Anglian Water revised dWRMP 2019 STATEMENT OF RESPONSE ANGLIAN WATER REVISED DWRMP 2019 - STATEMENT OF RESPONSE
We sought the views of our customers and This document has been published in two formats: stakeholders on our draft Water Resources Management Plan (WRMP) between March • A spreadsheet, where responses can be filtered and June 2018. In this Statement of Response, by topic and respondent we explain how we have revised our WRMP in response to customer and stakeholder views, • A PDF version for printing including feedback on our technical analysis from the Environment Agency, Ofwat and the Consumer This document should be read in conjunction with Council for Water. our revised dWRMP.
We received responses from:
• Bedford Borough Council
• Buckinghamshire County Council
• Central Bedfordshire Council
• Campaign to Protect Rural England (Norfolk)
• Canal & River Trust
• Environment Agency
• East Suffolk Growth Programme Board
• Greater Lincolnshire Local Enterprise Partnership
• Huntingdonshire District Council
• Lincolnshire County Council
• Natural England
• NFU
• Ofwat
• Philips 66
• RSPB
• RWE Generation
• South Holland District Council
• Tendring District Council
• The Water Retail Company
• Waterlevel Limited
2 Anglian Water dWRMP Statement of Response
Ref Organisation Respondent Comment Anglian Water Response/ Action For more detail No. 1 Affinity Water Affinity Water has requested at both pre-consultation and now during consultation the We have held a number of meetings and telephone discussions with Affinity Water in preparing our revised n/a confirmed DO reductions for Grafham, Affinity Water require these profiles and the basis for dWRMP. We provided an updated profile of climate change impacts along with a written explanation on 26th them in order that the EBSD modelling is consistent. At dWRMP19 Affinity Water assumed June 2018. the worst case, but in order that consistency can be confirmed that both parties are applying the same reductions the supporting rationale and climate change work will need to be reviewed by Affinity Water.
2 Affinity Water We can confirm, that at this time aside from modified terms with existing Ardleigh and We have held a number of meetings and telephone discussions with Affinity Water in preparing our revised Revised dWRMP - Grafham agreements, there is only one additional option for consideration between Anglian dWRMP. We have included the 50 Ml/d export to Affinity Water as a scenario in our stress-testing and long- Chapter 6 and 7 Water and Affinity Water. This is for a new import of 50Ml/d from Anglian Water to Affinity term EBSD runs. In addition, we will include it in our adaptive planning. Water. We will maintain communications throughout the on-going modelling phase and share the status of this scheme, and if required at what date. It is possible that this scheme could be included within the revised plans as an ‘adaptive option’, which could be developed further should alternative more feasible options not progress over time.
3 Affinity Water It is important that Anglian Water provide Affinity Water with the associated ‘upstream’ costs We have held a number of meetings and telephone discussions with Affinity Water in preparing our revised n/a for supplying this additional [50Ml/d] import. At pre-consultation, the options meetings dWRMP. Now that we have concluded the modelling for our revised dWRMP and finalised our planning included this request and at the recent meeting (22nd May 2018) the request was made solution, we are able to model and provide costs for the export to Affinity Water. We aim to provide these by again. Currently, the Affinity Water EBSD modelling is using a surrogate cost, in the absence the end of September 2018. of an Anglian Water cost. For some degree of confidence to be attained in the costs for this particular option, Anglian Water will need to provide improved cost estimates for the Affinity Water EBSD modelling, until which time it remains difficult to optimise against alternative imports where Affinity Water do have clearer visibility over potential upstream costs.
4 Bedford Council officers support AWS’s approach of planning to meet local authority growth targets. We have used the latest local authority growth targets as the basis of forecasting population within our Technical Borough Council demand forecast. We will continue to work closely with local authorities in our region to monitor on-going documents: housing delivery against targets. Further detail is provided in the Demand Forecast technical supporting Demand Forecast report. 5 Bedford Yes, AWS is right to prioritise demand management, but the demand savings need to be We have continued to prioritise demand management within our dWRMP as described in Chapter 4. We have Technical Borough Council regularly reviewed to ensure that they remain on target. included supply options in the form of transfers and will continue to explore resource options over the next documents: five years. Further detail is provided in the Demand Management Strategy technical document. Demand Management Strategy 6 Bedford Compulsory metering is not always possible to all properties, especially those with shared We have considered the range of views expressed regarding compulsory metering during our consultation, as Technical Borough Council supplies. Perhaps a compromise? well as a wider analysis of the costs and benefits (as described in the Demand Management Strategy technical documents: document). We have also taken into account our high level of meter penetration (which is forecast to reach Demand 93% of households metered and 86% paying measured charges by 2020). As a result, we have not included Management compulsory metering in our revised dWRMP. We will continue to monitor the proportion of customers billed Strategy based on a meter reading and will review the need for compulsory metering at WRMP 2024.
7 Bedford Council officers consider that the investment programme should include this additional Please refer to the revised dWRMP for details of our new adaptive planning approach. We have included Revised dWRMP - Borough Council [Adaptive Planning] investment. investment for this approach in our PR19 Business Plan. Chapter 8
3 edford es, this . p a average bill increase for drought resilience is an acceptable strategy as ur revised dW position on severe drought remains the same as for the dW we will ensure that all evised dW orough Council rota cuts and standpipes are unli ely to be popular in a severe drought event, leading to of our customers have a . annual average ris of severe restrictions, from . Chapter significant reputational issues and logistical problems to solve. usiness lan
edford Can a compromise be considered Could there be some investment from onwards It is ollowing the consultation on our dW we have chosen not to defer investments in climate change evised dW orough Council appreciated that this could affect investment across two different A periods though. impacts until and have accommodated these impacts within our referred lan with a residual ris Chapter and in the South uthamford W that we are managing via preparation for a rought ermit application . ur dW supply forecast modelled climate change impacts from onwards. or our revised dW we have included climate change impacts from the start of the W planning period .
uc inghamshir We support the approach of planning to meet local authority growth targets rather than We have used the latest local authority growth targets as the basis of forecasting population within our echnical e County using trend based pro ections. demand forecast. We will continue to wor closely with local authorities in our region to monitor on going documents Council housing delivery against targets. urther detail is provided in the emand orecast technical supporting emand orecast report. uc inghamshir he demand management strategy being based on both action by Anglian Water and We have continued to prioritise demand management within our dW as described in Chapter . We have echnical e County crucially by the customers in ta ing responsibility for their own water demand and included supply options in the form of transfers and will continue to e plore resource options over the ne t documents Council management should be a ey priority going forward. he introduction of smart metering is a five years. urther detail is provided in the emand anagement Strategy technical document. emand good way forward in this area. anagement Strategy uc inghamshir It would be good to consider compulsory metering in A . ore information of the We have considered the range of views e pressed regarding compulsory metering during our consultation, as echnical e County benefits of this and the pro ected reduction in demand would be useful, alongside the well as a wider analysis of the costs and benefits as described in the emand anagement Strategy technical documents Council reasons for why this is not seen as the right strategy. document . We have also ta en into account our high level of meter penetration which is forecast to reach emand of households metered and paying measured charges by . As a result, we have not included anagement compulsory metering in our revised dW . We will continue to monitor the proportion of customers billed Strategy based on a meter reading and will review the need for compulsory metering at W .
uc inghamshir Additional investment should be ept on the table as an option and re considered on a We will continually review our future investment re uirements as part of our adaptive planning approach. evised dW e County regular basis. he uplift in annual bills per household is small and the benefits that the e tra Chapter Council investment would secure are large, ma ing this an attractive option.
uc inghamshir he resilience to drought and a small charge per household per annum seems a reasonable ur revised dW position on severe drought remains the same as for the dW we will ensure that all evised dW e County strategy. Is the charge in addition to the e tra charge mentioned in point of our customers have a . annual average ris of severe restrictions, from . Chapter Council uc inghamshir he investment in climate change resilience should not be deferred but implemented as soon ollowing the consultation on our dW we have chosen not to defer investments in climate change echnical e County as possible. impacts until and have accommodated these impacts within our referred lan with a residual ris documents Council in the South uthamford W that we are managing via preparation for a rought ermit application . ur Supply orecast dW supply forecast modelled climate change impacts from onwards. or our revised dW we have included climate change impacts from the start of the W planning period .
uc inghamshir he ambitious lea age reduction programme and the intention to wor with developers to hese are retained in the revised dW . n a e County ensure that new housing is as water efficient as possible are both welcomed. Council
4 uc inghamshir Ambition is to prevent deterioration in W status. It would be good to see an ambition for Anglian Water is committed to delivering both improvements to water bodies, and preventing deterioration evised dW e County delivering improvement in W status of water bodies. of water bodies. In A , we will be delivering our largest ever programme of improvement schemes, as well Chapter Council as carrying out investigations and options appraisals to loo at other areas that may need further improvement. We also have various environmental initiatives such as our lourishing nvironment rant, and echnical iver Care. documents Sustainable Abstraction
uc inghamshir With regard to integration of natural and social capital accounting in the optioneering for the We will ma e this available to our regulators and more generally on re uest. Available on e County W to better understand environmental valuation of natural assets. his is mentioned in re uest Council the Strategic nvironmental Assessment but where is the supporting documentation for the cosystem Services Assessment uc inghamshir It would be useful to have more detail on what the recommissioning of o cote would entail. he recommissioning of the reservoir at o cote no longer appears in our referred lan. As part of our echnical e County adaptive planning process and preparation for W we will wor with the nvironment Agency to documents Council assess in further detail, where appropriate, the environmental assessments and mitigation re uired for Supply side individual options. ption evelopment uc inghamshir Any recommissioning or construction of new reservoirs would re uire lood is We are aware of the re uirement to complete lood is Assessments, which have already been completed evised dW e County Assessments in addition to geotechnical investigations mentioned. for some reservoir options as part of our adaptive planning process. We only underta e these assessments at Chapter Council site selection stage and not for all the options considered in the W process. We have updated the Section . . narrative in our revised dW to include flood ris assessments as well as geotechnical investigations.
Canal iver aving reviewed the Anglian Water dW we are encouraged that canal transfer he differences in costs are those associated with our subse uent actions including abstraction, pumping, pre echnical rust schemes have been assessed as feasible options. owever, in our opinion there are treatment etc. documents une plained discrepancies in the cost information provided and the assumed yields on the Supply side proposed canal schemes. In terms of the yield benefit of options, the canal transfers are limited by storage availability and networ ption constrains within uthamford. We have sufficient treatment capacity in uthamford orth and therefore we evelopment We also believe that investment into canal schemes will allow the waterways to contribute would be using such a transfer to maintain storage levels. Whilst the rust is welcome to submit proposals for fully in delivering significant social and economic outcomes and this should be included in a smaller transfer this may give yet smaller benefits because there is a non linear relationship between Anglian Water’s assessment of all feasible options. This will ensure their customers, additional transfers and Water esource System deployable output. regulators and sta eholders have greater transparency on future supply and demand investment decisions. In addition, we would re uire assurances about the reliability of the yields offered, particularly with reference to severe droughts.
Canal iver We also understand that Anglian Water have calculated social and environmental costs or We have calculated a number of social and environmental costs and benefits as part of our appraisal process. n a rust benefits associated with any of the supply demand options, to inform their preferred plan. Anglian Water have provided a consolidated brea down of these costs, but it is not clear how We welcome further information from the rust on benefits specific to waterways. benefits are calculated, if at all. We feel that this lac of clarity has the potential to disadvantage proposed canal schemes.
It is widely recognised that vibrant waterways significantly contribute to economic development, social welfare, wellbeing, environmental enhancement and community benefit. y e cluding these positive impacts in their assessments, Anglian Water are not reflecting the full value of canal transfers in their draft plan.
5 anal i er We were please to see that both canal schemes were eeme technicall an The iel benefits of the canal options are limite an the total costs are relati el higher than the options n a Trust en ironmentall feasible b Anglian Water reference abo e , but isappointe that neither selecte in our referre lan. of the schemes are propose in their preferre plan. n a ition, we woul re uire assurances about the reliabilit of the iel s offere , particularl with reference to se ere roughts. anal i er When anal sing the etail within the plan, the following uestions The ifferences in costs are those associate with our subse uent actions inclu ing abstraction, pumping, pre Technical Trust are raise treatment etc. ocuments . Wh is there a significant increase in the assesse schemes ape an pe compare to uppl si e those originall propose b the Trust n terms of the iel benefit of options, the canal transfers are limite b storage a ailabilit an networ ption constrains within uthamfor . We ha e sufficient treatment capacit in uthamfor orth an therefore we e elopment . Wh is there a ifference in the option benefit l to those originall propose b the woul be using such a transfer to maintain storage le els. Whilst the Trust is welcome to submit proposals for Trust a smaller transfer that this ma gi e et smaller benefits because there is a non linear relationship between a itional transfers an Water esource stem eplo able output.
anal i er There is a significant ifference in the ape an pe figures in the ar et nformation The ar et nformation tables represent the whole life costs of the options, ta ing into account factors such Technical Trust tables from those originall propose b the Trust for these schemes which is shown b the as asset renewal an on going operational costs in contrast the W summaries ocument pro i es initial, in ocuments estimate increase in A . There is no clarit or e planation for this ariance within the raft ear or annual costs onl . uppl si e plan an can onl assume the it is ue to Anglian Water treatment an istribution costs but ption are not certain. e elopment
The Trust woul li e greater transparenc on how these schemes ha e been assesse to ensure that the optimum suppl solutions are e elope for Anglian Waters customers.
anal i er ince publishing their W , Anglian Water ha e informe the Trust that the options n terms of the iel benefit of options, the canal transfers are limite b storage a ailabilit an networ Technical Trust benefit of . l was use for both schemes as efine b the eplo able output gain constrains within uthamfor . We ha e sufficient treatment capacit in uthamfor orth an therefore we ocuments from itsfor reser oir. f Anglian Water ha informe the Trust of this re uirement earlier, woul be using such a transfer to maintain storage le els. Whilst the Trust is welcome to submit proposals for uppl si e we woul not ha e propose the two pre iousl mentione schemes. The Trust will now a smaller transfer this ma gi e et smaller benefits because there is a non linear relationship between ption e elop a costing summar for a l canal transfer to the uthamfor W an woul a itional transfers an Water esource stem eplo able output. e elopment li e assurances from Anglian Water that this will be e aluate fairl an consistentl against other suppl options. n a ition, we woul re uire assurances about the reliabilit of the iel s offere , particularl with reference to se ere roughts.
anal i er Whilst the Trust are supporti e of their inclusi e approach, we will re uire reassurance that ee the responses to the specific anal an i er Trust comments. n a Trust the propose canal schemes ha e been assesse fairl an consistentl with other suppl options.
The Trust woul li e Anglian Water to consi er the following summarise e points in preparation of their re ise raft an final plans nclusion of uantifie social an en ironmental costs an benefits for all feasible schemes ro i e greater cost transparenc on the assessment of canal schemes an the assumptions ma e, ensuring that the optimum suppl solutions are e elope for Anglian Water customers an ro i e assurances that a Trust proposal for a l ariant to T an T options will be assesse an e aluate consistentl against other suppl options.
6 entral We woul see the inclusion of wor ing in the W offering strong support for ocal lan hanges to ocal planning efficienc stan ar s re ucing current stipulations from l h to l h an Technical e for shire policies which re uire the higher water efficienc stan ar as a means to re uce eman . below , esigne to increase efficienc are acti el supporte an encourage . ocuments ouncil eman The Council’s Submission Local Plan includes a Climate Change and Sustainability policy We monitor the current status ocal Authorities esign efficienc stan ar s , across the region. as etaile in anagement which supports minimising water usage through high water efficienc stan ar s litres the re ise eman anagement trateg eport. trateg ection per person per a an see s a water sensiti e approach to the esign of all new . . e elopments. We are also loo ing to encourage e elopers to in estigate the potential for gre blac water reuse, with incenti es being consi ere . entral entral e for shire ouncil support the twin trac approach to mitigate suppl eman ris This approach remains the same in our re ise W . n a e for shire an the prioritisation of eman management through the installation of smart meters an ouncil the re uction in lea age, o er increasing suppl .
orfol t shoul be mentione that another change in the raft lan is to re efine the areas of the We ha e pro i e a new chapter on Water esource one integrit an a comprehensi e map igure . e ise W e isting Water esource ones but while the maps mentione abo e map at igures . , an table . escribing the changes. hapter . elineate the new boun aries, the are not labelle on these or elsewhere.
orfol We note that with the eman management measures in the preferre lan AW is confi ent We ha e use the latest local authorit growth targets as the basis of forecasting population within our Technical to more than satisf the planne growth an this approach is both sensible an appropriate. eman forecast. We will continue to wor closel with local authorities in our region to monitor on going ocuments housing eli er against targets. urther etail is pro i e in the eman orecast technical supporting eman orecast We a howe er that AW shoul continue to trac housing eli er , an that an continuing report. shortfall in eli er coul offer some fle ibilit for other relate uses.
orfol o in summar , orfol strongl supports Anglian Water in their approach to prioritise We ha e continue to prioritise eman management within our W as escribe in hapter . We ha e Technical eman management of water resource. inclu e suppl options in the form of transfers an will continue to e plore resource options o er the ne t ocuments fi e ears. urther etail is pro i e in the eman anagement trateg technical ocument. eman anagement trateg orfol There shoul be no e emptions to metering. We ha e consi ere the range of iews e presse regar ing compulsor metering uring our consultation, as Technical well as a wi er anal sis of the costs an benefits as escribe in the eman anagement trateg technical ocuments There is a nee to start this approach with A , the upcoming business plan for ocument . We ha e also ta en into account our high le el of meter penetration which is forecast to reach eman but if not then, in the following fi e ears. The intro uction coul come in the form of of househol s metere an pa ing measure charges b . As a result, we ha e not inclu e anagement a pilot scheme in a count we sa count because that has more public recognition in compulsor metering in our re ise W . We will continue to monitor the proportion of customers bille trateg progressing a scheme. urther we suggest that orfol is a strong conten er for base on a meter rea ing an will re iew the nee for compulsor metering at W . implementing a pilot scheme as it faces the whole spectrum of challenges, an we suggest the greatest public awareness on the issues.
orfol orfol strongl supports the retention unchange of the W , as o man ur re ise W commits to the eli er of all sustainabilit re uctions inclu e in W an the e ise W organisations, albeit there ma be pressures to wea en as being unnecessar re tape. ut capping of all groun water licences to ensure sustainable le els of abstraction. We are committe to hapter the lan has to assume that the remain. eli ering these changes between an .
n summar then, in response to , orfol consi ers that the in estment proofing for We will continue to in estigate the potential for further sustainabilit re uctions as part of our a apti e sustainabilit re uction is integral to the lan re uirements, an is not an a itional option. planning.
orfol rought proofing shoul also be ta en as an integral part of the lan. This is something the ur re ise W position on se ere rought remains the same as for the W we will ensure that all e ise W public woul want an e pect an shoul remo e pressure from the public an politicians of our customers ha e a . annual a erage ris of se ere restrictions, from . hapter that river flows, wildlife and landscapes should take the ‘knock’ in a drought event.
7 CP orfolk There is a case for deferring climate change work as stated above to . t would allow ollowing the consultation on our d P we have chosen not to defer investments in climate change Technical nglian ater to incorporate the Climate Pro ections which are to be launched impacts until and have accommodated these impacts within our Preferred Plan with a residual risk documents formally in ovember . eferring climate changes impacts however increase the risks in the South uthamford that we are managing via preparation for a rought Permit application . ur Supply orecast including rota cuts and standpipes in the short term compared to the preferred strategy. d P supply forecast modelled climate change impacts from onwards. or our revised d P we have included climate change impacts from the start of the P planning period . CP orfolk suggest that there is a fine balance here, but delay should lead to a better and more effective long term Plan, with better data and less uncertainty, and this should be given e will review the Climate Change Pro ections during our preparations for P . due weight.
ast Suffolk The SGPB therefore endorses Anglian Water’s approach to using local plans as the most e have used the latest local authority growth targets as the basis of forecasting population within our Technical Council comprehensive source documents, supported by significant analysis, and these should demand forecast. e will continue to work closely with local authorities in our region to monitor on going documents continue to be used to inform investment proposals by infrastructure providers. housing delivery against targets. urther detail is provided in the emand orecast technical supporting emand orecast report. ast Suffolk e note that of the water resource ones out of a total of s that are e pected to e have continued to prioritise demand management within our d P as described in Chapter . e have n a Council face large deficits in supply from onwards are in Suffolk ury averhill ast included supply options in the form of transfers and will continue to e plore resource options over the ne t Suffolk . s a result, while an overall demand management approach can be taken, five years. nglian ater must continue to prioritise investment in securing supply particularly in those areas that have already been identified as having an imbalance. e welcome the two supply side transfer initiatives that are proposed S for these s.
ast Suffolk s a predominately public sector board we do not have a view on compulsory metering. n a n a Council ast Suffolk t would be useful to compare this increased cost to the worst case future investment ur revised d P commits to the delivery of all sustainability reductions included in P and the evised d P Council requirement if this £88m is not invested in the short term (by 2025) – i.e. in the short term capping of all groundwater licences to ensure sustainable levels of abstraction. e are committed to Chapter there is a savings of per customer but over the longer term this could increase to delivering these changes between and . additional cost. e will continue to investigate the potential for further sustainability reductions as part of our adaptive planning. ast Suffolk This uestion relates to the balance of demand and supply side measures that are proposed ur revised d P position on severe drought remains the same as for the d P we will ensure that all evised d P Council by nglian ater and the associated costs to the customer. The S P , as a predominately of our customers have a . annual average risk of severe restrictions, from . Chapter public sector board, is keen to ensure that nglian ater e plore all opportunities to ensure all customers receive the highest level of service at a competitive cost.
ast Suffolk hile the S P recognise the merits in delaying investment in specific climate change ollowing the consultation on our d P we have chosen not to defer investments in climate change evised d P Council measures to await further evidence collection and analysis, we would not want to see impacts until and have accommodated these impacts within our Preferred Plan with a residual risk Chapter and prohibitive restrictions, e.g. rota cuts standpipes, implemented should we face a water in the South uthamford that we are managing via preparation for a rought Permit application . ur shortfall in the si year period . ased on the data presented in the report the d P supply forecast modelled climate change impacts from onwards. or our revised d P overall cape saving of m e uates to a per customer saving of . p.a. or . over we have included climate change impacts from the start of the P planning period . the si year period of delay.
Should we face a severe drought and water is cut off, particularly to rural areas, is the cost, both financial and non financial in terms of disruption and public hygiene, likely to be more than . per household
8 nvironment ecommendation The company should produce a ne truly resilient long term strategic We have produced a revised plan that addresses all ey ris s. etails are provided in response to specific evised dW P Agency plan that ensures climate change time limited licences and other ris s are incorporated points. hapter 2 and There are a number of specific ris s and uncertainties identified throughout this plan hich affect the supply demand balance and in combination could lead to deficits both in the Technical initial part of the plan and in the longer term. Whilst identified else here in this report these documents issues have been dra n together in an over arching recommendation. eferences to the Supply orecast issues else here in this report containing supporting detail have been included so the detail and Sustainable is not duplicated. Abstraction
nvironment The company should demonstrate its best understanding of the supply demand balance We have no incorporated these ris s into the first five years of the planning period. n summary evised dW P Agency through the full planning hori on. The company should produce a revised plan that hapter 2 and climate change has been brought for ard to 2020 2 includes the impact of climate change impacts from the beginning of the planning period time limited licence reductions have no been considered in 2022 in the main plan rather than in our Technical include the ris associated ith rene als of time limited licences on more restrictive terms Adaptive Plan scenario in A P8 along ith a cap to all ground ater sources to reflect the future licence documents changes these are li ely to e perience Supply orecast delivers all measures required by the W P and to meet e isting obligations and Sustainable current modelling suggests the full all yield is resilient to a in 00 year event. This Water esource one Abstraction ensures transfers are consistent ith neighbouring companies only becomes resilient to a in 200 year drought event after investment in 202
ensures deployable output is correct. e have engaged ith detailed discussions ith our neighbouring ater companies to agree final trading numbers t is possible that the improved methods the company has adopted for this plan have resulted in deficits hich previously did not e ist. Where these deficits occur in the initial these changes have all been represented in our Aquator system model and deployable output recalculated years of the plan they may be difficult to resolve and the company should identify these for all scenarios. comment on differences bet een old and ne method small clearly and outline its approach to close the deficits as quic ly as possible. e have identified residual supply demand deficit in South sse and uthamford South and e have sought to manage this through short term solutions. This is discussed in chapter .
5 nvironment .2 is of supply demand deficits due to on going uncertainty The deliverability of options is assessed as part of the options appraisal process as detailed in the Supply evised dW P Agency ption evelopment and emand anagement Strategy supporting technical documents. hapter A number of ey uncertainties remain in deliverability of schemes and options. These include
• suitable timescales are allowed for the development of strategic options (see ecommendation )
9 nvironment is of suppl demand deficits due to on going uncertaint dditional detail has now been included regarding the lea age savings found in the smart meter trials along echnical genc with those e pected from other lea age interventions documents number of e uncertainties remain in deliverabilit of schemes and options hese emand include urther scenario testing (with reduced demand management reductions has been conducted and described anagement in the emand anagement trateg eport trateg • considering risk that the demand and leakage management strategy will not deliver savings as planned (see ecommendation mprovement is s and issues have been identified and the plan will be progressed with metrics identified and continuous monitoring strategies in place such that alternate mitigations can be enacted if e pected savings do not materialise nvironment he compan should complete wor identified as part of the specified recommendations and he deliverabilit of options is assessed as part of the options appraisal process as detailed in the uppl evised d genc improvements to consider ris s of implementation of options ption evelopment and emand anagement trateg technical documents hapter and he compan should produce one plan to address these ris s and uncertainties to provide confidence in securit of supplies and clarit to regulators and sta eholders n addition we have considered ris s associated with the demand management options b stress testing our preferred plan using lower levels of demand ( and
nvironment is of suppl demand deficits due to ongoing uncertaint e have underta en further wor to uantif uncertaint and ris e have updated the assessment of the evised d genc challenges we face in light of the consultation hapter number of e uncertainties remain in deliverabilit of schemes and options hese include
• the scale of the problems the company faces and what is driving them (Improvement 1).
nvironment verriding of scaling e uation dela s investment ollowing the consultation on our d we have chosen not to defer investments in climate change evised d genc impacts until ur d suppl forecast modelled climate change impacts from onwards hapter and he compan has adopted the nvironment genc scaling e uation as outlined in the but for our revised d we have included climate change impacts from the start of the planning supplementar note but has amended the glide path so that all climate change impacts are period ( echnical dela ed until he compan has underta en this to allow choice between suppl documents demand balance options including climate change impacts from the start of the planning period we do not have sufficient time to uppl orecast he compan is also consulting with customers about e tending the deferral to invest in uthamford outh s a result we are reporting a suppl demand deficit in the first four ears of e have sought to manage this ris through preparation for a rought ermit application his is nglian ater should not hide potential deficits in resource ones b moving the impacts of discussed in chapter climate change he compan must include the impacts of climate change as set out in the guidance and ensure it has options to cope with them f it does not it will need to tell its customers and change the planned level of service
nvironment omplete modelling of all selected climate change pro ections n order to assess the climate change scenarios in the most efficient manner all were run through our echnical genc rainfall runoff models and groundwater models to assess impact on surface water and groundwater ields documents hilst considerable climate change wor has been underta en b the compan much of this respectivel his allowed a representative selection of scenarios to be identified for use in the uator uppl orecast is underta en using its previous source wor s models and onl limited wor appears to have impact assessment been implemented within uator f the climate change pro ections previousl modelled have been selected for modelling within uator including a single pro ection representing the best estimate and a further two “high” and two “low” scenarios to inform uncertaint
10 1 nvironment he company should run the full range of climate change pro ections for the appropriate tier e believe that it is ade uate to select the best estimate and headroom runs on the basis of the climate echnical gency through its baseline model and select the most appropriate pro ection from outputs as the change pro ections and the modelling of the impact on yield (e.g. in rainfall runoff models). In addition we documents best estimate. his will also allow greater definition of uncertainty for use within headroom. have reviewed the results of the simulator modelling. unning all of the climate change pro ections upply orecast through would be very time consuming and would not provide much additional information especially as pro ections often overlap. nvironment . hoice of climate change tier in conte t of problem characterisation e have updated the upply orecast technical document to provide further ustification for ier echnical gency application. documents he company has adopted a tier approach to climate change assessment but on the basis upply orecast of a pilot study making a comparison with tier in a sample catchment. he company believes tier to present a greater range of uncertainties than tier .
ier use of spatially coherent pro ections has been adopted company wide for all climate change work.
he company has undertaken a tier approach informed by a tier assessment. his is not fully compliant with the guidance.
he company should present further evidence and ustification should it wish to continue with its adopted tier approach albeit supported by the pilot study to confirm this is suitable for the whole company area.
nvironment . utline how climate change pro ections inform headroom distribution of uncertainty. e e plored a number of potential candidates from among the patially oherent ro ections for high and echnical gency low pro ections to inform the headroom distribution. e selected igh 1 and ow . ull details of the documents here is little information on how the selected climate change pro ections have been used to volumetric impacts are provided in the anaging ncertainty and isk supporting technical report. anaging represent uncertainty within headroom. ncertainty and isk he headroom assessment lacks clarity as it is poorly documented.
nvironment epresentation of climate change uncertainties within headroom should be fully presented. e e plored a number of potential candidates from among the patially oherent ro ections for high and echnical gency his should build upon the completion of the work identified in ecommendation 1 above. low pro ections to inform the headroom distribution. e selected igh 1 and ow . ull details of the documents volumetric impacts are provided in the anaging ncertainty and isk supporting technical report. anaging ncertainty and isk nvironment he reporting is confused due to the parallel assessments of climate change using the ll of the climate change assessments have been carried out using our updated rainfall runoff models for evised d gency company’s old model assessment and new assessment approaches. river flows and groundwater models for groundwater yields which have then been used in uator for hapter assessment. his builds on our previous work for the 1 . e have updated the reporting of climate here is a lack of clarity in the reporting with the assessment of climate change. change in the revised d and supporting upply orecast technical document to improve the clarity of echnical this e planation. documents Improve reporting on assessment of climate change upply orecast
nvironment ecommendation hen producing its final plan the company must clearly demonstrate dditional detail has now been provided regarding the assessment of the options with data to support the echnical gency options are viable and they can be implemented in time (linked to irections (f) and (h)) current assumptions that inform the options. documents emand etail regarding the demand strategy rollout and delivery programmes has been included showing the anagement geographic distribution of smart meter installations the respective customer cohorts that will be targeted by trategy water efficient measures and the targeting of leakage programmes.
11 n ronment . rect on rther data re ard n the costs o the meter n opt ons the rea down o the component meter n echn cal ency pro rammes and the r rollo t ha e een ncl ded n the e sed emand ana ement trate y eport. doc ments he company has not presented clear n ormat on on the costs o ts c rrent meter n emand strate y or optants and chan e o occ p er wh ch s a cont n at on o e st n company ana ement pol cy altho h some o th s appears n np l shed deta led cost n s reports. trate y ect on . he company m st present rele ant costs or ts on o n meter n strate y.
n ronment e ha e ta en the dec s on to pr or t se demand mana ement opt ons ollow n cons ltat on w th o r echn cal ency n add t on the company has not pro ded a clear compar son o s pply opt ons compared to c stomers and re lators as descr ed n hapter . s s ch we ha e not d rectly compared demand and doc ments meter n and other water demand mana ement opt ons. s pply opt ons. emand ana ement trate y n ronment he company m st present clear n ormat on on the costs o the d erent meter n opt ons e ha e ta en the dec s on to pr or t se demand mana ement opt ons ollow n cons ltat on w th o r echn cal ency and the r compar son w th alternat e opt ons to alance s pply and demand. c stomers and re lators as descr ed n hapter . s s ch we ha e not d rectly compared demand and doc ments s pply opt ons. emand ana ement dd t onal deta l re ard n the cost and rollo t o the component meter n pro rammes has een deta led n trate y ect on the emand ana ement trate y eport . . n ronment . rect on h rther data re ard n the costs o the meter n opt ons and the rea down o the component meter n echn cal ency pro rammes costs pro ramme del ery and pro ected sa n s has een ncl ded n the e sed emand doc ments he company has not presented clear n ormat on on the cost o comp lsory meter n ana ement trate y eport. pt on de elopment has een descr ed n reater deta l. emand compared to optant and chan e o occ p er select e meter n . hese are presented as ana ement c rrent pol cy w tho t clear cost n s altho h some o th s appears n np l shed deta led trate y ect on cost n s reports and an add t onal note on comp lsory meter n costs and ene ts. . .
n ronment . lanned meter n nstallat ons and water sa n s rther data re ard n the costs o the meter n opt ons and the rea down o the component meter n echn cal ency pro rammes and rollo t has een ncl ded n the e sed emand ana ement trate y eport. doc ments he company has not presented clear n ormat on on ts planned domest c meter n emand nstallat ons and water sa n s or each aspect o ts meter n pro ramme and alternat e dd t onal deta l has een presented re ard n cost and sa n rea downs or the pre erred plan and the ana ement meter n opt ons altho h some o th s appears n np l shed deta led cost n s reports and alternate opt ons cons dered. trate y ect on an add t onal note on comp lsory meter n costs and ene ts. . ect on dd t onal deta l has een pro ded re ard n sa n s that ha e een catalo ed rom the smart meter tr als . ect on he company sho ld present clear n ormat on on n m ers o ho seholds and water sa n s n ewmar et and orw ch. h s data s presented n the re sed emand mana ement trate y eport or each cate ory o domest c meter n .
n ronment . ppropr ateness o opt ons selected and t m n o del ery e ha e repeated the opt ons appra sal process ncl d n the pdated and short term r s s. e sed d ency hapter he nal opt ons selected may not e appropr ate as a res lt o nderest mat n r s and ltho h some opt ons re re s n cant lead t mes these are not re red n and there ore w ll orm ncerta nt es dent ed n ecommendat on and the l m tat ons n the dec s on ma n part o o r adapt e plann n process. e ha e also compared t re select on o opt ons w th lar er stora e echn cal process see mpro ement opt ons to test or red ndancy. or rther deta ls see the res lts o o r stress test n and lon term r ns doc ments s mmar sed n chapter and more lly d sc ssed n the ana n ncerta nty and s s pport n techn cal ana n ome opt ons may re re s n cant lead t mes other opt ons may e re red and need to report. ncerta nty and e mplemented sooner than c rrently planned. h s nderm nes con dence that the s selected opt ons are a cost e ect e way o sec r n p l c water s ppl es and protect n the en ronment and that they w ll e del ered n a t mely way.
12 n ronment . sta na l ty o nd d al opt ons e ha e nderta en a thoro h eas l ty assessment o all o the opt ons ncl ded n o r modell n e sed d ency phase n accordance w th the del nes. he nd d al opt ons h hl hted n th s comment no lon er hapter ome opt ons n e ther the pr nc pal plan or adapt e plan may not e en ronmentally appear n o r re erred lan. s part o o r adapt e plann n process we w ll wor w th the n ronment s sta na le or re re rther assessment and poss le m t at on meas res. n part c lar ency to assess n rther deta l where appropr ate the en ronmental assessments and m t at on re red echn cal o cote reser o r recomm ss on n and some opt ons s n r er rent trans ers. or nd d al opt ons. doc ments pply s de hese opt ons may not e del era le or the r costs and cost e ect eness may e pt on s n cantly d erent. e elopment
n ronment he company sho ld re ew ts trate c n ronmental ssessment see also he select on o opt ons or the re sed dra t plan sed the conom cs o alanc n pply and emand echn cal ency ecommendat on and nderta e rther wor to assess the s sta na l ty o these opt ons (EBSD) methodology to identify the lowest overall cost, or ‘least cost’ solution, to meet the supply demand doc ments and re ew ts opt on select on or the nal plan. h s sho ld ncl de ll appra sal o de c t. h s least cost plan was rther de eloped nto a est al e plan wh ch ta es acco nt o a w der ran e report m t at on meas res water al ty mpacts and n as e and non nat e spec es mpacts. o actors s ch as en ronmental mpacts o pro rammes res l ence c stomer pre erences n add t on to cost.
he re sed d s l ely to ha e a n m er o pos t e e ects on del er n rel a le and s sta na le water s ppl es that are le le to cope w th t re rowth. os t e e ects dent ed ncl de ncreased a a la l ty and res l ence o water s ppl es or h man se ncreased a a la l ty o water w th n the nat ral en ronment th s ncreas n res l ence ene t n water dependant ecolo cal s tes and ma nta n n an attract e nat ral landscape red c n the need or t re water s pply n rastr ct re and allow n c stomers to nderstand the r water sa e.
here ne at e e ects were dent ed n the opt ons assessment these ha e een m t ated thro h the opt ons des n process where poss le y re ro t n p pel nes or s n d rect onal dr ll n nder sens t e s tes and r ers or n est ated rther thro h the and processes. he se o est pract ce constr ct on methods w ll also e t l sed to m n m se any e ects d r n the constr ct on phase. nor ne at e e ects rema n or one opt on d e to the pred cted moderate e ects on o ect es. here e ects relat n to reenho se as em ss ons were nown all opt ons had m nor ne at e e ects apart rom three opt ons where ma or ne at e e ects were dent ed. se o renewa le ener y technolo es co ld help to red ce e ects.
e are comm tted to del er n the re red m t at on to del er the opt ons de ned n the re erred lan.
13 Environment Environmental costs and enefits We have undertaken a thorough assessment of Environmental and Social impacts, following the ‘building or a high level gency blocks’ approach proposed in the WRP Guidance. The SEA (informed by the Habitats Regulations Assessment description of our here appears to e limited uantification of environmental costs and enefits in relation to ( ), D assessment and nvasive on ative Species ( S) assessment) provided ualitative and semi multi criteria the scale of the pro lem t is unclear what has influenced social and environmental costs in uantitative assessments of the environmental and social effects at a detailed level e have also underta en assessment the differences etween verage ncremental osts ( ) and verage ncremental Social a ualitative Ecosystems Service ssessment (ES ) to complement the SE e considered the use of approach see osts ( S ) in the planning ta les environmental valuation (using a monetised Ecosystems Services pproach) owever, the a sence of an hapter of the agreed methodology and a lac of data means that currently, only certain environmental and social effects revised d he company should review and provide clearer e planation of what these costs and enefits can e costed, there y leading to a partial assessment he only e ception is car on, which we have are and how they have een derived alongside a review and clear e planation of the role of monetised and included in the S calculations Supply ption SE and environmental appraisal in the final option selection Development e have made improvements to the description of our final option selection process including how we have supporting used a multi criteria approach (including environmental costs and enefits) technical document (appendices), and Demand anagement Strategy supporting technical document (appendices)
Environment ac of detail on feasi ility studies and economic analysis of supply options e have provided all the feasi ility studies re uested to the Environment gency to accompany the draft echnical gency he full suite of studies that have een updated for the revised draft will e availa le documents he company has referenced ut not provided detailed feasi ility studies and economic Supply side analyses for the development of supply options used in the options appraisal ption Development his has made audit y regulators difficult and reduced confidence that the proposed options will deliver secure supplies in a timely way and will protect the environment
Environment he company should provide detailed feasi ility studies of selected options as part of its plan he full suite of feasi ility studies that have een updated for the revised draft will e availa le echnical gency along with sufficient information on economic appraisal to allow the costs to e audited documents Supply side ption Development
14 Environment R . mproved level of service We have now completed the assessment of the economic benefits of moving to an improved level of service. See report on Agency ur proposed investments are cost beneficial. We will provide our consultant s report to our regulators. Huddle The company has liaised with its customers and has presented support for adopting improved levels of service for moving to no emergency drought orders in a event. However, the company has not fully completed its assessment of the economic benefits of undertaking this change to levels of service. Reference is made to further work by economic consultants, however this report is not yet complete and a draft was not available for review as part of this audit.
The company has not presented the full economic case for improving its levels of service.
To complete this work, the company should present the full economic argument in support of moving to a better level of service. This should be supported by the external consultant’s report when complete.
Environment Some options within Table WRP for dWR P have missing A and A S cost values or We have completed all costs information in the WRP tables allowing the A and A S s to be calculated. The Technical Agency ero values. A A S values for the demand management options have been updated. documents Presentation of feasible and preferred options between Tables and unclear missing Supply side information. We have included an e planation as to differences in cost and scope between options that featured in the ption WR P and WR P in the Supply Side ptions evelopment report. evelopment Stakeholders cannot understand the costs of options. There is a lack of clarity on whether final choice of options is cost effective.
The A A S values for smart metering, supply pipe repairs and water efficiency options are very low ( p m . Some option type costs appear to have changed substantially between WR P and dWR P (e.g. effluent re use, desalination and it is unclear why. Environment Recommendation The company should protect the environment and invest in new We have planned for all water resources related environmental obligations listed in the W EP, including the Revised dWR P Agency solutions where changes cause a deficit or reduce resilience closure of our udham source in . The timing of impacts are aligned to meet obligation dates, as well as hapter and the renewal dates of our time limited licences, and risks associated with possible changes to permanent and time limited licences to prevent deterioration. As a result, we are investing in supply side options to address Technical sustainability reductions, as well as a significant number of agreed environmental mitigation options. documents Sustainable Abstraction
Environment R . Time limited licence renewals and no deterioration We have committed to maintaining all of our groundwater abstractions below recent historical abstraction Revised dWR P Agency rates in order to eliminate the risk of W deterioration. To reflect this, we have assessed the impact of hapter and The company has a significant number of time limited licences which are due for renewal on sustainability changes on all groundwater sources in in our Preferred Plan, rather than in A P as ecember . The renewal is e pected to be on more restrictive terms to prevent detailed in our dWR P Adaptive Plan scenario. Technical deterioration in Water ramework irective (W waterbody status. The company has ocuments made some allowance for this in its adaptive plan, but the timing and uantities may be Supply orecast, earlier and larger than it is planning. and Sustainable Abstraction
15 nvironment The company should revise its plan to include details of hich resource ones are at ris from e have committed to maintaining all of our ground ater abstractions belo recent historical abstraction evised d gency more restrictive time limited licences and provide evidence to sho ho it ill bring for ard rates in order to manage the ris of deterioration. To reflect this e have assessed the impact of hapter options from the adaptive plan if needed to maintain security of supply. sustainability changes on all ground ater sources in in our referred lan rather than in as detailed in our d daptive lan scenario. Technical The company should confirm ho sustainability change scenarios have been derived and documents hat mitigation it ill put in place to prevent deterioration in ater body status hilst upply orecast it develops long term solutions. and ustainable bstraction t should complete a scenario ith all ground ater licences time limited and permanent capped to ards recent actual abstraction here increased abstraction ris s causing deterioration in aterbody status.
nvironment . mpacts of sustainability issues in neighbouring companies e have or ed closely ith our neighbouring ater companies and the nvironment gency in the evised d gency preparation of our revised d to confirm the impact of sustainability issues both on our o n plan and hapter and It is uncertain how Anglian Water’s plan may be affected by sustainability issues in on neighbouring plans. These discussions have focussed on our existing trading agreements ith ffinity neighbouring companies’ plans (Affinity Water, Cambridge Water and South Staffs Water and ater and the potential for a future trading agreement. e ill continue to or ith ffinity ater and evern Trent ater . ssex and uffol ater to deliver the re uired improvements in the rett atchment.
nglian ater should or ith neighbouring ater companies to confirm the impact of the ur adaptive planning approach demonstrates ho e are investing to develop ne resource options no to latest version on and on their plans and if this affects options for transfers and trading ensure they are ready for future delivery should they be re uired. These options ill be available should the ater. The company should sho ho it ill bring for ard options from the adaptive plan if need arise to support neighbouring companies in the future. needed to maintain security of supply.
nvironment . eliverability of ater ndustry ational nvironment rogramme mitigation n our d e stated that e ere still in discussions ith the nvironment gency regarding the evised d gency options mitigation options and that there may be some refinement to the final option set in time for the revised hapter and d . o ever e had planned for the perceived orst case sustainability changes and hence there as The company has assumed options identified to deliver sustainability changes identified in a lo ris that the impact upon our supply forecast ould increase. Technical the ill provide full benefits but or is still on going to confirm the feasibility of the documents options. ll mitigation options have no been confirmed and agreed ith the nvironment gency. There as no ustainable The company states that other options ill need to be brought for ard. o ever it does not increase in the impact on the plan since the d . o ever some detail remains to be confirmed for bstraction provide further explanation of ho or hat may be done if its preferred options do not schemes deliver the re uired benefits. • Kennet-Lee Brook river support: The final flow volume of the river support option, as well as the source of ater for the support is still in discussion ith the nvironment gency. o ever the sustainability change ustainability changes may have a greater impact on the plan than anticipated. The company is confirmed as is the restoration scheme. may need to bring for ard options in its adaptive plan sooner than it currently intends. f • Tiffey: Selection of the waterbody to receive river support is not yet complete. However, the sustainability these options cannot be brought for ard security of supply ill be at ris . change is confirmed.
or the umpstead roo e have removed the option to relocate our source due to uncertainties over its feasibility. hilst e are still investigating the feasibility of the source relocation option e are no instead planning for a supply side solution for the closure of the source to account for this uncertainty.
n some cases there is uncertainty over hether or not the solution ill deliver the full benefits re uired and as such there is a potential need for additional mitigation options in . here this is the case schemes ill be implemented in the early stages of the to allo for the revie of need before .
16 nvironment The company should ensure its final plan includes all measures needed to deliver the WI We have planned for all water resources related measures listed in the WI , and included investment in evised dW - Agency and ensure security of supply. supply-side options, demand management options, and mitigation options in order to maintain the security Chapter of supply Technical documents: Sustainable Abstraction
nvironment . elivery of e isting environmental obligations Anglian Water is committed to meeting Habitat egulation irective re uirements. ur revised dW has evised dW - Agency been corrected to reflect the arch obligation date for the closure of our Ludham source. Chapter The company has an obligation to deliver a further sustainability change at its Ludham- Catfield source to meet the deadline set out in the iver Basin anagement lan ( arch Technical and under the Habitats egulations. We note that the company does commit to documents: delivering this change as soon as possible within the first years of the plan (Technical report Sustainable – sustainable abstraction s3.2), but the full sustainability change is not scheduled until 2024 Abstraction in the company’s planning tables (Happisburgh water resource zone).
The company risks failing to deliver its obligations under the Habitats egulations.
The company needs to make the re uired sustainability change at its Ludham-Catfield source as soon as possible to meet our re uest to achieve the deadline as set out in the iver Basin anagement lan and deliver its obligations under the Habitats egulations.
nvironment . Completion of Habitats egulatory Assessment for all sites or the W (B , LC and the adaptive planning strategies all options that include abstraction from Technical Agency the iver Witham or the iver Trent have been revisited to ensure any impacts on the Humber and the Wash documents: H A Habitats egulations Assessments have not been completed for all relevant sites (Humber have been identified appropriately. Where applicable, updated assessments have been included in the final report and Wash uropean designated sites for options supported by abstraction from the Trent H A reports. and Witham . For the two desalination options (ESU1 - Felixstowe and NFN1 – Kings Lynn), the level of detail of the plan Impacts on internationally designated features of the environment have not been assessed. does not allow detailed consideration of effects on individual uropean sites and it has been concluded that These may affect viability of the options or mean further measures must be considered to the effects of the impacts identified during operation (i.e. potential increase in salinity as a result of brine ensure the options are sustainable. discharge will need to be e plored further in order to demonstrate that the integrity of uropean sites will not be significantly adversely affected. This includes potential impacts on the Wash from the Kings Lynn Habitats egulations Assessments must include all relevant sites (Humber and Wash for desalination option. At this strategic level however, the assessment undertaken still allows confidence that options supported by abstraction from the Trent and Witham the option could go ahead without harm to uropean sites, sub ect to more detailed scrutiny of mitigation options at the lower tier plan or pro ect level and potential mitigation for this adverse effect has been recommended regardless. It is reasonably assumed that as these options are further developed, and the specifics of brine discharge within the options is fully understood assessment at lower tier plan or pro ect level H A will result in appropriate mitigation being developed to ensure desalination options result in no significant adverse effects on the integrity of the uropean sites identified.
nvironment ecommendation : emonstrate that transfers of water between Anglian Water and We have worked hard between dW and revised dW to improve the alignment between water evised dW - Agency neighbouring companies have been presented consistently between plans company plans and specifically how e isting agreements are presented. We are confident that there is now Chapter full alignment between our plans.
17 Environment .1 ffinity ater transfer e are continuing to wor closely with ffinity ater to understand their future trading re uirements. e evised d - gency do not include an export to ffinity in our revised d referred lan. hapter he company has presented the export to ffinity ater in both the principal and adaptive plans. here are some discrepancies in the timing and volume of this transfer between However, we have considered a potential future export to ffinity in our stress testing, to ensure that we are echnical nglian ater and ffinity ater s plans. ffinity ater may re uire more water sooner. able to adapt our referred lan to meet future need which are currently uncertain. documents here are also differences in the way in which uncertainty in this transfer has been anaging considered. Uncertainty and is This uncertainty presents a risk to Anglian Water’s supply demand balance if a significant additional export is re uired. lternately if nglian ater cannot provide it in the uantities and timing required by Affinity Water then there is a risk to Affinity Water’s supply demand balance. 0 Environment nglian ater should wor closely with ffinity ater prior to the preparation of the revised e have held several meetings with ffinity ater whilst preparing our revised d and we are now gency d to ensure that options reliant on neighbouring companies are valid. confident that our plans are aligned.
1 Environment .2 Severn rent ater transfer e have wor ed with Severn rent ater in preparing our revised d to ensure the options included evised d - gency are the most up to date available. he option referred to in this comment does not appear in our revised hapter The company’s preferred programme of measures to address deficits in its Ruthamford d referred lan. North zone includes a 3 l d import from Severn rent ater. he import is scheduled to start in 2030 31 at a rate of around 2 l d increasing to 3 l d by 203 40. However, this e will continue to wor closely with Severn rent ater via ater esources East and the rent or ing transfer is not reflected in Severn Trent Water’s planning tables. roup in our adaptive planning and preparations for 2024.
he company should clarify this new transfer with Severn rent ater and report any exports through the relevant planning tables.
2 Environment .3 onsistent results with other water company e have liaised with ffinity ater to agree the share of rdleigh and we are continuing discussions gency regarding management of short-terms ris s in the area. here are some minor discrepancies between recipient and donor water companies including timing of change of amended share of rdleigh with ffinity ater. e are not altering the deployable output estimate at rafham because the design event has been assessed as being consistent with the revised levels of service at rdleigh the stochastic analysis of severe drought t is also expected that future deployable output estimates from rafham and rdleigh will indicates that there would be no change to deployable output for the South Essex . also change with new levels of service.
3 Environment e have wor ed hard between d and revised d to improve the alignment between water gency nglian ater should liaise with its neighbours to ensure the latest transfers are used company plans and specifically how existing agreements are presented. e are confident that there is now consistently and that any updates to deployable output are shared with the receiving full alignment between our plans. companies.
18 nvironment R . all source orks deployable output is overestimated in the plan to Technical Agency urrent modelling suggests the full all yield is resilient to a in year event based on rainfall return documents The company’s Hall source works is reported to have a deployable output of 20Ml/d, falling period analysis of the drought. The yield assessment of all is discussed further in the Supply Supply orecast to around . l d in hen a year level of service is adopted. o ever if is orecast technical report. e cluded from the analysis as it is considered to be outside of the current level of service the yield ould be ust under l d. With additional drought investment entral incolnshire becomes resilient to a in year drought event This issue contributes to Recommendation ith regard to potential for deficits in the initial in . years of the planning period
eployable output for years up to for the entral incolnshire ater resource one WR is over estimated by around l d. This could mean levels of service are currently over stated and options to address any deficits are not being brought for ard quickly enough. nvironment The company should include the best estimate of all source orks contribution to WR urrent modelling suggests the full all yield is resilient to a in year event based on rainfall return Technical Agency deployable output from the start of the planning period for the current and proposed level of period analysis of the drought. The yield assessment of all is discussed further in the Supply documents service. orecast technical report. Supply orecast
nvironment R . The company has not prepared a drought permit for the ne ly commissioned all We are currently engaging ith the nvironment Agency and atural ngland on the proposed all intake Agency source orks. drought permit and ill carry out formal consultation on it as part of the revised rought lan . t as not included in the rought lan as the intake as not operational hen the plan as ritten. The company has identified it ill need a drought permit to reduce the hands off flo condition to achieve the full output of the orks. Whilst the company has considered the impact of a drought permit to lo er the hands off flo at this site the permit does not appear in the company’s published drought plan. There has been no consultation on the sustainability and feasibility of using such a drought permit as an option to increase supplies.
nvironment The company should investigate drought permit options and update its drought plan. This We are currently engaging ith the nvironment Agency and atural ngland on the proposed all intake Agency ork should include establishing a frequency of proposed use of the drought permit aligned drought permit and ill carry out formal consultation on it as part of the revised rought lan . t as ith appropriate triggers and complete all necessary ork to ensure the permit ill not have not included in the rought lan as the intake as not operational hen the plan as ritten. a significant adverse impact on the environment including designated sites.
nvironment R . ustify choice of flo s for assessing yield of all source orks and confirm suitability of Technical Agency artificial influences in adopted flo record. We agree yield results can be sensitive to small changes in flo and have undertaken further revie of the documents modelled flo series and yield assessment for the all intake. We have had a number of discussions ith the Supply orecast The assessment of reliability of the all source orks ith the current hands off flo is local A hydrologists and have no been advised historic flo s are belo those e have modelled using highly dependent upon the methodology for deriving flo s. sing modelled data the yield is R A data . sing revised modelled flo s the yield assessment no suggests the modelled yield ould assessed at . l d during the critical year of though using historic data for the same be about . l d much closer to the historic yield. event the yield is assessed as around l d before impacts of climate change are assessed. t is une pected that for this critical year the modelled flo s are lo er than the observed flo s as the e pectation is that there is a greater net import of ater into the catchment than contained ithin the historic record. t is clear from this analysis that small changes in flo hen assessed against a specified hands off flo may have significant impacts on yield.
19 nvironment The company should ustify its choice of flows based on both model performance and e have undertaken further review of the modelled flow series and yield assessment for the Hall intake. e Technical gency representation of artificial influences in the historic record. have had a number of discussions with the local hydrologists and have now been advised historic flows are documents This should be agreed with the nvironment gency as this assessment would need to be below those we have modelled using data . sing revised modelled flows, the yield assessment now upply orecast consistent with any consideration of changes to hands off flow as part of an application for a suggests the modelled yield would be about . Ml/d, much closer to the historic yield. drought permit for the source.
0 nvironment ecommendation pdate the trategic nvironment ssessment nvironment report to The nvironment gency reviewed an earlier version of the provided for audit. The final version Technical gency ensure legal compliance published on website with our d M did include all of the missing sections. documents report The trategic nvironmental ssessment is not currently legally compliant. The nvironmental eport does not contain sufficient information to allow a full assessment of the impact of the company’s options. t re uires updating with the inclusion of the non technical summary and cumulative impact methodology, the cumulative effects assessment, monitoring plan, plan/policy/programme review and spatial scope.
nvironment ecommendation nsure the plan is legally compliant by adhering to the M irections e have reviewed the M irections and ensured that the revised draft M is legally compliant. gency 2 nvironment . irection b e have presented our current and future evels of ervice in our revised d M in the form of annual evised d M gency escribe the annual average risk of all restrictions as a percentage, and how they change average risks. hapter 2 through the planning period Technical The company has not set out how it e pects the annual risk of the need to impose documents prohibitions or restrictions on its customers to change over the course of the planning period upply orecast as a result of the measures that it has identified through its options appraisal. t has presented target information but e pressed this in the form of return periods instead of percentage risk. nvironment The company must e plain how the risk of customer side restrictions is e pected to change or entral incs, heveley, ury Haverhill, ewmarket and outh enland, 2020 202 , we are maintaining evised d M gency as the principal and adaptive plans are implemented through the planning period. our current evels of ervice, which allows one instance of severe restrictions standpipes and rota cuts hapter 2 t must present the information as an annual percentage risk. e perienced in a in 00 year severity drought event. rom 202 , following further drought investment, we have committed to ensuring our customers are protected against up to a in 200 year event without the risk Technical of any severe restrictions. e have presented this as an annual percentage risk. documents upply orecast e have assessed our other s to already be resilient against up to a in 200 year event without the risk of severe restrictions. ur fre uency of restrictions for hosepipe and non essential use bans remains the same.
nvironment .2 irection c escribe the assumptions it has made to determine the annual average e have not changed our methods or evels of ervice for Temporary se ans and 2 on Technical gency risk of all restrictions ssential se ans / rdinary rought rders . e have used a combination of historical and stochastic documents approaches to assess the yield of severe droughts, which has been used in T to determine additional upply orecast The company has not provided a methodology on how it has assessed actual risk of resources where re uired to avoid severe restrictions , ota uts and tandpipes / mergency rought restrictions. t is not clear if it has undertaken this work as part of irection b . rders .
The company must set out the assumptions used to estimate the planned annual risk for its planning period of i temporary water use restrictions ii ordinary drought orders and iii emergency drought orders under irection b .
20 n i onment . i ection e ha e esc i e the emission of eenho se ases as a es t of the efe e an in te ms of onnes of e ise
ency esc i e the emission of eenho se ases i e y to a ise as a es t of each meas e in its e i a ent in ection . of the . hapte p an ection . n i i a option ca on costs a e p o i e in the p ate ta es. he company has p esente info mation on ca on emissions associate ith s pp y an eman options a tho h some of this appea s in np ishe etai e costin s epo ts. e ha e p o i e the eenho se as emissions f om o c ent ate ope ations in chapte . o e e it oes not p esent the e i a ent info mation fo its c ent ope ations a tho h ene a te t imp ies that the company oes possess e e ant info mation. n a ition hi st e ha e se the t a e cent a a es of the ecem e e sion of the ta es. the company has se e e ant o e nment i ance . o . on eenho se ases app aisa it is nc ea hich e sion of these costin s it has se .
he company m st p esent the ca on emissions fo its c ent ope ations. he company m st c a ify hich e sion of eenho se as costs it has se an p ate its app aisa ith p to ate fi es if necessa y.
n i onment . i ection e i esc i e the ass mptions ma e e a in the imp ications of c imate his is the same as fo the ase ine eca se e a e not e e opin any s pp y si e options that a e sensiti e ency chan e inc in in e ation to the impact on each of its s pp y an eman meas es to the impact of c imate chan e.
he company has inc e c imate chan e in its assessment of ase ine s pp ies an eman s. he company has assesse the impact of c imate chan e on its ne options t has not eassesse the nce tainty ithin its hea oom assessment fo the ne confi e s pp y system. his is e i ent f om the ase ine an fina p annin c imate chan e hea oom a o ances as p esente in the ta es sho in the same c imate chan e nce tainty. hi st the company may ha e consi e e the a itiona c imate chan e nce tainty an ete mine that this is not si nificant this is not epo te e p icit y in the ief hea oom epo t tho h the epo t oes note that the e a e no hea oom a o ances fo options.
n i onment he company m st ens e the nce tainty fo c imate chan e ithin hea oom is eassesse his is the same as fo the ase ine eca se e a e not e e opin any s pp y si e options that a e sensiti e n a ency fo the com ine fo ecast s pp y fo the fina p an an epo t this sepa ate y o e p ain hy to the impact of c imate chan e. this is the same as the ase ine c imate chan e nce tainty.
n i onment . i ection f the ata e a in the costs of the mete in options an the ea o n of the component mete in echnica ency esc i e its mete in p o amme inc in costs app oach imp ementation an timin of p o ammes costs p o amme e i e y an p o ecte sa in s has een inc e in the e ise eman oc ments the p o amme ana ement t ate y epo t. ption e e opment has een esc i e in eate etai . eman ana ement he company has not p esente c ea info mation on the costs of its c ent mete in t ate y ection st ate y fo optants an chan e of occ pie hich is a contin ation of e istin company . ection po icy a tho h some of this appea s in np ishe etai e costin s epo ts. . . . . ection he company m st inc e etai s of its se ecte mete in st ate y inc in ho it i imp ement mete in ac oss its a ea an a so the costs of insta in an ope atin the mete s in its mete in p o amme to meet i ection f .
21 n i onment . i ection h esc i e its assessment of the cost effecti eness of omestic mete in the ata e a in the costs of the mete in options an the ea o n of the component mete in echnica ency types p o ammes costs p o amme e i e y an p o ecte sa in s has een inc e in the e ise eman oc ments ana ement t ate y epo t. ption e e opment has een esc i e in eate etai . eman he company has not p esente c ea info mation on the cost of comp so y mete in ana ement compa e to optant an chan e of occ pie se ecti e mete in hich a e p esente as ote the c ent p an aims to each the feasi e imit of mete in ea y in the p an pe io . t ate y ection c ent po icy itho t c ea costin s a tho h some of this appea s in np ishe etai e . ection costin s epo ts an an a itiona note on comp so y mete in costs an enefits. n . . a ition the company has not p o i e a c ea compa ison of s pp y options compa e to . . ection mete in an othe ate eman mana ement options.
n i onment he company m st p o i e an assessment of the cost effecti eness of the fo o in types of the ata e a in the costs of the mete in options an the ea o n of the component mete in echnica ency mete in to meet i ection h p o ammes costs p o amme e i e y an p o ecte sa in s has een inc e in the e ise eman oc ments • Compulsory ana ement t ate y epo t. ption e e opment has een esc i e in eate etai . eman • Selective ana ement • Change of occupier t ate y ection • Optant. . .
his i ena e compa ison ith a te nati e options to a ance s pp y an eman .
eate i en this is a yea p an f e ent contact sho e maintaine ith the monito in office e ha e se the atest oca a tho ity o th ta ets as the asis of fo ecastin pop ation ithin o echnica inco nshi e of the e e ant oca an a eas to a e ho sin e i e y a ainst a opte oca an ho sin eman fo ecast. e i contin e to o c ose y ith oca a tho ities in o e ion to monito on oin oc ments oca nte p ise ta ets. ho sin e i e y a ainst ta ets. the etai is p o i e in the eman o ecast technica s ppo tin eman o ecast a tne ship epo t. ea y an eco nisin the nee fo a consistent an i o o s e i ence ase it o e p efe a e to ta e a f e i e app oach that f y en a es in oca o th aspi ations athe than ete minin a sin e fi e app oach that is app ie ac oss the oa .
eate e f y s ppo t this app oach. e ha e contin e to p io itise eman mana ement ithin o as esc i e in hapte . e ha e echnica inco nshi e inc e s pp y options in the fo m of t ansfe s an i contin e to e p o e eso ce options o e the ne t oc ments oca nte p ise fi e yea s. the etai is p o i e in the eman ana ement t ate y technica oc ment. eman a tne ship ana ement t ate y eate e a e conce ne that the ta ets fo ea a e e ction an ate efficiency a e e y e ha e contin e to p io itise eman mana ement ithin o as esc i e in hapte . his echnica inco nshi e am itio s an it is the efo e essentia that the an contin es an is a e to a apt to ef ect inc es o p opose p o amme of ate efficiency initiati es. e ha e inc e s pp y options in the oc ments oca nte p ise f t e p actices to i e efficiency campai ns an to p omote an p o i e oppo t nities fo fo m of t ansfe s an i contin e to e p o e eso ce options o e the ne t fi e yea s. eman a tne ship e istin c stome s to et ofit an ma e ette s staina e se of the ate that fa s ithin ana ement in i i a p ope ties. t ate y
chie in ea istic eman e ction ta ets on e istin in i i a c stome s m st e as m ch of a p io ity as p o ision of ate efficiency fo f t e c stome s.
e consi e eman mana ement to e an essentia pa t of a i e s ite of app oaches that is app op iate fo the imme iate fi e yea pe io of the aft ho e e it is n i e y to emo e the on e te m nee fo p annin fo si nificant inf ast ct e imp o ements in ine ith oca an nationa o th nee s an sho e consi e e a on si e these.
22 reater consensual voluntary approach oul appear to offer the est e have consi ere the range of vie s e presse regar ing compulsory metering uring our consultation as echnical incolnshire opportunity in the long term to promote ater saving ehaviours alongsi e the intro uction ell as a i er analysis of the costs an enefits as escri e in the eman anagement Strategy technical ocuments ocal nterprise of technical solutions that coul ta e a vantage of them. ocument . e have also ta en into account our high level of meter penetration hich is forecast to reach eman artnership of househol s metere an paying measure charges y . s a result e have not inclu e anagement compulsory metering in our revise . e ill continue to monitor the proportion of customers ille Strategy ase on a meter rea ing an ill revie the nee for compulsory metering at .
reater aptive planning is therefore perhaps even more important than state . e agree that the a aptive planning process is very important. s such e have set out our initial plans in evise incolnshire our revise an have inclu e investment in our usiness lan. Chapter ocal nterprise e also recognise the potential for i er multi sector enefits than are referre to in the artnership propose a aptive plan inclu ing in the commercial sector. iven that there are three e loo for ar to or ing ith sta ehol ers inclu ing incolnshire County Council in our a aptive planning months et een the consultation finishing an the pu lication of nglian ater s as ell as in the ne t phase of ater esources ast. Statement of esponse incolnshire County Council an its partners oul support an ish to participate in any efforts ma e to re shape the a aptive plan to create i er enefits an greater certainty of outcomes.
reater t is goo ris management to for ar plan an i entify appropriate resources to increase Our revise position on severe rought remains the same as for the e ill ensure that all evise incolnshire the resilience of the pu lic supply particularly in of our customers have a . annual average ris of severe restrictions from . Chapter ocal nterprise vie of the e isting pro ections for ater availa ility in the east of nglan . artnership herefore e oul support this approach especially consi ering the isproportionate impact that interruptions have on those househol s most li ely to e challenge y access to affor a le utilities. reater urther to our comments ma e a ove hile it is esira le to eep ills as lo as practica ly ollo ing the consultation on our e have chosen not to efer investments in climate change evise incolnshire possi le e oul strongly support an approach that see s to sprea the investment in impacts until an have accommo ate these impacts ithin our referre lan ith a resi ual ris Chapter an ocal nterprise climate change resilience over a longer perio to avoi a much larger re uirement for in the South uthamfor that e are managing via preparation for a rought ermit application . Our artnership a aptation later on an to allo for effective future planning of infrastructure to support supply forecast mo elle climate change impacts from on ar s. or our revise future gro th re uirements. e have inclu e climate change impacts from the start of the planning perio .
or these reasons encouragement shoul e given to investing sooner rather than later in or er to avoi these costs.
unting onshire We do not support a move to trend–based projections. Local Authority Growth projections as e have use the latest local authority gro th targets as the asis of forecasting population ithin our echnical istrict Council set out in the nnual onitoring eports offer the most relia le metho of assessing future eman forecast. e ill continue to or closely ith local authorities in our region to monitor on going ocuments gro th. housing elivery against targets. urther etail is provi e in the eman orecast technical supporting eman orecast report. unting onshire o the Council oes not agree ith this approach. eman anagement shoul not e the e have continue to prioritise eman management inclu ing lea age re uction ithin our as evise istrict Council only priority of nglian ater. eman from population gro th cannot e totally offset y escri e in Chapter . e have inclu e supply options in the form of transfers an ill continue to e plore Chapter an eman management. nvestment in ne provision has to e a priority alongsi e eman resource options over the ne t five years. management. ncreasing the efficiency of transporting ater y continuing to re uce ater lea age in the net or shoul also e a priority.
unting onshire es if legislation permits an there is clear evi ence that this ill re uce ater usage thus e have consi ere the range of vie s e presse regar ing compulsory metering uring our consultation as echnical istrict Council allo ing for future housing gro th an ne eman can e partially fulfille as a result. ell as a i er analysis of the costs an enefits as escri e in the eman anagement Strategy technical ocuments o ever in rural areas there are instances of pipes eing share here in ivi ual metering ocument . e have also ta en into account our high level of meter penetration hich is forecast to reach eman might e ifficult to achieve. Such househol s shoul not e ur ene ith higher utility of househol s metere an paying measure charges y . s a result e have not inclu e anagement costs ue to this situation. compulsory metering in our revise . e ill continue to monitor the proportion of customers ille Strategy ase on a meter rea ing an ill revie the nee for compulsory metering at .
23 untin donshire the additional investment will increase the availability o water to meet e istin demand We have developed a plan that represents the best value or our customers and the environment over the or speci ic detail istrict ouncil and rowth the investment would be relevant. owever An lian Water need to demonstrate lon term and we have evidence rom our customer en a ement wor to support additional investment to relatin to the that any additional inancial impact on householder bills is directly invested towards uture proo our strate y. challen es and improvements in the networ improved resilience etc. here needs to be tan ible and proposed demonstrable bene icial outcomes or householders in untin donshire. ur re erred lan delivers resilience to the untin donshire area speci ically to address the impacts o investment in climate chan e. untin donshire re er to the Water esource one ummary reports. untin donshire is our utham ord outh W Area
untin donshire es investment to improve resilience in the istrict is supported. A ain as per our response ur revised dW position on severe drou ht remains the same as or the dW we will ensure that all evised dW istrict ouncil to there needs to be tan ible and demonstrable proo that householders will bene it o our customers have a . annual avera e ris o severe restrictions rom . hapter rom this e penditure. untin donshire o it should not be de erred. nvestment is li ely to protect and increase supply which will ollowin the consultation on our dW we have chosen not to de er investments in climate chan e evised dW istrict ouncil enable rowth. e errin investment is a ris and the Governments re uirements should be impacts until and have accommodated these impacts within our re erred lan with a residual ris hapter and met in the short term not de erred. in the outh utham ord W that we are mana in via preparation or a rou ht ermit application . ur dW supply orecast modelled climate chan e impacts rom onwards. or our revised dW we have included climate chan e impacts rom the start o the W plannin period .
Lincolnshire Given this is a year plan re uent contact should be maintained with the monitorin o icer We have used the latest local authority rowth tar ets as the basis o orecastin population within our echnical ounty ouncil o the relevant Local lan areas to au e housin delivery a ainst adopted Local lan housin demand orecast. We will continue to wor closely with local authorities in our re ion to monitor on oin documents tar ets. housin delivery a ainst tar ets. urther detail is provided in the emand orecast technical supportin emand orecast report. deally and reco nisin the need or a consistent and ri orous evidence base it would be pre erable to ta e a le ible approach that ully en a es in local rowth aspirations rather than determinin a sin le i ed approach that is applied across the board.
Lincolnshire We ully support this approach. We have continued to prioritise demand mana ement within our dW as described in hapter . We have evised dW ounty ouncil included supply options in the orm o trans ers and will continue to e plore resource options over the ne t hapter and ive years. Lincolnshire A consensual voluntary approach would appear to o er the best opportunity in the lon We have considered the ran e o views e pressed re ardin compulsory meterin durin our consultation as echnical ounty ouncil term to promote water savin behaviours alon side the introduction o technical solutions well as a wider analysis o the costs and bene its as described in the emand ana ement trate y technical documents that could ta e advanta e o them. document . We have also ta en into account our hi h level o meter penetration which is orecast to reach emand o households metered and payin measured char es by . As a result we have not included ana ement compulsory meterin in our revised dW . We will continue to monitor the proportion o customers billed trate y based on a meter readin and will review the need or compulsory meterin at W .
24 Lincolnshire While it is di icult to predict the course o uture environmental re ulation ollowin the his is why the adaptive plannin process is so important. As such we have set out our initial plans in our evised dW ounty ouncil s e it rom the uropean nion it is reasonable to assume that a stron re ulatory revised dW and have included investment in our usiness lan. hapter ramewor will remain in place and will need to be accommodated. or this reason it seems preferable to include a realistic provision for remaining abreast of – and helping to influence - We loo orward to wor in with sta eholders includin Lincolnshire ounty ouncil in our adaptive plannin re ulation rather than incurrin potentially reater costs in the uture by reactin to it as well as in the ne t phase o Water esources ast. retrospectively.
We also reco nise the potential or wider multi sector bene its than are re erred to in the proposed adaptive plan. Given that there are three months between the W consultation inishin and the publication o An lian Water s tatement o esponse Lincolnshire ounty ouncil and its partners would support and wish to participate in any e orts made to re shape the adaptive plan to create wider bene its and reater certainty o outcomes.
Lincolnshire t is ood ris mana ement to orward plan and identi y appropriate resources to increase ur revised dW position on severe drou ht remains the same as or the dW we will ensure that all evised dW ounty ouncil the resilience o the public supply particularly in view o the e istin projections or water o our customers have a . annual avera e ris o severe restrictions rom . hapter availability in the east o n land. here ore we would support this approach especially with re ard to maintainin access to water or those households most li ely to be challen ed by access to a ordable utilities.
Lincolnshire ollowin the consultation on our dW we have chosen not to de er investments in climate chan e evised dW ounty ouncil urther to our comments made above while it is desirable to eep bills as low as practicably impacts until and have accommodated these impacts within our re erred lan with a residual ris hapter and possible we would stron ly support an approach that see s to spread the investment in in the outh utham ord W that we are mana in via preparation or a rou ht ermit application . ur climate chan e resilience over a lon er period to avoid a much lar er re uirement or dW supply orecast modelled climate chan e impacts rom onwards. or our revised dW adaptation later on and to allow or e ective uture plannin o in rastructure to support we have included climate chan e impacts rom the start o the W plannin period . uture rowth re uirements.
We would also emphasise the need to ta e important decisions on investment in strate ic in rastructure in time to mana e identi ied need thereby avoidin unnecessary environmental economic and social costs. or these reasons encoura ement should be iven to investin sooner rather than later in order to avoid these costs.
atural n land We have raised a number o concerns in relation to the A and A assessment as we do echnical A and A documents have been amended or the revised dra t W to address the concerns echnical not consider that they have ully assessed the impacts o the dW on the natural raised. ee individual reports or details. documents A environment. report and A report
25 atural ngland atural ngland has a number of concerns ith the hich can be summarised as creening and as reports have been revised to address concerns echnical follo s documents - he ppropriate ssessment is incomplete as it does not asses all of the options - as appropriate assessments underta en for all options in the and adaptive planning report included in the plan strateg ith identified during creening - here are three further options hich e advise should be included in the ppropriate - hapter includes a summar of the and conclusion on the effects on site integrit ssessment hich have been screened out at the creening stage - he final includes a clear commitment to provide the mitigation detailed in the and for the - he ppropriate ssessment does not include a clear conclusion on the legal test of chosen options dverse ffect on ntegrit to uropean ites and is not consistent ith statements in the - n-combination effects assessed d on this issue detailed in-combination assessment as not underta en at the as creening stage in accordance ith - he d does not appear to include a clear commitment to provide the mitigation current guidance he report has ho ever given a preliminar assessment of the potential intra-plan in- identified as necessar ithin the ppropriate ssessment combination effects of the final he assessment did not identif an options in the - he in-combination assessment is too narro in scope and has not considered potential in- or the hich could combine to result in potential cumulative effects on uropean sites he combination effects ith other plans and pro ects implementation of the daptive lanning olution ho ever has the potential to result in cumulative effects - n terms of specific pro ects e have concerns on the assessment of the umber on esalination cheme ● The Wash SPA/Ramsar site/SAC, should the King’s Lynn desalination and water reuse schemes be implemented and e therefore advise that the d is not currentl compliant ith the re uirements of the ● Stour and Orwell Estuaries SPA /Ramsar site should the Felixstowe desalination and Ipswich water reuse abitats egulations scheme be implemented his as e plored further in the as ppropriate ssessment hich details both intra-plan effects and inter-plan effects The potential for cumulative effects of the WRMP 2019 in-combination with neighbouring Water Company’s s based on draft s that ere available has also been identified for the eben stuar the use ashes and the tour an r ell stuaries his can onl be e plored hen final neighbouring s become available atural ngland here are inconsistencies bet een the selected options in the plan and those assessed in the he as creening as underta en in t o parts echnical ppropriate ssessment eport f particular note are the follo ing options hich ere ● assessment of the feasible options list for the dWRMP as of June 2017 (Chapter 4); and documents identified as having a li el significant effect to uropean ites in the creening eport ● assessment of all options that were included in the revised dWRMP 2019 Best Value Plan (BVP), Least Cost report but not included in the ppropriate ssessment lan or daptive lanning trateg hapter he revised includes some options that ere - enland eservoir included in the d but had been changed through the options design process or e ample b re- - liff ua ater euse routing pipelines agreement of the use of directional drilling under sensitive sites and rivers or investigated - orth enland to orfol ural orth ransfer and further through the and processes he d assessments for these options have been - orfol ural orth or ich the oards ransfer superseded and the original assessments can be found in ppendi of the as creening report he revised as creening ssessment identified si options contained in either the or e note also that the options of outh enland to orth enland ransfer and adaptive planning strateg that ma result in i el ignificant ffects on uropean sites hese ere o estoft ater reuse are included in the ppropriate ssessment but do not appear ● ESU1 Felixstowe Desalination; to be part of the draft plan he ppropriate ssessment is therefore incomplete and ● SHB2 Pyewipe Water Reuse for Non-Potable Use; must be amended ● ESU2 Ipswich Water Reuse; ● NFN1 Kings Lynn Desalination; ● NFN2 Kings Lynn Water Reuse; ● NFN3 Fenland Reservoir. herefore as ppropriate ssessments ere re uired to assess hether these options ere li el to adversel affect the integrit of the potentiall affected uropean sites hese are detailed in the as ppropriate ssessments report
26 atural ngland e consider the assessment for is overl negative as it does not recognise that he report has been amended for the revised draft echnical ith appropriate mitigation and careful design the option is li el to result in biodiversit and documents landscape enhancements and that benefits to recreation and the local econom ould result uture strategic suppl -side options include t o ne reservoir options eservoirs ill have negative effects report associated ith landta e and visual intrusion o ever the also have significant opportunities for ecolog and recreational enhancement
ositive effects include increased resilience of ater supplies and recreational opportunities hich ma provide opportunities for emplo ment itigation measures ill be implemented during construction to reduce effects on ater ualit ecolog landscape historic environment and the communit he hase assessment concluded there ould be moderate effects arbon emissions ill be generated during construction and operation he scaled e ill be higher than the scaled operational average se of rene able energ technologies ma reduce effects here is significant opportunit to benefit ecolog and recreation through providing etland and other habitat creation and recreational facilities at the reservoir
here negative effects ere identified in the options assessment these have been mitigated through the options design process here possible b re-routing pipelines or using directional drilling under sensitive sites and rivers or investigated further through the and processes egative effects for options associated ith construction are assumed to be mitigated using best practice construction or ing methods inor and ma or negative effects remain for the follo ing options outh incolnshire reservoir - the options ill have moderate negative effects on ob ectives and ill re uire a hase if the are ta en for ard as screening and hase assessment concluded potential for moderate adverse effects he options ill also have minor negative effects on the landscape due to the introduction of a ne reservoir changing the landscape character here is also an opportunit to create a reservoir hich is a recreational and tourism asset and provides habitat creation cle a s and roads could also be enhanced as part of reinstatement or s
atural ngland urrentl the d considers these options enland and outh incs reservoirs purel in he outh incolnshire and enland reservoir storage options are included in our pre-planning activit in evised d - terms of their ater suppl benefits aving established that the should form part of the hapter hapter daptive lanning cenario e ould encourage the inclusion in the d of a positive vision recognising ho the ould allo the ater compan to provide ider benefits to the ince the d the cos stem ervices ssessment has been developed to recognise the potential environment and their customers environmental benefits of reservoir creation including the opportunit for enhanced landscaping improved fish stoc s through a uaculture pro ects and etland creation ocial benefits of reservoir construction highlighted in the revised d include the opportunit to create a visitor centre and provide information boards on reservoirs and etlands the opportunit to promote the reservoir for recreational activities o ever these have not been included in the ecos stem services scores as the reservoir design is based on a standard baseline design and does not include an environmental enhancement measures s mentioned in hapter during the pre-planning process these options ill go through additional studies to support the nvironmental mpact ssessments
arms are often geographicall isolated and e ould li e to see clear provision made to ur revised d referred lan delivers resilience benefits to all our customers including customers in usiness deliver uninterrupted ater services into rural areas arms are vulnerable to lo mains rural geographicall isolated locations ur referred lan delivers substantial benefits for reducing the lan - esilience ater pressure and livestoc farms in particular demand rapid response to those number of customers supplied b a single suppl s stem in the ound interruptions in the interests of animal elfare concerns e are also committed to delivering our performance commitment associated ith interruptions to suppl as set out in our usiness lan
e have a legal dut under the ater ndustr ct ith regard to enabling ne connections
27 The agricultural sector is also vulnerable to ‘temporary use bans’ and we would like to see e are refreshing our rought lan this ear and ill ensure alignment ith our revised d e n a close correlation bet een the and related drought plan to ensure high levels of continue to offer the same evel of ervice for emporar se ans service for farming customers ommit nglian ater to a t in-trac approach if not multi-trac approach that assesses e remain committed to a t in-trac approach hich ill prioritise demand management but include n a demand management and ne resource options on a long-term basis ta ing full cost and significant suppl -side investment benefit account of environmental and social effects avour the introduction of compulsor household metering particularl in areas here e have considered the range of vie s e pressed regarding compulsor metering during our consultation as echnical ater resources are under stress to the point of full cost benefit ustification and as soon as ell as a ider anal sis of the costs and benefits as described in the emand anagement trateg technical documents practicable alongside improved tariffs and measures to protect those on lo incomes document e have also ta en into account our high level of meter penetration hich is forecast to reach emand of households metered and pa ing measured charges b s a result e have not included anagement compulsor metering in our revised d e ill continue to monitor the proportion of customers billed trateg based on a meter reading and ill revie the need for compulsor metering at
plore opportunities for nglian ater to further investigate sharing ater resources and e have e plored a number of ater compan trading and third part options in our d and invited evised d - developing ne resources in partnership ith other companies and ith other sectors li e further interest via the ar et nformation platform e ill continue to investigate sharing and partnership hapter and farming opportunities through ater esource ast avour a catchment approach hich focuses on the greater involvement of all e support development of a catchment-based approach for certain aspects of public ater suppl his is evised d - sta eholders in local ater governance e prefer the introduction of a programme to discussed in hapter hapter deliver the infrastructure that or s on a catchment-b -catchment basis his approach means that progress on implementation ould be consistent ith better understanding of the catchment and reacting to the local needs of users and the environment
o ever no improvements are proposed for temporar use bans and non-essential use bans on- ssential se ans are e pected once ever ears on average annual average ris n a that potential impact on non-household sites – now the customers of retailers – with these restrictions forecast to be introduced in a ear event e continuall or ith farmers and the nvironment genc to be as fle ible as possible ith our abstraction regimes for e ample through the o er ene- iddle evel or ing group e ould li e to see greater resilience offered to business consumers of ater particularl vulnerable consumers li e farms especiall here animal elfare issues might arise
e support this approach consistent ith longer term and thereb less certain decision- n a n a ma ing plitting previous s into d seems a sensible step to ta e n a n a
28 e agree that sustainable levels of abstraction should be based on the principles of sound ur revised d commits to the delivery of all sustainability reductions included in and the evised d - science and we agree that nglian ater should invest on the basis of robust evidence ut capping of all groundwater licenses to ensure sustainable levels of abstraction e are comitted to delivering hapter we have misgivings about the potential for disputes between nglian ater and the these changes between and n addition we have acted collaboratively with the agricultural sector Environment Agency regarding the nature and significance of each party’s evidence; and in response to the recent hot and dry weather would be dismayed if disagreements over evidence delayed transition to sustainable levels of public supply abstraction
The long term nature of these licence changes is increasingly harming the interests of local farmers particularly in catchments such as roadland ivers e are currently finding that farmers with short term licences face immediate risk of volume reduction or even revocation because of locally identified environmental pressures n some of these cases the dominant cause of the pressure is a large-volume ‘perpetual’ (no expiry date) Anglian Water licence with the farm licence having a relatively insignificant impact ut the farm licence is caught up in a review because its impact is considered ‘in-combination’ with the Anglian Water licence
e would like this indirect impact on agricultural licences to be identified and accommodated in the process by for e ample a speedier conclusion to licence negotiations between nglian ater and the regulator which could have the effect of relieving some pressure on irrigation licences
Farmers recognise that the most effective – although also the most expensive and potentially e agree that ater esources ast will provide the principal platform for e amining the feasibility of multi- complex – means of improving resilience to water scarcity is through the construction of on- sector and multi-use options and will be continuing our support and involvement farm storage reservoirs ollaborative schemes between groups of farmers are gradually becoming more commonplace e anticipate that will e amine the feasibility of multi- sector and multi-use storage
e do not have a strong view but it is logical for pro ections to be consistent with local e have used the latest local authority growth targets as the basis of forecasting population within our Technical authority growth targets demand forecast e will continue to work closely with local authorities in our region to monitor on-going documents housing delivery against targets urther detail is provided in the emand orecast technical supporting emand orecast report We agree that demand management must continue to be Anglian Water’s priority, albeit e have continued to prioritise demand management within our d as described in hapter e have Technical within a clear twin-track approach included supply options in the form of transfers and will continue to e plore resource options over the ne t documents five years urther detail is provided in the emand anagement trategy technical document emand e congratulate nglian ater on its industry leading performance on leakage and we anagement welcome steps proposed in d to improve leakage performance trategy
n areas where future supply risks being in deficit we believe that there is a strong case to be e have considered the range of views e pressed regarding compulsory metering during our consultation as Technical made for the introduction of compulsory universal household metering perhaps in well as a wider analysis of the costs and benefits as described in the emand anagement trategy technical documents con unction with variable tariffs and linked to water efficiency advice to all customers e document e have also taken into account our high level of meter penetration which is forecast to reach emand believe that compulsory metering should be the long term ambition for nglian ater and of households metered and paying measured charges by s a result we have not included anagement we support plans contained in d for the widespread introduction of smart meters compulsory metering in our revised d e will continue to monitor the proportion of customers billed trategy based on a meter reading and will review the need for compulsory metering at evertheless we understand the business case for the suggested current approach of achieving full meter penetration without resorting to compulsory metering
29 F es iven the enormity of the water resources challenges faced by the region it seems very n a n a sensible to invest in future proofing F We approve of the principle but are not ualified to comment on the costings ur revised dW position on severe drought remains the same as for the dW we will ensure that all evised dW - of our customers have a annual average ris of severe restrictions, from - hapter
F n the basis that forecast impacts of climate change will not diminish let alone disappear, Following the consultation on our dW we have chosen not to defer investments in climate change evised dW - then we do not thin that investment should be delayed impacts until - and have accommodated these impacts within our referred lan (with a residual ris hapter and in the outh uthamford W that we are managing via preparation for a rought ermit application) ur dW supply forecast modelled climate change impacts from - onwards For our revised dW we have included climate change impacts from the start of the W planning period ( - )
fwat there are a number of important areas where the plan fails to provide convincing evidence We have engaged extensively with household and non-household customers to understand their views of the evised dW - that it delivers in the best interest of customers ris s and impacts associated with investment in resilient water supplies he results of this research were hapter central to the development of our dW ( ection ), and ustomer and etails of our customer engagement strategy and results are provided in the ustomer and ta eholder ta eholder Engagement Appendix hapter of our main summary report describes how customer preferences shaped Engagement our referred lan Appendix
fwat he company faces a number of challenges including population growth, climate change and We completed a draft roblem haracterisation assessment in une , which was discussed with the echnical abstraction licence reductions Anglian Water also intends to enhance its drought resilience Environment Agency he results showed moderate to high levels of concern across our region his was documents and has revised the number of water resource ones from in the previous plan to in the primarily driven by uncertainty associated with complexity factors, including vulnerability to severe drought anaging draft plan onsidering these factors we are therefore concerned the company has assessed and eployable utput ( ) calculations ncertainty and and characterised the planning problem as low concern is ince completing the draft assessment, we have significantly improved our understanding of the planning problem For example, we carried out further modelling to allow us to refine our understanding of current We also completed a detailed analysis of our vulnerability to severe drought and an extensive programme of customer engagement to explore trade-offs related to our W
n our final roblem haracterisation we have updated our assessment to reflect this improved understanding he final assessment confirms that our supply demand balance is under significant pressure; however, the associated complexity is greatly reduced onse uently we are facing lower concerns across our region compared with the draft assessment, and the E approach to decision ma ing is appropriate for use in raft W
30 fwat Anglian Water proposes significant investment in - with the largest proportion We have added new sections on our approach to decision ma ing, and the criteria used in adapting the least evised dW - allocated to interconnecting the multiple water resource ones identified Further cost E output to a best value plan hapters considerations (demand-side) We are using demand management options to mitigate growth impacts, whilst using supply-side measures and (supply- o he company should ensure that it uses robust methods to identify and fully ustify this (principally transfers) to mitigate supply-side impacts side) investment in its final preferred plan We have presented a full ustification of our strategic grid on a section-by-section basis, considering drivers in For deliverability o Anglian Water should demonstrate in the final plan that the solutions selected are each roblem haracterisation area see technical appropriate, considering the uncertainties associated with the ey drivers, and that they are documents also deliverable against the proposed timeline he deliverability of options is assessed as part of the options appraisal process as detailed in the upply upply ption ption evelopment and emand anagement trategy technical documents evelopment, o he company should clearly identify in the final plan how it will manage the uncertainty and emand and deliverability ris associated with this significant programme anagement trategy
fwat Anglian Water has wor ed closely with the Water esources East (W E) regional group and We have wor ed hard between dW and revised dW to improve the alignment between water recognises the importance of water resource cross-boundary schemes and trades owever, company plans and specifically how existing agreements are presented We are confident that there is now there are inconsistencies between draft plans of companies in this group full alignment between our plans
his is especially a concern as the potential for future exports drives investment in Anglian We will continue to support Water esources East Water’s plan. The WRE members should work to better coordinate their approaches and to clearly identify options in the near term that are beneficial at both the regional and national level
fwat We have concerns around the approach to problem characterisation, water resource ones ee the responses to the specific fwat comments n a and non-drought resilience fwat lanning tables are only presented for the principal plan which means it is not possible to We provided the adaptive planning tables to the Environment Agency owever, for the revised dW we n a fully understand the adaptive plan his reduces transparency and for the final plan the are not producing a separate adaptive plan company should consider what steps it could ta e to provide a clearer overview for both plans his could include the provision of aggregated company level tables for each plan
31 wat The compan s problem characterisation assessment appears to conclude that it is acin a We completed a dra t roblem haracterisation assessment in une which was discussed with the Technical low le el o concern. owe er this is inconsistent with the approach o other companies En ironment enc . The results showed moderate to hi h le els o concern across our re ion. This was documents facing similar challenges and Anglian Water’s approach is presented differently in the draft primaril dri en b uncertaint associated with comple it actors includin ulnerabilit to se ere drou ht ana in plan narrati e and technical appendices. reater clarit on problem characterisation is and eplo able utput calculations . ncertaint and re uired in the inal plan to pro ide assurance the approach adopted is robust. Risk ince completin the dra t assessment we ha e si ni icantl impro ed our understandin o the plannin The dra t plan indicates that an earlier problem characterisation assessment su ested that problem. or e ample we carried out urther modellin to allow us to re ine our understandin o current the plan should be de eloped based on a hi her le el o concern. or clarit n lian Water . We also completed a detailed anal sis o our ulnerabilit to se ere drou ht and an e tensi e should pro ide a clear and transparent summar e plainin how and wh the assessment has pro ramme o customer en a ement to e plore trade o s related to our WR . chan ed. n our inal roblem haracterisation we ha e updated our assessment to re lect this impro ed The dra t plan indicates that an earlier problem characterisation assessment su ested that understandin . The inal assessment con irms that our suppl demand balance is under si ni icant pressure the plan should be de eloped based on a hi her le el o concern. or clarit n lian Water howe er the associated comple it is reatl reduced. onse uentl we are acin lower concerns across our should pro ide a clear and transparent summar e plainin how and wh the assessment has re ion compared with the dra t assessment and the E approach to decision makin is appropriate or use chan ed. in ra t WR .
... the problem characterisation is inconsistent between the narrati e and technical appendi . The narrative states “We have since updated this initial assessment and completed a Final roblem haracterisation assessment which con irms that we are acin moderate and hi h le els o concern across our re ion . owe er the conclusion in the technical appendi is that the compan aces low to moderate le els o concern and this is the approach adopted in the dra t plan. This needs to be corrected or e plained.
wat n lian Water has si ni icantl increased the number o water resource ones to rom We ha e increased the number o WR s rom 19 to in our current plan. We ha e set out a detailed Re ised dWR in the pre ious plan. This is a ke dri er and is dri in si ni icant in estment throu h the e planation or this chan e in a new chapter o the re ised dWR . hapter stated re uirement to interconnect a number o ones. owe er onl limited in ormation has been pro ided in the dra t plan to support such a si ni icant chan e and reater clarit needs to be pro ided in the inal plan.
wat or transparenc the compan should pro ide a water resource one inte rit report with We pro ided our WR nte rit Report to the En ironment enc and will make it a ailable to all re ulators. Re ised dWR the inal plan. This should clearl articulate the supportin e idence or each o the re onin We ha e also set out a detailed e planation or this chan e in a new chapter o the re ised dWR . hapter decisions usti the splittin o ones that ha e pre iousl been considered inte ral and demonstrate the risks aced in the current s stem.
wat inked to the abo e point the inal plan should demonstrate the support or the chan e rom s discussed in the new chapter o the re ised dWR we ha e ollowed the En ironment enc s method Re ised dWR ke stakeholders such as the En ironment enc and detail the assurance process and liaised with the En ironment enc on our WR con i uration. hapter ollowed. wat t is unclear wh i there are now independent water resource ones the ha e been The roupin o WR s was undertaken to make the roblem haracterisation more mana eable and was rouped into the same se en areas as in the pre ious plan or the problem characterisation possible because WR s in each area ha e similarities in terms o resources and risks. owe er the t picall e ercise. reater clarit is re uired on how this approach is appropriate i en the si ni icant do not share resources or ha e a connected suppl s stem and there ore cannot be considered sin le WR s chan es made to the ones. usin the En ironment enc de inition.
wat There is some e idence o non drou ht resilience consideration includin the potential We reco nise the importance o the WR in the conte t o our wider resilience strate and ha e included R usiness increased resilience to un oreseen e ents rom increased connecti it . The compan should some additional detail on the bene its and ali nment o our plans in our re ised dWR . owe er we ha e lan Resilient consider pro idin urther detail o its approach in the inal plan re erencin the ull ran e o re rained rom pro idin e tensi e detail in this area as we eel this is more appropriatel addressed in our Water upplies potential ha ards and threats such as ree e thaw e ents. R usiness lan. and Resilience in the Round chapters
32 f at o ever it is unclear if customers fully understand and support the approach on areas such ur customer engagement strategy focussed on three areas evised dW as resilience or ill impacts of potential solutions and greater clarity on these points is • Views on resilience and severe restrictions (such as rota cuts and standpipes) hapter re uired in the final plan • Views on the choices of solution (i.e. demand management, new resource options), and ection and • Impacts on bills and what customers are willing to pay for. ustomer and ta eholder We have e plored in detail the accepta ility of severe restrictions ith our customers We have or ed hard ngagement to ensure that engagement as as meaningful as possi le y testing the language and materials used to Appendi communicate ris and y ensuring that the descriptions used can e readily understood The results of this research ere central to the development of our dW
etails of our customer engagement strategy and results are provided in the ustomer and ta eholder ngagement Appendi hapter of our revised dW descri es ho customer preferences shaped our referred lan
f at t is unclear hether the impact and timing of the selected level of resilience as discussed ur customer engagement activities included research presenting customers ith alternative levels of evised dW ith customers in terms of the supply demand alance the scheduling of options or the ill services including investing in drought resilience ut not climate change investing in drought resilience and ustomer and impact t is also unclear if customers have een presented ith the impacts of selecting climate change and the inclusion of future proofing investments Another study as ed customers ta eholder alternative levels of service or hether relative drought resilience levels have een preferences regarding alternative evels of ervice for severe restrictions from years to to ngagement compared ith other companies to ena le informed engagement to never Appendi
There is limited comparative information availa le on the evel of ervice for severe restrictions The ma ority of companies plan to ensure resilience against the historic record and this varies et een regions e cept for or shire Water and outhern Water hich provide a in year evel of ervice This as discussed ith customers at the follo up focus groups to the stated preference study
etails of our customer engagement strategy and results are provided in the ustomer and ta eholder ngagement Appendi
f at Anglian Water presents ill impacts in its draft plan and states investment in supply side Follo ing the su mission of draft W e undertoo further deli erative research ith customers to evised dW enhancement ill add a out a year to the average ill o ever it is unclear if customer discuss the accepta ility of our referred lan We presented customers ith three alternative options ustomer and support for this has een demonstrated and greater clarity is re uired in the final plan o nvesting in drought resilience ut not climate change hich ould add p a to the average ill y ta eholder ngagement t is unclear if the a year increase as presented to customers in the conte t of one of a o nvesting in drought resilience and climate change hich ould add a total of p a to the average ill Appendi num er of factors that could influence ills t also appears the impacts are focused on y and aspects of the plan independently such as supply rather than as a pac age supply and o Future proofing our net or y uilding additional capacity no hich ould add a total of p a to demand options the average ill y
iven that Anglian Water have ro en do n the increase in ills into areas such as drought The ma ority of customers supported the future proofing option as it carries the least ris and as felt resilience climate change and sustaina ility reductions the company needs to demonstrate to e the most proactive although note that this is not ro ust pricing research this has een presented to customers in a transparent manner We e pect the final plan to clearly account for the influence of customer preferences and their illingness to pay We have ta en the decision to prioritise demand management options follo ing consultation ith our customers and regulators as descri ed in hapter As such e have not directly compared demand and supply options
33 fwat he draft plan does not include reference to engagement with, or challenge from, the In the initial stages of developing our strategy in we agreed a number of ob ectives with our oard and evised d company’s Customer Challenge Group (CCG) on the customer participation programme. In our ustomer ngagement orum. hese were then reviewed again by the ustomer ngagement orum in ustomer and the final plan clarity is re uired on the approach adopted to engagement and how this arch and updated. ta eholder engagement has shaped the plan. ngagement ur ob ectives include ppendi • To run a programme of engagement activities that are genuinely co-created and designed with a representative group of customers and other sta eholders (employees, ustomer ngagement orum etc.), with special attention paid to customers in circumstances that may ma e them vulnerable • Demonstrate best practice customer engagement in a way that builds understanding and enables sta eholders to recognise us as a leader • Be clear that we are interested in customers’ long term priorities • Be strategic and have a clear thread between the different elements of the programme, as well as a clear view about how customer insight will drive decision ma ing • Draw evidence from all the different channels through which we engage with customers and triangulate the insights
fwat nglian ater should continue to engage with retailers and large users to further validate on ousehold demand is currently . metered. his has provided e tensive data, upon which the on echnical the demand forecast, and reflect these outputs in the final plan. ousehold forecast has been based. documents emand e continue to engage with the retail and non household sectors, through our retail partners to drive water anagement efficiency and monitor consumption. trategy ( ection ( . . )), and emand orecast ( ection )
fwat owever, the company faces significant challenges with respect to abstraction licence e have created an infographic in the main lan which summaries our option selection and relationship to evised d reductions and climate change. urther e planation is re uired regarding the status of its ey drivers. hapters and system model and the relationship between the restrictions that have been identified and the selection of options in the preferred plan.
fwat he impacts of the ater Industry ational nvironmental rogramme ( I ) abstraction e have committed to maintaining all of our groundwater abstractions below recent historical abstraction evised d licence changes are presented differently in the principal and adaptive plans rates in order to manage the ris of deterioration. o reflect this, we have assessed the impact of hapter sustainability changes on all groundwater sources in in our referred lan, rather than in as detailed in our d daptive lan scenario. echnical documents upply orecast, and ustainable bstraction
fwat or the final plan we e pect nglian ater to revise its forecasts with reference to the latest ur revised draft has been updated to reflect I and the referred lan has been updated to evised d I outputs (release ) and e plain any variations between these two releases and how reflect this. he timing of these impacts has also been updated to reflect consultation responses received. e hapter the selected plan, either principal or adaptive, has changed as a conse uence. his should clearly describe the differences between our d and revised d . also provide details on how the company intends to appropriately manage this uncertainty echnical reports around reductions. upply orecast
34 fwat nglian ater states it has delayed the impact of climate change in its plan from to e are no longer adopting this approach evised d - , to allow the choice between supply-demand options, rather than phasing in climate Chapters and change over the period. or clarity, the final plan should provide a further detail on the benefits and ris s of this approach. fwat Given the inherent uncertainty regarding potential climate change reductions the company e have considered alternative climate scenarios in the stress testing section of the referred lan evised d - should clarify if they have considered how this would be accounted for in the adaptive plan. Chapter This would reflect the potential for both lower and higher impacts and identify the fle ibility of the plan and the ey decision points to ensure effective investment decisions.
fwat In a change from the previous plan nglian ater has used a new system modelling e have built a systems model in uator to represent our entire region which has been used for our Technical approach for the uthamford and incolnshire ones. The company should confirm if it plans deployable output assessment in all but two ater esource ones. ur uthamford and incolnshire areas documents to e tend this approach further across its area and how the plan has been influenced by the are considered to be more con unctive than others and this has been represented in uator through inter- upply orecast identification of networ constraints through this modelling. one transfers. e are e ploring options to improve connectivity between the rest of our ones which we will represent in uator as appropriate. uator has improved our understanding of networ constraints on D Technical as previously these were not considered, which has allowed us to identify options to utilise e isting resource. documents upply ptions
fwat The outage allowance is appro imately , marginally lower than the previous plan and The outage allowance has been updated and the average level reduced, ta ing into account the reduced ris Technical below the industry average of . The company states the intention of updating outage for from single source of supply. documents the final plan based upon its resilience assessment and the final plan should clearly e plain anaging any changes from the draft plan. ncertainty and is fwat nglian ater use a simple approach to headroom adapted from the approach defined in the eadroom is capped to . ( s - ) and . ( ) in the baseline forecast the same volumetric Technical guidance. Target headroom is of demand in , increasing to of demand by headroom is used in the final forecast and therefore there may be some differences in the percentages documents which is slightly higher than the industry average. There are inconsistencies in its relative to the final forecast especially in s where demand has reduced significantly. anaging presentation between the narrative and planning tables, as the narrative states headroom ncertainty and will be no greater than . of demand by rather than the noted above. This is should be e plained or corrected in the final plan.
fwat In the final plan we e pect nglian ater to provide clear evidence for the choice of final In moving from our draft to our revised draft we have simplified our description of the planning planning scenario (either principal or adaptive). This should e plain how the outcomes of scenario, and associated investment plan. e are no longer to referring to a rincipal and daptive plan, consultation with customers and ey sta eholders have influenced the decision. instead we have one referred lan, and we describe the process of adaptive planning that we will underta e as we move towards . In our revised d summary report we describe the ustification for the selection of the planning scenario and referred lan. e have included more detail and further ustification than we did in our d .
fwat review of the supply-demand balance components is complicated by the number of ones e have provided aggregated summary numbers in our revised d owever, in general terms the evised d - in the nglian ater area. The company should consider whether production of an s are the building bloc s. Chapter aggregated company level table for both scenarios would aid understanding and transparency of the plan.
35 fwat nglian ater has considered a wide range of supply and demand options, reflecting the e have created a new section in our revised d to strengthen the ustification for our referred lan evised d - scale of challenge faced. owever, as referred to in section , further evidence is re uired to (Chapter referred lan). e also include details of the development of our demand management strategy ecutive ustify the drivers for the options selected. in Chapter and our supply-side strategy in Chapter . ummary, and Chapters , , In addition, we have also updated the supporting graphics for our plan to help e plain the ustification for the and strategy and specifically to e plain the need to develop the strategic grid. The figure, which appears on the third graphics page in the ecutive ummary, and in Chapter referred lan, shows how each transfer scheme addresses deficits in specific water resource ones. The map on the first graphics page in the ecutive ummary also provides a visual aid to e plain the drivers of the deficits in each . e have also strengthened the description of the drivers in Chapter , the scale of the challenge.
fwat ollowing the publication of the draft s, we have wor ed closely with our neighbouring water evised d - There is uncertainty regarding the trading re uirements of neighbouring companies which companies, Defra and the nvironment gency to clarify the position relating to future trading re uirements. Chapter would have a large impact upon the proposals, especially those in adaptive plan. e agreed with ffinity ater to consider a future e port of l d, which although does not form part of ( ection . ) our referred lan, was included in the stress testing scenarios. e will continue to wor with ffinity ater to develop this e port option ahead of .
fwat owever, third-party options appear to have been screened out due to insufficient e included a number of trading and third party options in our feasible option set. e have engaged in Technical information and we would welcome further evidence to show the criteria have been applied detailed discussions with our neighbouring water companies as well as water management organisations in documents consistently. our region such as the nvironment gency and the Canal and iver Trust. e have also held discussions with upply-side third party suppliers and other large industrial users in our region to e plore trading opportunities. e ption considered trading and third party options identified through nconstrained options wor shops, Development Collaborative water resource planning pro ects groups, and the ar et Information platform.
ll of the options identified were assessed using the same method for in-house options, and any discounted options are recorded in the re ection register.
fwat nglian ater has provided evidence of engagement and discussion with third parties to e sought input from third parties via the ar et Information platform. n a generate options for consideration within the planning process. owever, the consideration of third party options appears to have focused on supply-side options and the company should consider what it could do in order to promote further demand-side options.
fwat Beyond the regional options discussed above, no third party options have been included on e included a number of trading and third party options in our feasible option set. evised d - the feasible list and a number were re ected due to insufficient data being available. or Chapter these options nglian ater should continue to actively engage with the third parties and e did not receive details of any further third party options through the ar et Information latform but we ( ection . . ) provide support to ensure viable options are not unnecessarily screened out. will continue to liaise with sta eholders through the ater esources ast programme. The ar et Information platform will also be regularly updated. Technical documents upply-side ptions Development
36 fwat e e pect nglian ater to demonstrate e ual vigour in gathering data on third party as in- e re uested option data to ensure that the trading and third party options were assessed using the same evised d - house options and to ensure e ual treatment of these options. It should be careful to ensure methodology as our own supply-side options. Chapter that its in-house options are not unfairly or unduly favoured and that the principles for ( ection . . ) company bid assessment framewor s are followed. or some third party options, the ris s associated with yield reliability, invasive non native species and water uality were considered too great to be included in the feasible options set without further investigation and Technical so were not included in the d programme appraisal modelling. documents upply-side e will continue to liaise with sta eholders through the ater esources ast programme and the ar et ptions Information platform to further develop third party options. Development
fwat Water trading is a key feature of Anglian Water’s plan reflecting its location and the e have wor ed hard between d and revised d to improve the alignment between water evised d - company’s involvement in groups such as WRE. However, we have concerns regarding the company plans and specifically how e isting agreements are presented. e are confident that there is now Chapter consistency of the presentation of some transfers and the limited evidence of the full alignment between our plans. development of a regional strategy and clarity on these points need to be provided in the final plan. ur revised d referred lan is consistent with emerging ater esources ast strategy as described in chapter . fwat The starting value, trend and end point of the reduced e port to ffinity ater is not e are continuing to wor closely with ffinity ater to understand their future trading re uirements. e consistent between the two companies. or e ample there is a difference of l d in its do not include an e port to ffinity in revised d referred lan. starting value. urther ustification for this trade is also re uired given the near term needs that ffinity ater faces. owever, we have considered a potential future e port to ffinity in our stress testing, to ensure that we are able to adapt our referred lan to meet future needs which are currently uncertain.
fwat The new import does not appear to be represented in the evern Trent ater preferred plan e have wor ed with evern Trent ater in preparing our revised d to ensure the options included where over l d of new e ports are identified in total with no clear description of the are the most up to date available. The options referred to in this comment does not appear in our revised individual component trades. d referred lan.
e will continue to wor closely with evern Trent ater via ater esources ast and the Trent or ing Group in our adaptive planning and preparations for . fwat In the adaptive plan significant new e ports of up to l d to ffinity ater and e are continuing to wor closely with ffinity ater to understand their future trading re uirements. e Cambridge ater commence in - . owever, these do not appear as imports in the do not include an e port to ffinity in revised d referred lan. respective companies preferred draft plans. owever, we have considered a potential future e port to ffinity in our stress testing, to ensure that we are able to adapt our referred lan to meet future needs which are currently uncertain.
e no longer include an e port to Cambridge ater, as agreed with the company.
fwat The focus on lea age reductions aligns with the reported customer preferences and there is ur assumptions are built upon our smart meter trials in ewmar et and orwich. owever, we do not Technical an e pectation that smart meters will help reduce supply pipe lea age. nglian ater consider smart metering to be a technological fi rather, it will be accompanied by water efficiency documents appears to be relying on the reduction in water bills as sufficient incentive to drive this activities. Demand behaviour. It should clarify its evidence and underlying assumption for this and whether anagement alternative approaches have been considered. trategy ( ection . . - . . )
37 fwat Anglian Water has an am itious metering programme with the level of metering penetration Actual meter installation penetration is currently and is forecast to increase to y . echnical forecast to rise from in to y . However, the company should provide documents further evidence to support the delivera ility of this strategy within the final plan. ur referred lan is proposing company wide roll out of smart meters. We discuss delivera ility in the emand emand anagement trategy. anagement trategy ection . . , . .
fwat Anglian Water’s long term target for average per capita consumption (PCC) is identified as We adopt the same approach to demand management in our revised dWR . echnical l h d y in the planning ta les. his is consistent with the average for other documents companies nationally and it is therefore maintaining comparative level of performance. We emand welcome the proposals to investigate the feasi ility of greywater and rainwater reuse and anagement consideration should e given to scaling these options to help drive further reductions to trategy ection meet challenges faced. .
fwat ew interconnections etween ones are included in the preferred plan for with a We have provided more detailed information on the e tension of our strategic grid in our revised dWR , Revised dWR significant e penditure. his includes the creation of a linked strategic grid. However, as including in relation to the drivers within each ro lem haracterisation area and WR . hapters and referenced in section , greater clarity for the drivers ehind this are re uired in the final plan. fwat ew interconnections he company should present options considered for each We provide more detailed information on the e tension of our strategic grid in our revised dWR , including Revised dWR interconnection and e plain how these have een evaluated in the conte t of the potential in relation to the drivers within each ro lem haracterisation area and WR . hapters and change in key drivers, such as future trades and climate change.
fwat ew interconnections Anglian Water need to demonstrate how it has optimised the We have undertaken stress testing and long term E runs which oth demonstrate the ro ustness of the Revised dWR solution and considered the enefits of a fle i le approach, such as e tending the delivery interconnections included in the referred lan. hapter phase. he company should provide evidence the solution presented represents an appropriate alance of risk and it is adapta le to varying future scenarios.
fwat A large variety of supply side options have een considered and significant supply side We have ad usted the supply risks in our revised dWR to take into account consultation feed ack and Revised dWR options are included throughout the planning period in oth plans. We e pect Anglian Water updated modelling. We have struck a alance etween future proofing and minimising redundancy through hapters and to consider the scale of investment re uired in its final plan, in light of potential e tending our strategic grid, whilst minimising the need for new resources. uncertainties, in particular if the future e ports to Affinity Water and am ridge Water of l d are not re uired. fwat he company is proposing development of a significant num er and scale of supply side he delivera ility of option is assessed as part of the options appraisal process as descri ed in the upply echnical options within and therefore should include greater detail on the potential risks in ption development technical report documents terms of environmental mitigation, delivera ility and uncertainty in timing. upply side ption evelopment
38 f at Anglian Water as adopted an economics of alancing suppl and demand ( ) approac We ave added ne sections on our approac to decision ma ing and t e criteria used in adapting t e least evised dW P to develop its plans o ever e ave concerns around t e transparenc and ro ustness of cost output to a est value plan We ave also included information on t e delivera ilit of t e C apters t e decision ma ing in t e draft plan We ould e pect to see greater clarit provided on t e options and t e assurance t at as een underta en (demand side) delivera ilit of t e programme and t e assurance processes underta en in t e final plan and (suppl side)
or delivera ilit see tec nical documents uppl ption evelopment and emand anagement trateg
f at e preferred plan is ased on t e principal plan it additional investment to ena le t e We ave added ne sections on our approac to decision ma ing and t e criteria used in adapting t e least evised dW P development of options in t e adaptive plan o ever it is unclear o t e preferred plan cost output to a est value plan C apters as selected and furt er clarit is re uired in t e final plan (demand side) and (suppl side)
f at W ile t ere is a large amount of material provided on ot plans it is unclear o t e final We ave added ne sections on our approac to decision ma ing and t e criteria used in adapting t e least evised dW P preferred portfolio as selected Anglian Water s ould clarif t e decision ma ing process cost output to a est value plan C apters and in t e final plan include a clear summar t at concisel e plains o and om t e (demand side) preferred plan as decided and (suppl side)
f at As noted in sections and a ove t ere is significant uncertaint in ot t e level of ased on significant furt er engagement it neig ouring companies e ave concluded t e trading or stress testing a straction licence reductions and t e ater trading re uirements of neig ouring arrangements and agreed a scenario to capture future uncertaint We ill continue it all e isting trades see revised companies Anglian Water s ould provide a clear e planation of o t is uncertaint as o capture potential future re uirements e ave agreed scenarios it Affinit Water for e port to Affinit dW P C apter impacted its decision ma ing process and o furt er information su se uent to t e draft ast and Affinit Central e most significant scenario is e ploring a l d e port to Affinit Central is plan led to an revisions for t e final plan is captured in t e stress testing of our preferred plan and ill e included in our adaptive planning or adaptive planning see revised dW P C apter
f at iven t e ig levels of uncertaint Anglian Water s ould consider o it can ensure We ave underta en stress testing using several scenarios and long term runs ic ot demonstrate or stress testing fle i ilit in t e final plan to ena le it to adapt to a variet of outcomes e plan s ould t e ro ustness of our Preferred Plan see revised consider e trigger points for decision ma ing to promote efficient investment Additionall dW P C apter t e evaluation and selection of options s ould account for t is ensuring lo er regret options We ill e moving into a p ase of adaptive planning during ic e ill develop e trigger points and are considered first and t e enefits of more fle i le solutions are realised (suc as modular alternative options pat a s deliver ) or adaptive planning see revised dW P C apter
39 f at As noted in section t e c allenge Anglian Water faces suggest more advanced decision We ave added ne sections on our approac to decision ma ing and t e criteria used in adapting t e least evised dW P ma ing tec ni ues could e adopted Anglian Water s ould consider o it could furt er cost output to a est value plan We ave also included information on t e delivera ilit of t e C apters validate its decision ma ing t roug more advanced tec ni ues and set out its options and t e assurance t at as een underta en (demand side) considerations in t e final plan and (suppl side)
or delivera ilit see tec nical documents uppl ption evelopment and emand anagement trateg
f at t is not clear o delivera ilit of t e preferred plan as een considered in t e decision e delivera ilit of options is assessed as part of t e options appraisal process as detailed in t e uppl ec nical ma ing process and t is needs clarif ing in t e final plan or e ample t ere is considera le ption evelopment and emand anagement trateg tec nical documents documents investment planned in ot demand side and suppl side options in ic could uppl side represent a c allenge for deliver at a programme level n addition e ave considered ris s associated it t e demand management options stress testing our ption preferred plan using lo er levels of demand ( and ) evelopment and emand anagement trateg
or stress testing see revised dW P C apter
f at Anglian Water riefl refer to t e assurance process for t e plan and approval t e ur plans ave een t roug rigorous internal and e ternal assurance processes is includes a t ree compan oard e compan s ould provide greater clarit on t e assurance process step process of follo ed and oard involvement for t e final plan a) c allenging and ustif ing t e need for an investment ) ensuring e select t e most appropriate solution to meet need including considering innovative approac es and c) costing t e selected solution from a aseline of our o n ac ieved efficiencies testing against industr enc mar s and t en appl ing furt er productivit en ancements and stretc efficiencies across our entire investment programme
f at Anglian Water as demonstrated it or ed closel it W and groups suc as t e iver We agree t at t ese groups ill continue to e important and e remain committed to t em including in our evised dW P rent and use steering groups during plan development o ever furt er or is re uired adaptive planning process C apter to uild a regional strateg consistent it W We e pect t e regional level discussions to e ongoing and for greater clarit on t ese considerations to e provided in t e final plan
f at e compan states ere options in t e preferred plan are consistent it t e W W strateg is road and includes a grid and ide variet of options our preferred plan uilds part of t e evised dW P outputs o ever to increase transparenc t e plan ould enefit from a summar and grid envisaged W and eeps options open regarding source of ne supplies ot ave significant s C apter e planation of t e differences et een W outputs and t e preferred plan
40 f at Anglian Water as selected t e standard planning period of ears ile ot er companies or t e revised dW P e ave underta en long term runs to and ese demonstrate evised dW P ave used longer periods We note W uses a longer term ori on and considers impacts consistenc it our Preferred Plan C apter into t e s e compan s ould clarif its c osen planning ori on in t e conte t of t e regional plan outputs it is using for comparison
P illips o consider t e potential impact of t e treating and diverting t e non pota le ater out of As e finalise our plans e ill e in a position to ans er t ese uestions more full o ever e can offer n a ls am P illips re uests t at Anglian Water provides t e follo ing comments at t is stage a) data on volumes of ater currentl treated and e ported as non pota le to t e out uestion ( ) t e forecast demand volume remains static at l d (note ater availa le is l d giving um er an industrial customers an l d surplus) ) forecast data on volumes of ater re uired as non pota le suppl t e out um er uestion (c) e currentl anticipate transferring l d pota le ater from ls am in rising to an industrial customers l d from in our revised dW P e ave altered t e utilisation rises more graduall from c) forecast data on volumes of non pota le ater to e treated and transferred out of ls am as pota le We ave alread eld post dW P discussions ic ill continue it retailers on t e out um er an or e ample t e capa ilit relia ilit and sta ilit of t e P e ipe non pota le ater suppl as ell as ualit and composition of suc ater must e in all regards at least We ill continue to develop t e P e ipe option ilst also considering alternative resources e uivalent to or etter t an t at provided t e current suppl from ls am Water reatment Wor s
ere follo s a list (a ) of re uirements for furt er anal sis of t e P e ipe option
P illips ere is also a concern et er ade uate ater suppl ac up capa ilities ill e As e finalise our plans e ill e in a position to ans er t ese uestions more full n a implemented to supplement s ort term and long term s ortages of non pota le ater suppl We ave alread eld post dW P discussions ic ill continue it retailers on t e out um er an
n t is regard P illips re uests t at Anglian Water facilitates We ill continue to develop t e P e ipe option ilst also considering alternative resources a) Consultation on t e num er of da s of ac up suppl availa le to t e out um er an industrial customers in t e event of a failure at t e P e ipe facilit or ot er disruption issues on t e ater suppl infrastructure ) Creation of a ac up suppl retaining a properl maintained connection to t e ls am Water reatment Wor s including details of o suc ac up facilities ould e implemented and an s ort term suppl disruption t at ma occur on s itc ing to t e ac up suppl
P We ant Anglian Water to commit in our final plan to pla ing a full role in continuing it We are committed to pla ing a full role in t e ne t p ase of Water esources ast and remaining an active evised dW P t e ne t p ase of Water esources ast and more generall in promoting and participating in participant in ot er regional and national planning initiatives C apter national and regional scale ater resource planning initiatives in A P
P o ever given t e limited resources in ast Anglia and t e out ast e ould also li e to We ave een colla orating regionall t roug t e W strateg ic includes a significant focus on ec nical see t ese companies colla orating more on demand side measures or e ample on lea age emand anagement ptions We ave referenced t is strateg ilst producing t e dW P documents or PCC ere currentl Anglian Water are at t e leading edge and Affinit are not is could emand free up additional valua le resources anagement trateg ( ection )
41 P • We want Anglian Water to clearly set out in your final plan what steps you are taking to ur revised dW P includes significant levels of sustaina ilit reductions ic ill leave large uantities of n a understand promote and uild t e resilience of t e natural environment in line it ater in t e natural environment for t e enefit of ecos stems and iodiversit OFWAT’s Resilience Planning Principle 2. We ave also reduced t e need for furt er a straction from t e environment t roug our am itious demand management programme and t e transfer of e isting resources
nvironmental impacts of options ave een considered as part of t e options appraisal process
P We are pleased to see t e W P sc eme to cease a straction at ud am ore ole near We are dedicated to t e improvements of Catfield en and t e Ants roads and ars es We are committed evised dW P Catfield en arc We ould li e to see Anglian Water support eco drological to closing our ud am source arc and are managing uncertainties surrounding potential future C apter monitoring of t is internationall important site so t at t e eneficial impacts of t e W P c anges to ot er sources in t e area We are full supporting t e nvironment Agenc and atural ngland in sc eme can e confirmed t eir ongoing investigation into t e ider Ants roads and ars es ec nical documents ustaina le A straction
P • We want Anglian Water to commit to continuing the investigative work in WRE in AMP7 to We ave supported t is t pe of investigative or as one of t e tec nical pac ages under Water esources assess future ris s to conservation sites and t e environment arising from our a stractions ast Wit ot er partners e ill revie t e tec nical re uirements for t e ne t p ase of or in due given a li el climate c ange scenario of c anging flo patterns and ground ater levels course
P • We ask Anglian Water to set out in more detail their proposals for utilising AIM in AMP7 A is one of several performance commitments set out in our P usiness Plan We list t ese evised dW P including ere and o t e ill use A to mitigate for ris s of impact on environmental performance commitments in our revised dW P urt er detail on our A commitments as een C apter sites and W status included in t e ustaina le A straction supporting tec nical document and also our P usiness Plan ec nical We e pect t at t e deliver of sustaina le a straction sc emes in A P ill remove t e need for A at all eports sites follo ing t eir completion ustaina le A straction
P • We are pleased to see that Anglian Water is not planning overall to put more water into ur revised dW P sees distri ution input fall from l d in to l d in remaining ec nical distri ution t e end of A P in is is one of our priorities in t e lueprint for close to l d in documents P We ould li e to see a similar commitment in t e longer term to emand orecast
• We are pleased to see Anglian Water’s evident commitment to remain at the leading edge in t e sector on lea age given t e ater scarcit c allenges in t e region
• We are pleased to see Anglian Water’s short and long-term commitment to metering
• We are pleased with Anglian Water’s ambition on PCC in both the short and long term.
42 2 7 R P • We want to see Anglian Water highlighting to OFWAT any issues that it is having in Changes to ocal planning efficiency standards reducing current stipulations from 2 l h d to l h d and Technical engaging business customers on water efficiency via the new water retail companies given below designed to increase efficiency are actively supported and encouraged. documents the water resources challenges highlighted in the draft plan. emand We monitor the current status ocal Authorities design efficiency standards across the region. as detailed in Management • We want Anglian Water to commit in your final plan to piloting the use of household and the revised emand Management trategy Report. trategy ection community incentives during dry weather periods or in water stressed areas to reduce . demand. We are currently developing incentive systems tied to our smart meter rollout that will be able to be targeted at specific households locations and communities. iven the potential for a much more dynamic • We want Anglian Water to commit to stepping up its engagement with developers and relationship with our customers we will be able to apply these incentives at times of greatest water stress local planning authorities to ensure all new ma or development incorporates water efficient dry weather drought homes. We would also like to see the company work with other stakeholders to advocate to government for stronger building regulations in water stressed areas. We are planning to incentivise developers to build more efficient homes building to a l h d standard with reduced waived onal charge fees.
2 R P owever there seems to be a significant level of uncertainty around the scale of We are now addressing in AMP7 all of the sustainability reductions recognised in the dWRMP. Revised dWRMP - sustainability WF no deterioration reductions needed and this has led to a rather comple Chapter 2 set of possible additional options. We believe that if as stated the sustainability reductions are likely then Anglian Water should act sooner rather than later to build in future proofing for the system. This would be preferable to the risk which has materialised for outhern Water of a supply system that is not fit for purpose following sustainability changes and relies on fre uent drought permits and orders.
2 R P • Given the levels of uncertainty and the range of potential future supply side options we We agree and will move into a phase of adaptive planning as soon as our WRMP is finalised. Revised dWRMP - suggest that Anglian Water starts the planning for 2 2 onwards early working with Chapter 7 stakeholder and customers to help refine and focus a robust plan for 2 2 onwards.
2 R P • Under the Adaptive Plan reference is made to a Fenland Reservoir in addition to the South either the Fenland Reservoir or the outh incolnshire reservoir currently feature in our Preferred Plan. They incolnshire Reservoir however it does not appear to be shown on the plan maps or listed in are options are considering as part of our adaptive planning process in preparation for WRMP 2 2 . We the tables. Please could more information be provided on this option in the final plan. There agree that both reservoirs have the potential to provide multiple benefits not ust to public water support but is an opportunity for such a scheme to provide multiple benefits for farmers conservation also the agricultural and environmental sectors. These flood risk and water supply and we would like to find out more about this proposal.
2 R P owever we have found it difficult to get a clear picture on the scale and location of inter- We have worked hard between dWRMP and revised dWRMP to improve the alignment between water company transfers. We understand that discussions are still live between companies and company plans and specifically how e isting agreements are presented. We are confident that there is now with the regulators and that these include ma or schemes such as the evern Thames full alignment between our plans. transfer.
2 2 R P • We believe that additional stakeholder and customer engagement will be necessary if there We have carried out e tensive stakeholder and customer engagement in the development of our plan as are any substantive changes between the draft and final plan with respect to the preferred outlined in the Customer and takeholder Engagement Appendi . There have been no substantive changes in supply side solutions. our preferred supply side solutions which would warrant further customer and stakeholder engagement.
43 RSP • We want Anglian Water to commit in its final plan that all the supply side water resource Our revised dWR P includes significant levels of sustainability reductions which will leave large uantities of schemes you progress in A P will deliver a net gain in biodiversity and for the wider water in the natural environment for the benefit of ecosystems and biodiversity environment We have also reduced the need for further abstraction from the environment through our ambitious demand management programme and the transfer of e isting resources
nvironmental impacts of options have been considered as part of the options appraisal process
nevitably with the transfer schemes there will be environmental impacts and whilst these will be mitigated wherever possible some will remain especially related to carbon emissions associated with energy use from pumping
RSP • We were disappointed to see so little in the draft Plan on your catchment management We have added some further detail on the alignment between our revised dWR P and our catchment Revised dWR P programme and proposals for A P given the relevance of catchment management to management strategy hapter current and future water supply in the region We know the company are doing some e cellent work in this area and are surprised at the lack of connection made in the draft plan We support the need for a targeted ban to address the risks associated with metaldehyde owever until Technical between this work and your current and future management of regional water resources there is certainty from the Government on the implementation of the ban the ban we chosen to include documents We hope this is something that can be addressed in the final plan metaldehyde treatment in our plan This ensures we are compliant with the W guidance and related water Supply Forecast uality legislation and that no customers are at risk of deteriorating water uality • We are disappointed to see so many energy intensive metaldehyde removal schemes in the draft Plan We know that Anglian Water have been progressing catchment initiatives to reduce levels and risk and that the company has also been advocating the use of regulatory measures such as a targeted ban where voluntary catchment actions have not been or are unlikely to be sufficiently successful We strongly believe that it is in the customers interests for targeted bans to be brought in as soon as possible through the vehicle of Water Protection ones
RSP • We are pleased to see that Anglian have undertaken a qualitative ecosystem services We have worked with researchers at the University of ast Anglia through the entre for Water Studies to assessment as part of its draft plan that assesses the potential impacts of options on the develop a register of the natural capital found in our region and consider the pressures it faces provision of ecosystem services. We are aware of Anglian Water’s wider work on Natural Understanding the risks that natural capital stocks face and the opportunities for better management will apital and are pleased that the company is considering setting a bespoke reputational help inform our decisions on how best to secure long term water resilience alongside reducing flood risk performance commitment on it We would like to see Anglian Water commit in the final Plan reducing our carbon footprint enabling sustainable housing and economic growth and supporting healthy to continue to progress its work to integrate atural apital into decision making on water lifestyles resource options and also wider business decisions
• We want to see Anglian Water commit to undertake an assessment of the Natural Capital stocks it is directly responsible for across its estate and to make a commitment to maintain and enhance those stocks
44 W eneration we do not support measures that would have the effect of reducing low flows in the use at All the supply side options on the use within the feasi le list are downstream of ittle arford and should echnical ittle arford not impact on flows in this area of the river. documents upply side We do not support any diversion of effluent that would otherwise have een discharged to ption the use upstream of ittle arford at low flow evelopment
we support measures that either increase flows at low flow or have the potential to increase flow at low flows at ittle arford
We may e supportive of transfers into the use upstream of ittle arford that would operate at low flows on the use outh olland outh olland istrict Council supports your approach of planning to meet local authority We have used the latest local authority growth targets as the asis of forecasting population within our echnical istrict Council growth target. ousing growth is a top priority for us as for other ocal Authorities and demand forecast. We will continue to work closely with local authorities in our region to monitor on going documents overnment. We are committed to accelerating our rates of housing and employment housing delivery against targets. urther detail is provided in the emand orecast technical supporting emand orecast delivery and therefore agree with your preferred approach. report.
outh olland outh olland istrict Council supports your approach to prioritise demand management. t We have continued to prioritise demand management within our dW P as descri ed in Chapter . We have echnical istrict Council is important that the country makes the efficient use of natural resources and that Anglian included supply options in the form of transfers and will continue to e plore resource options over the ne t documents Water continues to invest in tackling leakage and encouraging all customers to reduce their five years. urther detail is provided in the emand anagement trategy technical document. emand water use. anagement trategy outh olland outh olland istrict Council supports your approach that water meters should not e made We have considered the range of views e pressed regarding compulsory metering during our consultation as echnical istrict Council compulsory. We encourage you to provide information on comparative costs of metered and well as a wider analysis of the costs and enefits as descri ed in the emand anagement trategy technical documents un metered water supply for typical households in order that consumers can make informed document . We have also taken into account our high level of meter penetration which is forecast to reach emand choices. of households metered and paying measured charges y . As a result we have not included anagement compulsory metering in our revised dW P. We will continue to monitor the proportion of customers illed trategy ased on a meter reading and will review the need for compulsory metering at W P .
outh olland outh olland istrict Council supports your prudent approach ut would urge you to ur revised dW P commits to the delivery of all sustaina ility reductions included in W N P and the evised dW P istrict Council review this aspect as soon as you understand the implications of the proposed new capping of all groundwater licences to ensure sustaina le levels of a straction. We are committed to Chapter environmental regulations. delivering these changes etween and .
We will continue to investigate the potential for further sustaina ility reductions as part of our adaptive planning. outh olland outh olland istrict Council supports the investment in increased resilience to drought ur revised dW P position on severe drought remains the same as for the dW P we will ensure that all evised dW P istrict Council and would ask you to work with the nvironment Agency and others to ensure that water of our customers have a . annual average risk of severe restrictions from . Chapter supplies for agricultural uses are planned alongside the water supplies needed for homes and usiness. outh olland outh olland istrict Council is not equipped to assess this strategic risk ut on alance ollowing the consultation on our dW P we have chosen not to defer investments in climate change evised dW P istrict Council would support a decision to invest sooner rather later ecause there is a tendency to impacts until and have accommodated these impacts within our Preferred Plan with a residual risk Chapter and postpone investment in strategic infrastructure and later regret the decision. in the outh uthamford W that we are managing via preparation for a rought Permit application . ur dW P supply forecast modelled climate change impacts from onwards. or our revised dW P we have included climate change impacts from the start of the W P planning period .
45 outh olland outh olland istrict Council recognises the need to plan for the future needs of the area As part of our adaptive planning process we will carry out planning activities to develop potential large scale istrict Council and that a new storage reservoir would e su ect to full consultation through a formal supply options including new storage reservoirs which may e needed in the future. Assessment of planning process. At this stage, the Council’s view is that any new storage reservoir should be opportunities for wider ecological health and well eing enefits will form part of this. designed so that it has ecological enefits for plant and animal life and also provides amenity and leisure opportunities. hese should enhance health and well eing as well as enefitting the local economy.
uffolk The SGPB therefore endorses Anglian Water’s approach to using local plans as the most We have used the latest local authority growth targets as the asis of forecasting population within our echnical Authorities comprehensive source documents supported y significant analysis and these should demand forecast. We will continue to work closely with local authorities in our region to monitor on going documents continue to e used to inform investment proposals y infrastructure providers. housing delivery against targets. urther detail is provided in the emand orecast technical supporting emand orecast report. uffolk While the rowth Programme oard recognises why Anglian Water has chosen to prioritise We have continued to prioritise demand management within our dW P as descri ed in Chapter . We have echnical Authorities demand management in this Water esources anagement Plan we note that of the included supply options in the form of transfers and will continue to e plore resource options over the ne t documents water resource ones out of a total of W s that are e pected to face large deficits in five years. emand supply from onwards are in uffolk ury averhill W ast uffolk W . As a anagement result while an overall demand management approach can e taken Anglian Water must trategy continue to prioritise investment in securing supply particularly in those areas that have already een identified as having an im alance. We welcome the two supply side transfer initiatives that are proposed for these W s.
uffolk As a predominately pu lic sector oard we do not have a view on compulsory metering. n a echnical Authorities documents emand anagement trategy uffolk t would e useful to compare this increased cost to the worst case future investment ur revised dW P commits to the delivery of all sustaina ility reductions included in W N P and the evised dW P Authorities requirement if this £88m is not invested in the short term (by 2025) – i.e. in the short term capping of all groundwater licences to ensure sustaina le levels of a straction. We are committed to Chapter there is a savings of per customer ut over the longer term this could increase to delivering these changes etween and . additional cost. We will continue to investigate the potential for further sustaina ility reductions as part of our adaptive planning. uffolk his question relates to the alance of demand and supply side measures that are proposed ur revised dW P position on severe drought remains the same as for the dW P we will ensure that all evised dW P Authorities y Anglian Water and the associated costs to the customer. he P as a predominately of our customers have a . annual average risk of severe restrictions from . Chapter pu lic sector oard is keen to ensure that Anglian Water e plore all opportunities to ensure all customers receive the highest level of service at a competitive cost.
uffolk While the P recognise the merits in delaying investment in specific climate change ollowing the consultation on our dW P we have chosen not to defer investments in climate change evised dW P Authorities measures to await further evidence collection and analysis we would not want to see impacts until and have accommodated these impacts within our Preferred Plan with a residual risk Chapter and prohi itive restrictions e.g. rota cuts standpipes implemented should we face a water in the outh uthamford W that we are managing via preparation for a rought Permit application . ur shortfall in the si year period . ased on the data presented in the report the dW P supply forecast modelled climate change impacts from onwards. or our revised dW P overall cape saving of m equates to a per customer saving of . p.a. or . over we have included climate change impacts from the start of the W P planning period . the si year period of delay.
hould we face a severe drought and water is cut off particularly to rural areas is the cost oth financial and non financial in terms of disruption and pu lic hygiene likely to e more than . per household
46 2 0 Tendring istrict The Council agrees to an approach of planning to meet local authority ob ectively assessed We have used the latest local authority growth targets as the basis of forecasting population within our Technical Council needs. The preparation of a sound ocal Plan sits at the heart of our corporate priorities and demand forecast. We will continue to wor closely with local authorities in our region to monitor on going documents the provision of adequate infrastructure is a ey part of our Plan. We want to be sure that housing delivery against targets. urther detail is provided in the emand orecast technical supporting emand orecast Anglian Water is wor ing with the most up to date information available. report.
2 Tendring istrict As stated, planning for the proposed new development should be a ey consideration and We have continued to prioritise demand management within our dW P as described in Chapter . We have Technical Council prioritising demand management appears to be prudent. included supply options in the form of transfers and will continue to e plore resource options over the ne t documents five years. urther detail is provided in the emand anagement Strategy technical document. emand anagement Strategy 2 2 Tendring istrict The Council has no comment on this. n a Technical Council documents emand anagement Strategy 2 Tendring istrict This would appear to be a logical approach. n a n a Council
2 Tendring istrict t is important to include measures to increase resilience to drought. ur revised dW P position on severe drought remains the same as for the dW P we will ensure that all evised dW P Council of our customers have a 0.5 annual average ris of severe restrictions, from 202 25. Chapter
2 5 Tendring istrict It is considered that adopting the Environment Agency’s 2017 method for calculating climate ollowing the consultation on our dW P we have chosen not to defer investments in climate change evised dW P Council change impacts is one of the most appropriate methods. t is considered logical to address impacts until 202 0 and have accommodated these impacts within our Preferred Plan (with a residual ris Chapter 2 and these impacts and therefore invest in a timely manner in line with nvironment Agency in the South uthamford W that we are managing via preparation for a rought Permit application). ur advice. dW P supply forecast modelled climate change impacts from 202 25 onwards. or our revised dW P we have included climate change impacts from the start of the W P planning period (2020 2 ).
2 The Water etail es, we agree with the approach of using the local authority growth targets. f local growth We have used the latest local authority growth targets as the basis of forecasting population within our Technical Company targets are not quite being met currently, this means that the water resources e ceed growth demand forecast. We will continue to wor closely with local authorities in our region to monitor on going documents which we believe ensures water supplies are secure. Additionally, should housing growth housing delivery against targets. urther detail is provided in the emand orecast technical supporting emand orecast ‘catch-up’ with targets, this will not endanger security of supply in the Anglian Water region. report.
2 The Water etail Yes, we believe that this is a good approach. We believe that Anglian Water’s ambitious We have continued to prioritise demand management within our dW P as described in Chapter . Technical Company growth targets set a precedent for the industry and the investment in the latest technology documents encourages innovation within the industry. The Water etail Company is committed to water We loo forward to wor ing with retailers on demand management. emand efficiency and would welcome a collaborative approach with Anglian Water to assist in anagement consumption reduction and demand management amongst our clients. Strategy
2 8 The Water etail The Water etail Company believe that Anglian Water should consider compulsory metering We have considered the range of views e pressed regarding compulsory metering during our consultation, as Technical Company in the upcoming business plan (2020 25). ull metering will aid the delivery of demand well as a wider analysis of the costs and benefits (as described in the emand anagement Strategy technical documents management, it will also provide higher resolution data for water resource management and document). We have also ta en into account our high level of meter penetration (which is forecast to reach emand lea age control and allow the roll out of smart water technology for domestic properties. of households metered and 8 paying measured charges by 2020). As a result, we have not included anagement compulsory metering in our revised dW P. We will continue to monitor the proportion of customers billed Strategy based on a meter reading and will review the need for compulsory metering at W P 202 .
47 2 he Water etail Yes, we believe that this is important. It is a small annual cost increase per customer which ur revised dW commits to the delivery of all sustainability reductions included in WI E and the evised dW - ompany will ensure that security of supply. We believe this money would be well invested in future- capping of all groundwater licences to ensure sustainable levels of abstraction. We are committed to hapter 7 proofing. delivering these changes between 2020 and 202 .
We will continue to investigate the potential for further sustainability reductions as part of our adaptive planning. 2 0 he Water etail Yes, we also believe that investment in drought resistance is highly important. Again, this ur revised dW position on severe drought remains the same as for the dW we will ensure that all evised dW - ompany would be a modest increase in bills which we believe would provide essential investment and of our customers have a 0. annual average ris of severe restrictions, from 202 -2 . hapter 7 reduce the impact of a severe drought event. 2 1 he Water etail o, we strongly believe that investment in climate change should be deferred until 202 - ollowing the consultation on our dW we have chosen not to defer investments in climate change evised dW - ompany 0. limate change poses a significant ris and action should be ta en as early as possible to impacts until 202 - 0 and have accommodated these impacts within our referred lan with a residual ris hapter 2 and mitigate any impacts. We assume that the e penditure in point will also offset some of the in the outh uthamford W that we are managing via preparation for a rought ermit application . ur e penditure in points and . dW supply forecast modelled climate change impacts from 202 -2 onwards. or our revised dW we have included climate change impacts from the start of the W planning period 2020-21 .
2 2 Water evel We broadly agree with the approach, on the basis that historic trends are irrelevant in the We have used the latest local authority growth targets as the basis of forecasting population within our echnical face of political pressure to meet national house-building targets. hese targets have demand forecast. We will continue to wor closely with local authorities in our region to monitor on-going documents historically been over-optimistic. evertheless, we believe that incumbents should prepare housing delivery against targets. urther detail is provided in the emand orecast technical supporting emand orecast their lans on the basis of current targets. report.
2 Water evel We believe that it right to prioritise measures which ma e best use of e isting resources We have continued to prioritise demand management within our dW as described in hapter , including echnical before investing in developing additional resources. Whilst we recognise Anglian’s current water efficiency activities as well as smart metering. documents achievements in this area, we note the ambitious future targets, and the reliance on emand sustained customer behaviour changes to achieve them. We regard this as a vulnerability in In addition we have modelled reduced demand management options scenarios as part of the stress testing of anagement the lan, unless steps are ta en to facilitate upside performance in other areas of water use our referred lan. trategy efficiency, particularly in relation to new build sites.
2 Water evel We regard this measure as being almost inevitable, and that it should be part of future We have considered the range of views e pressed regarding compulsory metering during our consultation, as echnical planning well as a wider analysis of the costs and benefits as described in the emand anagement trategy technical documents document . We have also ta en into account our high level of meter penetration which is forecast to reach emand of households metered and paying measured charges by 2020 . As a result, we have not included anagement compulsory metering in our revised dW . We will continue to monitor the proportion of customers billed trategy based on a meter reading and will review the need for compulsory metering at W 202 .
2 Water evel uture-proofing of the lan against potential sustainability reductions appears to Waterlevel hese sustainability reductions are now addressed in A 7. owever, we will continue to assess other to be a sensible measure. scenarios as part of our adaptive planning process. 2 Water evel We agree that resilience to drought should be a significant aspect of water companies’ Plans, ur revised dW position on severe drought remains the same as for the dW we will ensure that all evised dW - and that all methods of effectively addressing this issue should be e plored of our customers have a 0. annual average ris of severe restrictions, from 202 -2 . hapter 7
48 Water evel We therefore endorse the “adaptive planning” approach, and believe that Anglian Water our proposal for an nsurance and mergenc ervice is interesting and re uires further information. n P usiness should ta e this one stage further. Waterlevel offers a collaborative approach to doing so, in particular we re uire considerable detail on water ualit , volumes the consultation response uotes Plan two e areas different amounts and costs.
Waterlevel proposes the oint development of an nsurance and mergenc ervice. We have Whilst we see to retain a fle ible and collaborative approach to planning, please note that formal trading defined this ervice as offers should be submitted via the ar et nformation platform established b fwat. his re uires a. reserving resources and deliver capacit additional information to that provided to date so that we can continue to evaluate options on a consistent b. incurring the higher cost of transporting water just once a year (a “proving delivery”) and timel basis. ur ar et nformation id Assessment ramewor has been published as part of our P c. a ing water more fre uentl when there is an operational need to do so. usiness Plan.
Water evel We believe that Anglian Water has been unambitious in its assessment of the potential for We note our suggestion of the potential for non potable water to reduce additional demand for water and echnical non potable water to reduce additional demand for water and sewerage services on new sewerage services on new housing developments. owever, we believe this has limited overall potential due documents housing developments. It has ignored the extent to which “Community Based Solutions” for to the disparate nature of much new development and the relative cost compared to other demand emand new developments can replace potable demand at the boundar with site generated water measures, which feature significantl in our revised dW P. owever, this is something we are considering anagement from , rainwater harvesting and rec cled effluent. in relation to a number of specific large developments which are currentl at pre planning or planning stage. trateg We are intending to underta e pilot studies in the period between and . Waterlevel offers to act in collaboration with Anglian Water, and its neighbours, to develop a framewor within which such services could be provided on a long term basis to the ma orit of new build sites in its area.
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