reason we have not looked to assess the variation in costs across option types, but to make sure that there is a sufficient mix of deliverable schemes available in the feasible option list and then allow the decision making process to ensure that we are generating a “best value” solution that considers least cost and appropriate mix of schemes.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA East Malling P1.1 Our preferred Clarification on the whether Ditton Sewerage works will We can confirm that there will be no impact on the None and Larkfield plan - be affected by the plans. existing Ditton Sewerage works linked to the delivery Parish Council Groundwater of the new Aylesford Newsprint scheme. - Aylesford Newsprint Site East Malling P1.2 Our preferred Interested in having a better understanding of the The Aylesford Newsprint scheme involves the None and Larkfield plan - Aylesford Newsprint site plans. treatment of the existing licenced boreholes in Parish Council Groundwater conjunction with abstraction from the Ditton stream - Aylesford to provide an output of 18.2Ml/d to distribution. Newsprint Simple conventional processes will be used for Site the treatment of the boreholes water alongside aeration, granular activated carbon filtration and UV disinfection for the treatment of the Ditton stream water. Outline plans are available for the scheme and can be provided alongside this response. East Malling P1.3 Our preferred Keen to keep the Ditton Stream running through the As part of the Water Framework Directive we will be None and Larkfield plan - Aylesford Newsprint site. required to maintain the current status of the stream Parish Council Groundwater and to ensure that there is no deterioration. The - Aylesford stream currently has a high status for invertebrates. Newsprint Further study is required to inform appropriate Site mitigation measures, which may include limits on abstraction volumes (particularly during summer months), to reduce any effects associated with abstraction. East Malling P1.4 Our preferred Old mill pond at Millhall Mill site should be kept for We note your comments and will ensure that this will None and Larkfield plan - historic reasons. be followed up as part of the design process and will Parish Council Groundwater be considered as part of our environmental studies - Aylesford and proposals. Newsprint Site

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA East Malling P1.5 Our preferred Information that the Aylesford Newsprint site is mainly in Thank-you for your representation to our dWRMP19, None and Larkfield plan - Ditton and the main access is out to New Hythe Lane and we can confirm that you comment has been noted. Parish Council Groundwater Leybourne Way in Larkfield. Only a small part of the site is - Aylesford in Aylesford Parish. Newsprint Site Individual I5.1 Our preferred Does not support the abstraction from Greywell Fen In our WRMP14 we were clear that the section of None plan - continuing until 2025 rather than 2020 which was in the Greywell Fenn source was dependent upon the Groundwater - originally proposed in WRMP14. development of an alternative water source and Greywell Fen associated pipe line route to transport the water to the area currently supplied by Greywell. Whilst the new source has been developed to the agreed schedule, the new pipe line route has proved more problematic. This is covered in the dWRMP19 1.4.6 under the section titled, ‘Groundwater Abstraction at Greywell’. We continue to monitor the fenn at Greywell and are committed to closing Greywell as soon as is feasibly possible while ensuring a reliable source of water for our customers and that the alternative pipeline route is environmentally sensitive. Basingstoke S4.1 Our preferred Disappointed to learn from the draft WRMP19 that the Comment noted, full explanation is provided in None Canal Society plan - pumping of Greywell Hill water will now continue until Section 1.4 of rWRMP19. (BCS) Groundwater - 2025, due to the impact on Basingstoke Canal. Greywell Fen Ofwat R4.27 Our preferred The company has included six interconnections between The rWRMP19 already includes this level of detail None plan - Inter- its zones in the preferred plan. However, the draft plan in the form of detailed option dossiers. The dossier Zonal only includes limited information on the schemes due for were made available for inspection at our offices Transfers delivery in the short term. The final plan should clarify in Farnborough and Snodland during the 12 week how issues such as route planning and environmental consultation period. Copies of the dossiers were concerns are being addressed. provided to the Environment Agency and Natural England who have provided feedback including with regard to route planning and environmental concerns. Copies of dossier can be provided on request. southeastwater.co.uk 97

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I38.2 Our preferred Stop leaks. Our revised plan includes considerable reductions None plan - Leakage in leakage. We currently invest over £17M each year controlling leakage on over 14000km of water mains Individual I64.1 Our preferred Need to be doing something about all the local leaks. None and plan to reduce leakage further in future years. By plan - Leakage 2025 we will reduce leakage by 15 per cent and are committed to halve leakage by 2050. We will continue to make finding and fixing leaks a priority. Individual I88.2 Our preferred More needed to prevent waste. Thank-you for your representation to our dWRMP19. Updated in plan - Leakage As part of the consultation process we have reviewed Section 8 and both our short term and long term strategies for Section 9 Individual I89.2 Our preferred Leaks need to remain a priority. demand management. As a result we are now plan - Leakage including much more ambitious targets in our plan Defra R1.2 Our preferred Plan suggests only a 4.3 per cent reduction in leakage, with a 15 per cent leakage reduction over the first five plan - Leakage not meeting the 15 per cent reduction challenge by years rising to 50 per cent by 2050. Ofwat. Strategy on leakage should be explored further. Environment R2.12 Our preferred Detail underpinning the assumption that there will be no Agency plan - Leakage impact of reassessing leakage on the preferred options should be provided, and a commitment made to review fully ahead of the final plan. Kent County A4.9 Our preferred The description of planned leakage reductions in Section We can clarify that all percentages referenced in this Updated in Council plan - Leakage 9.3.1 is difficult to follow and the inclusion of percentage section are calculated based on savings beyond our Section 8 and reductions is confusing as each refers to a different current baseline level of leakage in 2016/17. Section 9 baseline and achievement date. Also, as part of the consultation process we have reviewed both our short term and long term strategies for demand management. As a result we are now including much more ambitious targets in our plan with a 15 per cent leakage reduction over the first five years rising to 50 per cent by 2050.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Edenbridge P5.5 Our preferred Can only offer a token agreement to the proposals Our rWRMP19 has been updated to incorporate the None Town Council plan - contained in the consultative document which, in my recommendations in the National Infrastructure Negative opinion, is fundamentally flawed based upon the views Commission’s reports. expressed above. Individual I116.5 Our preferred I see no reason for the focus on reservoir building We are aware of the North London Artificial Recharge None plan - Other or transferring water to rivers when the ideas from Scheme (NLARS). In terms of the re-charging of Technologies NLARS provides a more economical alternative. Urgent aquifers, we have looked at the potential for this consideration should also be given to the conversion across our supply area and identified a couple of of other effluent treatment facilities to re-charge the locations in our western region where this might be Kent chalk aquifers. Inevitably water in a reservoir will suitable but not so in East Kent. evaporate and will have a significant environmental impact through the displacement of indigenous creatures and plants with those that prefer a wetter environment. Canterbury A1.4 Our preferred Little detailed information available in respect of these We recently met with Canterbury City Council, and None City Council plan - future schemes and we would welcome the opportunity agreed to meet more regularly and formalise an Overview to engage further to better understand the selection engagement programme with them. This programme process and detail of the preferred proposals. will run between 2019 and 2021 and support dWRMP24. Kent County A4.3 Our preferred We find the plan to be heavily biased towards supply We have included more evidence in Section 9.2.2 Updates to Council plan - side options and rather unambitious in terms of the of our SOR in the appendices in Section 2 of our Section 8 and Overview contribution from demand management options. rWRMP19. To demonstrate customer support and Section 9 willingness to pay to move to one in 200 year levels of resilience.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Kent County A4.4 Our preferred The cost of the plan of £1billion appears very high. We have updated the preferred plan in our rWRMP19, None Council plan - and this figure is no longer valid. Overview Edenbridge P5.3 Our preferred The need for more reservoirs, for reduced demand Section 1.4 of our rWRMP19 describes what we are None Town Council plan - through domestic and business metering, for doing now to maintain the balance between supply Overview desalination, re-cycling of waste water, etc., is identified and demand. Section 9 of the rWRMP19 demonstrates in the consultative document, but only in terms of we will maintain a surplus of water over the whole 60 ‘years ahead’, not immediately and with urgency and year period. commitment. Kent County A4.7 Our preferred Query around figure 64 and low level of ambition in this Thank-you for your representation to our dWRMP19. Updated in Council plan - PCC dWRMP for tackling one of the highest rates of pcc in the As part of the consultation process we have reviewed Section 8 and industry. both our short term and long term strategies for Section 9 demand management. As a result we are now including much more ambitious pcc targets in our plan to achieve significantly lower levels of customer water usage over the planning period. In the first five years of our plan we will work to achieve 14Ml/d by 2025, 56Ml/d by 2045 and 150Ml/d by 2080. This equates to the following PCC figures: 139l/h/d by 2025, 118l/h/d by 2045 and 90l/h/d by 2080. Wealden A3.2 Our preferred Good information developed on locally specific issues. We welcome this support for our plan. None District Council plan - Positive Individual I92.2 Our preferred Pleased that consideration is being given to sharing Collaborative working through Water Resources South None plan - Regional resources with neighbouring areas and their water East group (WRSE) and the Water UK Water Resources Transfers companies. Long Term Planning Framework continues to inform and support our long-term planning and management of water resources, including consideration of sharing and transfer of water between companies and helping us to achieve the most sustainable and cost efficient water resources strategy.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Hampshire A6.3 Our preferred Transfers such as proposed Portsmouth Water’s Clanfield Thank-you for your representation to our dWRMP19, None County Council plan - Regional Reservoir scheme, are encouraged and supported. we welcome this support for our plan. Transfers Kent Wildlife S12.38 Our preferred Given the potential energy and environmental costs This is a sensible proposal and we will consider, when None Trust and plan - Regional associated with pumping water, we would want to appropriate, that our rWRMP19 makes the case. Sussex Wildlife Transfers see real cost benefit arguments put forward for why Trust it is better to pump through pipelines than conserve resources at source. Affinity Water W1.1 Our preferred Confirm our understanding of the alignment based on We are working closely with neighbouring water Updated plan - Regional the draft plan submissions. companies both within and outside of the WRSE group Section 9 Transfers to ensure that our final plans are aligned. for shared company schemes and transfers Southern W2.1 Our preferred Confirmation of existing shared resources, future shared We are working closely with neighbouring water None Water plan - Regional resources and plans for new contracts. companies both within and outside of the WRSE group Transfers to ensure that our final plans are aligned. Ash Parish P4.3 Our preferred Limited plan which only considers movement from one Our plan has not been constrained to movement None Council plan - Regional southern area to another. of water from one southern area to another. Our Transfers plan takes account of the findings from the Water Resources in the South East (WRSE) modelling group, which considered water supply options feeding into the region from as far afield as Wales, the west country, the midlands and the north of England.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.1 Our preferred Thames Water transfer: We recommend the This option is no longer part of our rWRMP19 None Agency plan - Regional company provides further information on bulk supply preferred plan. However your comments are noted for Transfers arrangements with neighbouring companies. This will future reference. provide assurance to customers and regulators that transfers are reliable and if any changes to transfers will affect security of supplies and/or the environment. In particular, we recommend the company include further information on these bulk supply arrangements, ensures its WRMP is consistent with the plans of all relevant neighbouring companies on these bulk supply arrangements, including how companies will operate during different drought events.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.111 Our preferred Every company receiving a bulk supply should ensure The Thames Water bulk supplies that were proposed None Agency plan - Regional the donor company has the appropriate assessments in dWRMP19 are no longer part of rWRMP19 but we Transfers in place, i.e. they should be accounted for in the donor agree to adopting this approach to our bulk supplies in company’s SEA. Details of the above transfer from principal. Thames Water is absent from Thames Water’s plan/ SEA/HRA (although the transfer volume is included in its Tables). It is possible the abstraction in Thames Water’s Kennet WRZ will need to be increased depending on how its sources are operated to support this transfer. This option may present a deterioration risk and possible risk to designated sites in the River Kennet. As such, this transfer option needs more assessment and inclusion in Thames Water’s plan/SEA, and the company should work with Thames Water to make sure this is in place. There is little detail in the company’s plan on how this transfer will be facilitated and what the environmental impacts might be, and how they may be mitigated. In Table 6 of the company’s WFD Assessment (SEA Appendices), the company state the source is Arborfield and suggest the sustainability and impacts of the source are the responsibility of Thames Water. We recommend the company work with Thames Water to ensure that, as the donor company, it has relevant environmental impact assessments in place for this bulk supply arrangement. The company should also explicitly outline its role in mitigating impacts from this transfer.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.2 Our preferred Portsmouth Water transfer: We recommend the This option is no longer part of our rWRMP19 None Agency plan - Regional company provides further information on bulk supply preferred plan. Transfers arrangements with neighbouring companies. In particular, we recommend the company engage with the donor company to resolve this issues and amend the plan accordingly, ensuring that both company plans align in terms of volumes and implementation dates. This will provide assurance to customers and regulators that transfers are reliable and if any changes to transfers will affect security of supplies and/or the environment, including how companies will operate during different drought events. Environment R2.6 Our preferred Southern Water transfer: We recommend the Since the submission of our dWRMP19 we have Updates to Agency plan - Regional company provides further information on bulk supply engaged further with Southern Water to confirm the Section 9 Transfers arrangements with neighbouring companies. In dates and yields around the need for this export. Our of plan to particular, we recommend the company engage with rWRMP19 includes a consistent approach for this update date the donor company to resolve this issues and amend transfer with SWS. and further the plan accordingly, ensuring that both company plans detail for this align in terms of volumes and implementation dates. transfer. This will provide assurance to customers and regulators that transfers are reliable and if any changes to transfers will affect security of supplies and/or the environment, including how companies will operate during different drought events.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.7 Our preferred SES Water transfer: We recommend the company Since the submission of our draft plan we have Updates to Agency plan - Regional provides further information on bulk supply engaged further with SES Water to confirm the Section 9 Transfers arrangements with neighbouring companies. In dates and yields around the need for this import. of plan to particular, we recommend the company engage with Our rWRMP19 now includes a consistent approach update date the donor company to resolve this issues and amend for this transfer. and further the plan accordingly, ensuring that both company plans detail for this align in terms of volumes and implementation dates. transfer. This will provide assurance to customers and regulators that transfers are reliable and if any changes to transfers will affect security of supplies and/or the environment, including how companies will operate during different drought events. Ofwat R4.22 Our preferred The company should consider if larger trades, potentially Due to the inclusion of more ambitious levels of None plan - Regional earlier in the planning period, could resolve the supply- demand management in our rWRMP19 preferred plan. Transfers demand challenge faced reducing the need to develop The need for new supply schemes, including transfers multiple new supply options. The outcome of these has reduced, and the scope for cost savings using considerations should be explained in the final plan. earlier transfers to offset cost has diminished. Earlier trading options could have the potential to reduce costs, reduce environmental impact and improve resilience. Ofwat R4.5 Our preferred New imports are only selected as options beyond 2036. plan - Regional South East Water should consider if larger trades, Transfers potentially earlier in the planning period, could resolve the supply-demand challenge faced without requiring the development of multiple new supply options. Ofwat R4.23 Our preferred In finalising its plan the company should consult further We have completed a further round of Updated plan - Regional with the other water companies involved in the proposed correspondence with other water companies, to Appendix 9A Transfers trades in order to ensure consistency regarding volume ensure our WRMP19 numbers are consistent. of rWRMP19. and dates of trades. Individual I106.1 Our preferred Request for map of Arlington Reservoir We have promised to provide a map on our website None plan - once it has been agreed with the landowner. Reservoir - Arlington southeastwater.co.uk 105

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I107.1 Our preferred Concerned about the proposal to extract additional The source of water for the new Arlington Reservoir is None plan - water from the River Cuckmere by way of a second from the river Ouse, so there will be no detriment to Reservoir - reservoir. In summer the river is often little more the river Cuckmere. Arlington than a stream down river from Arlington in current circumstances. Individual I108.1 Our preferred Concerns with car park location on the current plan, The design of the reservoir is not fixed and is None plan - pylons, mobile phone mast, loss of privacy and views. conceptual at this stage. We acknowledge that there Reservoir - is existing infrastructure (pylons and phone masts) Arlington that will need to be diverted to accommodate a reservoir. We will undertake Landscape and Visual assessments to ensure the scheme is developed with least impact to the landscape and current views. Car parking location has been raised as a local concern and will be addressed as we progress with the scheme design. Individual I108.2 Our preferred Why wasn’t the area Adjacent to the A27 considered. The selected location for the new reservoir is None plan - based upon geological and topographical factors Reservoir - and proximity to enable expansion of the existing Arlington treatment works and water mains to deliver the additional flow into supply. Individual I109.2 Our preferred The existing reservoir is a well managed asset. We thank you for your positive comment on the None plan - successful management of the existing Arlington Reservoir - reservoir. The new reservoir would be linked and Arlington managed to the same high standard. Individual I17.2 Our preferred Would appreciate a copy of the site plans. We have promised to provide a map on our website None plan - once it has been agreed with the landowner. Reservoir - Arlington

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I18.4 Our preferred It would be good to make Arlington as accessible as The concept design for the reservoir proposes to None plan - possible to the public. extend the existing footpaths and recreational access Reservoir - around the existing reservoir to include the new Arlington development and link in other footpaths crossing the site. SEW will take into account type of access and usage during their development of the scheme. Individual I21.2 Our preferred Agrees with a second reservoir. We welcome this support for our proposed reservoir. None plan - Reservoir - Arlington Individual I23.1 Our preferred Please send map. We have sent a copy of the preliminary, conceptual None plan - map to the individual who made the representation Reservoir - and we have promised to provide a map on our Arlington website once it has been agreed with the landowner. Individual I24.1 Our preferred Contact Re: Environmental features on site. Further studies are planned for the new Arlington None plan - reservoir option between 2019 and 2021. These Reservoir - studies will provide the further information that has Arlington been requested and we will invite the individual who made the representation to meet with us when those studies are implemented and to share the findings and final reporting. Individual I31.2 Our preferred Move set down area, add field boundaries to map, view Further studies are planned for the new Arlington None plan - into reservoir. reservoir option between 2019 and 2021. These Reservoir - studies will provide the further information that has Arlington been requested.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I45.1 Our preferred For the extension to Arlington Reservoir, area needs more The concept design for the reservoir proposes to None plan - footpaths, and extension of the bridleway which the extend the existing footpaths and recreational access Reservoir - reservoir will run over. Also would it be possible to use the around the existing reservoir to include the new Arlington water for sailing, windsurfing like on Ardingly Reservoir. development and link in other footpaths crossing the site. SEW will take into account type of access and usage during their development of the scheme. SEW will consider other recreational uses of the new reservoir during development of the scheme. Kent Wildlife S12.20 Our preferred In relation to Arlington, we recommend that SEW consult We have made contact with Highways England and Updated text Trust and plan - thoroughly with Highways England (HE) so that their will work together to ensure it is possible for both in Section 9 Sussex Wildlife Reservoir - current study into an offline bypass between Lewes proposals are able to be delivered. of rWRMP19. Trust Arlington and Polegate can incorporate the details of a potential extension. The options being considered by HE include routes that run both south and north of the current reservoir which may conflict with SEW plans.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I115.2 Our preferred I was also concerned at the impact which the proposed We acknowledge your comments on the access from None plan - reservoir would have on the village of Tyler Hill. The plan Tyler Hill to the visitor centre. We envisage the access Reservoir - shows an access road to the Mayton promontory starting road being a locked private road with sufficient space Broad Oak from half-way down Wood Hill, in front of Hillside Cottage for vehicles to stop, set back from the main road. The and continuing along the present track until it reaches visitor centre would be for groups by appointment the Sarre Penn and then sharply turning north and and they would be limited keeping traffic on the running up the field to Mayton. This road would be very private road very low. We shall continue to work with unsatisfactory for Tyler Hill. In the first place, the access the public to develop a scheme that provides the right would be on a bend in a narrow road with poor vision for balance of access and amenity whilst maintaining the motorists and close to a turning a few yards up which amenity value of the surrounding landscape. leads to the village hall. Traffic passing through the village is heavy at rush hour times and an access road could only add to further congestion. Secondly, to enlarge the track which currently runs at the exit of the woods would be a gross intrusion into a calm and peaceful area and would put walkers and dog-walkers at risk of colliding with traffic as they emerged from the woods. Thirdly, the new road which would have to be constructed from the river to Mayton would involve considerable construction work with its concomitant noise and disturbance. This area is rated by the CPRE as one of the few remaining tranquil areas in the heavily developed South-East and in the interests of preserving the environment, which the Water Boards claim to be wedded to, it should be left undisturbed. All traffic associated with the reservoir should be routed round Sturry. Finally, I would view such a road as the thin end of the wedge. Once it has been constructed, it would be impossible to keep the general public from using it, despite promises of the road being ‘gated’ and limited to ‘school nature parties’.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I115.3 Our preferred I am concerned at the proposal to alter the flow of the Our concept design at this stage includes the proposal None plan - River Sarre Penn and at the impact on downstream to divert the Sarre Penn around the reservoir to Reservoir - flow which this might have. No-one has yet been able maintain a connectivity in the river for fish passage to Broad Oak satisfactorily to explain why such a measure, which goes comply with the Water Framework Directive (WFD). against EU directives, should be necessary. We shall continue to engage with the regulator on the For these reasons I am very concerned at the proposal for requirements of WFD as we develop the scheme and a reservoir at Broad Oak and trust the Water Board will provide what is right for the catchment. consider alternatives for meeting the need for ‘resilience’. SEW have considered other sources of supply in our option modelling and have selected Broad Oak reservoir as being key to providing the supply required to meet projected demand, taking account of leakage and demand reductions. This option provides resilience to our supply as the area is currently mainly supplied by groundwater sources. Individual I4.1 Our preferred Concerns regarding dry winter filling of Broadoak SEW will apply to the Environment Agency for an None plan - Reservoir and the impact on the Stour stream. abstraction licence from the river Stour. We will adhere Reservoir - to licence conditions with specific rates of abstraction Broad Oak and clear stipulations as to when we cannot abstract. Our application would take due consideration of abstraction rates and river levels to ensure no detriment to the river in a dry winter or any other low flow condition. SEW are progressing with more detailed assessments of the abstraction regime required. This will be undertaken during 2018 and 2019. Individual I49.1 Our preferred Broadoak Reservoir is critical infrastructure and will be We welcome this support for our proposed reservoir None plan - needed to support the anticipated growth in population and the need for the additional water supply this will Reservoir - in the area. provide to the area. This scheme is a part of the overall Broad Oak strategy to provide a sufficient and resilient supply taking into account population growth. Individual I50.1 Our preferred On all plans on display, the boundary of the land you own We will ask our Land Agents to verify the extent and None plan - to the north is incorrect as it includes greenacres and boundaries of the land ownership and liaise further Reservoir - Blaxland farm. with the respondent. Broad Oak

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I50.2 Our preferred The proposed road for access to the reservoir and The concept design envisages access for visitors and None plan - Barnet’s lane is very narrow and certainly not wide SEW operational staff to be from Herne Bay road, Reservoir - enough for cars to pass each other. where a suitable entrance with access and egress Broad Oak slipways is planned. Access via Barnets Lane would only be for residents on the lane or SEW operational staff for occasional access to the reservoir crest for maintenance activities. Individual I50.3 Our preferred Staggered to hear that no planning consent has been We have been engaging with all relevant stakeholders None plan - applied for after 30+ years of first hearing of the plan during the recent concept design development of the Reservoir - and would have thought that at least ‘outline permission’ reservoir to ensure our plans are likely to be granted Broad Oak would have been applied for before now. outline Planning Permission. Planning Permission is intended to be sought following the outline design and environmental impact assessments in before 2025. Individual I51.2 Our preferred Would like to see the possibility of recreational use. Our concept design for the reservoir currently None plan - includes recreational provision in the form of car Reservoir - parking, footpaths and bridleways linking into the Broad Oak existing network of paths and bridleways. Other recreational activities can be considered and will be during the further development of the scheme taking into account public preferences and what can be delivered without adversely impacting the local residents. Individual I52.1 Our preferred The water storage will prove insufficient for the area Our decision making modelling has used a significant None plan - needs in 50 to 60 years. number of options to select schemes to meet water Reservoir - usage projected for 60 years. This reservoir forms Broad Oak an important part of our plans for this region. Our rWRMP19 sets out how we intend to meet water needs in the area for the full 60 year planning period.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I52.2 Our preferred The dam should be sufficient in size to allow a greater Our current concept design is constrained by the None plan - area to be flooded. need to avoid the SSSI and ancient woodland. We Reservoir - have raised and fed back comments we have received Broad Oak to Natural England. Before our dWRMP24 and/or an application for outline planning permission, we will explore whether there are options to have a deeper reservoir and extend the leg of reservoir toward Tyler Hill and whether this would increase the potential supply yield of the scheme. Individual I52.3 Our preferred Not enough thought has been given for the public to Our concept design for the reservoir currently None plan - benefit from the scheme. includes recreational provision in the form of car Reservoir - parking, footpaths and bridleways linking into the Broad Oak existing network of paths and bridleways. Other recreational activities can be considered, including fishing and sailing, and will be considered during the further development of the scheme taking into account public preferences and what can be delivered without adversely impacting the local residents. Individual I52.4 Our preferred Water sports and swimming with access areas should be Our concept design for the reservoir currently None plan - provided. includes recreational provision in the form of car Reservoir - parking, footpaths and bridleways linking into the Broad Oak existing network of paths and bridleways. Other recreational activities will be considered e.g. fishing, sailing etc. and will be considered during the further development of the scheme taking into account public preferences and what can be delivered without adversely impacting the local residents.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I52.5 Our preferred Public footpaths should be provided around the edge of We agree that full public footpaths should be None plan - the lake. provided. The concept design for the reservoir Reservoir - includes for accessible routes and circular walking Broad Oak routes around the full perimeter of the reservoir. These would be linked up to the public parking area and to existing footpaths that currently cross the land to be flooded to ensure linked routes are provided. Consideration will be given to facilitate a varied and enjoyable mixture of routes through woodland, open spaces and areas to enable the views to be taken in of the surrounding landscape and across the reservoir. Individual I53.1 Our preferred The proposal outlined makes sense but as always the We acknowledge that the figures for the storage None plan - figures are made to suit the setting. volume do indeed take account of the setting and Reservoir - the constraints and balance between available source Broad Oak supply, volume of storage and fitting the flooded area to the landscape without flooding sensitive and environmentally valuable areas. Individual I53.2 Our preferred The proposal is too small. Our current concept design is constrained by the None plan - need to avoid the SSSI and ancient woodland. We have Reservoir - raised and fed back comments we have received on Broad Oak the plan to Natural England. Before dWRMP24 and/or an application for outline planning permission, we will explore whether there are options to have a deeper reservoir and extend the leg of reservoir toward Tyler Hill and whether this would increase the potential supply yield of the scheme.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I53.3 Our preferred Would like to see the provision of recreational activities Our concept design for the reservoir currently None plan - on the site, including a network of footpaths. includes recreational provision in the form of car Reservoir - parking, footpaths and bridleways linking into the Broad Oak existing network of paths and bridleways. Other recreational activities can be considered, including fishing and sailing, and will be considered during the further development of the scheme taking into account public preferences and what can be delivered without adversely impacting the local residents. Individual I53.4 Our preferred It would be more convenient if the access could be Our current concept design is constrained by the None plan - achieved from Tyler Hill. need to avoid the SSSI and ancient woodland. We have Reservoir - raised and fed back comments we have received on Broad Oak the plan to Natural England. Before dWRMP24 and/or an application for outline planning permission, we will explore whether there are options to have a deeper reservoir and extend the leg of reservoir toward Tyler Hill and whether this would increase the potential supply yield of the scheme. Individual I54.2 Our preferred A smaller reservoir than expected, it could be bigger Our current concept design is constrained by the None plan - need to avoid the SSSI and ancient woodland. We have Reservoir - raised and fed back comments we have received on Broad Oak the plan to Natural England. Before dWRMP24 and/or an application for outline planning permission, we will explore whether there are options to have a deeper reservoir and extend the leg of reservoir toward Tyler Hill and whether this would increase the potential supply yield of the scheme.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I55.2 Our preferred Suggested a larger lake The current date for providing water into supply from None plan - the Broad Oak Reservoir is based upon the timescales Reservoir - required to develop and build the scheme. This Broad Oak includes the design, attaining planning permission, constructing the reservoir and filling it whilst building and putting into service the water treatment plant and transfer pipelines. During the next stage of developing the scheme, should it be feasible to accelerate this process, we shall endeavour to do so. The date for completion and the addition of this water into our supply based on our rWRMP19 is 2033. Individual I56.3 Our preferred Thinks the reservoir should be bigger. The impact of the SSSI on the footprint of the None plan - reservoir has been considered and the concept Reservoir - design at this stage takes a balanced view of required Broad Oak footprint, storage volume and protection of sensitive sites. We will continue to engage with the Regulators when developing the reservoir design to maintain sensitivity to the SSSI and ensure constraints are not arbitrarily imposed upon the development unnecessarily. Individual I56.4 Our preferred SSSI is too restricting and unnecessary. This assessment will be undertaken as part of detailed None plan - planning and design as the option goes into planning Reservoir - phase. It should be noted that our options are already Broad Oak restricted as a result of the Richborough connection project within the same footprint. Individual I60.6 Our preferred The quality of the Sarre Penn flow and its banks needs We welcome this support for our proposed reservoir None plan - priority. and our concept design as currently developed. Reservoir - Broad Oak Individual I60.7 Our preferred Good design as a priority for carparks and the dam areas. We welcome this support for our proposed reservoir None plan - and our concept design as currently developed. Reservoir - Broad Oak southeastwater.co.uk 115

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I61.1 Our preferred Concerned about the rerouting of the Sarre Penn. It is a We will avoid adverse impacts on the SSSI woodland as None plan - major contributor to the SSSI woodland. Its course should part of our design. Reservoir - be carefully considered before rerouting takes place. Broad Oak Individual I67.1 Our preferred Send Broadoak Map. Maps of the Broad Oak Reservoir concept design as None plan - envisaged at this stage will be published on the SEW Reservoir - website. Broad Oak Individual I69.13 Our preferred Alternatives We have updated our rWRMP19 to include very None plan - As noted above, demand management, recycling and ambitious levels of demand management. This has Reservoir - reuse would be preferable to a Broad Oak reservoir removed the need for many alternative schemes, Broad Oak because of the impacts of the proposed reservoir. although Broad Oak still features strongly in our Desalination preferred plan, see Section 9 of rWRMP19. We are working closely with industry suppliers to roll out The scheme yield at Reculver is given as 20 Mld smart meter and usage monitoring technologies with (dWRMP19 page 159) is 20 Mld – very similar to the Broad trials already underway. We have considered re-use Oak scheme. and desalination schemes, though in our rWMRP19 Bankside storage but these do not currently feature in our future plans. I note the SEA Environmental Report 8.2.9 says a new The rWMRP19 reflects the best plan for managing bankside storage reservoir would be created at Plucks leakage and demand as a priority whilst ensuring Gutter to provide 14.8 Mld treated water, but it gives no we react to future reductions in abstraction and indication of the storage volume. achieve a balanced economic investment and provide In my submission to the Broad Oak 1979 reservoir Inquiry, resilience to our supply. I referred to Richard Martin (a water consultant), the We are grateful for the detail and extent of the expert witness on behalf of CPRE and Hackington Parish representation provided by I69. There are many key Council, who gave the example of bankside storage references referred to, that will be taken into account volume of 2580 Ml being able to increase the existing as we progress with further investigations. A number water sources peak yield of 185.4 Mld to 257.3, an of the references to historical information need to be increase of 72 Mld. reviewed and updated as these may no longer apply. An advantage of bankside storage is that it would also The input on cost of the Richborough Scheme has minimise pumping costs from the river to reservoir, and already been incorporated into the latest costs. possibly from reservoir to the water main, and because continues more site options would be available it could reduce new overleaf pipework needed.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I69.13 Our preferred Richard Martin identified a site beside the Stour and the Our concept design for Broad Oak reservoir does not None continued plan - Promoters also gave an example of a possible bankside include any bankside storage at Plucks Gutter. We Reservoir - option, which should be available in the archives. propose an abstraction point and pumping station Broad Oak Clearly if bankside storage at Plucks Gutter is already to transfer flows directly to the reservoir. We would planned it would make sense to increase its volume not be able to provide the level of storage volume rather than create new storage at Broad Oak especially as required for a resilient storage reservoir with bankside conjunctive use would increase the total available yield. storage hence why we propose the reservoir as it is currently proposed. Reasons against The SEA Environmental Report pages 138/139 gives significant reasons against the proposal and also notes that for several aspects ‘further detailed study required’, so I do not think that the overall benefit is as great as expected. The costs are likely to be higher, and thus its viability affected, because the National Grid’s Richborough Connection pylons were not located to help the reservoir, which means that reservoir construction activity has to avoid areas that were previously available and would need to have increasing vigilance over the work. The Vale Farmhouse (SEA Environmental Report page 108) is a very well well-preserved 17th Century building. Relocating it would damage it and completely change it and its environment which is very similar to that of more than 100 years ago. Impacts on downstream interests – the BOR Inquiry 1979 spent a lot of time on the problems for farmers with the marsh feeding system and the fisheries all of whom were very concerned at the minimum residual flow in the river continues Stour which in practice would have been the river flow for opposite most of the year.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I69.13 Our preferred So I query whether these interests have in fact been None continued plan - adequately consulted and taken account of. Reservoir - It is very concerning that 36 hectares good quality Broad Oak agricultural land (SEA Environmental Report page 108) would be lost at a time when there is an even greater need for such land for food. The proposed reservoir would cause significant intrusion into a very quiet and undisturbed area which has been unchanged for centuries, with very high wildlife value with Sites of Special Scientific Interest (SSSI). In particular the car park at western end and its associated traffic would have a high impact on the area around the access road and on Tyler Hill. Access from other end with a car park there would be better, but any significantly increased access would disturb this area and change its character. It would be contrary to government’s new Environmental Strategy which requires the environment to be left better than it is now. Individual I69.14 Our preferred The documents refer to Broad Oak Reservoir and to Our concept design for Broad Oak reservoir does not None plan - bankside storage at (or near) Plucks Gutter, but I haven’t include any bankside storage at Plucks Gutter. We Reservoir - found plans of how big or deep they would be, only I know propose an abstraction point and pumping station Broad Oak WRMP 14 proposed a smaller BO Reservoir, and I don’t to transfer flows directly to the reservoir. We would recall any mention of bankside storage. not be able to provide the level of storage volume So more details would be much appreciated so that I can required for a resilient storage reservoir with bankside ask intelligent questions at your public exhibitions here in storage hence why we propose the reservoir as it is Tyler Hill etc. proposed. As a participant in the 1979 BO Inquiry I recall bankside storage was proposed by Hackington Parish council/ CPRE, so is this new proposal something similar to that? Also I would expect bankside storage to be more efficient than a BO reservoir because it would reduce the need to pump water up over the hill.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I7.2 Our preferred Disappointment that Broadoak Reservoir is only being The current date for providing water into supply from None plan - implemented in 2033 after the compulsory purchase of the Broad Oak Reservoir is based upon the timescales Reservoir - land occurred in 1976. required to develop and build the scheme. This Broad Oak includes the design, attaining planning permission, constructing the reservoir and filling it whilst building and putting into service the water treatment plant and transfer pipelines. During the next stage of developing the scheme, should it be feasible to accelerate this process we shall endeavour to do so. The date for completion and the addition of this water into our supply based on our rWRMP19 is 2033. Individual I71.2 Our preferred Access is of concern Access to the reservoir for the public has been None plan - considered in the concept design and includes routes Reservoir - around the reservoir and linking existing footpaths, Broad Oak bridleways, tracks and roads to this network. Car parking provision is included in the concept design to allow wider public access without impacting the village of Broad Oak. SEW shall continue to engage with the public to ensure we take account of any individuals concerns or required provision as we develop the design. Individual I71.3 Our preferred It looks like a promising plan but the Tyler Hill access to Our current concept design is constrained by the None plan - the Visitor Centre could be a problem. need to avoid the SSSI and ancient woodland. We have Reservoir - raised and fed back comments we have received on Broad Oak the plan to Natural England. Before dWRMP24 and/or an application for outline planning permission, we will explore whether there are options to have a deeper reservoir and extend the leg of reservoir toward Tyler Hill and whether this would increase the potential supply yield of the scheme. We shall continue to look at the source abstraction alongside this to evaluate the available water against storage volume and potential peak supply output.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I72.2 Our preferred Challenge should be geared to providing water rather We agree the first priority is security of supply. None plan - than recreational facility. However, reservoirs do in themselves become a Reservoir - point of interest to visitors and we have proposed Broad Oak recreational facilities that are commensurate with the scale of the reservoir and balancing the needs of local residents. Individual I72.3 Our preferred Minimise impact on environment of Honey Ward and We agree it is an important requirement that the None plan - Sarre Penn Valley. scheme minimises the impact it has. Reservoir - Broad Oak Individual I72.4 Our preferred Case for new road to access from Tyler Hill. Other access Access to the reservoir for the public has been None plan - from Broad Oak should be explored. considered in the concept design and includes routes Reservoir - around the reservoir and linking existing footpaths, Broad Oak bridleways, tracks and roads to this network. Car parking provision is included in the concept design to allow wider public access without impacting the village of Broad Oak. We shall continue to engage with the public to ensure we take account of any individuals concerns or required provision as we develop the design. Individual I75.2 Our preferred Landowners along the route. Please send through any The pipeline route shown in our concept design are None plan - relevant information as soon as its available. indicative routes taking account of key physical and Reservoir - environmental constraints. Broad Oak Once our rWRMP19 is approved for publication as a final plan we will send out the pipeline route for consultation with the landowners and residents along the route.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I77.3 Our preferred Concerned about the reservoir large surface area. The loss of water due to evaporation potential None plan - Evaporation with concentrate salts. concentration of salts is a factor we consider in Reservoir - design. The concentration would actually be very Broad Oak low as the stored volume verses the loss due to evaporation will enable sufficient dilution to be maintained with out impact on water quality. As part of the scheme development modelling will be undertaken for water quality within the reservoir during full and near empty conditions to ensure the design maintains a water quality right for treatment and for the aquatic inhabitants, this includes taking account of evaporation. Individual I77.4 Our preferred Circular walk/wheelchair access around the reservoir. The provision of a circular walk around the reservoir None plan - has been included in the concept design to date as Reservoir - has wheelchair access from the visitors car park to Broad Oak the walkways and reservoir crest. We shall consider whether it is feasible to create a full circular route that is wheelchair accessible within our design as the scheme progresses. Individual I77.5 Our preferred Visitor centre - Vale Farmhouse - toilets at the car park We will consider the appropriate level of facilities to None plan - off the Herne Bay Road. serve anticipated visitor numbers such as toilets to Reservoir - be provided at the car park during the next stage of Broad Oak development. The views of local residents will be key during this assessment work. Individual I79.2 Our preferred Make sure not traffic uses Barnets Lane. Access via Barnets Lane would only be for residents on None plan - the lane or SEW operational staff for occasional access Reservoir - to the reservoir crest for maintenance activities. Broad Oak

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I8.1 Our preferred Fully support the Broadoak Reservoir scheme but would The current date for providing water into supply from None plan - encourage the project to be completed sooner to avoid the Broad Oak Reservoir is based upon the timescales Reservoir - clashes with other developments and need for further required to develop and build the scheme. This Broad Oak changes to the plans. includes the design, attaining planning permission, constructing the reservoir and filling it whilst building Individual I55.3 Our preferred How soon can this begin. and putting into service the water treatment plant plan - and transfer pipelines. During the next stage of Reservoir - developing the scheme, should it be feasible to Broad Oak accelerate this process we shall endeavour to do so. Individual I80.2 Our preferred Build the reservoir soon. The date for completion and the addition of this water plan - into our supply based on our rWRMP19 is 2033. Reservoir - Broad Oak Individual I90.2 Our preferred If possible move the finish date sooner. plan - Reservoir - Broad Oak Individual I85.1 Our preferred In favour of the plan particularly the Broad Oak reservoir. plan - It can be started as soon as possible. Reservoir - Broad Oak Individual I87.2 Our preferred Happy with the proposal. Just as shame it can’t come plan - sooner. Reservoir - Broad Oak Individual I8.5 Our preferred Cycle route connections from Tyler Hill to Broad Oak will We agree that linking cycle routes would be a benefit. None plan - be vital to encourage modal shift. Providing cycle routes The current design envisages footway and bridle path Reservoir - will provide improved recreational facilities. routes which may also be used for cycling. We shall Broad Oak consider the linkage of cycle routes between Broad Oak and Tyler Hill to improve cycle route connectivity within our design as the scheme progresses. There is a particular benefit to linking up national cycle route number 1 to the west of Tyler Hill to the reservoir.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I81.2 Our preferred Maybe a leisure area to provide small boating/canoeing We will balance the need for and likely demand for None plan - on the north east side near Calcolt as in the 1975 plan. different types of recreation, considering this in Reservoir - more detail during the next stages of the scheme Broad Oak development. During the coming five year period we intend to develop the design to a level suitable to seek outline planning permission. In this period the recreational provision will be discussed with the local residents to ensure the right provision is made. Individual I82.2 Our preferred Hope to see it completed. We welcome this support for the reservoir and are None plan - fully committed to delivering this scheme in the Reservoir - timescales set out. Broad Oak Individual I84.4 Our preferred Pleased to see the reservoirs footprint has reduced, to Our current concept design is constrained by the None plan - minimise land-take from agriculture. need to avoid the SSSI and ancient woodland. We have Reservoir - raised and fed back comments we have received on Broad Oak the plan to Natural England. Before dWRMP24 and/or an application for outline planning permission, we will explore whether there are options to have a deeper reservoir and extend the leg of reservoir toward Tyler Hill and whether this would increase the potential supply yield of the scheme. We shall continue to look at the source abstraction alongside this to evaluate the available water against storage volume and potential peak supply output. Individual I86.2 Our preferred Really looking forward to having the reservoir facilities. We thank you for your supportive comments on the None plan - Think it will be a benefit for the area. proposal and the benefits this will bring to the area. Reservoir - We are fully committed to delivering the scheme Broad Oak within the timescales set out in our rWRMP19, and potentially earlier should we find we are able to.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I91.6 Our preferred Would also appreciate preferential fishing and As we develop the scheme we shall continue to None plan - sailing rights. engage with the local community to consider what Reservoir - recreational facilities would benefit the community Broad Oak the greatest. We will take a balanced view of what could be provided with what impact visitors from further afield may have on the area especially traffic and parking. Fishing and sailing are considerations we will look at. Canterbury A1.2 Our preferred Although the Local Plan does not identify land for the We have met with Canterbury City Council and agreed Updated text City Council plan - development of a reservoir at Broad Oak, paragraph 7.69 to work closely together to ensure their requirements in Section 9 Reservoir - sets out the Council’s expectations in the event that a are met. of rWRMP19. Broad Oak planning application is submitted for such a scheme. It remains the case that the Council would wish to agree the scope and timetable of environmental assessment and the assessment of impact on communities, and that any application should be supported by robust justification of the need, location and supply options. Ashford A8.6 Our preferred The Council seeks much greater involvement in the We have met with Canterbury City Council and agreed None Borough plan - continued progress of this substantial infrastructure to work closely together to ensure their requirements Council Reservoir - project. Would like to know who SEW has identified as key are met. Broad Oak stakeholders in future consultation. As part of those further discussions we will produce a list of stakeholders for the scheme, of which Ashford Borough Council will be a key stakeholder. Kent Wildlife S12.18 Our preferred We note that the long-standing option at Broad Oak, The larger proposed scheme has been reviewed by None Trust and plan - whilst larger than proposed previously, has been subject the Environment Agency and Natural England, with Sussex Wildlife Reservoir - to various assessments looking at how environmental both regulators satisfied the environmental impacts Trust Broad Oak impacts can be mitigated. associated with the scheme can be adequately mitigated in principle. Further work is planned to progress the scheme ready for a formal outline planning application by 2025.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Kent Wildlife S12.19 Our preferred We also note that there has also been some concern The Richborough Connection DCO Inquiry inspector None Trust and plan - regarding the deliverability of the Broad Oak scheme in report concluded that both schemes were able to Sussex Wildlife Reservoir - light of the Richborough Connection Project and would be delivered and co-exist. On this basis the scheme Trust Broad Oak seek clarification on whether or not this still affects the remains feasible. feasibility of this option. CPRE Kent S2.1 Our preferred See word document - Interaction between Broadoak The current concept is for abstraction from the River None plan - Reservoir/Sarre Penn/Plucks Gutter. Stour to occur at Plucks Gutter. Reservoir - We are progressing with more detailed assessments Broad Oak of the abstraction regime required to identify the rate of abstraction and any hands off flow conditions, whilst validating the yield for the reservoir. This work will include a catchment wide model of inflows and abstractions to ensure our plans for abstraction rates do not detrimentally impact the river. Individual I30.2 Our preferred Very much in favour of new reservoirs for water supply We welcome this support for our plan. None plan - and wildlife habitat created. Reservoirs Kent Wildlife S12.16 Our preferred We are not opposed to the building of new reservoirs in In our rWRMP19 we have set out how the reservoir None Trust and plan - principle; we recognise the need to provide sufficient schemes included form part of the best solution Sussex Wildlife Reservoirs water to meet demand in a way that minimises for delivering resilience for customers and the Trust environmental impact. We would however need to be environment. convinced that there is no alternative way of meeting future water demands. Kent Wildlife S12.17 Our preferred Some of our principle concerns for reservoirs proposed at We agree with the principal concerns as set out. None Trust and plan - Broad Oak, Arlington and Goose Green are: the inevitable We have started work on assessing and agreeing Sussex Wildlife Reservoirs loss of valuable habitat and species from the sites to be the mitigation measures to satisfactorily address Trust flooded (particularly from designated sites); the effect concerns. We are also identifying opportunities to on the rivers downstream (including alterations to flow, improved or enhanced the existing environment. water quality, sedimentation and siltation, and changes in salinity); and the inevitable impact on local and landscape connectivity caused by the schemes.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Kent Wildlife S12.21 Our preferred We welcome the recognition that the plans for We are pleased with this feedback and recognition None Trust and plan - the above-mentioned schemes present potential that opportunities will exist. We see Kent and Sussex Sussex Wildlife Reservoirs opportunities to make a contribution to a better Wildlife Trust as two key stakeholders we will engage Trust environment. Any major construction scheme must, closely with on these matters as we progress our work as well as mitigating impacts, secure significant on the reservoir schemes. enhancements for the environment. Natural R3.3 Our preferred There are opportunities to provide significant We agree that the there is significant opportunity for None England plan - biodiversity enhancement and net gain in the three enhanced biodiversity associated with the proposed Reservoirs reservoir options which are included in this dWRMP. reservoirs and we confirm our commitment to deliver a net environment gain as the reservoir designs are developed further. WWF-UK S9.10 Our preferred We want South East Water to ensure that any new supply We agree that the there is significant opportunity for plan - Supply- side schemes implemented will deliver a net gain in enhanced biodiversity associated with the proposed side schemes biodiversity and for the wider environment. reservoirs and we confirm our commitment to deliver a net environment gain as the reservoir designs are developed further. WWF-UK S9.11 Our preferred Should there be any notable changes between the draft There have been no additional supply schemes None plan - Supply- and final plan with respect to the preferred supply side included in out rWRMP19. side schemes options, we urge that further stakeholder and customer engagement is undertaken. WWF-UK S9.9 Our preferred We note that there are a large and wide range of supply Our rWRMP19 preferred plan has been updated and is plan - Supply- side schemes proposed from 2025 onwards to fulfil a more twin track and demand led strategy with over side schemes the supply: demand balance. Whilst some of these, 50 per cent of new water being met from demand such as catchment management activities, would management schemes. appear to probably have limited impacts, others are particularly significant and capital-intensive, such as new reservoirs and desalination plants. We must question why supply-side schemes appear to be favoured over more challenging and ambitious demand management reduction.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Ofwat R4.4 Our preferred The company has included the development of Deliverability is considered in our rWRMP19 and we None plan - Supply- significant supply options prior to 2035 including two have included long lead scheme costs during AMP7 side schemes reservoirs, an effluent reuse scheme, a treatment works (2020-25) to complete this work. The adoption of expansion, a new groundwater source and four internal more ambitious levels of demand management in our company transfers. However, it is unclear from the draft rWRMP19 has led to a reduction in number and timing plan if deliverability of the programme has been fully of new supply schemes required up until 2035. This considered and greater clarity is required on this in the will make delivery more achievable. final plan. Individual I113.1 Our preferred Do not take any more water out of the South East’s rivers. Thank you for your comment, our rWRMP19 includes None plan - Surface You need to build new and enlarge existing reservoirs for the development of a new reservoir in Sussex and Water before the countryside is covered in new houses. in Kent.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Group Against S6.1 Our preferred All elements of Thames Water’s deficit forecast should Thank-you for your representation to our dWRMP19. None Reservoir plan - Surface be reviewed to determine whether an Upper Thames This option is no longer part of our rWRMP19 Development Water Resource Development will be available in time to meet preferred plan. (GARD) South East Water’s future needs. Group Against S6.2 Our preferred There should be investigation of the potential for Reservoir plan - Surface the Teddington DRA scheme (or other Thames Water Development Water London-based option) to meet South East Water’s future (GARD) needs and enable early sustainability reductions in the Thames valley. Group Against S6.3 Our preferred Noting the over-dependence of all of South East England Reservoir plan - Surface on the over-stretched water resources of the River Development Water Thames, there should be more focus on the need for “new (GARD) water” to be transferred into the Thames valley to meet South East Water’s needs and to facilitate long overdue sustainability reductions. Group Against S6.4 Our preferred There should be an independent review of Thames Reservoir plan - Surface Water’s investigations of the Severn Thames transfer Development Water and Abingdon reservoir options, which have led to their (GARD) selection of Abingdon reservoir as their preferred option for a new Upper Thames source. Group Against S6.5 Our preferred There should be a review of Thames Water’s option Reservoir plan - Surface cost estimates that have led to their selection of the Development Water Abingdon reservoir as the future Upper Thames source (GARD) for supplying South East Water. Group Against S6.6 Our preferred South East Water should demonstrate that the relevant Reservoir plan - Surface aspects of Thames Water’s WRMP have been critically Development Water reviewed independently of Thames Water and their (GARD) consultants and that they have not been over-accepting of Thames Water’s own analysis.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.9 Our preferred New abstraction from the Thames at Maidenhead: We Thank-you for your representation to our dWRMP19. None Agency plan - Surface recommend the company provides further information This option is no longer part of our rWRMP19 Water on bulk supply arrangements with neighbouring preferred plan. companies. In particular, we recommend the company engage with the donor company to resolve this issues and amend the plan accordingly, ensuring that both company plans align in terms of volumes and implementation dates. This will provide assurance to customers and regulators that transfers are reliable and if any changes to transfers will affect security of supplies and/or the environment, including how companies will operate during different drought events. Kent Wildlife S12.12 Our preferred We are concerned about the suggestion of new surface All new abstractions are subject to a sustainability None Trust and plan - and groundwater abstractions within the plan which assessment (which includes WFD). This assessment is Sussex Wildlife Sustainable would contribute to an overall increase in the amount of undertaken prior to the operation of the source. Trust abstraction water abstracted from rivers and groundwater. Kent Wildlife S12.13 Our preferred A comprehensive assessment of the impact of new or Trust and plan - increased abstractions on the surrounding biodiversity Sussex Wildlife Sustainable must be carried out and abstraction proposals must Trust abstraction demonstrate that they would not cause any deterioration in Water Framework Directive (WFD) status of local water bodies. Kent Wildlife S12.14 Our preferred We recommend that as part of its commitment to ensure Trust and plan - the sustainability of all abstractions. Sussex Wildlife Sustainable Trust abstraction Kent Wildlife S12.15 Our preferred We are particularly concerned about existing We have included significant levels of sustainability None Trust and plan - abstractions on chalk streams, a rare and threatened reductions in our plan for a number of our chalk Sussex Wildlife Sustainable habitat, and would like to see a greater drive to ensure groundwater sources. In our rWRMP19 during the Trust abstraction existing abstractions are sustainable (above and beyond next 60 years over 50 per cent of new water will come those changes being pushed for by the regulators). from demand management, and the remaining from sustainable new sources of water that avoid further abstraction from Chalk aquifers. southeastwater.co.uk 129

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA South East S7.2 Our preferred Stopping chalk stream abstraction - water supplied Comment noted. None Rivers Trust plan - by South East Water is heavily reliant on groundwater Sustainable resources, including those which feed some of the UK’s abstraction globally rare chalk stream rivers. WWF-UK S9.14 Our preferred Noting that new reservoirs, a new groundwater source All new abstractions are subject to a sustainability None plan - and a new raw water abstraction are all supply-side assessment. This assessment is undertaken prior to Sustainable options being considered post-2025, the plan needs operation of the source. abstraction to specifically assess how these will be sustainable abstractions. Individual I69.11 Our preferred Existing exemptions from licensing for some abstractions We welcome the feedback and support of demand None plan - have been ended, and a licence is now usually needed. management in our rWRMP19. Timescales This may not, in the short term, make a lot of difference, but in due course it is likely that licences will be subject to more restrictions, especially because of the Water Framework Directive (WFD) and other environmental issues. This may assist in keeping more water in the environment and reducing the water abstraction reductions required from water companies for the WFD. I am very pleased that the first phase, 2020 to 2025 , Figure 22 (Non technical summary 2020 to 2080 [NTS]) focuses on leakage management and water efficiency, as these are obviously making the best use of the resources that we already have. Individual I101.3 Our preferred Concerns with an increase in traffic. Comment noted, full traffic management surveys will None plan - Traffic form part of detailed design phase. Impact Individual I102.2 Our preferred Main concern is Eccles does not want an increase in plan - Traffic traffic. Impact

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Appendix 2I - Our preferred plan continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I11.2 Our preferred Concern in advance was whether the proposals would We are pleased you found our stakeholder event None plan - Traffic lead to increase lorry traffic through Eccles Village, reassuring. Following updates to our rWRMP19 our Impact reassured that this is not the case. need for Aylesford re-use has been removed. We are aware it is still a preferred scheme for Southern Water. We have fed back your comments to Southern Water so these can be given proper consideration by them. Individual I98.2 Our preferred Concern is traffic flow during construction - impact of Comment noted, full traffic management surveys will None plan - Traffic traffic on village. form part of detailed design phase. Impact Defra R1.5 Our preferred Consideration should be given to increasing tree cover in We have chosen to consider this issue further in our None plan - Tree the SEW area to assist in water management. business plan rather than the rWRMP19. Coverage Swale Borough A5.3 Our preferred Efficiency - clearer explanation of how efficiency is going As part of the consultation process we have reviewed Updates to Council plan - Water to be increased requested. both our short term and long term strategies for Section 8 and Efficiency demand management. As a result we are now Section 9 including much more ambitious targets in our plan with a 15 percent leakage reduction over the first five years (rising to 50 percent by 2050) and significantly lower levels of customer water usage over the planning period,14Ml/d by 2025, 56Ml/d by 2045 and 150Ml/d by 2080. This equates to the following PCC figures: 139l/h/d by 2025, 118l/h/d by 2045 and 90l/h/d by 2080. These more ambitious levels of demand management were tested with customers and stakeholders during the preparation of our rWRMP19 and received their support. In Section 9 of our rWRMP19 we explain the core elements our water efficiency program to deliver reductions in per capita consumption.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Waterwise S8.4 Our preferred Waterwise recommends South East Water include a As part of the consultation process we have reviewed Updates to plan - Water broader range of water efficiency actions in their baseline both our short term and long term strategies for Section 8 and Efficiency or final options in order to support greater ambition on demand management. As a result we are now Section 9 reducing per capita consumption. including much more ambitious targets in our plan with a 15 percent leakage reduction over the first five years (rising to 50 percent by 2050) and significantly lower levels of customer water usage over the planning period, 14Ml/d by 2025, 56Ml/d by 2045 and 150Ml/d by 2080. This equates to the following PCC figures: 139l/h/d by 2025, 118l/h/d by 2045 and 90l/h/d by 2080. These more ambitious levels of demand management were tested with customers and stakeholders during the preparation of our rWRMP19 and received their support. In Section 9 of our rWRMP19 we explain the core elements our water efficiency program to deliver reductions in per capita consumption. Waterwise S8.5 Our preferred Given higher water efficiency is the second highest As part of the consultation process we have reviewed Updates to plan - Water priority for customers willingness to pay, this should be both our short term and long term strategies for Section 8 and Efficiency better reflected in the final WRMP. demand management. As a result we are now Section 9 including much more ambitious targets in our plan with a 15 percent leakage reduction over the first five years (rising to 50 percent by 2050) and significantly lower levels of customer water usage over the planning period,14Ml/d by 2025, 56Ml/d by 2045 and 150Ml/d by 2080. This equates to the following PCC figures: 139l/h/d by 2025, 118l/h/d by 2045 and 90l/h/d by 2080. These more ambitious levels of demand management were tested with customers and stakeholders during the preparation of our rWRMP19 and received their support.

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Appendix 2I - Our preferred plan continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA WWF-UK S9.8 Our preferred Especially given the anticipated levels of population The population and property forecasts that support None plan - Water increase - 56 per cent by 2080 - we’d like to see South our plan have been prepared by Experian in liaison Efficiency East Water commit to working with developers to ensure with local planning authorities. The forecasts comply new developments are water efficient. fully with the WRMP guideline requirements and enable us to meet our existing statutory duty to supply all new homes. Operating in a water stressed region, we work closely with local planning authorities so they are well informed of where the challenges of meeting new housing and population growth is greatest. We engage proactively with local planning authorities on their local plan, design policies, water cycle strategies and infrastructure development plans to minimise the impact new housing might have as far as is practicable. Natural R3.5 Our preferred Natural England broadly supports the programme of The rWRMP19 includes further and more ambitious Updates to England plan - Water demand management options for both water efficiency levels of demand management. Section 8 and Efficiency and leakage reduction in the dWRMP. Section 9 Individual I10.1 Our preferred Resident of Peacehaven wants more information on the This option is no longer part of our rWRMP19 None plan - Water proposed “Water re-use scheme”. preferred plan. However, we noted this request and on Re-use the 22 March send the individual PDF documents by email with the additional information requested and a note to request that they contact us for anything further. Individual I103.4 Our preferred The same applies to water reuse schemes which should Water re-use is no longer part of our rWRMP19 None plan - Water be a last resort once we’ve already got increased storage preferred plan. Re-use from adding new reservoirs.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I11.3 Our preferred The impact of Aylesford water re-use option on Eccles Water re-use is no longer part of our rWRMP19 None plan - Water will need to be addressed. Agreement of the plan in preferred plan. This scheme is being led by Southern Re-use principle now, should not pre-empt the future need for Water, who have a need for the water from this consultation on the specifics of implementation. scheme. We are engaging closely with Southern Water to feedback concerns by residents that have been highlighted by our consultation. In particular on Eccles and the local surrounding area due to result of temporary construction and on-going operational traffic. Individual I116.1 Our preferred The failure to think about water re-use with any sense Our thinking around effluent reuse has been to None plan - Water of urgency - No real explanation is provided for starting identify existing wastewater treatment works where Re-use to re-use water processed at Weatherlees in the period the effluent discharge would otherwise be to lost to 2045 to 2080. Apart from the plan to do this at Aylesford sea i.e. coastal or tidal reach sites. This prevents any in 2025-2045, no explanation is provided for a failure risk of WFD deterioration of existing river flows which to utilise waste water at any of the other wastewater we are likely to contravene if we were to capture. As treatment facilities in Kent. The thinking provided by part of our option development we have identified SEW does not seem to accept that waste water is treated that the quality of the effluent that discharges to sea to a sufficiently high standard that it can be turned into is of a lower quality (and saline) to that discharging to potable water. rivers, this requires additional treatment to ensure a SEW also has an inability to think beyond a reservoir and high enough standard for discharge to river, storage does not understand that it is possible to re-charge an or aquifer. aquifer and hence store high quality water underground.

continues opposite

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Appendix 2I - Our preferred plan continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I116.1 Our preferred Section 5.1 of the dWRMP acknowledges that South East A range of alternatives for developing new and None continued plan - Water Water has “less first-hand experience (such as effluent sharing existing resources were considered in the Re-use re-use)….”, but simple Google research demonstrates development of the rWRMP19. We agree that further that help from a nearby water company, that is not only improvements in demand management and water re-using effluent but is also re-charging its aquifers, is efficiency must also be considered alternatives to any readily available! I looked at: proposals that causes significant harm to the natural https://www.thameswater.co.uk/Help-and-Advice/ environment. Water-Quality/Where-our-water-comes-from/North- We are aware of the North London Artificial Recharge London-Artificial-Recharge-Scheme Scheme (NLARS). In terms of the re-charging of Amongst the interesting facts from this website the aquifers, we have looked at the potential for this following extracts seem particularly relevant: across our supply area and identified a couple of locations in our western region where this might be “Under northeast London lies Britain’s only artificially- feasible but not suitable locations in East Kent. recharged aquifer used for public water supply. North London Artificial Recharge Scheme (NLARS) uses a chalk In our rWRMP19 preferred plan effluent re-use is no aquifer beneath Enfield, Haringey and the Lee Valley longer required but our modelling work still includes which we top up with treated water when rainfall is Broad Oak reservoir as a preferred scheme. plentiful to use as a back-up resource to boost supplies during droughts. These aquifers were first artificially recharged back in the 1890s by what was then the East London Water Works Company. Further larger-scale trials were carried out by the Metropolitan Water Board in the 1950s, before work on the project in the 1970s by what was then the Thames Water Authority. This later became a private company, Thames Water Utilities Limited, in 1989. We have used the NLARS since 1995. After the 2006 drought we spent £6m to improve its potential daily output from 150 million litres a day (enough for 1m people) to 180 million litres a day per year. The scheme is designed to be able to provide additional water during extended droughts, with its daily output starting off at around 200 million litres, decreasing to around 140 million litres as the water stored in the continues aquifer is used up.” overleaf southeastwater.co.uk 135

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I116.1 Our preferred This raises the issue of why SEW is so keen to transfer the None continued plan - Water water generated from Aylesford to the Medway or that Re-use generated from Weatherlees to either the Stour or to Broad Oak (the report is not very clear about where this water is going). The supply demand balance for Kent in the final year of the plan (2079/80) is a maximum in summer of 111.2 million litres per day (see Figure 13), remarkably close to the potential output from NLARS. Like most of Kent, the NLARS is based on a chalk aquifer. Why South East Water has failed to consider aquifer recharge for immediate implementation is a mystery. If South East Water wishes to research the idea of aquifer recharge more thoroughly, the following website provides useful ideas: http://www.water.wa.gov.au/urban-water/water- recycling-efficiencies/managed-aquifer-recharge Given the limited rainfall in Kent, it seems illogical and economically unsound to seek to create a reservoir to store fresh water from the Stour or to simply put water into the Medway from Aylesford, when all of this water could be used to increase the water levels in the aquifer. There are of course other effluent treatment facilities in Kent other than Aylesford and Weatherlees that could equally well do this.

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Appendix 2I - Our preferred plan continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I40.2 Our preferred Sewage treatment to flow to Eccles Reservoir instead of Water re-use is no longer part of our rWRMP19 None plan - Water Medway the other side of Maidstone. preferred plan. This scheme is being led by Southern Re-use Water, who have a need for the water from this scheme. We are engaging closely with Southern Water to feedback concerns by residents that have been highlighted by our consultation. In particular on Eccles and the local surrounding area due to temporary construction and on-going operational traffic. We are aware Southern Water’s preferred option is now to transfer treated water only as far as Eccles Lake. Individual I40.3 Our preferred Would like live copies of the reuse of WTW schemes - These options are no longer required in our rWRMP19 None plan - Water public facing maps. preferred plan but remain potential future feasible Re-use options. An outline plan is available for the scheme and can be provided alongside this response. Kent Wildlife S12.25 Our preferred We support in principle the proposal to re-use water, This option is no longer part of our rWRMP19 None Trust and plan - Water but the development of any new infrastructure must preferred plan but we agree and support the Sussex Wildlife Re-use be accompanied by stringent assessment of the principles set out, and will keep these comments on Trust environmental and energy impacts. record for future reference. Kent Wildlife S12.26 Our preferred We are concerned about the about the impact on both Re-use options are no longer required in our rWRMP19 None Trust and plan - Water the terrestrial, freshwater and marine environments of preferred plan. Sussex Wildlife Re-use the three proposed water re-use schemes Aylesford, Trust Peacehaven and Weatherlees and note that the Habitats Regulations Assessment (HRA) states that two of these proposals “have pathways which could result in the significant effects to a Natura 2000 or Ramsar site, or that there was sufficient uncertainty associated with the potential impacts of the option that the potential for significant effects could not be ruled out”.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Kent Wildlife S12.28 Our preferred We welcome the recognition that long lead times are Thank-you for your representation to our dWRMP19, None Trust and plan - Water needed for the development of many of the new future we welcome this support for our plan. Sussex Wildlife Re-use new resource options to ensure flexibility to bring Trust forward alternative options should any of these prove unfeasible. Kent Wildlife S12.30 Our preferred Water Reuse - SEW would need to demonstrate that This option is no longer part of our rWRMP19 None Trust and plan - Water there were no less damaging alternatives to this preferred plan, but we agree to the principle and Sussex Wildlife Re-use development, including better management of existing will keep these comments on record for future Trust water resources. reference. Environment R2.3 Our preferred Weatherlees Effluent Reuse: The company and Southern This option is no longer required in our rWRMP19 None Agency plan - Water Water need to agree together whether this is a preferred preferred plan. Re-use option and agree a joint design and take forward to environmental assessment. Environment R2.4 Our preferred Water Reuse at Aylesford.: The company should cross Agency plan - Water reference proposals with Southern Water and agree Re-use outline designs together so that environmental assessment can be consistent. Environmental Assessment, WFD assessment and HRA will need to be done when a single preferred version of the option is selected. Ofwat R4.28 Our preferred We welcome that South East Water has discussed joint plan - Water development of effluent reuse schemes with Southern Re-use Water and it should continue to explore such options. The companies should ensure these schemes are represented consistently within the plans and that the delivery timescales accurately reflect the constraints of both parties.

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Appendix 2I - Our preferred plan continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I107.2 Our preferred Concerned about the proposal to recycle water in This option is no longer part of our rWRMP19 None plan - Water Peacehaven. The intended site is presumably near preferred plan, but we are grateful for the Re-use - the existing wastewater works and could result in the representation and will keep these comments on Peacehaven further loss of high grade agricultural land. Any such record for future reference. development wherever situated should be suitably concealed by a ‘green’ roof. Individual I26.2 Our preferred Asked why pump water from Peacehaven WTW to plan - Water Newhaven WTW to Barcombe then to the river. Re-use - Asked why not pump straight to Arlington Reservoir. Peacehaven Newhaven P6.1 Our preferred Concerns with the Newhaven WwTW - Landscape, Town Council plan - Water traffic challenges. Re-use - Peacehaven Newhaven P6.2 Our preferred Suggestion to treat waste at site adjacent to Peacehaven Town Council plan - Water WwTW before being transferred. Re-use - Peacehaven Newhaven P6.3 Our preferred Concerns with the impact to the River Ouse and effect Town Council plan - Water on Sea Trout. Re-use - Peacehaven Individual I95.2 Our preferred Abstraction of water from the Stour at plucks gutter We do not anticipate there being a salinity issue from None plan - Water is saline. the proposed abstraction point. There is an existing Re-use - abstraction at this location by Southern Water and Weatherlees no reported salinity issues. South East Water are progressing with more detailed assessments of the Individual I96.2 Our preferred Plucks gutter abstraction could be tricky due to abstraction regime required to identify the rate plan - Water tidal range. of abstraction and any hands off flow conditions Re-use - whilst validating the yield for filling the reservoir. Weatherlees This modelling will include validating the tidal range impact on proposed abstraction. southeastwater.co.uk 139

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Kent Wildlife S12.22 Our preferred Development of the proposals to improve water The improvement work at Bewl WTW will not lead to None Trust and plan - Water treatment works at Bewl and Ford must be accompanied an increase in water abstraction from the reservoir, Sussex Wildlife Treatment by stringent assessment of the environmental impacts. it will replace the INNS raw water transfer risk that Trust Works currently exist for South East Water with the Bewl Darwell transfer scheme. The work programmes for Bewl and Ford WTW schemes include stringent assessments of environmental impacts. Kent Wildlife S12.23 Our preferred SE Water should demonstrate that there is an The Bewl WTW scheme has a significant None Trust and plan - Water environmental as well as economic benefit to environmental benefit by removing a current INNS Sussex Wildlife Treatment improvements to the water treatment works rather than risk of raw water transfers, and it is part of our WINEP Trust Works tackling water resource and quality issues at source. too. The Ford scheme is a relatively small localised scheme that will address naturally occurring water quality conditions. Kent Wildlife S12.24 Our preferred Consideration should be given to the savings to be We agree with this principle, but it does not apply to None Trust and plan - Water made through improvements in water quality before the two schemes proposed. Sussex Wildlife Treatment treatment, through working in partnership at a Trust Works catchment level to achieve reduction of inputs. Environment R2.8 Our preferred Bewl reservoir: The company and Southern Water should This option is no longer part of our rWRMP19 None Agency plan - Water agree together whether the volume of water from preferred plan. Treatment this option will be shared between the companies. The Works company should update the plan with this information and ensure the company engage with Southern Water around an amended agreement, should this option be brought online. Environment R2.128 Our preferred There is no connection between WINEP drinking water Option SEW-RZ4-CGW-2 also includes catchment None Agency plan - WINEP schemes and the options selected, for example, there management to reduce nitrates from agricultural Schemes is a WINEP scheme to reduce nitrate in groundwater and other sources. We have changed the title of the at Woodgarston by engaging with farmers, but option option to ‘Catchment Management to reduce nitrates SEW-RZ4-CGW-2 to reduce nitrate from septic tanks in the Woodgarston Catchment’. We can also confirm in similar localities makes no mention of this (relates to that we have a very ambitious wider catchment Improvements 3.17 and 3.18).The company should make management programme for 2020 to 2025, based sure any WINEP schemes and options are joined up. upon our WINEP schemes. Details related to this are to be found in our business plan and associated performance commitments. Draft Water Resources Management Plan 2020 to 2080 – Statement of Response 140

Appendix 2J - Comments on SEA

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Kent Wildlife S12.42 SEA - We would like to see more commitment to collaboration Thank you for your offer of help with collaborative None Trust and Catchment at the catchment level. We would also like to again working, we will take this into account as we develop Sussex Wildlife Management highlight that, like many Wildlife Trusts, we have pledged our programme for 2020-2025. Trust our support with particular reference to engaging with landowners within SEW’s area of supply. We are keen to be involved with helping to create solutions that will help safeguard the resilience of the ecosystems from which raw water is sourced. Environment R2.57 SEA - Woodgarston Nitrate Removal Plant: The company CGW-3 Option prevents loss of DO due to water None Agency Catchment should acknowledge increase in licence usage as a result quality issues and potential for any within licence Management of this and assess any impacts this may have. increase is acknowledged but is assessed as low risk for WFD. This option is linked to WINEP. Environment R2.58 SEA - Septic tanks/cess pit discharge to Woodgarston: The CGW-2 Woodgarston nitrate reduction - this option None Agency Catchment company should acknowledge increase in licence usage does not involve increased abstraction within Management as a result of this and assess any impacts. Discuss both licence - there is a potential loss of DO if water Woodgarston nitrate reduction projects in conjunction quality improvements are not achieved and these with each other. losses have been taken into account in the baseline. Without CGW- 2 a nitrate removal system would need to be provided which would not provide wider environmental benefits. Therefore this catchment management option is identified as being supportive of WFD objectives and the option is linked to the issues identified through WINEP. Environment R2.54 SEA - Desalination of River Medway tidal water at Aylesford/ This option is no longer part of our rWRMP19 None Agency Desalination - Snodland: This option should not be progressed unless preferred plan and the SEA has been revived and River Medway an alternative disposal solution for the brine waste updated accordingly. stream is identified. It is unlikely to be acceptable to discharge this to the estuary. The dispersal pathways and residence times for hypersaline, high density brine in the estuary should be modelled. There is a risk that this type of discharge could result in a long term cumulative impact. The impact assessment for this option should be combined with the one for the Aylesford re-use option. southeastwater.co.uk 141

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.129 SEA - Detail is provided on the methodology used for This information is provided in Appendix 7G of the None Agency Environmental assessment of environmental and social costs including rWRMP19. and Social the cost of carbon, but no break-down of cost values Costs or commentary is provided on the variation in costs per option type. Lack of transparency in generation of environmental and social cost values. Add commentary on environmental and social cost values to highlight significance to each option type. Environment R2.41 SEA - In the SEA Appendices, screening seems to be limited to Table 1 of Appendix A has been updated with Updated Agency Environmental one surface water body in Table A1. Detail impacts on information regarding additional waterbodies Table 1 of Impact multiple surface water bodies. affected by options within the preferred plan. A Appendix A further appendix to the WFD assessment (Appendix of SEA B) is being prepared which details WFD screening information for all feasible options - this is based on the master WFD assessment spreadsheet which includes multiple water bodies including ground and surface water where relevant for each option but is too unwieldly - a summary version of this provided in Appendix B of the WFD assessment as a draft. Environment R2.43 SEA - The WFD Assessment only considers the impacts of There is no further increase in abstraction beyond None Agency Environmental constrained options. Consider the impact of growth state planned increase - the plan as a whole Impact of existing sources and sustainability reductions that addresses demand growth and takes account of likely may be required in the future as a result of this risk. sustainability reductions and tests sensitivity to Clearly identify the licences that are indirectly taking up possible increased sustainability reductions. headroom, and provide assessment on this impact. Environment R2.44 SEA - The company should be consistent as to when all options Table A1 of Appendix A of the WFD assessment Updated Agency Environmental will commence. The company should also add the missing has been updated with waterbody WFD status Table A1 of Impact information into the tables and figures for this option. information for the preferred plan options. Updated Appendix A The company should also ensure risk from increased or corrected information for the feasible plan options of SEA licence uptake of existing sources is considered in its will be provided in a new Appendix B to the WFD assessments, and should correct/add the appropriate assessment (draft document provided). waterbodies for evaluation in assessments.

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Appendix 2J - Comments on SEA continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.45 SEA - Providing quantitative assessments of hydrological The WFD assessment summary has been amended to Updated Agency Environmental regime would be beneficial to the quality of the WFD incorporate all relevant waterbodies identified in our WFD Impact assessment and environmental conclusions, and would working tables. Quantitative hydrological assessment assessment improve the environmental assessment by providing is not considered appropriate at this stage of option summary of a more in depth analysis of the potential ecological development. Mitigation proposals set out in the SEA. impacts. SEA and WFD assessment detail further studies that would be undertaken as part of option progression, including quantitative hydrological assessment where necessary and our commitment to develop monitoring plans for each scheme addressing WFD aspects where appropriate has been clarified. Environment R2.46 SEA - The company should include monitoring of WFD Where additional monitoring of WFD status of None Agency Environmental waterbody status or deterioration in its plan. deterioration is required over and above that Impact already undertaken (including as part of the WINEP programme) then this can be agreed. Environment R2.47 SEA - Further information needs specifying in relation to This scheme no longer forms part of our rWRMP19 None Agency Environmental discharging to the Ouse in terms of timing, location etc. Preferred Plan. Impact in order for us to comment on the risks associated with potential impacts. Environment R2.48 SEA - More clarity and further information is required for us to The assessment of cumulative effects in the initial None Agency Environmental adequately comment on the schemes proposed. draft was based on best available information about Impact other water companies preferred plan options, and has been updated as part of our rWRMP19. Environment R2.49 SEA - There is little information on mitigation specified. We Fish screens would be included on all abstraction Updated Agency Environmental suggest the company provide further narrative around intakes. A list of mitigation measures that are Section Impact mitigation for these options. considered to be included within scheme designs 6.4.3 of the where necessary has been added to Section 6.4.3 Environmental of the Environmental Report, which includes this Report of SEA. measure amongst others.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.50 SEA - It would be beneficial to the plan if the company were We are committed to developing environmental None Agency Environmental to develop an environmental monitoring plan, including monitoring programmes for the preferred plan Impact baseline data collection and proposals for monitoring options once the initial detailed ecological, the impact of each option the SEA has identified requires hydrological and other environmental studies have mitigation. This should be linked to the Drought Plan been undertaken - this is part of the environmental Environmental Monitoring Plan. action plan and linked to the SEA monitoring plan and South East Water annual environmental reporting- further clarification of scheme monitoring plans and links to drought plan will be added to SEA EAP. Environment R2.51 SEA - The company should ensure that it has considered the This option does not involve new abstraction or None Agency Environmental Pevensey Levels Water Level Management Plan as part of discharge of water to the environment, and will Impact its plans for the new Hazards Green transfer. be compliant with the Pevensey Levels Water Management. This is a replacement of a raw water transfer. Environment R2.52 SEA - Progress studies and investigations identified, Preliminary WFD assessments have been undertaken None Agency Environmental particularly in relation to Broad Oak which is expected to and discussed with the EA as part of the work on the Impact be delivered over shorter timescales. To include impacts National Grid Richborough Connection DCO hearings. on WFD status for Sarre Penn and any water quality This SS decision on this is reported in Environmental or hydrology impacts and an assessment of potential Report and the potential requirement for a WFD impacts on the SPA/Ramsar downstream of Plucks derogation identified by the Environment Agency Gutter. The company should also highlight any wider due to the constraints of developing the both the benefits the additional capacity of Broad Oak Reservoir Richborough Connection and the reservoir. The HRA will have. covers the impacts on the SPA/downstream in the context of previous studies and discussions with Natural England. The potential benefits from winter/ high flow water storage are identified in the SEA as contributing to resilience. Further studies and investigations for Broad Oak are referred to in the EAP and option dossier.

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Appendix 2J - Comments on SEA continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.53 SEA - These options involving additional abstraction direct No additional abstraction from Bewl Reservoir is None Agency Environmental from Bewl Water need to be assessed for impacts on proposed as part of South East Waters preferred plan. Impact the Medway, Teise and Beult through any associated The proposed direct abstraction from Bewl Reservoir required changes in the Southern Water River Medway replaces the existing transfer from Bewl to Darwell Scheme licence. The impacts of greater flows in these that would be discontinued due to the risk of INNS waterbodies also need to be investigated. transfer as identified during the WINEP ANP6 study. Environment R2.56 SEA - In Table 6.1 of the SEA, the company appear to be not to Effluent re-use options are no longer part of our None Agency Environmental fully acknowledge possible impact the plan has on water rWRMP19 preferred plan. Impact quality. Identify and evaluate reductions to flow from effluent re-use, and its impact on water quality. Environment R2.61 SEA - If there is any intention to use the Aylesford re-use This option is no longer part of our rWRMP19 Updated SEA Agency Environmental to offset Bewl releases then further details must be preferred plan. Our SEA has been reviewed and Impact supplied to enable us to adequately understand the updated accordingly. impacts, more consideration will be required within the SEA/HRA/WFD assessments. Update the WFD assessment for Aylesford effluent reuse to account for the discharge of concentrated wastewater and brine to the Medway Estuary. This will likely increase the impact from low to moderate/major and recommendations for future investigations will need to be updated for the option to include detailed investigations into water quality impacts to align with the recommendations of the HRA and SEA. Natural R3.1 SEA - Biodiversity with respect to designated sites and Agreed, we will make a minor amendment to Updated SEA England Environmental landscape issues. action plan. Impact Natural R3.2 SEA - The preferred option programme is broadly compatible We have updated the SEA, to reflect the rWRMP19 None England Environmental with the Strategic Environmental Assessment (SEA). preferred plan, which performs better than the Impact dWRMP19 in SEA terms.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Natural R3.4 SEA - Natural England broadly supports the approach adopted The revised Environmental Report will include a new Additional England Environmental for avoiding adverse impacts to SSSI sites through appendix (Appendix F) which will comprise of a SSSI Appendix Impact detailed design modification particularly for pipeline screening table as a summary of information in option added to SEA routes. screening and dossiers . A draft of this appendix is provided to check before completion. Environment R2.87 SEA - In Section 8.2.3 of the SEA, the company state We have reviewed and updated the SEA accordingly. Updated SEA Agency Groundwater groundwater options not having any likely adverse Groundwater options feature very little in our impacts is not supported by a narrative that clearly sets rWRMP19 revised plan. out whether these confined aquifers (at the intended location of abstraction) become unconfined at a location where there could be impacts. The company should provide clarity on its understanding of the impacts on ground waters. Kent Wildlife S12.4 SEA - We welcome the proposal to produce a “landscape Our landscape protection strategy would relate to None Trust and Landscape protection strategy” to take into account the potential protected landscapes which form 44 percent of our Sussex Wildlife Protection cumulative impacts of proposals by SEW, other water supply area. Trust Strategy companies and other significant schemes on the environment. It is not clear if such a strategy would be restricted to landscape-scale impacts solely within those landscapes that are designated or if it would encompass the wider landscape as a whole and we would seek clarification on this.

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Appendix 2J - Comments on SEA continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Hampshire and S10.6 SEA - Natural Better accounting for the value of the natural A natural capital approach was utilised as part of None Isle of Wight Capital environment in future. a suite of measures when assessing our WRMP. Wildlife Trust This is explained in more detail in our Strategic Environmental Assessment which accompanies this plan. As part of our business plan we have considered our current and future performance related to Natural Capital accounting. This is contained within Appendix 10 environmental resilience. Kent Wildlife S12.6 SEA - Natural We would like to see natural capital integrated within the A natural capital approach was utilised as part of None Trust and Capital decision-making process for the preferred plan. a suite of measures when assessing our WRMP. Sussex Wildlife This is explained in more detail in our Strategic Trust Environmental Assessment which accompanies this plan. As part of our business plan we have considered WWF-UK S9.18 SEA - Natural We can find no reference to natural capital in the our current and future performance related to Capital dWRMP. We would like to see commitment from South Natural Capital accounting. This is contained within East Water to explore the natural capital approach, with Appendix 10 environmental resilience. determination to apply this to their work as soon as possible. Kent Wildlife S12.37 SEA - Regional We are concerned that no firm consideration appears Within Company transfers will follow our existing None Trust and Transfers to have been given to the impact on the natural planning processes that have been very effective and Sussex Wildlife environment at a landscape level of the infrastructure successful in mitigating impacts. Trust required to increase water transfers within the company All but one of our water transfer schemes between supply area and also between water companies. Although water companies has been removed. The remaining the SEA suggests that impacts on designated sites will scheme will be designed and routed to avoid be considered and avoided where practicable, a more significant and immeasurable impacts on the robust approach should be taken to the avoidance of environment. impacts on both designated sites, and locally important but undesignated sites such as Local Wildlife Sites . The longer, larger pipelines needed for water transfer schemes between water companies have the potential to inflict significant and irreversible damage upon ancient woodland.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I69.12 SEA - It is made clear from the outset, that the guiding We will be completing further detailed yield Resilience principle of this ‘plan for generations to come’ should be assessment work that will be used to update our yield one of resilience in every aspect of the S.E. Water 2020 estimates, and to inform dWRMP24 and/or outline – 2080 programme for securing water supplies for all planning applications. customers: while addressing the increasingly urgent need Responding to the main points made: to protect the environment and maintain the prescribed • We completed more detailed yield assessment levels of service under drought conditions of a severity work for WRMP09 and WRMP14, that confirmed exceeded on average, only once every 200 years. the reliability of the scheme yield at the reservoir The SEA Environmental Report, paragraph 7.10.3, refers size proposed now to the large difference between the 50 per cent and • in both those WRMP09 and WRMP14 plans, the 100 per cent sustainability reductions for the WFD, and recent net gain of 20Ml/d from sustainability in particular for the 50 per cent reduction, the model reductions was not included, and we expect that selects Aylesford & Weatherlees reuse schemes. As the updated yield assessment work will show an progress has been very slow so far in moving towards improved position regarding the ability of the the WFD targets, it seems likely that the 50 per cent river Stour to support abstraction for Broad Oak target is the practical achievable one, within the reservoir than reported previously WRMP timescales, hence providing another reason for supporting them, as well as giving more consideration • the annual average day output required from Broad to the other reuse schemes at Faversham, Hythe and Oak is 13 Ml/d, only during part of the year, under Reculver. summer peak periods, will the yield of the scheme operate at 20Ml/d One area of concern relates to the scale and timing of preferred supply options selected for zone WRZ 8 • the further yield studies will include an assessment around mid-plan-period. It is assumed that the WFD for of biodiversity, salmonid migration and control of restoring sustainable abstraction will be implemented shoaling in 2026/27, (at least in part Ref. dWRMP19 Fig. 30) by • the 1979/80 Broad Oak scheme is incomparable a reduction of 20 Ml/d in the authorised abstraction with the current proposal. The 1979/80 scheme from the Company’s borehole sources at Chilham and included a significantly largely reservoir, larger Godmersham: giving a commensurate increase in the yield, larger rate of abstraction and a different base flow of the river above Horton / Canterbury, and in abstraction point too. It is important when we the tidal Stour at Plucks Gutter. share the results from updated yield assessments that we explain how these compare and differ to continues overleaf historical schemes

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Appendix 2J - Comments on SEA continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I69.12 SEA - The outcome for the river at Plucks Gutter would be • we agree with the proposals for further modelling continued Resilience a gain in summer flow of 20 Ml/d but winter period studies. These already form part of our existing flow below Plucks Gutter would need to increase by an programme to be completed to inform our average of at least 40 Ml/d if abstraction were to be dWRMP24. required for Broad Oak Reservoir, to ensure total re-fill of the reservoir – leaving a net deficit of 20 Ml/d in the river. A winter period reduction of this order could have implications for biodiversity, salmonid migration and control of shoaling. This could be corrected, by bringing the Weatherlees indirect waste-water re-use option, rated at 15 Ml/d. To do otherwise could be seen as a lost opportunity to fully to commit to investment in resilient and ‘drought- proof’ re-use options in the management of one of Kent’s most stressed catchments. However there is clear evidence the River Stour flow has decreased decade by decade so it would be unwise to rely on it to fill the proposed Broad Water. In particular the Secretary of State’s decision to refuse Broad Oak Reservoir in 1979/1980 was based on the fact that abstraction for the reservoir would mean that the river would be at Minimum Residual Flow ( 1 cumec) for most of the year, with obvious adverse effects on the river and everything that relies on it, and this was before the continuing decline in river flows had been fully appreciated. In addition historic evidence points to the continuing impact of climate change on the spring-fed baseflow of the river between Wye and Horton. There would also seem to be a strong case here for further model studies to support long-term projections of the inter-action of climate-change, RSA and increased abstraction on continues the hydrographs for the tidal and non-tidal reaches of opposite the river. southeastwater.co.uk 149

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I69.12 SEA - SEW’s dWRMP19 does not appear to mention the option None continued Resilience of Discharge effluent to chalk near Wye. Other locations in the region also offer similar potential reuse, these would remove major pollutants from the river and help meet WFD needs. The effluent is very clean before discharge to chalk. Swale Borough A5.2 SEA - Sustainability Reductions - confirmation that industry We confirm that best practice is being followed. Four None Council Sustainable best practice is being followed. modelling runs were used to look at the impact of abstraction a range of sustainability reductions, and integrated with our SEA. Kent Wildlife S12.3 SEA - We were pleased to see that locally important but Thank you for your comments, at this stage it has not None Trust and Undesignated undesignated sites, such as Local Wildlife Sites, were been possible to list sites by name. Sussex Wildlife sites recognised as part of the environmental context of the Trust plan however we do not believe that the importance of these sites has been adequately reflected. The terms “non-designated sites”, “non-designated habitats” and “non-statutory designated sites” sites are used interchangeably within both the plan and the associated Strategic Environment Assessment (SEA). Where these terms refer to Local Wildlife Sites, we would like to see them referred to as such and for them to be identified by name.

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Appendix 2J - Comments on SEA continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.60 SEA - Water Water Reuse at Aylesford: Cost benefit analysis and This option is no longer part of our rWRMP19 None Agency Re-use - environmental assessment should be carried out for preferred plan. Our SEA has been reviewed and Aylesford an alternative pipeline and discharge to Eccles Lake to updated. understand if this option is less risky than discharging to the Medway. An alternative solution to discharging concentrated waste/ brine to the estuary needs to be found to make this scheme acceptable. Direct re-use would be more acceptable in terms of impact on the environment and should be considered by the company. Currently, the company should update the WFD assessment for Aylesford effluent reuse to account for the discharge of concentrated wastewater and brine to the Medway Estuary. This will likely increase the impact from low to moderate or major and the recommendations for future investigations will need to be updated for the option to include detailed investigations into water quality impacts to align with the recommendations of the HRA and SEA.

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Appendix 2K - Comments on HRA

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Kent Wildlife S12.32 HRA - We are concerned about the about the impact on both Our more ambitious revised demand management None Trust and Desalination the terrestrial and marine environments of the three strategy has removed the need for some of the supply Sussex Wildlife proposed desalination plants at Eastbourne, Reculver side schemes that were previous included in our draft Trust and Aylesford/Snodland and note that the Habitats plan. We can confirm that the desalination scheme at Regulations Assessment (HRA) states that these Reculver no longer features in our rWRMP19. proposals “have pathways which could result in the significant effects to a Natura 2000 or Ramsar site, or that there was sufficient uncertainty associated with the potential impacts of the option that the potential for significant effects could not be ruled out”. Kent Wildlife S12.33 HRA - Desalination - We endorse the recommendation of the Thank-you for your representation to our dWRMP19, None Trust and Desalination HRA, that alternative options must be implemented if we welcome this support for our plan. Sussex Wildlife any of the preferred options would result in a significant Trust impact on European designated sites. Kent Wildlife S12.27 HRA - Water Water Reuse - We endorse the recommendation of the Thank-you for your representation to our dWRMP19, None Trust and Re-use HRA, that alternative options must be implemented if we welcome this support for our plan. Sussex Wildlife any of the preferred options would result in a significant Trust impact on European designated sites. Natural R3.13 HRA Several European sites, for example Ashdown Forest, See R3.8 - two new paragraphs (see below) added at Updated HRA England Woolmer Forest, The Swale and Thames Basin Heaths, are Section 4.1 in the report clearly explaining how the clearly within the current plan area but are not included sites have been selected - also addresses why it is in Table 4.1 and are therefore not taken further forward not appropriate to simply screen all sites within the in the assessment process. Natural England advise that plan area. this section of the HRA should be amended to ensure all European sites within the study area are listed and there is clear documentation to illustrate which sites have not been taken through to the HRA screening of preferred plan options with a justification of this decision.

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Appendix 2K - Comments on HRA continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Natural R3.14 HRA Natural England suggest that detailed maps should be New maps included to address this. We provide Included new England provided and their location clearly referenced for each two example sets of maps based on the data maps in HRA preferred option in relation to all European sites (not just used in the dossiers mapping task. The first, those assessed as being potentially affected) to support ‘LandscapeBiodiversityContext_EuropeanSites’ and illustrate HRA screening decisions. is the same data and scales as the Landscape context dossier maps, but with only the European sites showing. The second example, ‘LandscapeBiodiversityContext_Concept_1’ is just the WRMP19 options scaled to each WRZ with the European Sites. Natural R3.15 HRA Not all the potential sensitivities of the European sites Noted. We have updated Table 4.2 with ref to site Updated England have been captured in Table 4.2. For example Sandwich management plans for all sites and update Table 4.2 Table 4.2 of Bay SAC is sensitive to hydrological change, water (and then Table 4.3). HRA pollution air quality and recreational disturbance. Table 4.2 should be amended accordingly and other sites checked for additional sensitivities. The screening of options and potential in-combination effects provided in Table 4.3 and the European baseline information in Table A1 should be amended accordingly. It would be beneficial to refer to the Site Improvement Plans (SIPS) when revising these tables. http://publications.naturalengland. org.uk/category/6149691318206464. Natural R3.16 HRA Page 24 of the HRA states that ‘none of the water We have created a new appendix and have screened New England efficiency and improvement scheme options would likely the 91 water efficiency and demand management Appendix cause significant effects to European sites, based on options using Tysley (2009) categories. Added to their discreet nature and scale, measures should be put HRA in place to minimise effects of these individual projects if any works take place within or close to a European site’. Natural England concurs that options for water efficiency and demand management are low risk however, the screening process should still be applied to these options and evidence (simple tables or lists of measures and why they would not have an effect) should be included within the HRA of the plan. southeastwater.co.uk 153

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Natural R3.17 HRA The use of mitigation to remove a likely significant effect The outcomes will not be affected because all sites Updated HRA England and avoid undertaking an appropriate assessment has requiring mitigation have been taken forward to been the subject to recent case law. Natural England appropriate assessment anyway. recommends that the HRA is reviewed in light of this However, we have updated text at paragraph 3.6 to case and that South East Water takes its own legal advice update methodology to be in line with the law. We on this. have also reviewed options potentially affected. This included Broad Oak which will now be Screened out not on the basis of a “detailed mitigation package” but on the basis studies will be done to identify appropriate abstraction amounts and limited to high flow only abstractions that will ensure no LSE. Natural R3.18 HRA There is insufficient information provided in the HRA See R3.19 - information has been inserted into the Updated HRA England regarding proposed alternative schemes and this does report to clarify the high-level situation with regards not reflect the extensive scenario testing carried out in to alternatives. developing alternative plans within the dWRMP itself. Natural England advise the HRA should more explicitly set out the alternatives for each of the schemes identified as requiring a ‘down the line’ appropriate assessment and include them in the dWRMP and SEA noting that they are the alternatives. Natural R3.19 HRA For the three desalination schemes and remaining The schemes are no longer included in our rWRMP19. Updated England effluent re-use scheme there are no alternative options Appendix A specified in the HRA. of HRA Natural R3.20 HRA HRA screening assessments for these alternative options These schemes are no longer included in our Updated England need to be presented in the HRA report and to have rWRMP19. Table 4.3 of concluded no likely significant effect in order to meet HRA the criteria set out above and for the dWRMP plan as a whole to meet the test within the Habitats Regulations. Natural England strongly recommend that these points are addressed, and any evidence gaps are filled, and are happy to advise the company further.

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Appendix 2K - Comments on HRA continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Natural R3.21 HRA We also have Marine Conservation Zone (MCZ) We will provide Screening for MCZ network (including None England assessments to provide as separate assessments rather the July 2018 round of MCZ sites currently undergoing than integrated - we will produce an annotated template consultation) and for sites that progress through to agree with NE as this is a new requirement. Screening a Stage 1 assessment template will be completed (and Stage 2 if necessary, but very unlikely) . Natural R3.6 HRA Further evidence is required to demonstrate fully how This is a request to show plan evolution since the Updated to England the HRA has influenced the development of the plan. Feasible Options stage. We will have provided a table Appendix A showing the iterations in the high-level filtering of of HRA the options in the Plan to get to the preferred Plan (i.e. that Appendix A deals with the HRA screening of). The initial filtering of options was based on a raft of constraints, of which potential issues with European Sites was one. Natural R3.7 HRA WRT down the line assessments, it is not clear what A screening category (Category F) has been created Updated to England alternatives would be selected if these later assessments as part of the development of new Screening criteria Appendix A are unable to conclude no adverse effect on integrity. that is allocated only to alternative options in the of HRA This must be amended for the final plan. HRA Screening table (an updated Appendix A) so it is easy to identify the alternative options. A new para headed “HRA screening assessment of alternative options” has been added to the report that clearly identifies the alternative options and explains that no LSEs have been identified for these options. Report to explain that the list of alternatives is a suite of options (e.g. desalination plants) and requirements (e.g. zonal strategies) for the whole scheme, therefore these have been considered together rather than substituting certain alternative(s) for a particular option in the Plan.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Natural R3.8 HRA Not all screening information is included within the HRA, Appendix A (the Screening assessment) has been Updated England so it is unclear if all likely significant effects have been restructured and revisited - a number of new headings Appendix A excluded on the basis of objective evidence. have been added and the table now clearly separates of HRA individual site assessments out. The table now lists site features, potential effects and a clear screening conclusion - so it is easier to follow the logic of the assessment. Also, a new ‘Screening category’ derived from new Screening criteria has been allocated to each assessment to help elucidate the reasoning behind the screening assessment. Natural R3.9 HRA Where appropriate assessments are identified, they In certain circumstances the updates to our rWRMP19 None England have not been undertaken but instead the plan relies preferred plan have removed the need for ‘down the heavily on assessments carried out throughout the line’ assessments as schemes of concern are no longer lifetime of the plan. Plan level appropriate assessments part of rWRMP19. are preferable to this ‘down the line’ approach, reliance on this latter increases the uncertainty of the plans deliverability. Natural R3.10 HRA There is a lack of clarity around alternative options that In certain circumstances the updates to our rWRMP19 None England will be selected should the ‘down the line’ assessments preferred plan have removed the need for ‘down the be unable to conclude no adverse effects on integrity. line’ assessments as schemes of concern are no longer part of rWRMP19. Natural R3.11 HRA We recommend that the HRA is amended to identify See R3.10 - Appendix A has been restructured and Updated England where sites and specific features have been screened out revisited to address this comment - a number of new Appendix A from impacts with the reasoning clearly explained and headings have been added and the table now clearly of HRA evidenced. separates individual sites assessments outs and lists site features, effects and a clear screening conclusion. Also, a new Screening category has been added to help elucidate the reasoning behind the screening assessment.

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Appendix 2K - Comments on HRA continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Natural R3.12 HRA We note reference to the early consideration of impacts The Feasible options list was the penultimate stage of Update to England to European sites at feasible option stage in the HRA. the high level filtering (based on a number of project HRA Table 4.1 lists 33 European sites for consideration at this constraints, as described above) before the preferred stage. However it is unclear how these sites have been Plan options were selected for HRA screening. Sites selected, the screening and evidence for this must be may have been discounted earlier in the filtering included within the HRA. process owing to factors such as being flagged as potentially affecting a European Site, but preferred list is now being taken forward for detailed HRA screening. Clarity to be provided in the report and a table provided showing the iterations in the high- level filtering of the options in the Plan to get to the preferred Plan.

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Appendix 2L - WRP Tables

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.89 WRP Tables There is some differences as to how an option has been We note the lack of consistency for this option across Updated Agency - Option classed. For example a number of closing the gap options the plan and option lists etc. and will ensure this (and Appendix 7B, Selection are both Groundwater Enhancement - Within Licence other discrepancies) are corrected for the revised plan 7C and D and (e.g.: EGW-23, Britty Hill Closing the Gap) and New by changing the closing the gap options to Existing WRP Tables Groundwater (NGW-8, Woodgarston Closing the Gap). Groundwater (EGW) schemes. of rWRMP19 There is some differences as to how an option has been classed. For example a number of closing the gap options are both Groundwater Enhancement - Within Licence (e.g.: EGW-23, Britty Hill Closing the Gap) and New Groundwater (NGW-8, Woodgarston Closing the Gap). More consistent categorisation of options required. Environment R2.90 WRP Tables Some of the options are inconsistently named We note the lack of consistency for this option across Updated Agency - Option throughout as well as classified (as noted above). E.g. the plan and option lists etc. and will ensure this Appendix 7B, Selection ASR seems to be interchangeably named ASR Beenhams (and other discrepancies) are corrected for the 7C and D and Heath and ASR near Maidenhead. It would make it a lot revised plan. WRP Tables clearer and easier to follow the documents if this could of rWRMP19 be consistent. More consistent categorisation of options required.

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Appendix 2L - WRP Tables continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Environment R2.132 WRP Tables - Some options within Table WRP5 for dWRMP19 have We have updated some of our option costs since None Agency Tables very high AIC and AISC cost values above £1000p/m3. our draft plan, following an update of our “unit cost Potentially inaccurate data. Check of option values. database” costing tool. This has since changed some of our previous AISC values. We have checked the costs of options where AISC costs appear to be high and identified a couple of points: 1) Some demand management options have high AISC costs, this is due to the very small benefit in Ml/d that some water efficiency and leakage options are able to provide. This generates a very high AISC cost when these options have a higher than average costs to deliver them. 2) In Table 5 of the WRP tables, the AISC cost for a DYAA scenario is calculated using the average yield of an option. Where there DYAA yield of an option is substantially lower than the DYCP yield of an option, this can generate a high AISC cost. in the DYAA WRP tables. Environment R2.91 WRP Tables - The WRMP includes TUBs and NEUBs. There is not a table We have updated Table 10 to provide further Table 10 Agency Tables which explains all the levels, and it is hard to determine information requested. updated the LoS for EDO’s. The company should make it clearer in the plan for all levels of restrictions, possibly by including a table to show this.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Kent County A4.6 WRP Tables Query around Figure 2 and Appendix 5c. We have produced a new set of WRP Tables to support Council - Water our rWRMP19. The comments received on the WRP Demand Tables have been addressed as part of the updates. Environment R2.119 WRP Tables - The company have shaded grey the Worst Historic Design Agency Tables event row in each Table 10, but we believe the company are moving to using a stochastic one in 200 as the design event of the plan. It would have been beneficial for the company to have followed the guidance and shaded in yellow the cell that relates to deployable output 7FP on which the plan is based. The company should distinguish which drought scenario its plan is based on, i.e. one in 200 drought event, in Table 10. Environment R2.131 WRP Tables - Some options within Table WRP5 for dWRMP19 have Agency Tables missing AIC and AISC cost values for WRZ1 to WRZ8. Completion of cost information for all options within Table WRP5.

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Appendix 2M - Other Comments

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I8.2 Other Unable to have a meter fitted on property due to shared We are sorry it was not possible to install a meter at None Comments - pipe but believes properties in area would benefit from it. your property. Unfortunately this can be the case Metering when more than one property share a single supply pipe. Where we have not been able to fit a water meter in a home, we offer customers the option of paying an Assessed Charge instead. Assessed Charges are annual sums which reflect the estimated amount of water used, based on the number of bedrooms and the number of people living in the property. Despite it not being feasible to fit a water meter we still want to provide advice and support to unmetered customers. Further details can be found on our website. Individual I114.1 Other I like to ask when main drains are going to be put in the This consultation response relates to waste water None Comments - Romney Marsh Brenzett area. As the hole village would services. South East Water is a water supply company Other Water like it and so would neighbouring Villages. and so this query falls outside the scope of our Companies At the moment we have to deal with cesspit and a rWRMP19 and also outside of the wider company water hub at the end of the village. and there are scope. We recommend the respondent contacts more and more houses being built in our village and in the company that provides his/her waste water the neighbouring areas which means more and more services. water is being and we are having dirty water spread all throughout the village and the drains are generally constantly full.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I12.1 Other A frequent visitor to the Rivers Itchen and Meon noticed This consultation response is not related to our None Comments - over the past 25 years significant increases in the rWRMP19. It relates to a Southern Water’s proposals Other Water turbidity of the former and in the water levels of the concerning their Candover abstraction licence Companies latter. application. Individual I12.2 Other The water clarity issue is to some extent a consequence A copy of Southern Waters WRMP can be found on Comments - of the effects of diffuse pollution. its website. Other Water Companies Individual I12.3 Other The problems of both rivers is that of reduced water flow Comments - caused by abstraction, and in particular that from the Other Water aquifers. Companies Individual I12.4 Other Currently an application to abstract yet more water from Comments - the Test, Itchen and Candover catchments. Other Water Companies Individual I12.5 Other The exceptionally heavy reliance placed by South East Comments - Water on the aquifers as the main source of supply, surely Other Water investment in more surface reservoirs would be a more Companies prudent option. Individual I12.6 Other Could abstraction from the Test or Itchen be undertaken None Comments - closer to their estuaries, thus maintaining the upper river Other Water flows to the benefit of the environment? Companies

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Appendix 2M - Other Comments continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Newland S3.1 Other The River Windrush West Oxfordshire has deteriorated so This consultation response is not related to our None Angling Club Comments - much over the last ten years there are no swans minnows WRMP19. It relates to a river outside of our Water Other Water may flies very few fish and weed, no children fishing. It Supply area. We believe it is related to Thames Water. Companies has been polluted so often for so long that its a disgrace that the EA has let it go on, while Thames Water take the good water for resale. No restocking plans all though the companies have been fined; Aylesford P3.3 Other Would wish to see more information regarding Southern A copy of Southern Water’s dWRMP19 can be found None Parish Council Comments - Water plans on its website. Other Water Companies

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Appendix 2N - Other Matters

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Hampshire and S10.2 Other Matters We would encourage SEW to adopt an AIM scheme This is addressed in our business plan. AIM forms part None Isle of Wight - Abstraction looking at the scope to limit abstraction from those of our business plan commitments it does not form Wildlife Trust sources in the shorter term, wherever the option exists part of the rWRMP19. to preferentially abstract from other less vulnerable water sources instead. Council S1.1 Other A statement on whether adequate time and financial We can confirm that adequate timing and resources None for British Matters - resources are available deal with any archaeological will be available to manage archaeological aspects Archaeology Archaeological implications of projects. of projects. We operate in an archeologically rich South-East Impact area and as a result have well practiced processes and procedures. As part of this we carry out desk top studies using a dedicated GIS layer, surveys, excavations and post-excavations (including publication and in some cases display in local museums). Where appropriate we design schemes around areas of interest in order to preserve exceptionally important archaeological remains in situ. Environment R2.121 Other Matters Although the Plan and Appendices refer to the Basic VA We contacted the representative to clarify this None Agency - Basic VA (Which stands for xxx) as following guidance, no direct comment and they were unable to do so. On this basis supporting information is presented to support this we have not responded further or made changes to statement. The company should provide evidence in the our rWRMP19. plan to show it has followed the guidance. Individual I109.1 Other Matters Upgrade the existing below ground supply pipes in This is more related to capital maintenance of our None - Below Arlington village. network rather that water resources management ground assets planning. We will contact the individual to confirm what our plans in this area are. Individual I25.2 Other Matters Beware climate change - 2012 was dodgy and could easily Our plan included assessment of the impacts from None - Climate happen again. climate change, and more extreme but plausible Change droughts than experienced historically. We have used this information to ensure our plan delivers improved levels of resilience, allowing us to manage events that are similar to, and more extreme than, seen in 2012.

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Appendix 2N - Other Matters continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Kent Wildlife S12.5 Other Matters It is unclear whether the non-household demand Work by Water UK confirms the volumes of water None Trust and - Fracking forecast, which is somewhat lower than in WRMP14, required for hydraulic fracking are relatively small. Sussex Wildlife takes into account the potential for gas extraction by The water required for each fracking event will be Trust hydraulic fracking given the interest in the development collected by the fracking operators and stored in of this industry in the south east. advance on site. This means the impact on demand will be minimised and controlled through supplying water during low demand periods. The volume of water required for fracking can be managed and accommodated in our current supply- demand balance. However, our assessment of water needs to support fracking will be kept under constant review. Kent Wildlife S12.7 Other Matters We would like to see more comprehensive investigations Invasive Non Native Species form a key element of None Trust and - INNS into the contribution of SEW’s activity to invasive non- our business plan. Further details on our current and Sussex Wildlife native species (INNS) spread. future performance is contained within Appendix 10 Trust of our business plan. Individual I100.4 Other Matters Issues with smell at treatment works, hard water and This option is no longer part of our rWRMP19 None - Negative traffic. preferred plan. We understand it is still part of Southern Water’s long term plans, and we have passed on comments received to Southern Water. Kent Wildlife S12.2 Other We would see it as a positive step if SEW were to We can confirm that from 2020 we will have a new None Trust and Matters - Net investigate the feasibility of implementing a net environmental performance commitment that covers Sussex Wildlife biodiversity biodiversity gain policy. both the protection and enhancement of biodiversity. Trust gain Further details of this measure are contained in our business plan. Canterbury A1.1 Other Matters Comment on drinking water taps and fountains to reduce We are working with WaterUK to look at an industry- None City Council - Plastic use our dependency on plastic bottles. wide approach to support the positive momentum that is around reducing plastic bottles and plastic waste.

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Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA Individual I9.2 Other Matters Not enough in the strategy about reducing pollution. While South East Water takes it’s environmental None - Pollution Would like road run off directed into woodland. Run-off impact and responsibilities seriously, our activities from roads should be directed into woodland so as to to reduce and prevent pollution are not documented avoid river pollution after heavy rain. Not enough in the in our rWRMP19. They form part of our catchment strategy about reducing pollution. management work which is detailed both on our website and in our draft Business Plan, which will also be available on our website once it is published in September 2018. Individual I6.1 Other Matters Comment on whether population policy should be The population and property forecasts that support None - Population considered for the future plans. our plan have been prepared by Experian in liaison with local planning authorities. The forecasts comply fully with the WRMP guideline requirements and enable us to meet our existing statutory duty to supply all new homes. Operating in a water stressed region, we work closely with local planning authorities so they are well informed of where the challenges of meeting new housing and population growth is greatest. We engage proactively with local planning authorities on their local plan, design policies, water cycle strategies and infrastructure development plans to minimise the impact new housing might have as far as is practicable. South East S7.1 Other Matters A call for regional planning - To ensure the regional We agree that co-ordinated regional planning None Rivers Trust - Regional perspective is considered, we would welcome the is important. As part of the development of our Planning introduction of a statutory requirement for regional rWRMP19, we have worked closely with neighbouring WRMPs alongside the establishment of regional water companies within the south east region. This planning bodies that include customer and stakeholder regional modelling work has been used to influence representation. the approach and schemes we have included in our rWRMP19. We would welcome the implementation of a full regional planning process is being considered for dWRMP24.

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Appendix 2N - Other Matters continued

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA WWF-UK S9.19 Other Matters We’d like to see South East Water commit to We are already strongly committed to national and None - Regional participating in and promoting national and regional- regional scale water resources planning through the Planning scale water resources planning which works with other work we do as part of the Water Resources in the major water using sectors to assess future challenges South East Group; Water UK Long Term Planning and develop solutions. This planning should be guided Framework Steering Group; and the Environment by recommendations from the Environment Agency’s Agency’s WRMP Technical Advisory Group (which has WRMP24 initiative. recently started to turn its attention to dWRMP24). Ofwat R4.6 Other Matters While we welcome South East Water’s participation We consider that the work undertaken by the Water None - Regional in regional planning, we are disappointed that the Resources in the South East (WRSE) group has made Planning draft plans in the south east appear to miss a major very good progress towards understanding and opportunity to secure the long term resilience of the taking steps to improve levels of resilience across the region. We appreciate that this is not an issue for the region and deliver more cost effective and resilient company alone but expect South East Water to urgently solutions. We have used the work by WRSE to support work with others to seize the opportunity of regional our own rWRMP19. However, we do accept more work solutions to address challenges in the south east. These is required, and are pleased all the water companies solutions could have the potential to reduce costs, involved in WRSE are committed to developing the reduce environmental impact and improve resilience. regional work further for dWRMP24. Kent Wildlife S12.1 Other Matters We would like to see greater dedication to improving the Thank you for your comment, environmental None Trust and - Resilience resilience of the natural environment that SEW rely on resilience forms a key part of our business plan and Sussex Wildlife to operate and would urge SEW to use this opportunity environmental performance commitments. These Trust to adopt their own bespoke performance commitment are contained in detail within Appendix 10 of our related to the environment. business plan. Individual I101.2 Other Matters SEW should be looking at sewage disposal. To date we have considered a number of effluent None - Sewage re-use option in our rWRMP19 options appraisal and preferred plan modelling exercises. Aylesford P3.2 Other Matters There is a need for water resources to work in We fully agree and we will continue to engage and None Parish Council - Sewage conjunction with wastewater. work closely with waste water companies to ensure our plans are compatible and clearly understood. Hampshire and S10.3 Other Matters We suggest that a ‘towards water neutrality’ Following the adoption of more ambitious levels of None Isle of Wight - Sustainable Performance Commitment should be adopted by those demand management in our rWRMP19 we have taken Wildlife Trust abstraction five companies as a bespoke environmental PC, in order a significant step towards achieving water neutrality to increase efforts to counter this trend. at a company level. southeastwater.co.uk 167

Organisation Representation Comment Summary of Comment Our Response Changes to Reference Type dWRMP/ SEA/HRA WWF-UK S9.15 Other Matters We can find no reference to the Abstraction Incentive AIM forms part of our business plan commitments it None - Sustainable Mechanism in the plan (despite it being referenced in does not form part of this WRMP. abstraction the Glossary), and would like to know if this has been considered or not in the plan preparation. Individual I91.5 Other Would appreciate tree screening of the pump houses on Comment noted, tree screening will be considered at None Matters - Tree the A291. the detailed design phase for the scheme. Screening Individual I110.1 Other Matters WRZ’s should be reconsidered. WRZs are key building blocks in a WRMP. They are None - Water reviewed as part of the WRZ integrity analysis at the Resource start of the WRMP process. For our rWRMP19, there Zones was not sufficient evidence to support a change to the WRZ boundaries against the WRZ integrity assessment criteria. As best practice, we will review again in preparation for dWRMP24.

Draft Water Resources Management Plan 2020 to 2080 – Statement of Response