Water Resources Management Plan 2020 to 2080 Strategic Environment Assessment Environmental Report

WRMP19

SEA Environmental Report

April 2017

1. Background 1 1.1 Introduction 1 1.3 Water resources management plan 2019 (WRMP19) 2 1.4 The purpose of strategic environmental assessment (SEA) 9 1.5 Scope of the SEA 10 1.6 Habitats Regulations Assessment (HRA) 10 1.7 Marine conservation zone (MCZ) assessment 11 1.8 The Water Framework Directive 11 1.9 Structure of the environmental report 13

2. The SEA process 15 2.1 The SEA process 15

3. Relevant policies, plans and programmes 18 3.1 Review of plans, policies and programmes 18 3.2 A Green Future: Our 25 Year Plan to Improve the Environment 20 3.3 Water Industry Strategic Environmental Requirements (WISER) 20

4. Consultation 21 4.1 The purpose of consultation 21 4.2 Pre-scoping and ongoing engagement 21 4.4 Scoping consultation 22 4.5 Consultation on the draft WRMP and Environmental Report 24 4.6 Future consultation 28

5. Key issues, constraints and opportunities 29 5.1 Baseline data and information collection methods 29 5.2 Population and human health 29 5.3 Material assets 33 5.4 Biodiversity, flora and fauna 36 5.5 Water 49 5.6 Climate change 67 5.7 Cultural heritage 69 5.8 Soils and geology 71 5.9 Ecosystem services 75

6. SEA scope and methodology 78

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WRMP19

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April 2017 6.1 Scope of likely significant effects 78 6.3 Proposed SEA objectives 83 6.4 Compatibility of SEA objectives 89 6.5 Method of assessment 90 6.6 Uncertainty and limitations 100

7. Environmental assessment of options and portfolios 101 7.1 Option alternatives 101 7.2 Option development and appraisal 102 7.3 Assessment of portfolios 111 7.4 Do minimum scenario 114 7.5 Scenario comparison 115 7.6 Drought selection 118 7.7 SEA model runs 119 7.8 Demand management (company level) 119 7.9 Sustainability reductions 119 7.10 Developing the WRMP 121 7.11 Ecosystems services assessment 131 7.12 Comparison of dWRMP preferred plan with preferred plan 134 7.13 Summary of reasons for selecting the preferred plan 136

8. Environmental assessment of the preferred plan 137 8.1 Preferred plan options 137 8.2 Components of the preferred plan 143 8.3 Overall preferred plan assessment against SEA objectives 147 8.4 Cumulative effects within the WRMP 164 8.5 Cumulative effects with neighbouring water company plans 174 8.6 Cumulative effects with other plans or programmes 177 8.7 Summary of WFD and designated sites assessments 179

9. Implementation and monitoring plan 183 9.1 Monitoring targets and indicators 183 9.2 Monitoring plan 183 9.3 Environmental action plan for implementation 184

10. Conclusions and summary 194

Glossary 199

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WRMP19

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April 2017

List of Tables

Table 1.1 Our 2015 to 2020 Restoring Sustainable Abstraction programme 6 Table 1.2 Our 2020 to 2025 restoring sustainable abstraction programme via WINEP 8 Table 1.3 INNS programme included within our 2020 to 2025 WINEP 12 Table 1.4 Structure of this environmental report 13 Table 3.1 Key PPP themes and objectives identified from review 18 Table 4.1 Key issues raised in the scoping consultation 22 Table 4.2 Key issues raised in the dWRMP19 consultation 25 Table 5.1 South East Water region human health indicators 30 Table 5.2 International and European wildlife designations* 37 Table 5.3 Key water-dependent priority habitats and species 40 Table 5.4 Freshwater fish types recorded in 2015 43 Table 5.5 INNS and impact on environmental resilience 46 Table 5.6 INNS programme included within our 2020 to 2025 WINEP 48 Table 5.7 ALS definition of water resource availability 52 Table 5.8 ALS definition of water resource availability (groundwater specific) 53 Table 5.9 Catchment water availability 55 Table 5.10 RBMP surface water quality 63 Table 5.11 RBMP groundwater quantitative status and quality status 65 Table 5.12 Links between SEA topics and ecosystem services 76 Table 6.1 Scope of likely significant effects 79 Table 6.2 Draft SEA objectives and proposed criteria 84 Table 6.3 Compatibility of SEA objective 89 Table 6.4 Standard mitigation measures 90 Table 6.5 Identifying the importance / sensitivity of the baseline 92 Table 6.6 Scale of effects 94 Table 7.1 Categorisation of water resource options 101 Table 7.2 Coarse screening results 105 Table 7.3 Fine screening results 107 Table 7.4 Summary of screening and input to modelling 109 Table 7.5 Baseline (i.e. ‘do minimum’ / ‘without Plan’) 115 Table 7.6 Modelled scenarios 117 Table 7.7 SEA objectives scenario comparison 122 Table 7.8 Ecosystem services least cost plan 131 Table 7.9 Ecosystems services preferred plan 132 Table 7.10 Key changes between options in the dWRMP and WRMP 134 Table 7.11 Plan alternative options 136 Table 8.1 Our revised preferred plan by water resource zone 137 Table 8.2 WRMP19 preferred plan by option type 138

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WRMP19

SEA Environmental Report

April 2017 Table 8.3 Assessment of leakage management and water efficiency measures to be implemented between 2020 and 2070 148 Table 8.4 Assessment of resource zone specific options 149 Table 8.5 Potential cumulative effects associated with pipeline installation and construction of new infrastructure 164 Table 8.6 In-combination effects on landscape receptors 168 Table 8.7 In combination effects on priority habitats 170 Table 8.8 In combination effects on ancient woodland and non-designated habitat types 171 Table 8.9 Potential in combination effects on landscape receptors 177 Table 8.10 SSSIs requiring further mitigation 181 Table 9.1 Monitoring plan 185 Table 9.2 Environmental action plan Including update on WRMP14 190 Table 10.1 Synergies between the Defra 25 year environment plan and our environmental resilience activities 197 Table 10.2 Synergies between the WISER expectations and our environmental resilience activities 198 List of Figures

Figure 1.1 Map of SEW supply area Figure 2.1 Stages of SEA alongside WRMP19 development and HRA Figure 5.1 1 Population, cultural heritage and infrastructure context to WRMP options: water resource zone 1 Figure 5.1 2 Population, cultural heritage and infrastructure context to WRMP options: water resource zone 2 Figure 5.1 3 Population, cultural heritage and infrastructure context to WRMP options: water resource zone 3 Figure 5.1 4 Population, cultural heritage and infrastructure context to WRMP options: water resource zone 4 Figure 5.1 5 Population, cultural heritage and infrastructure context to WRMP options: water resource zone 5 Figure 5.1 6 Population, cultural heritage and infrastructure context to WRMP options: water resource zone 6 Figure 5.1 7 Population, cultural heritage and infrastructure context to WRMP options: water resource zone 7 Figure 5.1 8 Population, cultural heritage and infrastructure context to WRMP options: water resource zone 8 Figure 5.2 1 Water context to WRMP options: water resource zone 1 Figure 5.2 2 Water context to WRMP options: water resource zone 2 Figure 5.2 3 Water context to WRMP options: water resource zone 3 Figure 5.2 4 Water context to WRMP options: water resource zone 4

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WRMP19

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April 2017 Figure 5.2 5 Water context to WRMP options: water resource zone 5 Figure 5.2 6 Water context to WRMP options: water resource zone 6 Figure 5.2.7 Water context to WRMP options: water resource zone 7 Figure 5.2 8 Water context to WRMP options: Water Resource Zone 8 Figure 5.3 1 Landscape and biodiversity context To WRMP options: water resource zone 1 Figure 5.3 2 Landscape and biodiversity context To WRMP options: water resource zone 2 Figure 5.3 3 Landscape and biodiversity context To WRMP options: water resource zone 3 Figure 5.3 4 Landscape and biodiversity context To WRMP options: water resource zone 4 Figure 5.3 5 Landscape and biodiversity context To WRMP options: water resource zone 5 Figure 5.3 6 Landscape and biodiversity context To WRMP options: water resource zone 6 Figure 5.3 7 Landscape and biodiversity context To WRMP options: water resource zone 7 Figure 5.3 8 Landscape and biodiversity context To WRMP options: water resource zone 8 Figure 5.4 SSSI impact risk zones - western region Figure 5.5 SSSI impact risk zones - eastern region Figure 5.6 ALS surface and groundwater availability - eastern region Figure 5.7 ALS surface and groundwater availability - western region Figure 5.8 ALC grades – eastern region Figure 5.9 ALC grades – western region Figure 7.1 WRMP19 screening process Figure 8.1 Preferred plan options: western region Figure 8.2 Preferred plan options: eastern region Figure 8.3 Preferred plan and water environment Figure 8.4 Preferred plan and water environment Figure 8.5 Preferred plan and biodiversity and landscape constraints Figure 8.6 Preferred plan and biodiverstiy and landscape constraints List of Appendices

A Habitats Regulations Assessment (HRA): screening assessment B Policy, programme and plan review C Water industry strategic environmental requirements (WISER) report D Marine conservation zone (MCZ) screening assessment E Summary assessment matrices F Water Framework Directive (WFD) assessment G Sites of Special Scientific Interest screening assessment H Summary of draft Blueprint asks for PR19 and how these have been addressed in South East Water’s Business Plan I Water industry national environmental programme (WINEP) report

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WRMP19

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April 2017 J Baseline and detailed option location plans

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Non-technical summary

Introduction

Water is an essential resource for our health and wellbeing as well as the environment. We need to plan to manage water resources to meet current demand, cope with changes in the future and at the same time ensure that the quality of the environment is maintained. South East Water has prepared a water resources management plan (WRMP) which presents proposals for managing water supply to meet predicted demand over the next 60 years. We supply eight water resource zones (WRZs): two in our western region and six in our eastern region as shown in the map below.

Figure 1 South East Water supply area Water resources management plans are required under UK regulations to be subject to strategic environmental assessment (SEA). The main objectives of SEA are to provide for a high level of protection of the environment, to promote sustainable development and to fully integrate environmental considerations into the decision- making process at an early stage.

This environmental report has been prepared in order to describe and summarise the SEA of the WRMP.

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Scoping stage of the SEA process

The first stage of the SEA process was to undertake a scoping study to identify both the focus and extent of the assessment. An early step in the scoping study was to review relevant legislation, policies, plans and programmes (PPP), to understand what commitments and policies were in place for the protection of the environment and communities. The PPP review considered international, national and local plans and policies, and highlighted the environmental and social priorities that should be taken into account during the SEA and when developing our WRMP.

The SEA scoping study also included a review of the environmental conditions relevant to the WRMP area. This considered the current environmental and social conditions, as well as the likely issues that would develop in the future without the WRMP. These are called the ‘baseline conditions’.

The PPP review and baseline review provided the basis for the development of a set of environmental objectives (SEA objectives and criteria). The SEA objectives and criteria have been agreed with key stakeholders through consultation (see section 4) and have provided the basis against which the WRMP has been assessed.

The SEA scoping report was consulted upon with statutory environmental bodies and other governmental and environmental stakeholders in May/June 2016, and the dWRMP consulted on for a period of 12 weeks ending in May 2018. Comments received have been addressed and where feasible and appropriate, incorporated into the environmental report. In response to consultation comments, the proposed plan has been revised substantially to provide increased level of leakage reduction and water efficiency. These changes along with revisions to the forecast demand have resulted in a plan (WRMP19) and the SEA environmental report has also been updated to reflect this.

Summary of environmental baseline and policy context

The following issues were identified and considered to be of particular relevance to the SEA of the WRMP:

• Our supply area is characterised by high water demand compared to the UK average. Tourism and agriculture (including horticulture) are important industries within the region, driving large seasonal variations in water demand. Seasonal peaks in demand will likely coincide with periods of drought (for example water required for tourism during the summer holiday period, and water required for irrigating crops)

• a significant proportion of our supply area is covered by statutory nature conservation sites. In addition, the south east region has the highest proportion of land covered by national or international landscape designations of any English region, and also the highest proportion of woodland

• water abstraction within the south east region places a substantial pressure on water flows within rivers and on the ability of groundwater bodies to maintain river flows and support groundwater fed ecosystems. Currently water flows in 28 per cent of Water Framework Directive rivers are below the minimum level required to support the Water Framework Directive target of “good ecological status” under high flow conditions, rising to 70 per cent under low flow conditions.

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SEA objectives

Taking into account the PPP review and understanding of the baseline, the following objectives have been identified against which to assess how the WRMP affects the environment.EA

SEA Objectives

1. Protect public health and wellbeing

2. Protect and, where appropriate, enhance built and natural assets and reduce waste

3. Protect and enhance biodiversity and contribute to resilient ecosystems

4. Protect landscapes, townscapes and visual amenity

5. Reduce greenhouse gas emissions

6. Contribute to environmental climate change resilience

7. Protect and improve surface water and groundwater status

8. Avoid risk of flooding

9. Protect and, where appropriate, enhance cultural heritage assets

10. Protect quality and function of soils

SEA approach to informing the development of the WRMP

There are many different investment options that could be chosen to address the water supply-demand deficit in the our supply region. The starting point in the development of the WRMP was therefore the identification of a wide range of possible option types. These options ranged greatly in scale, cost and reliability. They included options aimed at reducing water demand such as efficiency measures and leakage reduction, and others to increase supply, such as storage reservoirs, water reuse, desalination of sea water, abstraction from groundwater and rivers, and options for the transfer of water both between South East Water resource zones and with other water companies.

An options ‘screening’ process was undertaken to reduce the list of possible options by removing those likely to be least acceptable or least deliverable within each type. It also aimed to leave sufficient choice for the WRMP to develop strategic alternatives of combined measures for meeting supply-demand deficit. These strategic plan alternatives are called ‘scenarios’. The process is outlined in Figure 1.

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Unconstrained Options Starting list of possible options and List identification of options based on options review and stakeholder input

Identifying environmental and social, Coarse Screening resilience, promotability and deliverability ‘show stoppers’

Options to be taken forward for the fine Constrained Options List screening process – further option definition and data collection

Multi-Criteria Analysis – assessment considering a range of technical, Fine Screening environmental (against SEA objectives) economic and deliverability issues with further removal of unacceptable options

Feasible Options List Options used as basis for modelling/decision making selection including costing and MCA informed by SEA qualitative assessment and environmental valuation

Figure 2 Integration of SEA in WRMP process Environmental considerations were integrated throughout the screening process. The environmental screening was undertaken in two stages:

• Stage 1: coarse screening – identification of clear ‘show stoppers’, such as direct effects on designated sites where there was little scope to alter the option or mitigate (i.e. avoid, reduce, remedy or offset the negative effect)

• Stage 2: fine screening – multi-criteria analysis, including consideration of a range of environmental issues, alongside technical and feasibility aspects

The list was reduced from 510 options to 175 feasible options through this screening process. The reasons for screening options out were largely environmental based on initial assessments against SEA objectives and criteria. The results of each stage were discussed with our Environment Focus Group made up of organisations representing water-related, environmental, governmental and rural interests. Additional detailed discussions on the options with Natural England and the Environment Agency also informed the screening process.

Assessment of alternatives

The development of plan alternatives is dependent upon economic modelling taking into account a complex combination of factors. This includes matching projected demand with supply, considering the water resource management network which controls and enables existing water supply, climate change effects, uncertainty, environmental factors and economics (for example, cost of each option and therefore the cost to the customer).

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The results of the modelling provide a number of plan alternatives called ‘scenarios’. A number of different scenarios were generated, which differed in terms of:

• Supply resilience to different drought conditions including worst historic (1:100 year or one per cent annual probability events) or severe drought (1:200 year or 0.5 per cent annual probability events)

• the extent and timing of future sustainability reductions

• degree of priority given to leakage and water efficiency measures

• inclusion, or not, of high risk environmental options and the timing for implementation of high risk environmental options.

Key elements of the preferred plan which were preferred over comparative scenarios include:

• More resilient plan capable of addressing severe drought conditions (1:200 year)

• supporting sustainability reductions in a realistic and adaptable way which will contribute to meeting objectives for improving surface and groundwater Water Framework Directive (WFD) status and water dependent protected areas

• reduced waste generation resulting from operation of water resource options

• reduced impact on sensitive landscape receptors (AONBs and National Parks)

• lower overall carbon emissions

• increased use of demand management measures including significant increased leakage reduction with reduced impact on the water environment over the long term

• removal of high risk environmental options identified in the dWRMP19 as requiring down the line Habitats Regulations Assessment (HRA)

• provision for delivering biodiversity net gain

• potential for supporting restoring sustainable abstraction schemes through conjunctive operation of new and existing schemes.

Assessment of preferred plan

The preferred plan includes a combination of water efficiency measures, leakage reduction, water treatment facility modifications, company and inter-company transfers, reservoirs and catchment management. One new groundwater source is also proposed. Alternative options include a water reuse scheme, a new reservoir and a bulk transfer scheme.

One of the preferred plan options is a scheme to replace an existing raw water transfer between Darwell and Hazards Green. This pipeline moves raw water from the River Medway to the Pevensey Levels Special Area of Conservation (SAC), a sensitive wetland with European protection and this was assessed as a high risk for spreading Invasive Non-Native Species (INNS). A scheme to replace the raw water transfer was idenitifed through WINEP investigation and approval for the scheme was given by the Environment Agency with a requirement to provide this by 2025 so that raw water transfer can cease. The replacement treated water transfer is therefore included as a scheme in the WRMP19.

Maps showing indicative locations of the preferred plan and plan alternative options are shown below.

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Figure 3 Location of preferred plan and alternative options: western region

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Figure 4 Location of preferred plan and alternative options: eastern region

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2020-2025

In the short term the preferred plan includes a mixture of demand management measures (leakage reduction and water efficiency) and a new groundwater supply option (new water supply option to construct a new water treatment works at the former Aylesford Newsprint site) with supporting improvements to the mains network in WRZ6.

2025-2045

Demand management measures will continue, however further water supply options are required in order to address the projected increased shortfall for the supply-demand balance. Proposed water supply options forming part of the preferred plan include:

• Targeted catchment management programmes in the Pembury (Kent) and Woodgarston () areas

• upgrading our water treatment works at Bewl Reservoir, which straddles the boundary between Kent and East Sussex

• two new reservoirs (one at Arlington, East Sussex adjacent to the existing reservoir, and one at Broad Oak, Kent)

• two further improvement schemes to the mains network

We have also identified alternative options for the proposed reservoirs at Arlington and Broad Oak. Alternative options for the new Arlington Reservoir would be either a water reuse scheme at Peacehaven or a new reservoir at Goose Green. The alternative option for Broad Oak Reservoir would be a bulk supply from Southern Water sourced from their water reuse scheme at Aylesford.

2045-2080

In addition to demand management measures, the preferred plan includes:

• a regional water transfer scheme from SES Water (formerly Sutton and East Surrey Water)

• two company water transfers

Key effects associated with each option type with recommended mitigation measures are described in Table 1. Residual effects identified take account of the mitigation put forward, and focus on those adverse effects which will not be readily eliminated through being avoided, fully remedied or fully compensated for. While residual effects may not be readily eliminated, with future additional investigation, project planning and design it is expected that they can be avoided or reduced to moderate to negligible effects. The preferred plan options provide important benefits in terms of:

• Support for delivery of likely sustainability reductions which will contribute to meeting Water Framework Directive objectives

• support for improved environmental resilience to climate change and other pressures for the freshwater and water dependent habitats

• reduced risk from raw water transfer and associated invasive non-native species (INNS) risk

• opportunities for significant habitat enhancement and recreational amenity provision associated with the proposed new reservoirs.

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Table 1 Summary of SEA findings and recommended additional mitigation

Potential effects (assuming good Option type construction management practices and Recommended additional mitigation Residual effects standard mitigation)

Leakage Potential for long-term significant benefits for Review of proposed works locations to identify Potential for Short term moderate effects on reduction sustainable resource use and carbon foot print any potential sensitive environments and to transport networks with associated traffic disruption reductions through water and energy savings ensure appropriate measures are taken. during repair works. The effects are dependent on and a reduction in the need for new water where leakage works are required so difficult to Review of programme of works in consultation resource supply. with highways authority to identify potential for predict at this stage. Potential temporary adverse effects on cumulative impacts and opportunities to minimise Long term beneficial effects associated with transport networks and sensitive landscape traffic disruption. reduction in water usage and energy savings. These and ecological sites from construction works. benefits also accumulate over time.

Water Long term beneficial effects from energy and Ensure initiatives widely accessible, and monitor efficiency carbon emission savings, and a reduction in uptake and effectiveness. the need for new water resource supply.

Catchment Small scale measures for pollution control on Locate new small scale infrastructure to avoid Moderate to long term beneficial effects for climate management farms for example and as such are considered sensitive ecological receptors or other features. change resilience and surface water/groundwater measures unlikely to present a risk to priority habitats or Water Framework Directive (WFD) status. other features. Long term minor beneficial effects on aquatic Potential wider benefits to soils and surface ecology, groundwater WFD status and soil quality. and groundwater quality.

Transfers Short term temporary adverse effects due to • Reinstatement approach for undesignated Short term moderate to minor adverse effects (company and disruption to access along minor roads and habitats to include enhancement measures associated with disruption to the road network and regional) public rights of way (footpaths and bridleways) (e.g. verge creation, tree and native species effects on sensitive landscape and ecological Zonal schemes during pipeline installation, and construction planting, hedgerow augmentation, mammal receptors. disturbance for local residents. boxes) where practicable and to provide an Long term minor beneficial effects for climate Short to medium term adverse effects linked to overall habitat/biodiversity net gain. change resilience as transfer options provide potential pipeline installation through or close to areas of to reduce demand on stressed water resources by • further refinement of pipeline routing to utiise previously undisturbed land/agricultural land, utilising alternative more resilient sources. existing tracks and/or use of trenchless protected sites (Hubbards Hill SSSI, West installation techniques to avoid direct effects Blean and Thornden Woods SSSI, Arlington on protected sites, areas of priority habitat and Reservoir SSSI, Folkington Reservoir SSSI), ancient woodland where possible or priority habitat (deciduous woodland, coastal replacement, aiming for overall net gain and PAGE xv

Potential effects (assuming good Option type construction management practices and Recommended additional mitigation Residual effects standard mitigation) and floodplain grazing marsh, semi-improved contribute towards Natural England’s grassland, lowland heathland, lowland Woodland and Downland Focus. Construction meadows and traditional orchard), ancient timings to minimise disturbance to bird woodland and undesignated woodland, populations at Arlington Reservoir. hedgerows and other habitats. • agree landscape restoration strategies with Potential loss of buried archaeological remains. relevant AONB units and National Park Short to medium term effects on sensitive authorities. landscape receptors including areas of • appropriate level of watching brief/ prior outstanding natural beauty (AONBs) and investigation for buried archaeological remains National Parks due to loss or degradation of as agreed with county archaeologist. natural landscape features. • prepare a soil management plan and carry out works using methods that protect the structure and composition of soils and design maintenance access to minimise impacts on soils

Upgrade to Effects as described against transfer options, Mitigation as described against transfer options. Short to medium term moderate to minor adverse existing water also: Also – effects associated with disruption to the road and treatment railway network and footpaths/bridleways and impacts works • Visual impact of construction works and new • Design of new plant to minimise visual effects, on landscape, biodiversity and buried archaeology. infrastructure for local communities and utilising landscape screening if appropriate. sensitive landscape receptors. Agree design of Bewl water treatment works • degradation/loss of buried archaeological with High Weald AONB unit. remains and priority habitat (deciduous • use of trenchless technologies and/or further woodland, coastal and floodplain grazing refinements to pipeline routing to avoid priority marsh and semi-improved grassland) during habitats pipeline installation between Bewl water treatment works and Bewl reservoir.

New surface Reservoirs Mitigation as described against transfer options. Short-term moderate adverse effects due to water storage Effects on local transport routes, sensitive Also – disruption to road network and recreational facilities, impacts on landscape, sensitive ecological receptors landscape areas, habitats (including ancient PAGE xvi

Potential effects (assuming good Option type construction management practices and Recommended additional mitigation Residual effects standard mitigation)

woodland and priority habitats) and wildlife and • Design (all) to minimise visual impact, ensure and water quality/hydromorphological regime of buried archaeology associated with pipeline potential for new habitat creation included, and nearby surface water courses. installation as described against transfer explore further potential for recreational Long-term minor adverse to negligible effects with options. facilities to be provided including consultation potential beneficial effects for recreation, biodiversity Arlington reservoir: with local stakeholders and resilience to climate change.

• Short to medium term adverse effect due to • design of Broad Oak reservoir to avoid loss of footpaths within reservoir footprint impacts on SSSI and ancient woodland and WFD effects of Broad Oak reservoir are uncertain disturbance to adjacent Arlington reservoir provide significant habitat creation and given the limitations to the reservoir design due to the SSSI. woodland block connectivity through sensitive high voltage electricity transmission line route crossing advance planting the reservoir site footprint. As recognised in the • long term adverse effects associated with Inspectors’ Report on the Richborough Connection new abstraction from the Ouse and effects • large scale habitat creation with provision for DCO inquiry, a derogation may be required to enable on the setting of a scheduled monument. informal recreation to be included in reservoir designs, replacing arable land around the reservoir scheme to proceed alongside the • long term benefits to biodiversity and wildlife reservoirs. Richborough Connection project. Further study on the and recreational opportunities from wetland design options and WFD assessment in discussion and open water adjacent to existing • address grade II listed building loss at Broad with the Environment Agency will be required. Oak reservoir and provide historical Arlington reservoir SSSI. interpretation as part of visitor information Broad Oak reservoir: • design of new Arlington reservoir to avoid • Loss of listed building and 36ha of high construction impacts on current SSSI value agricultural land within the footprint of Broad Oak reservoir • stream realignment or compensation flow and WFD measures to be determined and • opportunity for significant habitat creation designed to minimise adverse effects on and recreation provision downstream watercourses and habitat loss • potential adverse effects on nearby (further detailed study required to inform protected sites mitigation design and determine approach to WFD) • visual impact of reservoir within sensitive landscape area • abstraction operating conditions to include limitations on abstraction volumes to high flow • impacts on Sarre Penn WFD status and conditions only (further detailed study required objectives. to inform mitigation design) (all)

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Potential effects (assuming good Option type construction management practices and Recommended additional mitigation Residual effects standard mitigation)

Goose Green reservoir (plan alternative option) • detailed design (all) to include measures to reduce risk of scour at drawdown outlet and • Potential adverse effects on tributaries of the siting of intake structures to avoid protected Adur resulting from realignment of streams species. within reservoir footprint • permanent loss of productive agricultural land. Visual impact of reservoir in rural landscape.

New Short term adverse effect associated with Mitigation as described against transfer options Short term moderate adverse to minor adverse groundwater disruption to the road network and visual Also - Abstraction continuation with operating effects associated with disruption to road network and source impact of construction works for local conditions to ensure no adverse effects on WFD impacts on ecological receptors and cultural heritage communities. assets. status of target aquifer (or potentially Ditton Potential for long term adverse effects on the Stream if integrated use is included). This may Long term effects minor adverse to negligible on WFD status of the Kent Greensand include limits on surface abstraction volumes to groundwater resources. Middle/Western groundwater body (although high flows only. low risk based on historic abstraction use) and A full environmental baseline will be established Ditton Stream WFD waterbody if integrated for the site to establish the level at which abstraction use with groundwater. abstraction is sustainable (this will be linked to various climatic (recharge) scenarios).

Water reuse Effects on local transport routes, South Downs Mitigation as described against transfer options. Short term moderate to minor adverse effects from (plan National Park, habitats (including priority Also – disruption for users of the road network and impacts alternative habitats, wildlife, best and most versatile on sensitive landscape and ecological receptors. option) agricultural land) and buried archaeology • Reroute pipeline to avoid Lewes Brooks SSSI Long-term effects would generally be minor associated with pipeline installation as careful timing of construction works and further adverse to neglible, with the exception of a described against transfer options. • geotechnical studies to avoid risks to Brighton moderate adverse effect associated with energy Also – to Newhaven SSSI consumption during operation. Energy-intensive and results in the discharge of more • Potential adverse impact on Lewes Brooks • agree plant design with South Downs National concentrated effluent/brine to the Ouse and marine SSSI and Brighton to Newhaven Cliffs SSSI Park authority environment compared to current discharges from the waste water treatment plant. Effects on water body status, aquatic ecology and fisheries are the main PAGE xviii

Potential effects (assuming good Option type construction management practices and Recommended additional mitigation Residual effects standard mitigation)

• construction of new treatment plant in close • use of trenchless installation techniques at concerns, and these need to be studied further and proximity to South Downs National Park river crossing near scheduled monument in mitigation measures and operational restrictions are Newhaven expected to ensure the effects are minimised to an • risks to a scheduled monument located in acceptable level. Newhaven in close proximity to the pipeline • reverse osmosis plant design and brine/waste route effluent outfalls to be developed such that Long term moderate beneficial effect for discharge of treated water to Ouse and environmental climate change resilience for rivers • potential effects on the WFD status and abstraction downstream and disposal of where low flows are supported with water treated to a aquatic ecology of the Ouse from discharge concentrated brine effluent to marine higher level. of treated effluent and on Sussex East environment does not pose unacceptable coastal waterbody and Beachy Head West adverse impacts on the aquatic ecology of marine conservation zone (MCZ) from brine receiving waters or Beachy Head West MCZ discharge • the use of renewable energy sources to reduce carbon emissions from operation could reduce carbon emissions.

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Water Framework Directive (WFD) assessment

A WFD assessment was undertaken in parallel to the SEA. The WFD assessment found that two of the preferred plan options and two of the alternative options presented a moderate risk to either water resources or the water environment during construction and/or operation, with the remainder representing a low risk. Those preferred plan options identified as presenting a moderate risk were the two reservoirs, Arlington reservoir and Broad Oak reservoir.

The Goose Green reservoir and water reuse at Peacehaven plan alternative options were also identified as having moderate risk. Catchment management, water treatment works upgrade and reservoir options along with the sustainability reductions for existing supply source also have potential to deliver WFD benefits. The SEA incorporates outcomes of the WFD assessment. Habitats Regulations Assessment (HRA)

The HRA screening assessment undertaken in parallel to the SEA found that none of the WRMP preferred plan options would result in significant effects on Natura 2000 sites and no further assessment is required.

Marine Conservation Zone (MCZ) assessment

The MCZ assessment screening identified that none of the preferred plan options required further assessment. The water reuse scheme identified as a potential alternative option potentially includes a marine wastewater discharge pipeline and was therefore identified as requiring further MCZ assessment. An assessment form has been completed for this option which will be developed further alongside further option studies.

Cumulative effects

The cumulative effects of the combination of options within the overall WRMP, and between the WRMP and other water company dWRMPs have been considered. The key potential cumulative effects are as follows:

• Construction disturbance for local communities and temporary disruptions to access for users of the minor roads associated predominantly with pipeline installation to support transfer options and zonal schemes

• potential adverse effects on sensitive landscape receptors (Kent Downs AONB, High Weald AONB, North Wessex Downs AONB, and South Downs National Park) resulting from loss or degradation of built and natural landscape features (e.g. woodland, hedgerows, field boundaries) during pipeline installation and the visual impact of small scale built infrastructure

• potential adverse effects on two SSSIs (within plan options only)

• potential adverse effects on water quality or flows within two river catchments (the Adur and Ouse and Medway).

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The cumulative effects on the WRMP with other plans and programmes has also been considered. The main issues identified include the potential conflict between Broad Oak reservoir and the National Grid Richborough Connection Project. In 2016 we objected to the development of new overhead powerlines at our site at Broad Oak, and both the Environment Agency and Natural England supported our objection. Part of our objection was related to the presence of new overhead lines (from the Richborough Connection Project (RCP)) and how they would interact with the area where we would divert the Sarre Penn. The Sarre Penn diversion was designed to comply with WFD requirements. In March 2017, the Planning Inspectorate gave permission for the erection of the RCP at our site at Broad Oak, this interacts with the area where we had planned to divert the Sarre Penn. As a result the proposed new alignment of the Sarre Penn is compromised as a number of WFD elements cannot be delivered due to the presence of the pylons and overhead cables. In the Planning Inspectors report, it was confirmed that, given the public interest in drinking water supply it is possible for South East Water to rely on a derogation under Article 4.7 of WFD for non-compliance with WFD objectives relevant to the Sarre Penn. To this end, we are committed to working with the Environment Agency undertake further WFD assessment to identify what might be achievable within the land holding available and agree appropriate mitigation as part of the planning and permitting process.

Potential cumulative and in combination effects identified in the cumulative effects assessment are to be addressed through the application of avoidance and mitigation approaches including detailed siting and pipeline routing studies to avoid impacts. The principles of biodiversity net gain would be applied for all infrastructure options, including pipelines, in line with the Government’s recently published ‘A Green Future: Our 25 Year Plan to Improve the Environment’.

The cumulative effects assessment will be updated as the other water company revised plans are published and preferred plan options are confirmed across all companies. A final cumulative effects assessment will be undertaken to inform the final WRMP and the SEA post adoption statement.

Monitoring and environmental action plan

We have recommended monitoring measures to check the progress of the WRMP against the SEA objectives. This builds upon the monitoring that we have in place through the Performance, People and Planet annual reporting,copy of which can be found on our company website: corporate.southeastwater.co.uk/media/1599/sewpppreport2017v2.pdf

The monitoring results will provide information that can be used to inform the SEA and WRMP during the next plan review in five years’ time.

We have also produced an environmental action plan, which summarises the actions and further work identified in the environmental report. The action plan is a way of ensuring that the recommendations of the SEA are met during the plan implementation phase.

We have a planning and environmental strategy which manages and where possible minimises environmental risk from project conception through implementation and through to project completion and sign off. Environmental risk is recorded through a project implementation document (PID). We are committed to taking forward the assessment information and assumptions and the mitigation recommendation through the SEA and to provide a starting point for this process so that the environmental assumptions and requirements follow each project as they are developed in the future so that projects are clearly linked to the SEA. This covers mitigation and monitoring identified for individual options and the plan as a whole including cumulative impacts.

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Consultation and next steps

We have taken account of stakeholder comments and views on the Environmental Report and on the dWRMP and welcome additional comments on this updated Environmental Report and WRMP. These reports are published with the Statement of Response and are part of the process of finalising the WRMP.

The WRMP and the Environmental Report have been published on our company website: https://corporate.southeastwater.co.uk/about-us/our-plans

We are planning a series of news articles to keep everyone informed and to encourage feedback during this formal consultation period, which will be published in the local media across our supply area, and on our company website at www.southeastwater.co.uk/yourwateryoursay.

The final WRMP will be issued in 2018 together with an SEA post adoption statement. This will include a summary of the consultation comments received and how these were addressed in finalising the plan. The Environmental Report will be amended if there are significant changes between the revised and final WRMPs, otherwise the Post Adoption Statement will be produced to conclude the SEA reporting.

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1. Background

1.1 Introduction

1.1.1 South East Water South East Water is a ‘water only company’ (not providing wastewater services) operating within the UK regulated water sector. Our water supply area covers an area of some 5,657 km2 across parts of Kent, Sussex, Surrey, Berkshire and Hampshire. Within this area we provide high quality drinking water to a population of around 2.2 million customers.

Currently, 73 per cent of the water supplied comes from just over 250 boreholes and wells, 19 percent from six river intakes and three surface water reservoirs, and eight per cent from neighbouring water companies. The water is pumped from these sources, treated and then distributed to customers’ properties through more than 14,500 km of mains.

The supply area, shown in Figure 1.1 below, is split into an eastern and a western region, each comprising distinct water resource zones (WRZs). Parts of Kent, East Sussex and West Sussex constitute the eastern region, with the western region extending through parts of Hampshire, Surrey and Berkshire.

Figure 1.1 Map of South East Water supply area

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1.3 Water resources management plan 2019 (WRMP19)

1.3.1 Background to water resources management plans The Water Act 2003, which came into effect in April 2007, placed a duty on water companies to develop, consult and publish water resources management plans (WRMPs). These look at the balance between water supplies and demands (referred to as the ‘supply-demand balance’) to see if there is any deficit and set out measures to address supply-demand requirements.

South East Water’s current WRMP (WRMP14) was published in 2014. However, water companies are required to update their WRMPs every five years. The WRMP19 outlines the overall approach and recommended options to reduce any predicted deficit, both by reducing the amount of water that is required and by providing more water, over the 25 year period from 2020 to 2045 required as a minimum. We have chosen to extend this to cover a 60 year period to allow longer term planning considerations.

1.3.2 Challenges for the WRMP19 Clean water is essential for health and hygiene, agriculture, industry and habitats. The water environment is also a source of recreation, relaxation and natural beauty. Water resources need to be managed to ensure that there are sufficient resources to meet demand for water without detriment to the environment. Pressures associated with delivering sustainable public water supplies include:

 Increasing water consumption per person

 population growth with fewer people in each home on average

 pressure to reduce abstraction to improve the environment

 pollution limiting suitability of some water sources and affecting treatment costs

 climate change with wide ranging effects on water availability, agriculture and the environment as well as on demand for water.

The whole of our supply area falls within a wider region which has been designated as an area of serious water stress by Government. In addition to existing pressures, parts of the supply area are identified for rapid population growth. The WRMP19 growth forecasts that the population in our supply area will increase by 53 per cent from a starting position of 2.19 million in 2016/17, to 3.34 million people in 2079/80.

Many habitats and species are dependent on rivers containing water of sufficient depth and quality, while water bearing rocks called aquifers also need to be managed in a sustainable way. Where current company water abstractions are identified by the Environment Agency as potentially either having a detrimental effect or likely to have a future effect on the environment, they are included in the Water Industry National Environmental Programme (WINEP).

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The Environment Agency and water companies undertake WINEP studies to assess the water quality and quantity within rivers and aquifers and the links with ecological status of waterbodies and protected areas (full details of our current and future commitments in this area can be found in the environmental appendix of our 2020 to 2025 Business Plan). The purpose of the studies is to identify the reasons for the impact on the environment and determine whether there is a connection with the abstraction of water for supply. The outcomes of the studies can include a range of actions including improving the resilience of habitats, working with farmers to improve land use and reduce pollution from run off, improving water quality from discharges as well as sustainability reductions, which can result in a water source being withdrawn from use. Where reduction or withdrawal of a water source is required, additional water sources need to be identified to maintain our water supply. Around 20 per cent of our water resources are taken from areas defined as ‘over-abstracted’, with around 32 per cent being within areas defined as being ‘over-licensed’.

Therefore the amount of additional water that will be required over the life of the WRMP19 is likely to increase due to a combination of population growth and potential restrictions on the existing water resources. Climate change and lifestyle change may further exacerbate potential shortages. WRMP19 sets out the proposed options that could be implemented to reduce the deficit and balance the supply and demand.

1.3.3 Changes since WRMP14 As a consequence of some changes to legislation and guidance since WRMP14, the WRMP19 process has a greater focus on the following issues:

 Resilience of water supply

 value of ecosystem services

 planning for sustainable catchments.

1.3.4 Resilience of water supply The Water Act 2014 placed a duty upon the Secretary of State and Ofwat to secure the long-term resilience of water supply with particular reference to the impact of environmental pressures, population growth and changes in consumer behaviour. Ofwat has defined resilience as:

“the ability to cope with, and recover from disruption, and anticipate trends and variability in order to maintain services for people and protect the environment, now and in the future.”

Ofwat recommends that coherent planning for resilience should be demonstrated within WRMPs and this requirement is further explained in the water resource planning guidelines (2016).

This is particularly relevant in the context of climate change to consider how the climate change can affect water supply and consumption in the future but also the sensitivity and vulnerability of the environment.

As part of improving resilience, WRMP19 is required to be more directly linked with drought planning and to include consideration of drought scenarios and how these can be met.

1.3.5 Value of ecosystem services The Final Water Resources Planning Guideline (2016) recommends water companies, as part of their WRMP development and approach for valuation of environmental and social costs and benefits, consider using an ecosystem services approach to environmental valuation. This approach is to be used where possible as this helps to promote a consistent and integrated approach to environmental valuation.

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Defra’s guiding principles for water resources planning (2016) says that water companies ‘should demonstrate how you value nature in your decisions.’ In order to ensure more informed decisions are made, it is recommended to use ‘natural capital as a currency’ to thoroughly consider and value ‘environmental and social costs and benefits.’

The Environment Agency’s Environmental Valuation in Water Resource Planning – Additional Information (2016) states that four principles should steer the approach to valuation:

 Methods should be proportionate to scale of water resource problems faced

 consider use of ecosystem services approach to environmental valuation

 use best available evidence and/or develop new valuation evidence

 adopt a transparent process to assessing environmental effects and valuation

The above policy guidance has been considered throughout the formulation of the methodology and approach for the environmental and social valuation as part of the WRMP19. This has been developed to input directly to the WRMP19 plan modelling and to sit along-side the SEA. Where appropriate it has informed specific aspects (such as cumulative carbon emissions and costs) and provided a comparative analysis.

1.3.6 Planning for sustainable catchments The Environment Agency’s water resources planning guideline (2016) emphasises the importance of water companies addressing their obligations under the Water Framework Directive (WFD). There are requirements to support the achievement of WFD obligations and river basin management plan (RBMP) objectives and these need to be integrated with the development of the WRMP including ensuring that planned abstractions will:

 Prevent deterioration in waterbody status (or potential) compared to the baseline status reported in the 2015 RBMP. However, if deterioration has occurred in the waterbody during the first RBMP cycle there may be a need to restore sustainable abstraction

 support the achievement of protected area objectives

 support the achievement of the environmental objectives in the 2015 plans and where relevant

 ensure a new activity or new physical modification does not prevent the future achievement of good status for a waterbody.

The guideline also identifies that the WFD promotes increased awareness of catchment processes and challenges the established dependence on a ‘treatment-led approach’ for the supply of European Drinking Water Directive (DWD) compliant potable water.

The need to consider the sustainability of existing abstractions as well as planned new or increased abstractions is highlighted in the guideline together with consideration of commitments under our WINEP. The guideline states that plans are required to consider targeted and cost-effective implementation of restoration measures required at the catchment scale, either working solely or in partnership with other catchment based organisations and application of the principles of adaptive management through pre-and post-project monitoring to address uncertainty.

The approach to including WFD assessment within the SEA is discussed below in section 1.6 and sustainable abstraction studies and identification of sustainability reductions are discussed further in the baseline section 5.4 and also in methodology section 7.2 in relation to considering the uncertainty for the requirements for sustainability reductions in the future.

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Ensuring our abstractions are sustainable

Restoring Sustainable Abstraction (RSA) is a process administered by the Environment Agency to determine whether an abstraction is environmentally sustainable or not. If the abstraction is found to be the cause of environmental failure then measures must be implemented to restore sustainable abstraction and improve the ecology in the area. Measures could include closure of the abstraction, changes to abstraction licences, habitat improvements or other mitigation measures.

There are three stages to the process and each stage typically runs over a five year period. The three stages are:

Stage 1: Investigation

The first step of the investigation is to establish whether the source is having a visible impact on the environment. This is done through detailed on the ground monitoring using ‘real live’ data rather than modelled data. This is then used to assess whether there are any abstraction impacts, or whether the environmental impact is as a result of another issue within the catchment. If this study shows that an abstraction is having a detrimental impact on ecology then the investigation is followed by an Options Appraisal.

Stage 2: Option appraisal

An options appraisal identifies the potential available options which could mitigate or remove the environmental impacts of the abstraction. These options are appraised against a number of criteria such as their cost, deliverability, environmental and social acceptability and environmental resilience.

Stage 3: Option delivery

The end point of this process is a preferred solution, this solution being implemented as soon as it is deliverable and funded. This is the third stage of the Restoring Sustainable Abstraction process.

2015 to 2020: How we have worked to ensure our abstractions are sustainable

We have 12 sources listed on our 2015-2020 Restoring Sustainable Abstraction programme. The programme is part of our WINEP set by our regulators. Our 2015-2020 Restoring Sustainable Abstraction programme is shown in Table 1.1.

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Table 1.1 Our 2015 to 2020 Restoring Sustainable Abstraction programme

Scheme Name Abstraction(s) RSA Stage Driver*

Maidenhead Ditch College Avenue, Cookham Options Appraisal wrLoc3

Darent Cramptons Road, Kemsing, Oak Lane Investigation and wrWFDs3a, Options Appraisal wrWFDg3a

Great Stour Thannington, Howfield, Chilham, Investigation wrWFDg3a Godmersham

Upper Stour Charing, Westwell, Henwood Investigation wrWFDs3a, wrWFDg3a

Little Stour Kingston Implementation (Habitat wrBiod1, wrWFDs1 Enhancement)

North Kent (Swale Halling, Ospringe 1, Ospringe 2, Investigation wrWFDg3a, & Medway) Boughton, Wichling, Wineycockshaw, wrWFDs3a Newnham, Stockbury, Boxley Chalk, Cossington Chalk, Ridley, Hartley Chalk

Greywell Greywell Sustainability Reduction wrSSS1

North Wey at Alton Lasham Investigation wrWFDs3a

Hart (Crondall to Itchel & Boxalls Lane Investigation and wrWFDs3a Elvetham) Options Appraisal

Poynings Saddlescombe Adaptive Management wrLoc1

Darwell Darwell Investigation and WFD11 Options Appraisal

Coggins Mill Coggins Mill No deterioration wrWFDs3a investigation

* Drivers may include WFD, biodiversity or SSSI concerns or local issues.

WINEP delivering our 2015-2020 commitments

Our investigations are complex and require a multi-disciplinary approach and outcomes tend to be site specific. In general, most of our investigations have shown that other pressures, such as water quality, sediment inputs, invasive species, barriers to fish migration, channel maintenance, SSSI maintenance, can have much more of a significant impact on the environment compared to abstraction and are often the reason for environmental failures.

Even with complete closure of abstraction some of the waterbodies or environmentally sensitive areas will not meet ‘good’ Water Framework Directive status without resolving other pressures in tandem. In these circumstances, it may be better to understand how we can operate in a flexible way and address other pressures within the catchment.

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Table A7 in appendix 10 of our Business Plan provides a breakdown of each scheme including the background to the study, the approach to the investigation, the options considered as a result of the study and the preferred option for delivery.

Each scheme has a different regulatory deadline which is tailored to the driver and the scope of work we agreed with our regulators. Some of these are in the future and we are still working towards achieving these statutory deadlines.

We remain on target to meet the statutory outputs and deadlines associated with all of our schemes in the period 2015 to 2020. The following schemes have been completed and signed off by our regulators:

 Maidenhead Ditch: Desk Top Options Appraisal  Raw Water Transfer Bewl to Darwell: Investigation and Options Appraisal  River Darent: Investigation

What are the key issues that affect the sustainability of our abstractions?

The majority of our sources on our Restoring Sustainable Abstraction programme abstract from Chalk aquifers. Most of the Chalk aquifers in the South East region are noted as ‘over-abstracted’ by the Environment Agency. Chalk aquifers also provide important base flow to chalk streams and chalk influenced streams. There are only about 220 chalk streams in the world and most of them are located in the southern half of England, within our supply area. It is therefore vital that our abstractions from chalk aquifers are sustainable to protect chalk streams for future generations to enjoy.

Our Restoring Sustainable Abstraction programme enables us to investigate the sustainability of our sources, to ensure that we are not impacting on ecology or the environment, and if we are to consider options for mitigation.

Restoring Sustainable Abstractions - sustainable catchments and no deterioration

In October 2016, the Environment Agency advised us of our abstractions that they considered to be causing environmental damage or those that could potentially cause deterioration if abstracted volumes increased. We worked with the Environment Agency and the outcomes formed the basis of our Water Industry National Environment Programme for 2020 to 2025. The Environment Agency released the final version of the WINEP programme in March 2018 and the schemes in the programme are detailed in Table 1.2 below.

We have already responded positively by not proceeding with a number of planned increases to our groundwater abstractions in our WRMP19. Instead we will complete an investigation linked to our WINEP before increasing the deployable output from any of our sites. This is to ensure that any growth of the source is sustainable and does not cause Water Framework Directive deterioration.

2020 to 2025 WINEP – How we will further improve our restoring sustainable abstraction programme

We are committed to delivering our environmental obligations under the WINEP. We will continue to work with our regulators, other water companies and form partnerships with key stakeholders to deliver our Restoring Sustainable Abstraction programme.

The table below describes the schemes that we will deliver from 2020 to 2025. There are 11 schemes that are a continuation of 2015 to 2020 studies. There are 12 new schemes that will determine whether or not the abstraction is environmentally sustainable.

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Table 1.2 Our 2020 to 2025 restoring sustainable abstraction programme via WINEP

Scheme Name Abstraction(s) RSA Stage Driver

Maidenhead Ditch College Avenue, Cookham Adaptive Management WFD_IMP_WRFlow

Darent Cramptons Road Adaptive Management WFD_IMP_WRFlow

Darent Kemsing Adaptive Management WFD_IMP_WRFlow

Darent Oak Lane Adaptive Management WFD_IMP_WRFlow

East Kent Chalk Thannington, Howfield, Investigation and Options WFDGW_NDINV_GWR (Great Stour) Chilham, Godmersham Appraisal

Upper Stour Charing, Westwell, Investigation and Options WFD_NDINV_WRFlow Henwood Appraisal

North Kent (Swale) Halling, Ospringe 1, Investigation and Options WFDGW_NDINV_GWR Ospringe 2, Boughton, Appraisal North Kent (Swale) Wichling, Wineycockshaw, Newnham, Stockbury, Boxley Chalk, Cossington Chalk, Ridley, Hartley Chalk

North Wey at Alton Lasham Options Appraisal WFD_INV_WRFlow

Hart (Crondall to Itchel & Boxalls Lane Sustianbaility Reductions WFD_IMP_WRFlow Elvetham) (TBC through Options Apprisial)

Darwell Darwell Implementation WFD11

Waterworks Road Waterworks Road Investigation and Options WFD_NDINV_WRFlow Appraisal

Clayton Clayton Investigation and Options WFD_INV_WRFlow Appraisal

Coombe Coombe Investigation and Options WFD_INV_WRFlow Appraisal

Whitelands Whitelands Investigation and Options WFD_INV_WRFlow Appraisal

Sheet Sheet Investigation and Options WFD_NDINV_WRFlow Appraisal

East Meon East Meon Investigation and Options WFD_NDINV_WRFlow Appraisal

Lasham Habitats Lasham Investigation and Options HD_INV Directive in Appraisal combination investigation

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Scheme Name Abstraction(s) RSA Stage Driver

Greatham Greatham Investigation and Options WFD_NDINV_WRFlow Appraisal

Revised CSMG flow Lasham Investigation and Options HD_INV; Flow_CSMG targets for the River Appraisal Itchen SAC

Goudhurst Goudhurst Investigation and Options WFD_NDINV_WRFlow; Appraisal WFDGW_NDINV_GWR

Crowhurst Bridge Crowhurst Bridge Investigation and Options WFD_NDINV_WRFlow Appraisal

Brisham Brook Cookham, Hurley Investigation and Options WFD_INV_WRFlow Appraisal

1.4 The purpose of strategic environmental assessment (SEA) The WRMP19 recommends future projects which are likely to have significant effects on the environment, and therefore it falls under the scope of the European directive 2001/42/EC ‘the assessment of the effects of certain plans and programmes on the environment’ (known as the ‘SEA directive’). The SEA directive is implemented in England through the Environmental Assessment of Plans and Programmes Regulations 2004 (SI 1633 2004).

The objective of SEA (as explained in article 1 of the SEA Directive) is ‘to provide for a high level of protection of the environment and to contribute to the integration of environmental considerations into the preparation and adoption of plans and programmes with a view to promoting sustainable development’.

The SEA process involves the following:

 Collecting and presenting information on the environmental baseline and current problems, and their likely future evolution

 predicting significant environmental effects of the plan or programme, including those of strategic alternatives and including cumulative effects within the plan and with other plans and strategies or proposed developments

 addressing adverse environmental effects through mitigation measures

 consulting the public and authorities with environmental responsibilities as part of the assessment process

 monitoring the environmental effects of the plan or programme during its implementation.

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1.5 Scope of the SEA South East Water covers an area of some 5,657 km2 of Kent, Sussex, Surrey, Berkshire and Hampshire in two discrete regions.

The general location of the supply area, associated resource zones and other water companies bordering the supply area are shown in Figure 1.1.

The WRMP and SEA study area are considered to be the same, and comprise both the supply area and any neighbouring areas which could potentially be affected by implementation of plan options. The environment can potentially be affected directly by the construction and operation of infrastructure or indirectly through changes to water quality or quantity, particularly in relation to effects on downstream catchments. The SEA study area includes a 5km buffer around the company boundary, together with upstream and downstream river catchments and coastal areas. The study area also includes the 5km buffer area around water transfer options where these are outside the company boundary. The plan covers the next 25 year period in accordance with requirements but also an additional 35 years to provide a 60 year timeframe (to 2080), allowing long-term planning. The SEA also considers longer-term and permanent effects. Both are revisited through the WRMP cycle every five years.

There are also links between the WRMP and the plans produced by neighbouring water companies, including the options involving water transfer from these water companies. The water resources in the south east (WRSE) group includes representatives from all of the water companies located within the south east of England, with the aim of exploring opportunities for bulk supplies (transfers between water companies) and to encourage the development of shared resources.

1.6 Habitats Regulations Assessment (HRA) As a ‘competent authority’, South East Water must ensure that its WRMP meets the requirements of the Habitats Regulations prior to implementation. If the WRMP (i.e. one or more schemes within it) may cause a likely significant effect on one or more European sites, either alone or in-combination with other schemes, plans or projects, the WRMP must be subject to appropriate assessment. In accordance with regulation 61 of the Habitats Regulations, South East Water is undertaking Habitats Regulations Assessment (HRA) of its WRMP.

The process has four stages:

 Screening: identifies likely effects, alone or in-combination with other projects or plans, and considers whether these effects are likely to be significant

 appropriate assessment: the assessment of the effects of the WRMP (alone and in combination with other plans and projects) on European sites such that a conclusion can be made as to whether the WRMP will affect site integrity, taking into account potential alternative solutions and mitigation measures

 assessment of alternative solutions: where alternatives are identified and consideration of their effects in comparison to those in the WRMP

 assessment where no alternatives exist and adverse effects remain: provides an assessment of imperative reasons of overriding public interest and compensatory measures required.

The requirements as stipulated in the Habitats Regulations are considered in Appendix A.

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1.7 Marine conservation zone (MCZ) assessment Section 126 of the Marine and Coastal Access Act (MCAA) (2009) places specific duties on public authorities with respect to the authorisation of an act that is capable of affecting (other than insignificantly):

(i) the protected features of a Marine Conservation Zone (MCZ);

(ii) any ecological or geomorphological process on which the conservation of any protected feature of a MCZ is (wholly or in part) dependent.

The Marine Management Organisation (MMO) has introduced a two-stage MCZ assessment process to guide the implementation of s.126. A MCZ assessment need only progress to Stage 1 Assessment if it is deemed that a proposed activity might significantly affect a MCZ feature, or a supporting process (wholly or in part), acting either alone or in-combination with other plans or projects. If an effect may be significant, or is not known, it would trigger the need for Stage 1 Assessment. The Marine impacts of options have been considered through the development of the WRMP including the need for MCZ assessment for the plan preferred options or alternatives. A template form for the assessment process was developed for this purpose.

1.8 The Water Framework Directive The Water Framework Directive (WFD) aims to improve and integrate the way water bodies are managed throughout Europe and is transposed into English law through the Water Environment (Water Framework Directive) (England and Wales) Regulations 2003 and (Amendment) Regulations 2015. The WFD is designed to:

 Protect the status and prevent deterioration of freshwater and marine aquatic ecosystems and associated species which depend on the aquatic ecosystems including wetlands

 enhance the status of aquatic ecosystems in order to achieve ‘good ecological status’ or ‘potential’ (where artificial or heavily modified) by 2027 through river basin planning cycles

 contribute to mitigating the risk of flooding thereby increasing flood protection

 promote the sustainable use of water

 reduce pollution of water, especially by ‘priority’ and ‘priority hazardous’ substances

 ensure progressive reduction of groundwater pollution

The objectives of the WFD and WFD regulations will need to be taken into account in the planning of all new activities in the water environment. Existing activities in operation are covered within the WFD process as part of the existing baseline (potentially including significant water management issues). As such, they are under regular review with respect to WFD objectives and therefore need to be considered as part of the context for WFD compliance assessment for any new proposals, especially if they are identified as a reason for failing WFD objectives in individual water bodies. Therefore, the Environment Agency (the competent authority in England responsible for delivering the Water Framework Directive) has recommended that decisions setting policy, including large-scale plans such as WRMPs, take account of the requirements of the Water Framework Directive. River basin management plans (RBMPs) set out how organisations, stakeholders and communities will work together to improve the water environment and are updated for each six-year river basin planning cycle leading up to 2027. The objectives set for individual water bodies within the RBMPs and the measures identified to achieved them, for example actions to address reasons for failure, the catchment based approach (CaBA) or requirements in related plans such as abstraction licensing strategies (ALS) are of key relevance for WRMPs.

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Key aspects to be considered in WFD assessments include ecological and chemical water quality, groundwater quality, flow (quantity and dynamics) and morphological conditions (hydromorphology), riparian corridor and invasive species transmission with potential to affect:

 The status of surface water and groundwater body quality elements (to ensure no deterioration)

 ability of water bodies to meet status objectives

 water dependent designated and priority habitats and species.

We have integrated WFD considerations into the SEA in order to help inform future project-level WFD assessment.

2020 to 2025: Invasive Non-Native Species (INNS) projects included in WINEP

INNS is a key area of concern for WFD compliance due to the serious environmental or socio-economic harm they cause and so form a large part of our 2020 to 2025 WINEP programme. This programme includes measures to identify priority pathways, the risks posed by the spread of INNS and how pathways of spread can be mitigated to meet conservation objectives and to prevent deterioration in raw water quality.

We have a programme committed to in our business plan for 2020-2025 which includes two innovative investigations to identify potential methods of controlling INNS. Further detail of the individual elements of our INNS programme is included in Table 1.3 below.

Table 1.3 INNS programme included within our 2020 to 2025 WINEP

Delivery Scheme Scheme detail date

Investigation and Options We will carry out a risk assessment to identify potential INNS pathways and 22/12/2022 Appraisal of INNS assess their influence in the transfer of INNS. An options appraisal will follow, pathways associated with assessing our assets which are found to be of high risk for INNS spread. our operations

Biosecurity facility Here we will establish where biosecurity provision should be established on 31/03/2025 provision company sites. We will develop an INNS awareness and training course for all staff and contractors and will establish a programme to raise awareness of INNS issues with our stakeholders.

Innovation project We will trial a pilot project to control Himalayan balsam on our site at 31/03/2022 investigation for Arlington. Himalayan balsam

Innovation project We will trial a pilot project to control New Zealand pigmyweed at Ardingly. 31/03/2022 investigation for New Zealand pigmy weed

Produce a company-wide We will produce a company-wide plan to demonstrate how we will manage 31/03/2025 invasive non-native INNS pathways and spread. species plan

New treated water Construction of an extension to our water treatment works at Bewl and the 31/03/2025 transfer to remove threat creation of infrastructure to move treated water to the Pevensey Levels Area. of INNS to Pevensey Levels SAC

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1.9 Structure of the environmental report Table 1.4 below summarises the contents of this environmental report, and how each main section relates to the requirements of the SEA Regulations.

This report incorporates responses to comments from the stakeholders made during the consultation process.

Table 1.4 Structure of this environmental report

Relevant SEA Section Description Regulation Requirement(s)

Non-Technical A summary in non-technical language of the content of the SEA Regulation 12-(3), Summary Environmental Report. Schedule 2: 10

1 Background Introduction to the WRMP, objectives of the WRMP, background Regulation 12-(3), to the SEA process, other relevant legislative processes and the Schedule 2: 1 (first purpose of the environmental report. It also outlines the structure part) of the environmental report.

2 The SEA process Background to the WRMP, description of the SEA process and Regulation 12-(3), how it is integrated with WRMP development. Schedule 2: 8 (second part)

3 Relevant plans and Describes the legal and policy context of the WRMP, including Regulation 12-(3), strategies international, national and local strategies, objectives and Schedule 2: 1 (second environmental standards which may influence the WRMP. part) Regulation 12-(3), Schedule 2: 5

4 Consultation Describes consultation already undertaken on SEA scoping, as Regulation 12-(3), well as the approach to consultation on this report and the WRMP. Schedule 2: 8 (second part)

5 Key issues, Describes the characterisation of the existing and predicted future Regulation 12-(3), constraints and environment in the study area, focusing on the key environmental Schedule 2: 2 opportunities constraints, issues / problems, and potential opportunities for Regulation 12-(3), environmental improvement. Schedule 2: 3 Regulation 12-(3), Schedule 2: 4

6 SEA methodology Details how the SEA process was undertaken, providing an outline Regulation 12-(3), of the techniques followed and legal requirements at the scoping Schedule 2: 8 (second and environmental assessment stages. part)

7 Comparison of An assessment of the potential, reasonable alternatives to the Regulation 12-(2) (b) alternatives draft WRMP considered, and description of how the preferred Regulation 12-(3), alternative was selected in light of environmental effects. Schedule 2: 8 (first part)

8 Environmental Assesses the ‘preferred plan’ under each SEA topic and objective, Regulation 12-(2) (a) assessment of the considering the key issues scoped into the SEA. It also outlines Regulation 12-(3), preferred plan any mitigation measures proposed in order to improve the Schedule 2: 6 environmental performance of the WRMP.

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Relevant SEA Section Description Regulation Requirement(s) Regulation 12-(3), Schedule 2: 7

9 Implementation and Provides a synopsis of the statutory SEA monitoring proposals. Regulation 12-(3), monitoring plan Schedule 2: 9

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2. The SEA process

2.1 The SEA process

2.1.1 Stages of WRMP19 development and the SEA process The development of the water resource management plan (WRMP19) has been an iterative process through which an initial long list of water supply and demand management options have been filtered down through processes of screening and appraisal to produce a shorter list of feasible options.

The decision-making process for the plan took into account the 2016 United Kingdom Water Industry Research (UKWIR) guidance1. which updates the previous guidance based on the economics of balancing supply and demand (EBSD) framework developed to guide public water supply companies in England and Wales in conducting resource planning. The updated UKWIR guidance report provides a decision-making framework which can be adapted using appropriate tools to address the complexity of the resource planning issues. The process includes:

 Characterisation of the problem (understanding the issues and level of complexity for example)

 applying a screening process to a long list of possible options to identify feasible options, feasible from which options can be selected to form the plan

 identification of plan scenarios - these will be scenarios to cover the uncertainty related to demand such as population growth or supply due to drought and climate change, water quality and sustainability reductions as well as other technical delivery uncertainties

 generation of portfolios of options to meet the deficits under different scenarios through economic supply demand balance modelling and a decision-making process with multi-criteria analysis (MCA) input. The process will include sensitivity and stress testing.

The main guidance on strategic environmental assessment (SEA) used in the UK is ‘A practical guide to the strategic environmental assessment directive’ which was published by the Office of the Deputy Prime Minister (ODPM) in 2005. This guidance sets the SEA process out into five stages (A to E), from scoping (stage A) through to monitoring implementation of the plan or programme (stage E). These stages have been adopted in much of the sector-specific guidance, including the UKWIR 2012 guidance on SEA for WRMPs (strategic environmental assessment and habitats regulations assessment – guidance for water resources management plans and drought plans).

The approach to assessment set out in this environmental report has taken account of the above-identified guidance on SEA but has tailored the proposed approach so that the stages and tasks associated with SEA were aligned to the preparation of our WRMP19. This approach enabled the integration of environmental considerations into the preparation and decision-making on the WRMP19, with a view to promoting sustainable development.

1 WRMP 2019 Methods – Decision Making Process: Guidelines (Report Ref No 16/WR/02/10, UKWIR 2016)

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Figure 2.1 Stages of SEA alongside WRMP19 development and HRA

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Figure 2.1 Stages of SEA alongside WRMP19 development and HRA Figure 2.1 above illustrates how the WRMP19, SEA and HRA processes were aligned, taking into account the five main stages (A-E) of SEA identified in the ODPM 2005 and UKWIR’s 2012 guidance2. This environmental report is the final output of stage C.

2.1.2 Geographic influence and timescale of WRMP19 As identified in chapter 1, our supply region covers an area of some 5,657 km2 of Kent, Sussex, Surrey, Berkshire and Hampshire in two discrete regions. For resource planning purposes, this area is split into eight different Water Resource Zones (WRZs) (see figure 1.2).

While the WRMPs are revised every five years, the WRMP19 considers supply and demand covering a 60 year plan period. This allows for long term planning.

WRZs are identified as follows in the WRMP19 and grouped into three areas:

 Sussex: WRZs 1 (Tunbridge Wells), 2 (Haywards Heath) and 3 (Eastbourne)

 West: WRZs 4 (Bracknell) and 5 (Farnham)

 Kent: WRZs 6 (Maidstone), 7 (Cranbrook) and 8 (Ashford)

2 Based on the steps outlined in the ‘A Practical Guide to the Strategic Environmental Assessment Directive’ ODPM 2006; and ‘Strategic Environmental Assessment and Habitats Regulations Assessment – Guidance for Water resources Management Plans and Drought Plans’ UKWIR 2012

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3. Relevant policies, plans and programmes

3.1 Review of plans, policies and programmes A review of legislation, policies, plans and programmes (PPP review) was undertaken at the scoping stage and documented in the Scoping Report. The results of the PPP review can be found in Appendix B. A summary of the key PPPs relevant to the WRMP are outlined in Table 3.1.

The PPP review helped to identify broad issues within the study area, to identify objectives set by other parties and to see where there are potential harmonies or conflicts in objectives between the WRMP19 and other PPPs. The objectives and aspirations set by other PPPs have been considered and used as a basis for the strategic environmental assessment (SEA) objectives used during the assessment process for the WRMP19.

The Water Industry Act 1991 sets out specific requirements for the water companies. In addition to supplying safe drinking water, water companies have obligations to the conservation and enhancement of the natural environment including landscape and biodiversity. This Act also requires that cultural heritage, archaeological interest, and public access are all taken into account in relation to any company works. These obligations underlie the PPP review.

Table 3.1 Key PPP themes and objectives identified from review SEA topics and policy objectives PPP sources

Population and human health

Developing the economy, creating jobs and increasing prosperity.

Promote a green economy in which economic growth and the health of natural resources sustain each other and better reflect the value of nature. European Union (EU) sustainable development strategy, national planning policy framework, Support sustainable development. county and local development plans Ensuring that everyone has an equal opportunity to benefit from and contribute to the region’s sustainable prosperity.

Improving health and wellbeing of people living within the region.

Promote the use of open spaces as part of healthier and more National Parks and Access to the Countryside active lifestyles. Act and Right of Way Act, county-based recreation strategies, area of outstanding natural Provide more opportunities for tourism and recreation within the beauty (AONB) management plans, South region. Downs National Park management plan

Material assets

County based waste management strategies and mineral plans. national planning policy Promote sustainable levels of resource use and minimising waste. framework, local planning authorities core strategies and local plans.

Biodiversity, flora and fauna

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SEA topics and policy objectives PPP sources

Habitats and Birds directives, Natural Environment and Rural Communities (NERC) Act, Water Framework Directive (WFD), UK biodiversity action plan (BAP), local BAPs, UK Protect and enhance statutory and non-statutory designated priority habitat and species, biodiversity and nature conservation sites. ecosystem service sustainability (BESS), national planning policy framework, Wildlife and Move from net biodiversity loss to net gain, by supporting healthy, Countryside Act, Conservation of Habitats and well-functioning ecosystems and coherent ecological networks. Species Regulations, Marine and Coastal Access Act 2009, Marine Works EIA Regulations, conservation strategy 2021, strategy to 2020 (Defra)

Freshwater Fisheries Directive, Salmon and Freshwater Fisheries Act, Shellfish Waters Directive, national planning policy framework, Protect priority habitats and species Wildlife and Countryside Act; Conservation of Habitats and Species Regulations, Eel Regulations.

Landscape

Protect and enhance the region’s nationally designated National Parks and Access to the Countryside landscapes, townscapes, and important distinctive landscape and Act, Countryside and Rights of Way Act, AONB visual features and landscapes of local intrinsic value. management plans, South Downs National Park management plan; conservation areas, national character area descriptions, county-based Conserve and enhance the network of ancient and new woodland landscape local value assessments defined by for its landscape, wildlife and historic value and maintain its extent. European landscape convention.

Air

Improve the quality of the environment and people’s health by Noise directive, air quality action plans. reducing air and noise pollution.

Climatic factors

Reduce greenhouse gas emissions. Paris agreement on climate change, Kyoto Become more adaptive to climate change and consider climate protocol on climate change, UK climate change change vulnerability and risks to habitats and species, landscape, programme, National Planning Policy ecosystems services, water resources and quality, as well as Framework, state of the environment reports. supply resilience.

Water

Prevent deterioration and improve ecological and chemical status Water Framework Directive, Marine and Coastal of water bodies including restoration of the natural functioning of Access Act 2009, Marine Works (Environmental rivers and river catchments, reducing water pollution and Impact Assessment) Regulations, Urban Waste maintaining groundwater resources and quality. Water Treatment and Nitrates Directives (and relevant acts), Bathing Water Directive, Water Promote awareness and the efficient use of water resources Act, Bathing and Drinking Water Quality Acts, Water for life white paper, river basin Continue to aim for sustainable levels of surface water and management plans (RBMPs), abstraction groundwater abstraction. licencing strategies, (ALS), water resources for

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SEA topics and policy objectives PPP sources

the future, flood risk management plans, Plan and protect to mitigate flood risk. maintaining water supply and groundwater protection guides (for water assessments)

Cultural heritage

Protect and enhance the historic environment and heritage assets, National planning policy framework, Ancient both designated and non-designated, including the settings of Monuments and Archaeology Act, Listed these sites. Buildings and Conservation Areas Act

Soils

Protect the viability of land use and mineral resources. National planning policy framework, pollution prevention guidance, soil strategy, land use Improve the quality of the environment by reducing soil pollution futures, geological conservation review series and the extent of contaminated land.

3.2 A Green Future: Our 25 Year Plan to Improve the Environment The 25 year Environment Plan was published in 2018 and sets out government action to improve the environment. Of specific relevance of our WRMP19 are the commitments to improve the proportion of waterbodies with enough water to meet environmental standards, meeting or exceeding WFD targets for waterbodies in line with RBMPs and to support Ofwat’s ambition to minimise losses from leakage. As part of the overarching aim to improve the environment within a generation, the plan also sets targets for the protection, restoration and improvement of marine and terrestrial biodiversity protected sites and embeds the principles of net gain for infrastructure development.

3.3 Water Industry Strategic Environmental Requirements (WISER) WISER was issued by the Environment Agency and Natural England in 2017 and sets out the main obligations for water companies. It includes a request for enhancements to be considered that go beyond the statutory minimum where there is customer support and to identify opportunities for working in partnership to achieve wider benefits.

WISER sets out regulatory aims and objectives for the water industry and areas of innovation and good practice for consideration. These are directed more widely than the development of the water company WRMPs and include the company PR19 business plans. The strategy is focused around three core objectives for customers and the environment which are aimed at:

 Enhancing the environment

 improving resilience in water supply and natural environment

 achieving excellent performance.

The role of valuing the environment, creating stronger partnerships and embracing innovation are highlighted across these themes. The document sets out expectations for the water companies across the three objectives and these have been taken into account in the approach developed for the WRMP and SEA particularly in relation to expectations set out on WFD waterbody status, designated areas, biodiversity and ecosystems, fisheries and Invasive Non-Native Species (INNS). Further details regarding how our current WISER actions and how our emerging business plan supports WISER expectations are set out in Appendix C.

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4. Consultation

4.1 The purpose of consultation Consultation has been an important part of the development of the water resource management plan (WRMP19) and the environmental assessment from the start of the process. The consultation approach has specifically aimed to include ‘engagement’ of stakeholders in the process. Engagement can be defined as the early and open-ended involvement of interested stakeholders in the development of a plan or its assessment. The purpose is to build in their views and opinions, knowledge and advice before particular tasks in plan development are complete. This is a proactive and responsive approach to consultation.

In the development of the WRMP19, we have included engagement approaches as part of their consultation. There are two stages of consultation in strategic environmental assessment (SEA): scoping and on the environmental report. Regarding scoping, the SEA Regulations require that the statutory consultation bodies are consulted at an early stage in the SEA process on the scope and level of detail of the information which must be included in the environmental report.

The objective of an environmental report is to document and to facilitate public and stakeholder consultation on the SEA process. In doing so, it will “contribute to more transparent decision making and with the aim of ensuring that the information supplied for the assessment is comprehensive and reliable” (SEA Directive, Preamble par. 15).

4.2 Pre-scoping and ongoing engagement An environmental focus group (EFG) was originally set up at the beginning of the WRMP14 process in January 2012 and has been continued for WRMP19 (see below for members of the EFG). The EFG has met regularly from January 2016, and has significantly influenced the process in many ways, for example, helping to shape the criteria used to filter and appraise potential future options.

Environmental focus group (South East Water) (2016/17) Basingstoke & Deane Borough Council National Farmers Union Bracknell Forest Council Natural England Canterbury and District Angling Association Ouse & Adur Rivers Trust Consumer Council for Water Ringmer Parish Council Council for British Archaeology - South East RSPB - South East CPRE (Sussex, Hampshire, Kent) Rushmoor Borough Council Customer Challenge Group Salmon and Trout Association East Sussex County Council South Downs National Park Authority Environment Agency South East Rivers Trust Farmer and catchment stakeholder The Inland Waterways Association Joint Parishes Group Wealden District Council Kent County Council Whitewater Valley Preservation Society Lewes District Council WWF and Blueprint for Water

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4.4 Scoping consultation The SEA Directive requires that a number of statutory bodies are consulted at an early stage in the SEA process on the scope and level of detail of the information which must be included in the Environmental Report. A statutory five-week consultation period on the scoping report, as stipulated within SI2004/1633, was undertaken in May/June 2017.

The legislation only requires the scoping report to be sent to statutory organisations; Natural England, Heritage England (previously English Heritage) and the Environment Agency. However, we have also issued the scoping report to the EFG (see above for the organisations within this group) and published the report on our website.

Table 4.1 below summarises main comments received in response the scoping report and how they have been addressed by the SEA process.

Table 4.1 Key issues raised in the scoping consultation

Key issues/themes raised SEA response

Effects on heritage assets have been scoped out of the Only the effects on access to heritage assets had scoped SEA out of the assessment but effects on heritage and archaeology has been specifically scoped into the assessment - the wording on what is scoped in for cultural heritage has been further clarified.

Further consideration of marine protected sites and Marine conservation zones (MCZs) and marine special marine habitats and species is required. areas of conservation (SACs) and special protection areas (SPAs) have been considered within the SEA, HRA (Appendix A) and MCZ assessment (Appendix D) as appropriate.

Sites of special scientific interest (SSSI) impact risk zones The SSSI impact risk zone dataset has been included should be used during assessment. within the baseline (see section 5.4) and used as a starting point for assessment of effects within the SEA and HRA.

Potential special protection areas (pSPAs), possible pSPAs, pSACs and proposed Ramsar sites have been special areas of conservation (pSACs) and proposed considered within the SEA and HRA. Ramsar sites, and compensation sites should be considered within the Habitats Regulations Assessment (HRA). Should likely effects on Natura 2000 sites or Ramsar sites be identified, and appropriate assessment will be required.

Impacts on local wildlife and geological sites should be Potential effects on local nature reserves (LNRs) and considered. regionally important geological sites (RIGS) are included within the SEA.

Impacts on protected species should be considered at the Where possible, the HRA and SEA have identified where strategic WRMP stage. potential impacts on wildlife, including protected species could occur. Where potential effects are clear at this stage of assessment, for example with the Arlington reservoir option, more detailed studies have been undertaken to inform concept design. Further ecological survey work would be undertaken as option development continues to inform design development and appropriate mitigation.

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Key issues/themes raised SEA response

Potential impacts on access land, public open land, rights Impacts on public access and recreation receptors has of way, coastal access routes and national trails should been considered within the SEA. be considered.

The SEA should identify where there are gaps in baseline Where there is uncertainty regarding the potential impact information, and how these will be filled. of an option this has been identified within the SEA along with the requirement for further, more detailed studies.

Further consideration of effects on priority species, Further information on priority habitats and species within including those habitats and species that may experience the study area is provided within section 5.3. Priority construction effects is required. habitats have been considered within the SEA. Potential effects on priority species have been considered where practicable at this stage of assessment, with a recommendation for further ecological survey work to inform option design development and appropriate mitigation where uncertainty exists.

If water transfer options are being considered from non- The cumulative impact assessment provided in chapter 8 adjacent sources then the relevant WRMP for these areas is based on the WRSE and considers the following water should also be considered in the SEA and include criteria company areas: to enable assessment of impacts beyond the  Thames Water neighbouring South East Water WRZ area.  Affinity Water  SES Water  Southern Water  Portsmouth Water Transfers included within the preferred plan are sourced from within the supply area of the above water companies. The study area includes the location of these transfers.

Environmental receptors located outside South East Environmental receptors located within 5km of our supply Water’s supply area should be included within the area, or within connected catchments or waterbodies that assessment where there is potential for hydrological could potentially be affected by the construction or influence or construction impacts to occur. operation of water resource management options, have been considered within the assessment.

Potential to deliver biodiversity enhancements through Potential biodiversity enhancements have been identified water resource measures should be considered. for reservoir options included within the preferred plan. Further detail is provided in section 8.3 and Appendix E.

Additional plans that should be included within the plans, All relevant plans identified by consultees have been policies and programmes (PPP) review. included within the PPP review.

WFD assessment should consider: These aspects are considered within the WFD assessment provided in Appendix F and summarised in  Surface water body scale issues around section 8.5.10. achieving good ecological status via flow compliance or the larger scale groundwater quantitative status.  risk of deterioration may constrain growth in Poor or at risk groundwater bodies or surface water bodies with flows that do not support good

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Key issues/themes raised SEA response

ecological status or are at risk of not supporting good ecological status.

Other company WRMP and drought plans should be The cumulative effects assessment (see section 8) considered within the assessment, as should other large considers each of these types of plans, projects and scale or locally significant projects that are either ongoing activities as far as is practicable at this stage of or planned. assessment and using publically available information.

4.5 Consultation on the draft WRMP and Environmental Report A formal consultation period for the SEA environmental report and the dWRMP19 was undertaken over a 12 week period ending May 2018 and included an extensive engagement programme as detailed in the following paragraphs.

Statutory consultees and stakeholders

 Formal notifications were issued to our statutory consultees

 emails were sent out to other interested parties (including a wide range of individuals and organisations including local authorities, parish councils, MPs, environmental groups and business organisations) detailing highlights of the dWRMP, offers of a meeting/discussion, and details of how the plan can be commented on

 a joint stakeholder event was held in partnership with Southern Water, Affinity Water, SES Water and Portsmouth Water

Wider public

 All dWRMP19 consultation materials and supporting documents were placed on a dedicated page on our website, which included an electronic feedback form. Details of the web page were published on all materials associated with the consultation such as posters, social media posts, newsletters, press releases and emails

 public exhibitions were held in areas where large and small infrastructure projects were proposed, with locations informed through pre-consultation discussions with the relevant parish councils

 open days were held at three of our water treatment works, which included presentation of the dWRMP19 proposals and opportunity for attendees to comment

 articles and posts were disseminated through our customer magazine and through social media channels including Facebook, Twitter and LinkedIn

Key themes amongst responses received through the consultation exercises set out above are set out in Table 4.2.

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Table 4.2 Key issues raised in the dWRMP19 consultation

Key issues/themes raised SEA response

Statutory consultees

The Water Framework Directive (WFD) assessment The WFD assessment summary has been amended to should detail impacts on multiple waterbodies where incorporate all the relevant waterbodies identified in our appropriate, include quantitative assessment of working tables other than those relating to pipeline hydrological regime and ensure target aquifers assessed crossings as at this stage a standard construction for new groundwater options are correct. Water reuse approach is identified but individual assessment will be schemes should be considered moderate risk. undertaken for project development.. The Peacehaven water reuse scheme has been considered moderate risk following a change in proposed treatment processes from reverse osmosis to conventional treatment (with a relatively small component of reverse osmosis). Quantitative hydrological assessment is not considered appropriate at this stage of option development. Mitigation proposals set out in the SEA and WFD assessment detail further studies that would be undertaken as part of option progression, including quantitative hydrological assessment where necessary and our commitment to develop monitoring plans for each scheme addressing WFD aspects where appropriate has been clarified.

The water reuse options at Peacehaven and the Medway The water reuse scheme at the Medway has been should not be developed further unless an alternative excluded from the WRMP. The water reuse scheme at location for the brine disposal can be identified. In Peacehaven has been included as a plan alternative addition, potential impacts of reduced volumes in option should the new Arlington Reservoir option prove receiving waters should be considered unfeasible. Detailed further ecological and hydrological studies would be undertaken during the development of this option to ensure it can be implemented without generating unacceptable adverse impacts on the environment. This would include consideration of alternative discharge arrangements. The waste water treatment plant at Peacehaven currently discharges to sea, so no adverse impact on receiving waters as a result of reduced flows is anticipated.. The treatment process for the Peacehaven water reuse scheme only includes a small element of reverse osmosis treatment and a reduced production of brine effluent. It may therefore allow for a greater range of options for brine disposal but further studies will be undertaken to address environmental concerns related to this.

Further information is required on how current and future Existing sustainability reductions have been addressed sustainability reductions have been considered through the WINEP process and the plan takes account of future sustainability reductions and tests sensitivity to possible future sustainability reductions. We are committed to not growing current sources until sustainability assessments have been completed to avoid future WFD status deterioration related to existing sources.

The WFD assessment should take into account planned No further increases in abstraction beyond the stated growth of existing sources, cumulative impacts of growth planned increases are anticipated.

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Key issues/themes raised SEA response and new options and options which indirectly increase licence uptake

The transfer option from Bewl water treatment works The WTW option which includes a transfer from Bewl (WTW) should take into account any requirements of the WTW replaces a raw water transfer with a treated water Pevensey Levels water level management plan and the transfer and there would be no releases to the water impact of additional abstraction from Bewl under the Bewl courses connected to the Pevensy levels. The transfer Bridge water treatment works expansion option has not option removes the existing INNS risk from the raw water been assessed transfer. There is no additional abstraction from Bewl planned.The Bewl Bridge water treatment works option has been excluded from the WRMP19, however it does not include additional abstraction from Bewl.

Further detail regarding environmental monitoring should High level monitoring proposals are set out in chapter 9. be provided, and the company should monitor WFD More detailed monitoring measures would be developed deterioriation as option design progresses and further studies are undertaken. There is a commitment to develop scheme monitoring plans.

Concerns regarding impacts of desalination schemes on These options have been excluded from the WRMP. terrestrial and marine protected sites

More detail is required regarding screening of impacts on Further detail regarding the SSSI screening process SSSI sites provided in Appendix G and summarised in section 8.8.2.

Opportunities to contribute to Natural England’s woodland This suggestion has been incorporated into proposed and downland focus areas should be considered mitigation for the WRMP19 options where appropriate.

The plan should contribute to net biodiversity gain, and Our commitment to net biodiversity gain and should consider mitigation/enhancement for all habitats mitigation/enhancement measures for habitats and and species whether protected or not species that are not protected under EU or UK law has been incorporated into the SEA mitigation as set out in section 8.6.3.

A separate marine conservation zone (MCZ) assessment A MCZ assessment has been undertaken. The results of should be undertaken the assessment are summarised in section.8.7.4.

Other stakeholders and members of the public

General support for Broad Oak Reservoir, however Projected population increases within the study area were several specific areas of concern including: taken into account during development of the supply demand balance for the area. The Broad Oak reservoir suitability of access via Barnet’s Lane • involves abstraction during winter high flow at Plucks • whether size of reservoir is sufficient for projected Gutter and abstraction during low flows such as during dry population increase winters would be limited by licence restrictions. Abstraction from the Stour would only take place when • impact on the Sarre Penne water levels are considered high enough during winter months. • impact on the Stour stream if reservoir filled during dry winters Recreational facilities planned for the site will support informal recreational activities and include improvements • provision of recreational facilities at the reservoir site to cycleways in and linking to the site, as well as footpaths and bridleways. A recreational plan will be developed with the local community to identify future recreational provision at the site. Access suitability will be considered in detail as part of this plan.

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Key issues/themes raised SEA response

The WFD assessment (Appendix F) identifies a requirement for further study into the potential impacts of the scheme on the Sarre Penne. It is likely that a WFD derogation would be required in order to allow the scheme to progress with the constraints of the Richborough Connection scheme.

General support for Arlington Reservoir, but requests for The SEA has identified the need for mitigation for the loss improvement to accessibility and existing recreational of a public right of way within the footprint of the proposed facilities and visual impact for nearby houses new reservoir and for the visual impact of the new reservoir. These issues, and potential further enhancements to public access and recreational facilities on the site, will be the subject of further study and consultation as the option design progresses.

Continuation of abstraction from Greywell Fens until 2025 We are currently investigating how best to make the necessary distribution upgrades whilst minimising impacts on the affected wetland site of special scientific interest (SSSI). This will be completed as quickly as possible, however we currently anticipate ceasing abstraction from Greywell Fens in 2023.

Increased abstraction from river Cuckmere There are no options within the WRMP that involve new or increased abstraction from the Cuckmere.

Potential increase in traffic through Eccles No traffic increases are anticipated as a result of the construction or operation of options included within the WRMP.

Loss of high quality agricultural land at Peacehaven and Peacehaven scheme is now an alternative scheme for the visual impact of new infrastructure WRMP. The SEA proposes that the design of the new plant is agreed with South Downs National Park authority to ensure that it is in keeping with this sensitive landscape area. There may be a small amount of loss of best and most versatile (BMV) soils during construction of the plant, however the land is not currently under agricultural use.

Query whether the proposed landscape protection The proposed landscape protection strategies refer strategies will cover both designated and undesignated primarily to designated landscapes, however specific landscapes mitigation has been identified for undesignated landscapes and the principles derived from the protected landscape strategies would be applied more widely and will be linked to biodiversity and cultural heritage.

Impact of proposed new surface water (particularly chalk The WRMP19 relies more heavily on leakage reductions streams) and groundwater abstractions and water efficiency measures than the dWRMP19, minimising the impact on environmental sources. Overall the preferred plan improves resilience and flexibility with the storage reservoirs, transfers and network improvements and provides opportunities for conjunctive use with existing sources to reduce abstraction pressure. We are also committed to not increasing abstraction until sustainability assessments have been completed to avoid future WFD status deterioration.

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Key issues/themes raised SEA response

Impact of new reservoir options on valuable habitats and Impacts on habitats and species, connectivity and species, downstream rivers and landscape connectivity downstream rivers have been assessed within the SEA, Habitat Regulations Assessment (HRA) and WFD assessment. It is concluded that residual impacts would be minor adverse or negligible following implementation of mitigation.

Integration of natural capital in the SEA Details of how ecosystem services have been considered and integrated within the plan development, in accordance with the water industry strategic environmental requirements (WISER) are set out in section 7.12 .

Feasibility of commitment to archaeological mitigation We are committed to provision of mitigation of required archaeological impacts as set out in chapter 8 and scheme costs include allowances for assessment and mitigation.

Local wildlife sites should be identified by name within All options will be subject to an environmental impact SEA assessments assessment, and local wildlife sites will be considered as part of this process. The SEA includes mitigation to avoid or reduce effects on non-statutory sites.

The dWRMP19 should be aligned with the high level Blue A detailed description of how our plan aligned with the Print for Water outcomes Blue Print for Water outcomes is provided in Appendix H.

Further details are provided in the statement of response document which accompanies the WRMP19.

4.6 Future consultation The EFG will continue to meet so that they are kept informed of the ways in which their feedback and consultation responses have been incorporated into the final WRMP19.

There will also be on-going consultation with other water resource companies in the WRSE group to ensure that effects between water company regions are considered.

As part of taking the WRMP19 preferred plan forward to implementation, schemes will also be developed further taking account of detailed consultation with local planning authorities and statutory and non–statutory consultees, as relevant.

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5. Key issues, constraints and opportunities

5.1 Baseline data and information collection methods

5.1.1 Study area and data collection methods The main study area for the strategic environmental assessment (SEA) comprises of our supply area (see Figure 1.1) and a 5km buffer, together with neighbouring areas and catchments which could potentially be affected by the implementation of WRMP19. The 5km study area buffer is expected to capture potential impacts related to the proximity of options while the inclusion of neighbouring areas and catchments extends the study area to include potential pathways for impacts through rivers, aquifers and habitats.

Baseline conditions were determined using a desk based review of available information sources, including:

 Ordnance Survey mapping

 data made available by the Environment Agency, Natural England and English Heritage under Open Government Licence V3.0 (www.data.gov.uk)

 the Corine Land Cover 2012 dataset provided by the European Environment Agency (http://land.copernicus.eu/pan-european/corine-land-cover).

Additional information sources used to inform baseline conditions are detailed within the relevant topic subsections below.

5.1.2 Identifying current and future baseline conditions The baseline information used for the SEA of the WRMP14 has provided the starting point for understanding the environmental context for the WRMP19. The baseline information has been reviewed for relevance and updated where appropriate. This includes the consideration of the current and future baseline and takes account of key trends and pressures. The future baseline refers to how the environment is expected to evolve in the absence of implementation of the WRMP19.

5.2 Population and human health

5.2.1 Topic definition This section considers the topics of population and human health together since they are closely interrelated. Water resource management planning can affect, and be affected by, issues related to population and human health, including effects on recreation and tourism.

The scope of this chapter considers the distribution and density of population across the study area as well as likely trends in terms of population change.

The topic of human health considers the current status and future trends in the population’s health and wellbeing as well as the consideration of inequalities in health and wellbeing across different population groups in the study area.

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5.2.2 Current baseline Economy

The western region is more economically prosperous than the eastern region, particularly within the M4 corridor. Business sectors important for the economy in the region include, light industry, tourism, service sector and agriculture. The northern parts of our eastern and western areas are part of the commuter belt for London. These economic influences have driven growth and the distribution of population in the study area.

Population

The south east of England as a whole is officially identified as an area of significant population and economic growth. Between 2015 and 2019, the population within our supply area is anticipated to increase from 2.09 million to 2.19 million. This was approximately 26,000 more people than we had forecast at the time of WRMP14, and this trend of accelerated population growth is considered likely to increase.

Health

Overall the health of the population within the study area is generally good, and above the UK average. Table 5.1 indicates the general heath and vulnerability of people within the health authorities covering our supply region, in comparison to England as a whole.

It can be seen that all areas are healthier than the England averages, however that there are also geographical differences within our supply area. The Thames Valley is notably the healthiest of the areas while Kent and Medway is the least healthy.

Table 5.1 South East Water region human health indicators Health Authority Indicator Thames Surrey and Hampshire & Kent and England Valley Sussex Isle of Wight Medway

% Good Health 74.2 71.0 71.0 69.3 68.8

% Fairly Good Health 19.8 21.6 21.7 22.8 22.2

% Not Good Health 6.0 7.3 7.3 8.0 9.0

% Households with one or more person with a limiting 26.05 29.5 30.4 32.2 33.6 long-term illness

% People who provide 8.6 9.7 9.1 9.5 9.9 unpaid care

% Households with no adults in employment: With 2.9 2.9 3.4 4.3 4.8 dependent children

2011 Data from: http://neighbourhood.statistics.gov.uk

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Vulnerability and deprivation

It is recognised that vulnerable groups can be more susceptible or less able to cope than others to changes in their situation. The definition of vulnerable groups can be widely drawn (including children and the elderly) and to some extent will depend on the issue under consideration. For water supply, in the past, the term was specifically defined by Ofwat in relation to eligibility for assistance with bills. Going forward, we have been working with our Customer Challenge group to define what vulnerability should mean for South East Water and our customers. It is our view that vulnerability is when a consumer’s personal circumstances and characteristics combine to create situations where he or she is either, significantly less able than a typical consumer to access the services provided by South East Water, and/or is significantly more likely than a typical consumer to suffer detriment, or that detriment is likely to be more substantial.

The Index of Multiple Deprivation (IMD) is a measure of relative deprivation calculated using combined information on poverty and deprivation from seven different domains (income, employment, education, skills and training, health and disability, crime, barriers to housing and services and living environment deprivation)3. The majority of the study area, particularly within the western supply region, has an IMD score which falls above the 5th decile for England (Figures 5.1.1-5.1.8). Main areas in the eastern supply area with an IMD score which falls significantly below 5th decile are centred around the larger settlements on the southern coast of East Sussex (Eastbourne, Eastbourne, Newhaven) and Kent (Lydd) and northern coast of Kent (Whitstable, Faversham, Sittingbourne, Herne Bay). Smaller areas with an IMD score which falls below the 5th decile surround Basingstoke, Farnham and Bracknell in the western supply area, and Canterbury, Ashford and Maidstone in the eastern supply area.

Recreation and tourism

Tourism and recreation are important economic and social factors within the area served by South East Water. Key recreational activities in the study area are walking, fishing and water sports. The picturesque landscape of the area offers many opportunities for such pursuits, and there are many designated areas including Areas of Outstanding Natural Beauty (AONB), the National Park, Heritage Coast (see section 5.5) and national trails. These areas, together with the network of public footpaths are important for wider access to countryside for informal recreation. Informal recreation is also widely recognised as promoting health and wellbeing through exposure to wildlife and the outdoors.

Tourism is important for the economy of the region and is particularly important for the WRMP19 as it adds to population pressure especially in coastal areas during the summer when demand is generally highest. Notable tourist areas are along the south coast including Eastbourne, Seaford and Newhaven (see Figures 5.1.1 and 5.1.2). Other large towns and cities in the area such as Whitstable on the North Kent coast and Canterbury (Figure 5.1.8) are also popular with tourists.

3 Department for Communities and Local Government, The English Indices of Multiple Deprivation (IMD) 2015 – Guidance, https://www.gov.uk/government/statistics/english-indices-of-deprivation-2015, [accessed 01 February 2017]

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5.2.3 Future baseline Population

The population level within our supply area is anticipated to increase by 24 per cent between 2016/17 and 2044/55 (from approximately 2.19 million to 2.7 million), with increases within individual water resource zones varying between 16 per cent and 31 per cent.

Water demand per person has historically increased at a rate of about 1 per cent per annum, however in recent years domestic demand has decreased as the proportion of metered customers grows. In addition, awareness of the need for water conservation action is likely to grow. However, overall water demand is expected to rise with population increase.

Health

Overall there is expected to be a deficit in water supply without the additional investment to be determined by the WRMP19. The deficit could be detrimental to health where access to water supply is reduced through level of service or affordability changes.

Vulnerability and deprivation

A deficit in water supply, and subsequent changes to level of service and affordability, could disproportionately affect certain vulnerable groups and/or a greater proportion of the population within deprived areas.

Recreation and tourism

Recreation and tourism are closely related to landscape and cultural heritage interest, as well as the accessibility of amenities. As population growth increases and trends for increased interest in outdoor recreation continue, demand for formal and informal recreational amenity is expected to increase steadily. Domestic tourism is likely to continue to rise with associated increasing seasonal populations in the coastal towns and greater demand for water.

Higher use of existing recreational amenity and pressure for additional resource is expected as population increases and awareness raising of benefits to are expected.

Areas of uncertainty

Population projections are based on recently available mid-year population estimates and a set of underlying demographic assumptions regarding future fertility, mortality and migration. However, the future implications of the 2016 United Kingdom European Union membership referendum (the “Brexit” referendum), which saw a majority vote in favour of leaving the European Union, are uncertain. The UK government has started the formal process invoking Article 50 of the Treaty of the European Union in March 2017. There are divergences of expert opinion on what influence leaving the European Union will have on issues such as the economy and migration; two issues which could heavily influence future trends in terms of population growth.

5.2.4 Interrelationships with other topic areas and ecosystem services Ecosystem services are the benefits that people obtain from ecosystems; therefore there is a relationship between population and all ecosystem services. Human health and wellbeing is therefore dependent on well- maintained and functioning ecosystems.

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The tourism and recreational aspect of ecosystems services topic area is strongly interrelated to the SEA topic areas of material assets, landscape and cultural heritage.

The National Ecosystem Assessment4 findings showed that about 70 per cent of England is farmed and that England is one of the world’s most densely populated countries, “with over 80 per cent of the population living in towns and cities. These urban areas are virtually certain to make the highest demands on, and be the greatest recipients of, ecosystem services”. It goes on to identify that “urban areas require more ecosystem services than they can provide”.

As population increases there are likely to be increased impacts on all aspects of the environment, including direct, physical impacts on biodiversity, flora and fauna, landscape and soils (through habitat loss, disturbance, soil erosion from recreational activities), and indirect impacts such as effects on the water table due to increased demand for water affecting wetland ecosystems.

5.3 Material assets

5.3.1 Topic definition The SEA Directive includes ‘material assets’ as a topic to be addressed in SEA but does not include a definition of what this topic might include. As a consequence it is interpreted in a number of different ways. For the purposes of this SEA, material assets is taken to include:

 Built assets e.g. infrastructure relating to energy / heat generation and distribution, flood protection, water supply and waste water management, transport, telecommunications, waste management and pipelines; land in relation to developed land / settlements, vacant, derelict and contaminated land; buildings and facilities such as housing, healthcare facilities, schools, greenspace, public rights of way, cycle paths and manufactured goods

 natural assets e.g. minerals (such as sand, gravel, rock, and slate), natural flood management processes, forestry and woodlands, agricultural land and associated elements such as field boundaries (e.g. hedges, stone walls).

5.3.2 Current baseline Transport infrastructure

There are major transport infrastructure networks across our supply area (see Figures 5.1.1-5.1.8). Most major roads cross the western area in a southwest – northeast direction, heading towards London. These include the M4, M3, A31 and A3. The main roads crossing these in the opposite direction include the A329(M), A332, A33, A331 and A404(M). Key railway lines run from Reading to Basingstoke; Basingstoke to Farnborough; Wokingham to Bracknell; Alton to Frimley and Guildford to Petersfield. Key roads in the eastern region include the M2/A2, M20, M26, A21, A26 and A299. High speed rail links in the eastern region including HS1 are providing improved connections to London and the continent.

The Thames is navigable as far upstream as Lechlade, while the Wey is navigable over 32km between Godalming and the Thames. Boating takes place on the over much of its length, although it suffers from problems of low water levels which can restrict navigation at times.

4 National Ecosystem Assessment, 2011, Chapter 17:Status and Changes in the UK Ecosystems and their Services to Society: England. pp694-695

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The River Medway is navigable over 31km from Allington Lock (the tidal limit) to the Lucifer Bridge, with the navigation maintained by a series of sluices, weirs and locks, while boating takes place on the Rother as far upstream as Bodiam. The Stour is navigable between Pegwell Bay (the river mouth) and Grove Ferry Bridge. The River Ouse has a long history of navigation, which has resulted in a complex array of structures including weirs and sluices to maintain levels; however now only 9.5km of the tidal river to Lewes is navigable.

Water supply infrastructure

South East Water has a network of pipelines that cross both the eastern and western region. Other water supply infrastructure includes numerous boreholes, pumping stations and treatment works, along with several reservoirs (see Figures 5.3.1-5.3.8). Ardingly is an online reservoir on the River Ouse. In the summer months it is used to augment flows in the Ouse, for re-abstraction downstream at a water treatment works within WRZ2. Arlington is an offline reservoir on the River Cuckmere. Water can be transferred between the WRZ2 water treatment works and Arlington Treatment Works, allowing transfer of water between different WRZs, which can be particularly important in terms of water distribution during drought situations.

Weir Wood, Bewl and Darwell reservoirs are within our supply area, but are owned and operated by Southern Water. We have a 25 per cent share of the Bewl Water reservoir. Southern Water provides a bulk supply of 5.9Ml/d from Weir Wood and up to 8Ml/d of water from Bewl / Darwell to our Hazard’s Green pumping station.

Recreational assets

There are three national trails within our supply area (see Figures 5.1.1- 5.1.8). The South Downs Way national trail runs for about 100 miles between and Eastbourne following prehistoric route ways through the chalk downs of Sussex and Hampshire. The North Downs Way is approximately 150 miles long and begins in Farnham, Surrey. It passes into Kent along the line of the North Downs and ends at Dover. There is a loop at the eastern end of the trail which passes through Canterbury. The Thames Path national trail follows the boundary of the western supply area, along the path of the River Thames.

There are several other long distance and regional walks throughout our supply area, including the long distance footpath in the western region (Figures 5.1.4 and 5.1.5). We promote a number of walking routes including the Osprey Trail around Arlington reservoir, the Pembury Heathland Walk through Marshley Harbour Wood and the Kingfisher trail around Ardingly reservoir. The network of Public Rights of Way (PRoW) play an important role in providing access for informal recreation. These include walks and cycle routes along rivers and canals, for example Basingstoke Canal, which can be important resources in urban as well as rural areas.

Arlington reservoir is widely used for trout fly fishing, while Ardingly reservoir is a renowned coarse/pike fishery, but is also used for all kinds of water sport, including sailing, windsurfing and canoeing. Bough Beech reservoir, Bewl reservoir and Brooklands Lake are used for angling, canoeing, boating, rowing, water-skiing and windsurfing.

Fishing and canoeing are popular on many of the watercourses in the area. The south coast is a popular recreational location for tourists and day trippers, with the resorts of Bexhill, Eastbourne and Seaford to the south (see Figures 5.1.2 and 5.1.3) and Whitstable, Herne Bay and Reculver to the north (see Figures 5.1.8).

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Natural assets

The main mineral resources in the study area relate to sand and gravel deposits (both superficial and bedrock) which are present in various locations across the study area, and limestone deposits between Maidstone and Folkestone (closely following the M20 motorway corridor). There are numerous active quarries (mainly sand and gravel) in the area, notably around Farnham, Trosley, Charing and Tonbridge5.

Approximately 70 per cent of south-east England is farmed. Agriculture and horticulture includes irrigated agriculture and intensive fruit production in Kent and East Sussex.

Woodlands and trees cover around 15 per cent of land within the south east compared to a national average coverage in England of 12 per cent 6.

Sustainable resource use

Material assets also include the use of raw materials and the generation of waste. For the dWRMP19 the main issues relate to potential construction projects which can consume significant quantities of non-renewable resources such as primary aggregates, processed materials including mechanical and electrical infrastructure, landscaping materials and packaging.

Construction projects can generate significant amounts of waste through demolition of existing structures, the excavation of spoil at a site and through packaging or other materials. Wastes can be reduced by following a waste hierarchy of prevention, reusing and recycling materials before considering disposal to landfill. For the potential types of construction projects for WRMP19 there is often potential to avoid the need for disposal of spoil through reuse within the site, for example in pipeline open cut trenching or in cut and fill projects such as new reservoir projects.

5.3.3 Future baseline Infrastructure

Increased pressure for development and infrastructure in the south east of England is expected as a consequence of the predicted population growth, household changes and economic growth.

Climate change is likely to increase the frequency of extreme weather events (for example, floods, droughts, storms) as well as sea level rise and coastal erosion. These events will increase the likelihood to damage to built infrastructure, including water supply assets, over time.

Natural assets

Climate change is expected to influence agriculture and horticulture and water use in the future, particularly through the types of crops planted and use of irrigated agriculture. Strategies to conserve and reuse water are expected to increase such as the use of small winter water storage.

5 British Geological Survey, 2008, South East and London Area Aggregate Mineral Resources outside of selected environmental designations, 1:250 000 map. 6 Forestry Commission, http://www.forestry.gov.uk/southeast, accessed January 2017.

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Areas of uncertainty

As identified in the previous topic section the effect of the UK leaving the European Union on the economy is uncertain. Changes in trading partners may influence the scale and type of agriculture and horticulture, as well as other industry in the area. This may have further implications for water use.

5.3.4 Interrelationship with other topic areas and ecosystem services Strong interrelationships exist between the built assets aspect of material assets and other topics such as population, human health, water and climatic factors.

Strong interrelationships also exist between the natural assets aspect of material assets and topics such as biodiversity, flora and fauna, soil, climatic factors, landscape and water.

A wide variety of ecosystem services flow from natural assets such as woodlands and farmland. For example, woodlands provide amongst the highest identified number of ecosystem services, including regulating climate, and water flows, providing timber and other wood products, as well as a range of cultural benefits. Farmland, whilst providing important ecosystem services such production for food, fibre, feed for animals and energy, also negatively effects some ecosystem services. For example, there is an associated decline in biodiversity, as agricultural (particularly arable) production has increased.

5.4 Biodiversity, flora and fauna

5.4.1 Topic definition Biodiversity is the variety of all living things; the plants (flora) and animals (fauna) in our forests, mountains, rivers, seas, gardens and parks, right down to the things living in our soils. It supports all our lives, our livelihoods and quality of life. Biodiversity provides us with a substantial proportion of our vital ecosystem services such as pollination and food, nutrient cycling and soil formation. Biodiversity is therefore our life support system and it is important that it is valued and looked after.

Many of the designated nature conservation sites, special areas of conservation (SACs), special protection areas (SPAs) and sites of special scientific interest (SSSIs), represent the very best examples as well as some of the rarest and most threatened habitats, plants and animals. Whilst a variety of areas are covered by these designations, the qualifying interests of these sites cover only a fraction of what exists and many species are mobile and found outside protected sites. It is therefore highly important that the biodiversity value of non- designated areas, terrestrial, freshwater and marine, is understood and recognised.

5.4.2 Future baseline Habitats and species are affected by many different factors including climate, water quality and land use. The ecological status of water bodies is likely to improve in the future as measures and strategies (such as the catchment based approach) to meet Water Framework Directive (WFD) objectives are implemented. This should have a net benefit to water dependent habitats and species. However, some habitat types and species are likely to be particularly sensitive to climate change. For example, sea level rise is threatening coastal margin habitats, particularly as a result of coastal squeeze, where habitats are prevented from migrating inland as a consequence of built infrastructure, such as coastal flood defence walls.

Climate change may further facilitate the spread of invasive species where they can cope with changes to environmental conditions better than native species. New invasive species may emerge.

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5.4.3 Current baseline Statutory designated sites

A relatively high proportion of the south east of England is covered by statutorily protected nature conservation sites. The European sites within the company area and wider area of influence are listed in Table 5.2 and illustrated in Figures 5.3.1-5.3.8 and comprise SACs, SPAs, and Ramsar sites. These sites are of particular significance and require a Habitats Regulation Assessment (HRA) (see section 1.5) to be undertaken for any potential projects that could impact the interest features of these sites; this assessment is also carried out at a strategic level during preparation of the WRMP19. In addition to these sites, there are 65 sites of special scientific interest (SSSIs) and four national nature reserves (NNR) that fall within or partly within the western region of our supply area, with a further 79 SSSIs and three NNRs in the eastern region. Figures 5.4 and 5.5 show the location and extent of SSSI Impact Risk Zones (IRZs) for SSSIs (and Natura 2000 or Ramsar sites also designated as SSSIs) within the study area.

Table 5.2 International and European wildlife designations*

SACs SPAs Ramsar sites

Ashdown Forest Ashdown Forest Dungeness, Blean Complex Dungeness to Pett Level Romney Marsh and Burnham Beeches Dungeness, Romney Marsh and Rye Rye Bay Castle Hill Bay Medway Estuary Dungeness Medway Estuary and Marshes and Marshes East Hampshire Hangers Stodmarsh Pevensey Levels Ebernoe Common Thames Basin Heaths Stodmarsh Hastings Cliffs and Sandwich Bay Thanet Coast and Lewes Downs Sandwich Bay Mole Gap to Reigate Escarpment Thursley, Hankley and Frensham Thursley and Ockley Mottisfont Bats Commons (Wealden Heaths Phase I) Bog North Downs Woodlands Walden Heaths Phase II The Swale Peter’s Pit Pevensey Levels River Itchen Sandwich Bay Singleton and Cocking Tunnels Stodmarsh Thanet Coast The Mens Thursley, Ash, Pirbright and Chobham Windsor Forest and Great Park * Sites within study area including buffer zone, neighbouring areas and connected catchments

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Figure 5.4 SSSI impact risk zones – western region

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Figure 5.5 SSSI impact risk zones – eastern region

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Within our landholdings we own and manages 33 SSSIs, one NNR, and two local nature reserves (LNRs). Furthermore 34 per cent of our supply area lies within various AONBs and almost ten per cent of our supply area lies within the South Downs National Park. All company owned SSSIs have management plans in place which set out, and monitor, the conservation work to be undertaken over a ten year period. Each plan has been agreed with Natural England. Currently 98.3 per cent of SSSIs within our ownership are in favourable condition or in recovering condition. As part of our Natural Environment and Rural Communities (NERC) work we have surveyed 72 company assets to establish whether biodiversity improvements can be made on these sites.

The Swale Estuary marine conservation zone (MCZ) coincides with the coastline of the WRZ 8 (Figure 5.3.8), while Beachy Head West MCZ coincides with the coastline of WRZ 2 and 3 (Figures 5.3.2 and 5.3.3), all within our eastern supply region. The purpose of MCZs is to protect the full range of nationally important biodiversity, as well as certain rare and threatened species and habitats.

Key habitats and species

The study area includes some of the main locations for some of Europe’s rarest and most threatened habitats, for example chalk rivers and coastal habitats such as vegetated shingle. Numerous habitats and species listed under Section 41 (England) of the NERC Act (2006) (termed priority species and habitats) are present within our supply area (see Figures 5.3.1- 5.3.8). Some of those priority habitats and species most likely to be affected by changes in water quality or quantity (termed water dependent habitats and species) are listed in the Table 5.3. This list is not exhaustive and is derived primarily from the water dependent designated features of Natura 2000 and Ramsar sites within the study area.

Table 5.3 Key water-dependent priority habitats and species

Key water dependent and coastal habitats Examples of key water dependent species

e.g. EC Habitats Directive Annex I habitats, NERC Mammals (e.g. EC Habitats Directive Annex II/IV, NERC S41 Habitats Act S41, Wildlife and Countryside Act Sch. 5) Eutrophic standing water Water vole Rivers (including chalk rivers, headwaters and near Otter natural rivers) Bechstein’s bat Aquifer-fed naturally fluctuating water bodies Daubenton’s bat Wet woodland Migratory fish (e.g. IUCN Red List, NERC Act S41 and EC Coastal and floodplain grazing marsh (including annex II/V) ditches) European eel Reedbeds Brown trout/sea trout Saline lagoons Atlantic salmon Lowland heathland (including acid grassland, bogs and Lamprey species (brook, river, sea) fens) Smelt Estuaries Freshwater fish (e.g. EC Habitats Directive Annex II ) Coastal saltmarsh Bullhead Coastal vegetated shingle Marine fish (e.g. NERC Act S41) Intertidal chalk Lesser sand eel Intertidal mudflats and sandflats Aquatic invertebrates (e.g. EC Habitats Directive annex II Subtidal sandbanks that are slightly covered by /V, NERC Act S41) seawater all the time Fine-lined pea mussel

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Key water dependent and coastal habitats Examples of key water dependent species

Subtidal sands and gravels Depressed river mussel Biogenic reefs Desmoulin’s whorl snail Little whirlpool ramshorn snail Shining ram’s-horn snail White-clawed crayfish Medicinal leech Southern damselfly Terrestrial/semi-aquatic invertebrates (e.g. NERC Act S41, British Red Data Book species, Wildlife and Countryside Act Sch. 5) Fen raft spider Marsh mallow moth Ground lackey moth Amphibians (EC Habitats Directive Annex II/IV, Wildlife and Countryside Act Sch. 5) Great crested newt Birds (EC Birds Directive qualifying species) Wildfowl and waders Bewick swan Black tailed godwit Dark-bellied brent goose Bittern Curlew Lapwing Turnstone Gadwall Others (e.g. raptors, seabirds, warblers) Hen harrier Roseate tern Sandwich tern Common term Aquatic warbler Coastal and wetland plants (e.g. British Red Data Book species) Perennial glasswort Whorled water-milfoil Rootless duckweed Greater water parsnip

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Terrestrial habitats and species can also be affected by water resource development options where land take and construction works are involved. Habitats of concern within the study area would include species-rich hedgerows, ancient woodland, dry and wet heathland, neutral grassland, wetlands and chalk downland. Species of concern might range from bats to reptiles and dormice.

Fisheries

There are extensive coarse fisheries within the study area, with over 23 species represented (see Table 5.4). Rivers with notable coarse fish populations include the Stour (including the Great Stour tideway), Rother, Medway, Beult, Teise, Eden, Darent, Cuckmere, Loddon, Adur and Ouse. The Royal Military Canal, which is fed by the Rother, also supports coarse fish populations. Coarse and game still water fisheries are located within the Stour catchment and at Ardingly reservoir at the head of the Ouse.

Stretches of the Adur, Ouse, Loddon, Test and Itchen are designated as either salmonid or cyprinid fisheries. The Basingstoke Canal, which runs adjacent to the river Loddon, also supports cyprinid populations. The headwaters of the Adur, Ouse and Cuckmere are spawning grounds for sea trout and brown trout and the Rother, Bede and Medway are known migratory routes for sea trout. The upper and middle Darent, Cuckmere and Loddon support brown trout populations and the Arlington reservoir, which is fed by the Cuckmere, is a rainbow trout fishery. In addition, the rivers Test and Itchen are internationally renowned brown trout fly fisheries, and the whole of the Test has been designated a national trout water under the Environment Agency’s National Trout and Grayling Fisheries Strategy. The most important commercial fishery within the study area is the Swale Estuary in North Kent which supports plaice, bass, cod, herring, mullet, sprats and shell fisheries.

Section 41 priority species present within the study area include lamprey (rivers Ouse, Adur and Loddon) and wild brown trout (Great Stour and tributaries and Loddon). Lamprey and bullhead are also listed Annex II species under the EU Habitats and Species Directive (92/43/EEC). Eels are Section 41 priority species and eel management plans are now required to establish measures for their recovery within each river basin district.

Key issues within the study area include structures within the river (such as weirs and sluices), which prevent free movement of fish and hinder migration. Eels and salmonids are especially sensitive to migration barriers, and some coarse fish are unable to navigate fish passes.

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Table 5.4 Freshwater fish types recorded in 2015 Main rivers Fish type

Salmon Roach Bream Perch Pike Eel Carp Tench Rudd Flounder Chub Bleak Gudgeon Trout Trout/Brown Sea trout Rainbow Bream Common Dace Stickleback 3 Spined Lamprey Loach Stone Bullhead Minnow Barbel Ruffe Grayling Zander Adur (Eastern and x x x x x x x x x x x x x x Western) Ouse x x x x x x x x x x x x x x x x x x Cuckmere x x x x x x x x x x x x x x x x x x Eastern Rother x x x x x x x Great Stour x x x x x x x x x x x x x Test x x x x Itchen x x x x x x x x x x x x x Hamble x x x x x x x Meon x x x x x x x x x x Wallington x x x x x x x x x x Darent x x x x x x x x x x x x x x Loddon x x x x x x x x Medway x x X x x x x x x x x x x x x Thames x X x X x x x x x x x x x x x x x x x x x x x x Wey x X x X x x x x x x x x x Note: Data taken from the National Fish Populations Database (https://data.gov.uk/dataset/national-fish-population-database-load-statistics)

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Invasive Non-Native Species (INNS)

Managing the risk of invasive non-native species (INNS)

INNS refers to plants and animals that colonise areas outside their normal range. This can happen as a result of deliberate or accidental introduction through activities such as recreation, transfer of raw water or by introducing them into the wild. Preventing the spread of invasive species is an important consideration in construction and for water management and the Environment Agency has recently issued a position paper7 requiring water companies to reduce the risk of spreading INNS through water transfers. The risk of providing pathways for the spread of INNS through cross-catchment raw water transfer is highlighted as a key concern.

INNS are a risk which we are starting to understand and plan for. South East England is particularly vulnerable to INNS risk and spread. This is both due to its proximity to mainland Europe, and, as a result of shipping interests from Europe into Kent and the Lower Thames which act as vehicles for INNS movement. As a result of this, our own operations can also be doubly impacted – our intrinsic link with transferring raw water between catchments means we can inadvertently act as a vehicle to the spread of INNS; and our treatment processes can also be adversely influenced by the presence of INNS in the raw water we abstract.

2015 to 2020: Our work to date on INNS

We recognise our responsibility to control the spread of INNS. Our performance to date has been concentrated in four areas:

 Understanding how INNS can be moved through our raw water transfers and storage reservoirs  understanding the risk posed by operating recreational venues  understanding future INNS threats when developing new water sources and infrastructure  consideration of the ways that INNS can be spread through our operational activities.

As a result, we are ensuring that we consider and put in place action plans to minimise the risk of our work both introducing and transferring INNS.

Our current performance

We are a partner of the national Check Clean Dry Campaign and are actively involved with this group. The aim of the group is to limit INNS spread, to implement controls and prevent future INNS risk.

Through our 2015-2020 water industry national environment programme (WINEP) biodiversity program we are controlling INNS on our ten biodiversity pilot sites. This has involved trialling various controls for Himalayan balsam.

Working more generally across our landholdings, we have trained all of our grounds maintenance team to recognise and control Japanese knotweed. This approach is controlling this invasive plant on our company sites.

7 Environment Agency ‘Managing the risk of spread of Invasive Non-Native Species through raw water transfers (January 2017)

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Our engineering and infrastructure development schemes are screened prior to commencement for the presence of INNS within or adjacent to the work site. If INNS are identified, appropriate measures are put in place to ensure risks posed by INNS are effectively controlled, eradicated or managed to prevent spread during the construction phase.

Identifying risk through the transfer of raw water between catchments

The majority of our pipelines transfer either treated water, or, raw water within one catchment. As a result, our pipelines present a low risk for INNS transfer. However the exception is our raw water transfer between Darwell and Hazards Green. This pipeline moves raw water from the River Medway to the Pevensey Levels SAC, a sensitive wetland with European protection.

We regularly monitor this transfer and its connecting reservoirs for INNS. In 2014 we identified the presence of an INNS concern species, zebra mussel. This resulted in the scheme being included in our 2015 to 2020 WINEP for investigation – with INNS being the principle driver for that investigation. We completed this investigation in 2016 and concluded that there was a significant risk from the introduction of INNS into the Pevensey Levels SAC.

Our investigation confirmed that the most pragmatic way to prevent current and future transfers of INNS was to cease raw water transfers across these catchments.

Our next step was to undertake an options appraisal process via our 2015 to 2020 WINEP programme to effectively find the most cost effective solution that would `replace’ that raw water transfer. This process concluded that a treated water transfer from our water treatment works at Bewl was the best solution. Approval was given by the Environment Agency and this scheme is now included in our 2020 to 2025 WINEP. The deadline for project completion is 2025.

Key INNS issues that could impact environmental resilience

A number of INNS have been identified as high risk to water companies. High risk INNS species and the key issues that could impact environmental resilience are listed in Table 5.5.

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Table 5.5 INNS and impact on environmental resilience

INNS species Impact on environmental resilience

Quagga mussel Biofouling – blockages at water treatment works (WTW) / pipes, impacts on submerged structures and boats. Increased costs for maintenance and implementation of biosecurity protocols. Could result in source being removed from service while investigation / eradication is undertaken with associated risks to network. Alteration of ecosystems by filtering out nutrients. Potential effect on biodiversity and also potentially financial implications to fisheries Potential risk to designated sites with associated financial and reputational risk. Selective removal of green algae by invasive mussels can increase likelihood of toxic algal blooms due to reduced competition for Cyanobacteria.

Zebra mussel Biofouling – blockages at WTW / pipes, impacts on submerged structures and boats. Increased costs for maintenance and implementation of biosecurity protocols (currently costs UK economy £5m p.a.) Could result in source being removed from service while investigation / eradication is undertaken with associated risks to network. Alteration of ecosystems by filtering out nutrients. Potential effect on biodiversity and also potentially financial implications to fisheries. Potential risk to designated sites with associated financial and reputational risk. Selective removal of green algae by invasive mussels can increase likelihood of toxic algal blooms due to reduced competition for Cyanobacteria.

Killer shrimp and Direct impact to ecosystems / biodiversity due to predation of native species (Loss of Demon shrimp diversity through ecosystem impacts could affect scoring of water quality using biological metrics and have implications for the Water Framework Directive). Potential risk to designated sites with associated financial and reputational risk. Increased cost of biosecurity protocols both recreational and operationally. Potential intermediate host for fish disease which can impact fisheries.

Signal crayfish Crayfish burrowing can cause erosion of water body banks. Burrows can be up to 2m deep, with many inter-connecting tunnels that weaken the bank. This can contribute to problems with flooding, livestock safety and stability of structures built on the banks. Crayfish also take refuges from salmonid fish and predate fish eggs, which could reduce the value of commercial fisheries. Direct impact to endangered native crayfish through competition and spread of disease. Signal crayfish eat more than white-clawed crayfish and have reduced the number of invertebrates and are partly blamed for amphibian declines, so potential effects on biodiversity and ecosystems.

Round Goby Direct impact to ecosystems / biodiversity due to predation of native species (Loss of diversity through ecosystem impacts could affect scoring of water quality using biological metrics and have implications for the Water Framework Directive). Direct impact to fisheries as a result of predation and competition for resources.

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INNS species Impact on environmental resilience

Himalayan balsam If dominant can promote erosion through dieback and subsequent destruction of bankside structure. Dense stands can impede water flow at times of high rainfall, thereby increasing the likelihood of flooding. Direct loss of biodiversity due to out-shading of native species. Biosecurity implications particularly around sludge movement and spreading.

Japanese knotweed High economic impact due to legislation that makes eradication a legal requirement. Biosecurity issues focused around access and management of sites which support Japanese knotweed. Can alter habitat structure and biodiversity which can have documented impact on salmonid fisheries.

New Zealand Economic impacts where it forms dense mats in shallow water, obstructing water-borne pigmyweed transport, navigation and flood defences. Impacts to biodiversity due to shading out of native plants. Oxygen depletion can have impact on invertebrates, fish and amphibians.

Floating pennywort Impacts to biodiversity due to out-competition of native plants and disruption of animal movement. Can lead to oxygen depletion and die back will increase nutrient loading within water body. Damage to waterworks and infrastructure by blocking pipes and pumps (cost Dutch water industry 1 million Euros in 2000)

Giant hogweed May form dense stands reducing biodiversity. Danger to human health due to phytotoxic sap.

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2020 to 2025: INNS projects included in WINEP

INNS is a key area of concern due to the serious environmental or socio-economic harm they cause and so form a large part of our 2020 to 2025 WINEP programme. This programme includes measures to identify priority pathways, the risks posed by the spread of INNS and how pathways of spread can be mitigated to meet conservation objectives and to prevent deterioration in raw water quality.

Our programme includes two innovative investigations to identify potential methods of controlling INNS. Further detail of the individual elements of our INNS programme is included in Table 5.6 below.

Table 5.6 INNS programme included within our 2020 to 2025 WINEP

Delivery Scheme Scheme detail date

Investigation and We will carry out a risk assessment to identify potential INNS pathways 22/12/2022 Options Appraisal of and assess their influence in the transfer of INNS. An options appraisal INNS pathways will follow, assessing our assets which are found to be of high risk for associated with our INNS spread. operations

Biosecurity facility Here we will establish where biosecurity provision should be established 31/03/2025 provision on company sites. We will develop an INNS awareness and training course for all staff and contractors and will establish a programme to raise awareness of INNS issues with our stakeholders.

Innovation project We will trial a pilot project to control Himalayan balsam on our site at 31/03/2022 investigation for Arlington. Himalayan balsam

Innovation project We will trial a pilot project to control New Zealand pigmyweed at 31/03/2022 investigation for New Ardingly. Zealand pigmy weed

Produce a company- We will produce a company-wide plan to demonstrate how we will 31/03/2025 wide invasive non- manage INNS pathways and spread. native species plan

New treated water Construction of an extension to our water treatment works at Bewl and 31/03/2025 transfer to remove the creation of infrastructure to move treated water to our WRZ 3 area. threat of INNS to This removes the threat of INNS transfer to the Pevensey SAC area Pevensey Levels SAC from our existing raw water transfer.

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5.4.5 Interrelationships with other topic areas and ecosystem services There is a strong interrelationship between biodiversity and water management. Wetland ecosystems provide many ecosystem services, which highlight a link between biodiversity and other SEA topic areas:

 Regulating services (which for freshwater often affect provisioning services): Aquifer recharge (important, especially when water is continually extracted for irrigation), water quality (the dispersal and dilution of pollutants and purification of water) and vegetation growth (which may act as both as a purifier and hazard regulator). In addition, freshwater plays significant roles in regulating flooding, erosion, sedimentation, local climates and water quality.

 provisioning services: floodplain habitats are important for food and fibre production, with 57 per cent of grade one agricultural land in England being on the indicative floodplain. Freshwaters provide for both consumptive and non-consumptive uses of water, including wetland-related crops, plants, livestock, fish (wild and domesticated), and energy, whilst crops dependent on irrigation rely on freshwater supplies. Floodplains also play an important role in provisioning, due to their high soil fertility. There is therefore a strong interrelationship between biodiversity, soil and water, especially in relation to provisioning ecosystem services

 cultural services: rivers, lakes and wetlands have significant cultural value, especially in terms of recreation, tourism and education. Wetlands are important for a variety of informal activities such as walks and birdwatching. Furthermore, they play a key cultural role as inspiration for the arts and religion. Tourism continues to focus on water-based holidays (e.g. activities such as sailing, swimming and fishing). Housing along or on rivers and canals is in high demand, and therefore it is often priced at a premium. There is therefore a strong interrelationship with the topics of population, human health and material assets.

5.5 Water

5.5.1 Topic definition There are a variety of issues that can be dealt with in the water SEA topic but water resources and quantity, water quality, flooding and flood risk are all included.

5.5.2 Current baseline Water resources and availability

During 2016/17 we supplied around 520 million litres of water every day (Ml/d) to meet demand. However, this increased rapidly to 594 million litres a day during the hotter and drier periods. The South East of England is already one of the driest regions in the country and is classified by the Environment Agency as an area of ‘serious water stress’. Whilst droughts are most likely to occur during very hot dry weather, periods of low levels of rainfall during the winter months also have a significant effect on the region’s water resources. Groundwater and surface water sources are recharged by rainfall during the autumn and winter months, so lower than average rainfall during the winter can reduce available water in the following seasons.

73 per cent of the water supplied by South East Water comes from groundwater resources (over 250 boreholes and wells). Of the remainder,19 percent comes from surface water sources including six rivers and three surface reservoirs, and eight per cent of supplies to customers come from water transferred from sources owned and operated by other companies.

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Abstraction licensing strategies (ALS)

ALS are published by the Environment Agency, with stakeholder consultation, detailing how water resources within defined catchment areas are to be managed. ALS documents provide an assessment of water availability and outline the Environment Agency’s strategy for abstraction licensing appropriate to each water body and groundwater body within an ALS area. Resource availability categories used in the ALS documents for water bodies are defined in Table 5.7. Resource availability is calculated at four different flows: Q95 (low flows- flows exceeded 95 per cent of the time), Q70, Q50 and Q30 (high flows- flows exceeded 30 per cent of the time). The same availability category is applied to both water bodies and groundwater bodies, except where:

 Investigations have identified resource concerns about groundwater

 better information is available on principal aquifers

 there are local requirements for greater protection.

Where the above exceptions apply, the resource availability categories shown in

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Table 5.8 are used instead.

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Table 5.7 ALS definition of water resource availability Resource availability status categories

Resource Definition and implications for licensing availability status

High hydrological There is more water than required to meet the needs of the environment. However, status due to the need to maintain the near pristine nature of the water body, further consumptive abstraction is severely restricted.

Water available There is more water than required to meet the needs of the environment. New consumptive licences can be considered depending on local and downstream impacts.

Restricted water Fully Licensed (FL) scenario8 flows fall below the Environmental Flow Indicators available (EFIs)9. If all licensed water is abstracted there will not be enough water left for the needs of the environment. Water is only available for abstraction at high flows, with any licence granted featuring appropriate conditions. It may also be appropriate to investigate the possibilities for reducing fully licensed risks. Water may be available if you can acquire the entitlement to abstract water from an existing licence holder.

Water not available Recent Actual (RA)10 flows are below the EFI. This scenario highlights water bodies where flows are below the indicative flow requirement to help support “Good” ecological status (as required by the water framework directive).

Water is only available for abstraction at high flows, with any licence granted featuring appropriate conditions. Water may be available if you can acquire the amount equivalent to recently abstracted from an existing licence holder.

Heavily modified These water bodies have a modified flow. Their flows may be influenced by reservoir water bodies (and/or compensation releases or they have flows that are augmented or both. They may be discharge rich water managed through an operating agreement, often held by a water company. The bodies) availability of water is dependent on these operating agreements. There may be water available for abstraction in discharge rich catchments.

N.B. The first and last categories are not applied to groundwater bodies

8 The FL scenario is defined as the flow situation if all abstraction licences were being used to full capacity. 9 The EFI is a resource allocation for the environment, defined as a proportion of the natural flow. 10 The RA scenario is defined as the amount of water which has actually been abstracted on average over the previous six years.

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Table 5.8 ALS definition of water resource availability (groundwater specific) Resource availability Definition and implications for licensing status

Water available Groundwater unit balance shows groundwater available for licensing. New licences can be considered depending on impacts on other abstractors and on surface water.

Restricted water Groundwater unit balance shows more water is licensed than the amount available, but that available recent actual abstractions are lower than the amount available OR that there are known local impacts likely to occur on dependent wetlands, groundwater levels or cause saline intrusions but with management options in place.

In restricted groundwater units, no new consumptive licences will be granted. It may also be appropriate to investigate the possibilities for reducing fully licensed risks. Water may be available if you can ‘buy’ (known as licence trading) the entitlement to abstract water from an existing licence holder.

In other units, there may be restrictions in some areas e.g. in relation to saline intrusion.

Water not Groundwater unit balance shows more water has been abstracted based on recent amounts available than the amount available.

No further consumptive licences will be granted.

The catchments of interest and relevant ALS documents for the western region of the study area are:

 Thames catchment abstraction licensing strategy, May 2014

 Loddon catchment abstraction licensing strategy, December 2012

 Wey catchment abstraction licensing strategy, December 2012

 The Test and Itchen catchment abstraction licensing strategy, March 2013 (barely, but just within the supply region)

The catchments of interest and relevant ALS documents for the eastern region of the study area are:

• Medway abstraction licensing strategy, February 2013

• Adur and Ouse abstraction licensing strategy, March 2013

• Cuckmere and Pevensey Levels abstraction licensing strategy, March 2013

• Darent and Cray abstraction licensing strategy, January 2013

• North Kent & Swale abstraction licensing strategy, February 2013

• Stour Abstraction licensing strategy, February 2013

• Rother abstraction licensing strategy, March 2013

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Table 5.9 provides a brief summary of how water from these catchments is used and their current resource status is given for each. The relevant catchments have been grouped according to which of our WRZs they fall into. Figures 5.6 and 5.7 show the current resource status within each WRZ mapped to WFD river water body catchments and WFD groundwater bodies.

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Table 5.9 Catchment water availability Catchment Key locations and catchment characteristics Source and uses of abstracted water Resource availability status

Water availability – Western region

Thames Thames ALS area encompasses the non-tidal Abstractions from the River Thames and All sub-catchments are designated as Water Not Thames and immediate tributaries. groundwater support significant abstractions for Available. However, a bespoke licensing strategy is public water supply, and to a lesser extent applied which changes the status to Restricted Our supply area falls into sub-catchments AP2 industry and agriculture. Water Available under certain flow conditions. Eynsham Weir, AP3 Days lock and weir, and AP4 Reading gauging station.

Loddon Sourced from chalk fed springs at Basingstoke. Abstraction uses include public water supply, All sub-catchments are designated as Water Not agriculture and industry. Available due to the flow requirements of the Flows northeast to join the Thames east of Reading. Thames.

Chalk is the dominant aquifer and provides a relatively constant baseflow to rivers, with clay in the middle and lower catchments.

Wey River Wey has two main branches – Wey North rises The majority of abstracted water is used for All sub-catchments are designated as Water Not near Alton; and Wey South rises near Haslemere. public water supply. Other uses include Available due to the flow requirements of the agriculture and aquaculture. Thames. The confluence of these two branches is at Tilford. Groundwater abstraction accounts for two thirds of licensed water abstractions.

Test and Small part of the Test and Itchen catchment lies within Public water supply (17%) and non-consumptive sub-catchment is designated Water Itchen our supply area, limited to the headwaters of the uses including fish farming and watercress Available under moderate and high flows, and River rivers. cultivation (75%). Itchen sub-catchment designated Water Available under high flow and either Restricted Water Both are high-quality chalk streams, supporting a Public water supply accounts for the majority of Available or Water Not Available under mid and diversity of wildlife and fisheries. consumptive uses. flow conditions.

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Catchment Key locations and catchment characteristics Source and uses of abstracted water Resource availability status

River Test Chalk and River Itchen Chalk groundwater bodies are designated Restricted Water Available under all flow conditions.

Central Hants Bracklesham Group is designated Water Available under all flow conditions.

Water Availability – Eastern Region

Medway Main tributaries of the River Medway are the Rivers 70% of water abstracted is for public water Sub-catchments to the far north of the catchment Beult, Bourne, Teise and Eden. supply, of which 90% is abstracted from surface are designated Water Available under all flow water bodies. conditions. Watercourses support a diverse range of habitats. Remaining abstractions are for industrial and To the centre and south of the catchment, sub- agricultural (e.g. general farming and spray catchments are generally designated as No Water irrigation) use. Available except under the highest flow conditions (Q30).

North Kent No single distinctive river. Abstraction uses include public water supply Groundwater bodies to the south of the ALS area and Swale and industry. are designated Water Not Available under all flow Surface water made up of many spring-fed streams, conditions. reliant upon groundwater. 90% of licensed abstractions come from the Chalk aquifer. Central and northern sub-catchments are Affected by abstraction from the North Downs Chalk designated either Water Available or Restricted and the Lower London Tertiaries. Water Available under moderate and high flow conditions. Under low flow conditions they are Grazing marsh habitats dependant on maintained designated Water Not Available. water levels.

Stour River Stour flows into Pegwell Bay. Public water supply (51%), agriculture (25%) Sub-catchments to the west of the ALS area are and industry. largely designated either Restricted Water Available River Dour flows south east into the English Channel and Water Available under mid and high flows at Dover.

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Catchment Key locations and catchment characteristics Source and uses of abstracted water Resource availability status

Great Stour and East Stour are tributaries in the upper 65% of water abstracted from groundwater respectively and Water Not Available under low parts of the catchment, and the Little Stour joins the sources. flow conditions. Great Stour downstream of Canterbury. Sub-catchments to the east are mainly designated Upper reaches of the Little Stour flow only when the Water Not Available under low and mid flows, and water table in the chalk aquifer is sufficiently high. either Restricted Water Available or Water Available under high flows.

Rother North and west of catchment are part of the High Abstraction uses include public water supply, Under low flow conditions the majority of sub- Weald made up of sands, silts and clay ridges with industry and agriculture. catchments within the central and eastern portion of incised river valleys. the ALS area are designated Water Not Available. Sub-catchments within the southern and north- These layers are collectively known as the ‘Hastings eastern areas are designated Restricted Water Beds’ and give rise to many small springs and Available or Water Available. streams. All sub-catchments are designated Water Available South and west are host a wide expanse of reclaimed under high flow conditions, with the exception of a coastal marshland. small area in the south east.

The major river valleys of the Rother and Brede follow the lines of faults to provide water to fill Darwell and Powdermill reservoirs.

Adur and Adur and Ouse ALS encompass the catchments of Groundwater abstraction accounts for 70% of all Under low flow conditions the majority sub- Ouse these rivers, as well as the Brighton Chalk water abstraction, and is mainly used for public catchments surrounding the River Adur are groundwater block, a major aquifer. water supply. designated No Water Available, with limited areas designated Restricted Water Available or Water Large areas of these rivers flow over Weald Clay, Available. making them flashy and prone to flooding. Sub-catchments surrounding the River Adur are Main tributaries are the River Uck, Bevern Stream, mainly designated Water Available under high flow Clayhill Stream, Shell Brook and Cockhaise Brook. conditions.

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Catchment Key locations and catchment characteristics Source and uses of abstracted water Resource availability status

Sub-catchments surrounding the River Ouse are mainly designated No Water Available under low flow conditions. Under mid and high flows sub- catchments are mainly designated Restricted Water Available, with the exception of those surrounding the Ardingly reservoir (No Water Available) in the north and Barcombe Mill (Water Available) to the south.

The Brighton Chalk block groundwater water body is designated Restricted Water Available.

The Lower Greensand and Ouse and Adur and Ouse Hastings Beds groundwater bodies are designated ‘Water available for licensing’.

Cuckmere Rural landscapes in East Sussex associated with the 90% of water abstracted is for public water Under low flow conditions sub-catchments are and Pevensey Wealden Anticline, including the South Downs, chalk supply. designated No Water Available, with the exception Levels cliffs, low-lying Pevensey Levels and High Weald. of a limited number of coastal sub-catchments.

Includes River Cuckmere, and the Pevensey, Coombe Sub-catchments to the east of the ALS area are and Wallers Havens catchments. designated Water Available under high flow conditions, whilst those to the west are designated No Water Available.

The Hastings Beds Cuckmere and Pevensey Levels groundwater water body is designated Water Available.

The Seaford and Eastbourne groundwater water body is designated Restricted Water Available.

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Catchment Key locations and catchment characteristics Source and uses of abstracted water Resource availability status

Darent and River Darent rises in Westerham, flowing north Abstraction uses include public water supply, Most sub-catchments are designated No Water Cray through Eynesford and Dartford to the Thames agriculture and industry. Available under all flow conditions. Three of the Estuary. northernmost sub-catchments are designated Restricted Water Availability or Water Available Darent and Honeypot Stream originate from a series under all flow conditions. of springs, either from the Greensand of Chalk of the North Downs.

River Cray is smaller, rising near Orpington and flowing to the Thames Estuary in a similar location to the Darent.

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Figure 5.6: ALS surface and groundwater availability - eastern region

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Figure 5.7: ALS surface and groundwater availability - western region

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April 2017 Surface water

Water quality is intrinsically linked to the amount of water available. During low flows in summer months, river water quality can suffer as there is less dilution of treated water discharged to watercourses. Low flows particularly during summer months place a strain on water based habitats and species, many of which are dependent on high-quality water (see section 5.4). There needs to be a balance between consumption of water through abstraction, while maintaining minimum flow to ensure sufficient dilution to maintain quality.

The WFD and associated regulations require assessment of surface waterbodies in terms of ecological status. The ecological status shows the overall condition of the waterbody, and is made up of several factors including biological quality, chemical quality, geomorphology and water availability. The Water Framework Directive’s aim is to prevent deterioration and to achieve or have plans in place to achieve “good ecological status” for all inland and coastal waters (or “good ecological potential” if artificial or modified for specific usage) by target dates unless derogations apply due to the disproportionate cost, technical feasibility or measures are prevented by natural conditions. Under the WFD, rivers that are artificial or have been subjected to a high degree of physical or chemical modification, may be designated as ‘artificial water bodies’ (AWB) or heavily modified water bodies’ (HMWB). As such, the directive requires that any works undertaken should contribute to the river achieving ‘good ecological potential’ (GEP).

Our supply area is covered by two river basin management plans (RBMPs); the Thames RBMP (December 2015) and the South East RBMP (December 2015). The western region is mostly within the Thames RBMP, while the eastern region is split between the Thames RBMP and the South East RBMP. It will be necessary to ensure that any proposed schemes within our WRMP19 do not have a significant adverse effect on overall ecological quality or status of individual quality elements within a water body, and further, must not compromise the ability of any water bodies to achieve good ecological status in the future by preventing the delivery of measures identified within the RBMP. Table 5.10 provides a summary of the proportion of water bodies within our supply area catchments which are achieving good overall ecological status, as provided in the supporting data sections of their respective RBMPs. The water quality and resource status of WFD river water bodies and groundwater units across the study area is shown in Figures 5.2.1-5.2.8.

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April 2017 Table 5.10 RBMP surface water quality Catchment Catchment Total number Number of Number of Heavily characteristics of waterbodies at waterbodies Modified/ waterbodies good overall with target of Artificial (rivers and waterbody good overall Water Bodies lakes) status in 2015* waterbody status by 2021* (HMWB)

Darent and Partially tidal rivers, with 5 0 (0%) 1 3 rivers Cray tributaries flowing through highly urbanised area in low lying valleys with some agricultural. Fed from aquifers. Susceptible to low flows.

Loddon and Predominantly rural with 21 1 (5%) 0 3 rivers Tributaries some urban areas including the towns of 3 lakes Basingstoke, Aldershot and Wokingham.

Medway Upper reaches 58 4 (7%) 0 24 rivers predominantly agricultural with urban downstream. 8 lakes Heavily engineered flood risk and navigation features and high number of landscape designations.

Wey and Upper reaches 42 2 (5%) 0 5 rivers Tributaries predominantly rural with urban areas in towns of 7 lakes Alton, Farnham, Haslemere and Godalming. Lower reaches primarily urban with major towns: Guildford, Weybridge and Woking.

Adur and Urbanised coast of City of 46 1 (2%) 1 9 rivers Ouse Brighton and Hove, Newhaven and Shoreham 1 port areas and inland lake/reservoir towns. Includes 5 groundwater bodies.

Cuckmere Bordered on the west by 18 1 (6%) 0 9 rivers and the Sussex Downs and Pevensey chalk cliffs and High Levels Weald in north east with lower land dipping to Pevensey Levels along

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April 2017 Catchment Catchment Total number Number of Number of Heavily characteristics of waterbodies at waterbodies Modified/ waterbodies good overall with target of Artificial (rivers and waterbody good overall Water Bodies lakes) status in 2015* waterbody status by 2021* (HMWB)

the coast. Commuter towns in the north.

East An urbanised coastal plain 12 3 (25%) 0 3 rivers. Hampshire, along the Solent, and including rolling chalk downland to Meon, the north. Internationally Wallington important wildlife sites including Portsmouth and Langstone Harbours but many industrial estates.

Rother Steep river valleys and 41 9 (22%) 3 12 rivers woodland of High Weald to north and marshes to 11 lakes the south east coastal boundary. Largely rural agricultural with limited industry near Rye Harbour.

Test and Mainly groundwater fed 32 10 (31%) 2 9 rivers Itchen with major abstractions – Otterbourne public supply, 1 lake Winchester.

*Data taken from Environment Agency dataset made available under Open Government Licence (available at: https://data.gov.uk/dataset/wfd-classification-status-cycle-2)

Groundwater

Groundwater bodies are also assessed under the WFD and must achieve “good status” based on water availability and chemical quality. Table 5.11 provides a summary of the status of groundwater bodies from which we draw resource, as provided in the supporting data sections of their respective RBMPs.

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April 2017 Table 5.11 RBMP groundwater quantitative status and quality status Groundwater body Quantitative status Chemical status

Thames RBMP

North Kent Swale Chalk Poor Poor

Lower Thames Gravels Good Poor

Kent Greensand Middle Poor Poor

Kent Greensand Western Poor Good

West Kent Darent & Cray Chalk Poor Poor

Kent Weald Western – Medway Poor Poor

Basingstoke Chalk Poor Poor

Farnborough Bagshot Beds Good Good

Godalming Lower Greensand Poor Poor

South East RBMP

Seaford & Eastbourne Chalk Block Poor Poor

Adur & Ouse Lower Greensand Good Good

Cuckmere & Pevensey Levels Lower Greensand Good Good

Cuckmere & Pevensey Levels Hastings Beds Good Good

Adur & Ouse Hastings Beds Good Good

Kent Greensand Eastern Poor Poor

Kent Weald Eastern – Rother Good Poor

Coastal water bodies

Coastal water bodies around our supply area include Sussex, Sussex East, Kent South, Kent North, Thames South and Whitstable Bay. Each of these coastal water bodies are identified as heavily modified with moderate ecological status.

Flood risk

The Environment Agency has powers to maintain and modify main rivers in order to ensure the efficient passage of flood flow and to manage water levels and water companies have responsibilities to contribute to reducing flood risk.

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April 2017 Information about flood risk in the WRMP19 area has been obtained by reviewing the relevant catchment flood management plans addressing fluvial flood risk. Coastal defence policy is set by shoreline management plans (SMPs). The section of the North Kent coast which falls within our supply area is covered by the Medway Estuary and Swale SMP, and the Isle of Grain to South Foreland SMP. The south coast between Eastbourne and Newhaven falls within the South Foreland to Beachy Head and Beachy Head to Selsey Bill SMPs.

General information on fluvial and coastal flood risk has been obtained from the Environment Agency’s online flood maps.

Flood risk is a significant issue for many parts of the supply area, particularly where the natural floodplain has been developed, leaving people and property at risk.

We have undertaken flood risk vulnerability studies for their assets and identified that their sites are resilient to 1:100 (1 per cent annual probability) flood events and in many cases, are resilient to more extreme flood events.

5.5.3 Future baseline Demand for water is predicted to increase in the future in the south east of England, for a number of reasons, including population increase, new development, tourism, changes in domestic, commercial and industrial use of water and climate change.

Climate change is likely to affect rainfall totals and variability during growing months, affecting the quantity and timing of water demand for irrigation. Therefore agricultural water use is also likely to increase and become more variable.

Flooding is expected to become worse due to climate change and the combined effects of sea level rise and intensification of rainfall during storm events.

The quality of surface water bodies is expected to improve as actions are taken to meet WFD objectives through implementation of the RBMPs. South East Water has identified a trend with deteriorating groundwater quality due to nitrate levels as an issue for which action is being taken.

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April 2017 5.5.4 Interrelationships with other topic areas and ecosystem services The water topic is closely interrelated with several other topics. The following key interrelationships have been identified:

• Population and human health and wellbeing: increasing population will increase demand on water availability. Human health can be affected directly by the availability of clean water, and indirectly by wellbeing associated with aesthetic and recreational benefits of water (e.g. river/lakeside walking routes and use of reservoirs for water sports)

• climatic factors: changes in rainfall may affect water quality and availability and flood risk, and increased surface temperatures have potential to affect water demand

• biodiversity: changes in water flow levels and water quality can affect aquatic habitats and their flora and fauna

• wetlands (including peat uplands, bogs, wet woodland, fens and marshes): changes in land use and drainage can affect water storage capacity, flood peak attenuation; also water quality improvements through loss of filtration

• soil: soils contribute to flood regulation, soil erosion may contribute to declining water quality. Soil structure degradation can impact infiltration and reduce groundwater recharge, also contributing to declining water quantity.

5.6 Climate change

5.6.1 Topic definition The SEA Directive’s ‘climatic factors’ is interpreted to relate to the factors that affect climate. Of particular relevance to human influences are the emissions of greenhouse gases (primarily carbon dioxide but also including methane, nitrous oxides, hydrofluorocarbons, sulphur hexafluoride and perfluorocarbons) which contribute significantly to climate change through the greenhouse effect11. Impacts of climate change include increases in temperatures, changes in rainfall patterns, sea level rises, and increases in occurrence of extreme weather conditions.

Climate change is an example of a synergistic effect. It is caused by the build-up of many actions, each of which only has a limited contribution, but which together cause serious effects.

This scope of this topic considers both the opportunities to reduce greenhouse gas emissions and the opportunities for options to address adaptation and resilience to the effects of climate change on the environment.

5.6.2 Current baseline The south east of England currently enjoys a relatively mild and uniform climate, with no extreme variables in temperature or precipitation. The area generally receives less than average rainfall, with 600-800mm of rainfall

11 Greenhouse effect: The effect caused by the presence in the earth’s atmosphere of compounds that absorb infra-red radiation emitted from the surface of the earth following its warming by the sun. More heat from the sun is thereby trapped in the atmosphere and not reflected back out to space. This is an essentially natural process (such as methane production from animals and emissions from the geosphere) without which the Earth would be around 20 degrees centigrade cooler and largely uninhabitable. However, human activity, primarily the burning of fossil fuels to release ‘greenhouse gases’, have enhanced the greenhouse effect leading to accelerated warming.

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April 2017 per year compared to the national average of 897mm. There are variations within this however, with wetter areas such as the Weald, which receives up to 1000mm per year, and drier areas such as the North Kent Coast, which normally only receives up to 650mm per year. Rainfall is spread fairly evenly throughout the year, although inter and intra annual variability can be significant. Water consumption is generally higher than average, particularly in the eastern region, where consumption per head is nearly nine per cent higher than the national average.

Relative sea level around the UK rose at a rate of approximately 1mm per year during the 20th century, and rates of sea level rise have since increased. To the north of the study area the Medway and Swale estuaries are currently experiencing net accretion, whilst in general the shoreline is retreating between Eastbourne and Newhaven in the south.

The most likely climate change scenario is that there will be less rainfall in summer and increased rainfall in winter, together with greater variability of weather events. This could adversely impact our current levels of water available in our surface and groundwater sources.

We have undertaken detailed modelling with the Met Office and HR Wallingford, to assess and quantify the impact of climate change on future water availability for the WRMP. Our approach has followed the Environment Agency’s 2017 guidance and modelled the impact of climate change on sources up to 2080. Compared with WRMP14 over the first 25 years of the plan, the effect has been a halving of our assumption of the climate change impacts on annual average conditions (6.3 Ml/d compared with 12.7 Ml/d), but a small increase in climate change impact during summer peak period conditions (7.3 Ml/d compared with 6.8 Ml/d).

For the majority of our supply area, the medium climate change impacts are modest. The exception is WRZ 2, Haywards Heath, where the yield of Ardingly reservoir has been found to be more sensitive to climate change. Ardingly reservoir makes up a significant proportion of the total climate change impact for the company. The detailed methodology and results of the climate change assessment are included in WRMP19 Appendix 4A.

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April 2017 5.6.3 Future baseline There is a high degree of uncertainty surrounding potential impacts of climate change due to the many variables affecting the climate predictions. Key considerations are provided in our report ‘Defra Reporting on Adaptation to Climate Change’ (first round report, January 2011) which draws on the latest predictions from the UK Climate Impacts Programme (UKCIP 2009):

• The South East of England is projected to experience some of the largest increases in temperature in the UK, with mean summer temperatures projected to increase by 2.0-6.5oC by 2080

• winters will be milder with mean temperature increases of 1.6-4.7oC by 2080

• changes in seasonal rainfall are likely to be more pronounced with decreases in summer (23 per cent by 2080) counterbalanced by increases in winter (22 per cent by 2080)

• sea level rise is projected to increase by 10 cm by 2020, 22 cm by 2050, and 36 cm by 2080

• there is an increased likelihood of more extreme weather events including more extreme droughts.

It is anticipated that sea level rise and increased storminess will induce or exacerbate coastal erosion in several locations within the study area12.

Climate change has the potential to both increase demand for water and to reduce supply. The dWRMP19 needs to plan for these changes to provide sufficient resources throughout the WRMP19 period.

5.6.4 Interrelationships with other topic areas and ecosystem services Climate change heavily influences the future baseline across all other SEA topics, particularly environmental trends for biodiversity, landscape, material assets, and the water environment.

5.7 Cultural heritage

5.7.1 Introduction This section considers the potential effects of water resource management planning on cultural heritage. The cultural heritage topic encompasses tangible (e.g. buildings, structures, artefacts, archaeological remains, landscapes and elements of landscapes) and intangible (e.g. customs, practices and knowledge) assets present today as a legacy from past generations. There is a relationship between the water environment and the historic environment with many cultural heritage assets being located near springs and watercourses, as well as coastal and navigable areas. Although some sites are designated, the majority of known sites are not protected and a greater number still remain undetected. There is potential for currently undetected archaeological remains to be of national importance.

12 Environment Agency. 2010. Medway Estuary and Swale Shoreline Management Plan Environment Agency. 2006. Beachey Head to Selsey Bill Shoreline Management Plan. Environment Agency. 2006. South Foreland to Beachy Head Shoreline Management Plan.

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April 2017 Many historic assets are located in floodplains, where the high moisture levels can preserve organic remains including leather and timber. These assets are vulnerable to changes in groundwater, where changes in oxygen content can have a negative effect on the archaeology. Buried deposits are also vulnerable to saline intrusion, which can also affect the preservation of artefacts.

This topic relates to the ‘cultural’ ecosystem services of cultural heritage and existence value.

5.7.2 Current baseline Our supply area coincides with areas of great historic and cultural significance. Archaeological remains are plentiful, particularly across the upland areas, whose well-drained, chalk soils have attracted settlement since Palaeolithic times. The coastal areas, being located near to continental Europe, have provided the scene for many invasions, including Roman and Norman. Our supply area also coincides with historic route ways, including the route of pilgrimage between Winchester and Canterbury Cathedrals (the Pilgrims Way, Figures 5.1.1, 5.1.2, 5.1.4 - 5.1.8).

World heritage sites (WHS) are considered to be of international importance although this is not a statutory designation. Canterbury WHS (Figure 5.1.8) was designated by UNESCO in 1988 and incorporates early Christian sites including Christchurch Cathedral and Precinct, St Augustine's Abbey and St Martin's Church. The WHS has an essential setting and buffer zone around Canterbury which are defined in the WHS management plan. The WHS is also situated within an area of archaeological importance (AAI) which has a high archaeological potential for undiscovered Roman and Anglo-Saxon remains.

Chatham Historic Dockyard (Figure 5.1.6), which has twice been nominated as WHS, is an example of a complete industrial military complex encompassing features from the era of sailing ships to the early period of the age of steam (1700 to 1865).

Canterbury WHS and Chatham Historic Dockyard encompass numerous other heritage designations which have statutory protection in their own right including numbers of conservation areas, scheduled monuments, listed buildings and registered historic parks and gardens.

Scheduled monuments (SMs) are statutorily designated archaeological remains which are considered to be of national importance. The number of SMs within the study area exceeds 500, and are therefore too numerous to list individually, and are indicated in Figures 5.1.1 to 5.1.8. However, any SMs located close to individual water resource options, the setting of which could be indirectly affected, will be included during the environmental appraisal process for individual options.

There are two registered battlefields in the supply region. Battle, in East Sussex is the location of the Battle of Hastings in 1066. The battlefield site is within WRZ3 (Figure 5.1.3.). The site of the Battle of Lewes (1264), also in East Sussex, straddles the southern boundary of WRZ2. Registered battlefields are afforded protection in the planning system via the National Planning Policy Framework.

Other sites of national and local heritage importance include registered historic parks and gardens, listed buildings and conservation areas. There are over 20,000 listed buildings and 119 registered parks and gardens within our supply area (Figures 5.1.1-5.1.8). Additional information on historic landscapes will be collected as options are assessed.

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April 2017 5.7.3 Future baseline Each year Historic England publishes a register which provides statistics on heritage most at risk of being lost as a result of neglect, decay or inappropriate development. The data are published in the form of a national report as well as regional reports which can be viewed or downloaded from Heritage England’s website. Based on recent trends, the type of heritage asset most at risk are barrows, which are particularly vulnerable to animal and ploughing damage. This trend is likely to continue. Furthermore, finding economic solutions to address the requirements to repair and maintain Grade I and II* listed buildings, and structural scheduled monuments, are becoming increasingly difficult, meaning there is a likelihood that the number of such buildings falling into disrepair is likely to increase over time.

The national heritage protection plan identifies future development pressures, social pressures, the impact of resource exploitation and professional infrastructure as threats to the historic environment. Climate change will also have an influence on cultural heritage, through changes in flood risk and flooding patterns, the water table and sea level rise.

5.7.4 Interrelationships with other topic areas and ecosystem services Key interrelationships between cultural heritage and other topic areas are as follows:

• Water: changes to the water table or below ground hydrological regime could affect the preservation of buried archaeological remains. This issue could be affected by water management options, and therefore could be considered in terms of risk for each option

• climatic factors: increased rainfall and sea level rise may increase the risk of fluvial or coastal flooding, leading to the damage or loss of cultural heritage assets. This issue could be affected by water management options. Some water management assets may in themselves be heritage assets that may need to be protected, whilst there is also potential for water management options to contribute to the level of risk assets already face

5.8 Soils and geology

5.8.1 Topic definition Soil, geology and water resources are closely linked topics. Porous or permeable geological strata, such as chalk, can be important aquifers (sources of groundwater). Impermeable strata, such as clay, can cause aquifers to be confined and so an understanding of the underlying geology is important in ascertaining the likely groundwater resources available.

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April 2017 Soil is closely linked to geology since the underlying rock of an area provides the parent material from which soil is formed. Soil is a fundamental natural resource which provides many essential services on which we rely including food production, water management and support for valuable biodiversity and ecosystems. As a large store of carbon it also plays an important role in terms of climate change. Soils in England face three main threats:

• Soil erosion by wind and rain: erosion affects both the productivity of soils but also water quality and aquatic ecosystems

• compaction of soil (e.g. from heavy vehicles tracking over it) reduces agricultural productivity and water infiltration, and increases flood risk through higher levels of run off

• organic matter decline: the loss of soil organic matter reduces soil quality, affecting the supply of nutrients and making it more difficult for plants to grow, and increases emissions to the atmosphere.

The contamination of soil is also an important issue. Pollutants enter the soil from many sources and can adversely affect human health if they enter into the food chain or drinking water sources. Remediating soils which contain pollutants is difficult and expensive and so it is important to prevent soil pollution wherever possible.

The type and quality of soil is an important factor in the classification and grading of agricultural land (other factors include topography, climate and frequency of flooding).

5.8.2 Current baseline The western region comprises predominantly chalk in the west, extending eastwards in a narrow band and with a smaller area in the very north, while Lower Greensand can be found in the south. The remainder of the area is mainly clay, which is an impermeable rock and an aquitard.

The eastern region cuts a north-south swathe across the Wealdon anticline, producing a complex geological regime. Moving from north to south in the eastern region, the North Kent Coast is formed from a combination of London Clay, which forms the Isle of Grain, Isle of Sheppey and parts of the coast between Whitstable and Margate, and a band of the Thanet Beds. Next is a band of chalk which runs broadly parallel to the north Kent coast. South of this are smaller bands of Gault clay / Upper Greensand, Lower Greensand and Weald Clay, before the Hastings Beds are reached, approximately in the centre of the region. The Hastings Beds comprise the Tunbridge Wells Sands and the Ashdown Beds.

South of the Hastings Beds are bands of Weald Clay, Lower Greensand and Upper Greensand / Gault Clay. Chalk can again be found in the south of the region, running broadly parallel to the Sussex coastline, thus mirroring the geology to the north.

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April 2017 Within the eastern and western regions there are a number of SSSIs designated for geological importance (rather than biodiversity conservation), and as regionally important geological sites (RIGS). RIGS do not receive any statutory protection, but will be protected from adverse effects by local planning policies. Although specific details of these sites have not been discussed in detail in this baseline, they will be taken into consideration as part of the appraisal of individual options for the WRMP19.

Outside of urban areas the majority of land within the study area is classified under the agricultural land classification (ALC) as grade 3 or 4, although there are three notable areas of grade 1 and 2 land; a large stretch in north Kent between Sittingbourne and Canterbury, a smaller stretch between Maidstone and Ashford, and the areas around Romney and Walland Marshes. Grades 1, 2 and 3a are recognised as being the best and most versatile types of agricultural land.

Large areas in Hampshire and Sussex are predominantly rural and agricultural, interspersed with small towns and villages. The Hampshire area of the western region has the best quality agricultural land, mainly ALC grade 3, but with significant areas of grade 2 between Basingstoke and Alton. The Surrey and Berkshire counties are mainly non-agricultural or lower quality (grade 4 or 5) agricultural land.

The distribution of ALC grades across the study area is shown in Figures 5.8 and 5.9.

Figure 5.8 ALC grades – western region

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Figure 5.9 ALC grades – eastern region

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April 2017 5.8.3 Future baseline Climate change may affect soils for example through increased vulnerability to erosion during drought conditions. Sea level rise linked to climate change may result in loss of some agricultural land or lead to saline intrusion.

Changes to the intensity or form of agriculture may result in reduction in soil fertility and increased vulnerability to soil erosion, whilst there may also be increased pressure on land resources due to population growth and infrastructure development.

5.8.4 Interrelationships with other topic areas Key interrelationships between soils and other topic areas are as follows:

• Population and human health: increasing populations may lead to increased development and coverage by impermeable surfacing, reducing the availability of soil resources and affecting the role of soils in flood regulation

• climatic factors: increased rainfall and changing weather patterns may increase soil erosion

5.9 Ecosystem services Ecosystem services are the benefits that people obtain from ecosystems. This definition was formalised by the United Nations’ 2004 Millennium Ecosystem Assessment13. Ecosystem services are considered in four main groups, each of which contains a variety of services:

• Provisioning services

• regulating services

• cultural services

• supporting services.

Table 5.12 sets out the main links identified between the ecosystem services and the SEA topics and has been developed from the Environment Agency’s 2016 guidelines on Environmental Valuation in Water Resources Planning – Additional Information.

The use of ecosystems services assessment is under development as an additional tool for taking account of the value of both natural and cultural environment and is being supported by recent guidance documents from Natural England, Defra and the Environmental Agency for water companies. The use of natural capital accounting and ecosystems services assessment is also specifically supported in WISER (2017).

Although valuation approaches sit outside the SEA requirements they can be considered a useful approach for examining interrelated effects at an ecosystem level.

13 The Millennium Ecosystem Assessment (MA) was called for by the United Nations Secretary-General Kofi Annan in 2000. The objective of the MA was to assess the consequences of ecosystem change for human wellbeing and the scientific basis for action needed to enhance the conservation and sustainable use of those systems and their contribution to human wellbeing. The MA involved the work of more than 1,360 experts worldwide.

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April 2017 Table 5.12 Links between SEA topics and ecosystem services

Biodiversity, Biodiversity, fauna and flora & Population health human Soil Water factors Climatic Cultural heritage Landscape assets Material Fresh water

Food (e.g. crops, fruit)

Fibre & fuel (e.g. timber & wool)

Genetic resources

Biochemical, natural medicines

Ornamental resources (e.g. shells)

Water for non- consumptive use

Climate regulation

Water regulation (e.g. flooding)

Provisioning services Provisioning

Groups and Examples and Groups Natural hazard

– regulation

Pest regulation

Disease regulation

Erosion regulation

Ecosystem Services Services Ecosystem Water purification & waste treatment

Pollination

Noise & light regulation

Cultural heritage

Recreation & tourism

Aesthetic value

Intellectual & scientific,

Cultural services Cultural education value

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Biodiversity, Biodiversity, fauna and flora & Population health human Soil Water factors Climatic Cultural heritage Landscape assets Material Inspiration of art, folklore, etc

Social relations

Spiritual & religious value

Existence value

Soil formation

Primary production

Nutrient cycling

Water recycling

Photosynthesis

Supporting services Supporting Provision of habitat

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April 2017 6. SEA scope and methodology

Chapter 3 has identified the key environmental protection objectives identified through the policy, plans and programmes (PPP) review (Appendix B), whilst chapter 5 has set out initial baseline information and identified issues for consideration in the strategic environmental assessment (SEA) based on the baseline understanding.

This information has been used to inform the scope of assessment for the SEA as proposed in the scoping report which was consulted on in May 2017. The scoping process has sought to identify which effects are likely to be significant and should be considered further, and which effects are likely to be relatively minor considerations in the context of the scale and scope of the likely influence of the water resource management plan (WRMP19) and can therefore be scoped out of the SEA.

6.1 Scope of likely significant effects Table 6.1 considers the potential issues for the SEA identified through the baseline review and whether or not they are likely to lead to likely significant effects. Where an effect has been judged likely to be significant, it is included in the scope of assessment. An effect is judged to be significant if it is felt that it could affect the environment in a way notable enough to be a key decision-making factor on whether the option or WRMP19 should be implemented. The magnitude and scale of the impact and effect, duration (short or long term), temporary / permanent and sensitivity and value of the receptor will all be considered in assessing the potential or risk of significant effects. The basis for the assessment and level of uncertainty is also recorded.

Where an effect is likely to be mitigated through standard construction management or operational procedures to protect the environment or community, it is not considered likely to be significant since it is considered normal practice to mitigate the effect (i.e. it would be done whether or not environmental assessment is carried out). Effects which are likely to be highly localised or temporary in nature are not likely to be significant unless a particularly valuable environmental resource is involved.

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April 2017 Table 6.1 Scope of likely significant effects

Rationale for assessment of individual Scoped in or Environmental Potential effects options and portfolios of options for out assessment approach different plan scenarios

Population and human health

Potential In Some options may give rise to impacts (i.e. as Assess qualitatively disruption or a result of noise, traffic, visual intrusion etc) through SEA objectives nuisance to which cause disruption to communities. The (informed by communities SEA aims to identify affected groups, including quantification i.e. number from if there are differential effects between socio- of people affected). implementation economic groups. or operation of options

Effects on quality Out The purpose of WRMP is to meet supply and N/A of water required demand. The portfolios of options within

for human health different scenarios will be determined to meet the water supply demand to accepted quality

standards. As part of the feasible options selection options all options are expected to be contribute to the provision of water supply meeting the required standards and therefore it is not considered necessary to assess this through the SEA.

Effects on In Portfolios of options will be selected to meet Assess qualitatively security of predicted water supply demand however through SEA objectives in

supply different scenarios will be tested and there may terms of additional differences between scenarios in the level of benefits where any resilience and security of supply above the improved security of minimum target level. supply is provided.

Effects on In Some options may affect leisure opportunities Assess qualitatively recreation and (positively or negatively) which has a link to through SEA objectives. leisure human health.

Material assets

Impacts on built In Some options may affect assets used by the Assess qualitatively and natural community, with associated costs (or benefits) through SEA objectives. assets to society.

Minimise waste In Some options may generate more waste than Assess qualitatively generation others, or there may be opportunities to identify through SEA objectives measures to reduce waste through the SEA. (quantify estimated volumes of waste if sufficient information allows).

Biodiversity, flora and fauna

Effects on In Likely effects on designated and valued Assess qualitatively habitats and habitats can be identified through the SEA. through SEA objectives species Options which affect valuable habitats are likely Quantify effects where to have a greater effect on biodiversity and possible. Habitats ecosystem services. Marine and coastal Regulation Assessment

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April 2017 Rationale for assessment of individual Scoped in or Environmental Potential effects options and portfolios of options for out assessment approach different plan scenarios protected areas are included in the (HRA) will inform the SEA assessment. in terms of risks of significant effects on Natura 2000 and Ramsar sites.

Species mobility In Habitat connectivity will be assessed through Assess qualitatively effects on habitats above, which will be a proxy through SEA objectives. for species mobility. Aquatic species mobility could be affected by water resource use/infrastructure. Beneficial effects for some options could also contribute.

Direct species In The assessment will consider the potential Assess qualitatively conflicts effects or risks for populations of protected and through SEA objectives. priority species including water dependent species (although this will not cover detailed individual species assessments that would be appropriate for project level assessment).

Invasive species In Certain options will present a higher risk of Assess qualitatively spreading invasive species. through SEA objectives

Wildlife and Out Coverage in the SEA will not meaningfully N/A water pollution inform decisions on options or the plan as whole or mitigation since there is legislation in place to prevent water pollution. It will be assumed that relevant environmental protection legislation will be adhered to and standard pollution control measures put in place.

Landscape

Changes to In Options may affect the character of a Assess through SEA landscape or landscape or townscape. This could include objectives. townscape cumulative effects from a number of new character elements in a given area.

Visual amenity In While there is unlikely to be sufficient Assess though SEA information about key views or design to objectives. assess this meaningfully at SEA level and such effects are better addressed at project-level through site specific surveys, micro-siting and good design. General risk to visual amenity related to proximity and potential for mitigation can be considered.

Air

Construction air Out Inclusion in the SEA will not meaningfully N/A emissions inform decisions on options or mitigation since effects would be localised and temporary. Standard measures to control dust are used on

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April 2017 Rationale for assessment of individual Scoped in or Environmental Potential effects options and portfolios of options for out assessment approach different plan scenarios construction projects. The consideration of proximity of people under ‘Population and human health’ will in part address air emissions (alongside other factors).

Operational air Out The scale and nature of most water N/A emissions management options are such that this is not likely to be a key issue (compared with other

types of plan such as transport and local development plans). Therefore, this is not a key issue for the plan assessment and is scoped out.

Climatic factors

Climate change In Carbon emissions and also potential savings SEA to be informed by mitigation will be calculated for each option and combined quantitatively/ monetise option portfolios. Carbon footprint for (link to environmental construction and operation and carbon costing valuation) and use to will be included as inputs to the decision- inform comparison of making to select options and overall portfolio overall option portfolios carbon footprint and costs can be generated (double counting of input through the decision making tool for to decisions on comparison. options/portfolios to be avoided).

Climate change - In Environmental climate change resilience is a Assess qualitatively environmental consideration in terms of sensitivity of through SEA objective. resilience receptors under a number of other SEA (Will need to guard (including categories (biodiversity, water and material against double-counting facilitating assets). It is included in the SEA to provide an with other SEA objectives adaptation for analysis of where there are opportunities to and supply resilience wildlife and address effects of climate change and enhance criteria). habitat) environmental resilience.

Water

Risk of water Out (Reasons as set out above under Wildlife and N/A although will be pollution water pollution’). important at a project level and for HRA.

Water resource In Options could constrain or improve WFD water Assess qualitatively sustainability body status and contribute to or conflict with through SEA objective. and quality RBMP objectives with associated costs or This will be informed (surface and benefits to ecosystems. through a WFD groundwater) assessment. Risk to water body status through deterioration or not achieving objectives, deterioration of flow compliance or groundwater quantitative status will all be considered.

Flood risk In There is unlikely to be sufficient detail at SEA Assess qualitatively level to provide a meaningful assessment of through SEA objective. flood risk, which requires information about the

likely footprint of works, levels and existing

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April 2017 Rationale for assessment of individual Scoped in or Environmental Potential effects options and portfolios of options for out assessment approach different plan scenarios flows. However, impacts on floodplain can be considered, with the potential to relocate options away from floodplains, design for flood risk or compensate for floodplain loss.

Cultural heritage

Designated or In Some options may affect known heritage Assess qualitatively non-designated assets or be located close enough to highlight through SEA objective. cultural heritage a likely risk to the asset or its setting or access. assets Potential opportunities for cultural heritage

Buried In Although most archaeological remains will be Assess qualitatively archaeology unknown it will be feasible to consider the risk through SEA objective. of disturbance to archaeology. Changes to hydrology/ groundwater and drainage in terms of effects on habitats e.g. wetlands will be considered under biodiversity and where risks are identified for changes to wetlands potential for buried archaeological risk will be also be considered.

Geology and Soil

Loss or In It will be feasible to assess this taking into Assess qualitatively degradation of account current land use and soil types likely to through SEA objective soils be affected by options. This may allow Assess through value measures to be identified that could reduce transfer where possible; overall loss of this resource (and related

ecosystem services) through option development.

Soil Out It is unlikely that there will be sufficient detail to N/A Although potential for contamination make a meaningful assessment. Whilst it will contamination will be be possible to identify brownfield locations and taken forward to project areas of higher risk, there are a range of level assessment measures that can be explored on a case-by- case basis to fully mitigate these risks, which are better addressed at project level.

Geological Out - There is unlikely to be sufficient information SEA qualitative features generally about key views or design to assess this at assessment SEA level. Such effects are better addressed at In - for project-level through site specific surveys, designated micro-siting and good design. Potential effects geological on geological SSSIs will be covered by the sites assessment.

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April 2017 6.3 Proposed SEA objectives The assessment approach has been to evaluate the WRMP19 against a set of SEA objectives and criteria linking to the baseline to then determine the potential for significant environmental effects. Section 5.A.12 of ‘A Practical Guide to the Strategic Environmental Assessment Directive’14 explains that while SEA objectives are not specifically required by the SEA Directive, they are a ‘recognised way of considering the environmental effects of a plan or programme and comparing the effects of alternatives’.

The SEA objectives are intended to reflect changes that contribute to sustainability. A suite of SEA objectives has been developed informed by:

• The key policy messages identified in chapter 3, demonstrating how WMRP options will support or conflict with the objectives of other plans

• current and future environmental conditions in South East Water’s supply area and key considerations identified by the baseline review in chapter 5

• the scoping of relevant issues under each SEA environmental topic, which is documented above.

The issues scoped in have been linked with each objective to provide a structure for assessing performance of an option in terms of potential significant effects on the baseline environment. These will help to ensure the assessments are comprehensive, and consistent. They are intended to assist the assessments in ensuring it is focused on the significant effects on receptors considered against each objective. The proposed SEA objectives are set out in Table 6.2.

14 14 ODPM (2005). A Practical Guide to the Strategic Environmental Assessment Directive. Produced jointly by Office of the Deputy Prime Minister, the Scottish Executive, Welsh Assembly Government and the Department for the Environment, Northern Ireland. Available at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/7657/practicalguidesea.pdf

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Table 6.2 Draft SEA objectives and proposed criteria April 2017 Draft SEA Objective SEA Topics linked l Criteria to Consider for: Possible Evidence

1)individual feasible options; 2) comparison of portfolios of options; and 3) cumulative effects with other plans and proposed WRMP19

Protect public health and Population & human Will the portfolio of options considered The decision-making tool will generate portfolios of promote wellbeing health for the WRMP19 meet the projected options to meet the supply demand deficit for a range of demand in all areas and how will supply scenarios – these criteria will be built into the modelling resilience be provided? but it is relevant for the baseline in terms of considering a do minimum scenario and the additional resilience Will the option require construction of some portfolios may provide (linked to meeting plan new infrastructure in areas of dense resilience objectives and benefits for drought planning). population or affecting transport routes (more likely to give rise to disruption and Use of GIS overlay mapping to show geographical nuisance)? location of options to settlements and potential for traffic disruption. Will the portfolio of options considered for the WRMP19 have disproportionate Indices of multiple deprivation to identify key areas of effects on vulnerable groups? deprivation.

Will the portfolio of options considered Comparative cost implications for customers and for the WRMP19 ensure that customers safeguards to avoid inequalities of access. are not disproportionality affected by cost? Use of public health profiles to identify health issues that may be related to socio-economic factors or access Will the option provide a beneficial to recreation. recreational asset or improve access to recreation or quality of recreational Environmental and social costing approaches for amenity? quantifying disturbance impacts and recreation access benefits for populations can inform the SEA.

Protect, and where appropriate Material assets, Will the option require demolition or Use of GIS overlay mapping to show geographical enhance, built and natural climatic factors removal of a built or natural asset that is location of options to existing infrastructure or natural assets and reduce waste of value to society?

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Draft SEA Objective SEA Topics linked l Criteria to Consider for: April 2017 Possible Evidence

1)individual feasible options; 2) comparison of portfolios of options; and 3) cumulative effects with other plans and proposed WRMP19

Will the option address a potential threat assets such as best and most versatile land or (for example from flood risk) to the woodland. condition of a built or natural asset?

Waste monitoring data (if available); review of options and assumptions for Identify high level assumptions for quantities of waste construction requirements. generated related to construction and operation to indicate for example any change to water treatment Will the portfolios/WRMP19 contribute to sludge required for disposal. an overall reduction of amount of waste generated compared with the baseline?

Will groundwater level resource/surface water flow changes affect other users and assets?

Protect and enhance Biodiversity, flora Will the option/portfolios/WRMP19 affect Use of GIS overlay mapping to identify where options biodiversity and contribute to and fauna statutory designated sites, non- coincide or have proximity spatially with designated resilient ecosystems designated sites or priority habitats? sites or woodland (with cross-checks against aerial photography). Will the option/portfolios/WRMP19 affect water-dependent sites/ecosystem (for Use of GIS to identify water bodies/wetlands in example through changes to water level, proximity to options and potential pathways. flow, watercourse morphology or water quality)? Use of GIS to identify options that may provide links between river catchments or regions (including potential Will the option increase the risk of pathways for the spread of invasive species) spreading invasive species? Monitoring data on condition of SSSIs, fisheries or habitats (if available); aerial photography (to identify green corridors surrounding options where relevant)

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Draft SEA Objective SEA Topics linked l Criteria to Consider for: April 2017 Possible Evidence

1)individual feasible options; 2) comparison of portfolios of options; and 3) cumulative effects with other plans and proposed WRMP19

Will the option/portfolios/WRMP19 improve a habitat, habitat connectivity, or biodiversity resilience?

Protect landscapes, Landscape, cultural Will the option be located within a Use of GIS to identify designations (e.g. National Park, townscapes and visual amenity heritage, material designated landscape or townscape? AONB, Heritage Coast, Conservation Areas) and assets proximity with options. Will the option introduce built infrastructure into an undeveloped/rural Use of aerial photography to identify land use and area, or require removal of landscape landscape features in proximity to options. features (trees, hedgerows, walls) (likely to affect character)? Identify proximity of receptors such as settlements and national /regional sites to options to identify potential Will the portfolios of options/WRMP19 visual amenity risk. result in combined effects which could be detrimental to landscape character or visual amenity or contribute to improvements?

Reduce greenhouse gas Climatic factors Will the WRMP19 contribute to an overall Our greenhouse gas reporting data (if available); review emissions reduction of greenhouse gas emissions of options and assumptions on construction compared with the baseline? requirements and use of carbon calculator embedded in Unit Cost Database.

Contribute to environmental Climatic factors, Will the option provide solutions in the Identification of assets most susceptible to storm, flood, climate change resilience human health, event of extreme weather events (such coastal erosion or drought damage - linked to supply material assets, as drought, flooding or sea level rise)? resilience objective for the plan and the drought plan. water

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Draft SEA Objective SEA Topics linked l Criteria to Consider for: April 2017 Possible Evidence

1)individual feasible options; 2) comparison of portfolios of options; and 3) cumulative effects with other plans and proposed WRMP19

Will the option/portfolio of options contribute to improving environmental adaptation?

Protect and improve surface Water, climatic Will the option/portfolio of options Environment Agency monitoring data (where available), water and groundwater status factors, biodiversity address identified issues of low flow, our water quality monitoring and catchment poor water quality or watercourse management study findings. Current abstraction modifications? (Recent Actual) data and future abstraction (Fully Licenced) data. Flow compliance data form the Will the option risk deterioration of WFD Environment Agency. And groundwater status and risk status or conflict with river basin data. Environment Agency sustainable abstraction risk management plan (RBMP) objectives for data under sustainable catchments programme and our the water body, Does the portfolio of assessment response. options/preferred WRMP19 contribute to RBMP objectives? Hydrological and hydrogeological assessment considering flow changes and connectivity will inform Will the option/plan affect aquifer levels the WFD assessments and potential for impacts on and resource availability and any habitats. associated activities or uses? Will the option/plan affect river flow or proposed measures for meeting RBMP objectives for the relevant waterbody?

Avoid flood risk Water, human health, Will the option affect flood plains or Areas of flood plain on GIS datasets. climatic factors impact flow in rivers changing flood risk? Information on flow changes to rivers from abstractions/ How do combinations of options affect discharges where available e.g. for water reuse river flood risk and overall losses to flood plain discharges. within catchments?

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Draft SEA Objective SEA Topics linked l Criteria to Consider for: April 2017 Possible Evidence

1)individual feasible options; 2) comparison of portfolios of options; and 3) cumulative effects with other plans and proposed WRMP19

Protect and where appropriate, Cultural heritage, Will the option be located close to Use of GIS to identify designations (e.g. scheduled enhance cultural heritage material assets, designated heritage assets? (Risk of monuments, conservation areas, clusters of listed assets landscape direct effects, or effects on settings). Are buildings, registered battlefields, registered parks and there opportunities for improving access gardens). or providing interpretation? Use of mapping and aerial imagery to identify area of Will the option disturb areas of greater land where archaeological risk may be greater such as archaeological potential? (i.e. areas greenfield locations, valley bottoms, marshland (broad where the risk of archaeological remains assumptions only can be made in relation to potential is judged to be higher, based on broad risk). assumptions)?

Will the option/ portfolios /WRMP19 contribute to the restoration of a feature that could be of heritage value?

Protect quality and function of Soils, biodiversity, Will the option affect agricultural land? Use of GIS to show areas of best and most versatile soils landscape, water agricultural land (agricultural land classification (ALC) Will the option affect previously grades 1, 2 and 3a if available). undeveloped land (likely to disturb/damage soils or introduce Use of mapping and aerial imagery to identify land use pollution)? and option information on construction areas and operational footprints. Will the option affect previously developed land (potential to remediate contaminated land)?

Overall loss or risk to soils from portfolios/WRMP19

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April 2017 6.4 Compatibility of SEA objectives Schedule 1 of the SEA Regulations requires that the inter-relationship between SEA issues should be explored.

Table 6.3 presents the compatibility assessment between the proposed SEA objectives. (Green = objectives are compatible; yellow = potential conflict between objectives; red = objectives are incompatible).

None of the proposed objectives have been identified as incompatible with each other. However, there is potential incompatibility between the objective to reduce greenhouse gases (objective 5) and the objectives to protect built and natural assets and to contribute to climate change resilience (objectives 2 and 6). This is because new infrastructure or a heightened maintenance regime may be required to meet objectives 2 and 6 which would be likely to involve embedded carbon or generate further greenhouse gas emissions through energy use and operation of plant.

Table 6.3 Compatibility of SEA objective

Protect public health public Protect waste reduce and assets natural and built Protect biodiversity enhance and Protect landscapes Protect emissions gas greenhouse Reduce resilience change to climate Contribute status groundwater and water surface Protect risk flood Minimise heritage cultural Protect soils Protect

1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 1. Protect public health

2. Protect built and natural assets & minimise waste 3. Protect and enhance biodiversity

4. Protect landscapes

5. Reduce greenhouse gas emissions

6. Contribute to climate change resilience 7. Protect surface water and groundwater status 8. Minimise flood risk

9. Protect cultural heritage

10. Protect soils

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April 2017 6.5 Method of assessment

6.5.1 Overall approach The SEA assesses the draft WRMP19 through:

 Option assessment: Where each feasible option will be assessed against the SEA objectives

 portfolio assessment: Where alternative combinations of options will be assessed to allow comparison of environmental performance between alternative portfolios and contribute to the decision-making on the preferred combination of options for inclusion in the dWRMP19

 comparison of the portfolios generated for different plan scenarios as part of sensitivity testing.

The assessment looks at each option in detail and identifies the likely significant effect against the SEA objectives (using each issue scoped in). The assessment recorded using assessment matrices. For each SEA objective, the pathway to a potential effect is recorded (for example, land take required for construction) and the key receptors are identified, including an indication of the value or sensitivity of the key receptors. The assessment includes consideration of enabling works; these are identified as zonal strategies involving network improvements or new connections to accommodate new schemes in the supply network.

The potential impacts against the SEA objectives are then summarised. Where it is known that standard procedures are already in place to manage the impacts, or there is legislation in place to protect the receptor against the identified potential impacts, this is also recorded. Table 6.4 lists such measures considered to be standard mitigation. The assessment takes these procedures or legislative protection into account, since they would be implemented regardless of the SEA process. The evidence that has informed the assessment, along with the level of certainty, is also be reported.

Table 6.4 Standard mitigation measures

Mitigation

Studies and surveys

Feasibility and scheme option studies including detailed pipeline routing, siting and technology options to avoid effects on designated sites and priority habitats.

Studies, surveys and consultation on environmental effects of proposed development following relevant good practice guidance to inform design, identify relevant mitigation and to support appropriate planning permission and licencing processes.

Investigation, monitoring and modelling studies for groundwater and surface water abstractions to be agreed with regulators where relevant in context of schemes meeting WFD no deterioration requirements and RBMP objectives.

Short term impacts only

Local residents provided with due notice of construction works.

Ensure safe access along public rights of way (PRoW) for pedestrians, cyclists and equestrians, providing diversions where necessary.

Implementation of traffic management measures to minimise disruption to minor roads, including, where possible, limitation of works within peak periods or times.

Use of construction techniques that avoid or minimise disruption to major infrastructure (rail and strategic road networks) and river crossings such as directional drilling (where appropriate).

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April 2017 Mitigation

Any disruption to the road and rail network to be agreed in advance through Highways England, Network Rail and any other relevant transport authorities.

No works to take place within curtilage of registered park and gardens, scheduled monuments or listed buildings without necessary consents in place. Directional drilling where needed.

No works to take place within or in close proximity to a SSSI without necessary Assent in place and impacts to be avoided through detailed routing and trenchless construction approaches where appropriate.

European Protected Species Mitigation Licence (EPSML) to be obtained for all works which may affect a European protected species.

Conservation Licence to be obtained for all works which may affect species listed under the Wildlife and Countryside Act (1981).

A suitably qualified and experienced Ecological Clerk of Works (ECoW) to carry out site supervision works during activities that affect sensitive habitats and species, ensure that site specific mitigation identified following surveys is undertaken and that any previously unidentified impacts

Appropriate ordinary watercourse consents and environmental permits to be obtained for construction activiites in or near water.

Consent for noisy works to be obtained under Section 61 of the Control of Pollution Act 1974.

Best practice measures to control noise, air and water pollution in accordance with the following publications:  Relevant Pollution Prevention Guidance (PPG) and Guidance for Pollution Prevention (GPP) documents and additional guidance provided at www.gov.uk/guidance  Guidance on the assessment of dust from demolition and construction (IAQM, 2014)  Relevant CIRIA guidance, including Environmental Good Practice on Site (C741) and Environmental Handbook for Building and Civil Engineering Projects (C512,C528 and C529).  BS 3882:2015 Specification for topsoil, BS 8601:2013 Specification for subsoil and requirements for use and the Construction code of practice for the sustainable use of soils on construction sites (Defra, 2009).  BS 5837: 2012 Trees in relation to design, demolition and construction – Recommendations

Medium to long term impacts

Full reinstatement of all PRoW and recreational areas.

Full reinstatement of all habitat types, including hedgerows, and provision of compensation habitat where appropriate.

All river abstraction points to be fitted with fish screens.

Full reinstatement of landscape features, and good management practice for the long term restoration of landscape features.

Full restoration of agricultural land and previously undeveloped land.

Appropriate abstraction licence to be obtained for new, increased or traded licences.

New built infrastructure to incorporate the appropriate flood defence measures

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April 2017 Recommendations for mitigation to help avoid or reduce the potential impacts or to contribute to achieving objectives are identified as part of the assessment. An assessment of significance is recorded with mitigation in place to address how the effects will change following implementation of the mitigation recommendations and provide an assessment of residual effects.

An environmental resilience risk category for each option is applied to highlight those options which perform better or worse overall against the combination of SEA objectives specifically related to environmental resilience such as biodiversity and water framework directive objectives. This has been used to help inform the assessment of option portfolios (see below) but avoiding double counting with the environmental and social costings which are also taken into account in the portfolio generation. In addition, an overall SEA risk category is identified taking all SEA objectives into account.

6.5.2 Identifying the value of receptors The SEA uses the information from the refined baseline review to identify the importance and/or sensitivity rating of the key receptors likely to be affected based on the (Table 6.5):

• Importance of sites/features: is it an area or feature of international, national, regional or local importance? Does it offer high, medium or low value ecosystem services?

• sensitivity to change: How sensitive is the receptor (including any identified ecosystem service) to the potential effect being considered? Is it ‘healthy’ or ‘at risk’? This will affect how the receptor responds to an effect and how quickly it can recover.

Table 6.5 Identifying the importance / sensitivity of the baseline Relative Definition for importance (negative Definition for sensitivity importance or effect focus) (negative effect focus) sensitivity

Negligible Not important or of no material Not Applicable. importance to the SEA.

Low Has some value to nature or society, but Is very resilient, and even with some if required, can accept notable losses / negative effects, is likely to perform well. negative effects.

Medium Is important to nature or society, but if Has ‘fair’ resilience, and change to required, can accept some losses / performance is likely to be proportionate to negative effects in exchange for benefits the effect and recovery is expected. or equivalent compensation.

High Is highly important to nature or society, Has low resilience and is sensitive to and losses / negative effects should be change and full recovery is unlikely and any avoided wherever possible and negative effect should be avoided wherever compensatory provisions are likely to be possible. required.

Critical No losses / negative effects should be Highly sensitive to change. No effect on its accepted, and if so, they must be fully health / performance should be accepted. compensated, often in advance of their loss or the negative effect occurring.

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April 2017 6.5.4 Assessing significance of effects The assessment of the effects that are expected to occur from the implementation of individual options are based on technical judgement and knowledge of similar schemes. The significance of the effect will be determined based on the sensitivity of the receptor and the scale of the change (Table 6.5 and Table 6.6). Using this method, a sensitive receptor (for example ancient woodland) may only require a small change to be considered as a significant effect. Alternatively, a less sensitive environment may tolerate a larger change and may therefore be judged as a minor or no effect. The effects can be beneficial or adverse as indicated in Table 6.6 . The effects are assessed both before and after the identification of mitigation. The magnitude of the predicted effect takes into account the likelihood of the effect occurring, the severity of the effect and the spatial extent (i.e. how large an area, or size of population).

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April 2017 Table 6.6 Scale of effects Baseline Major loss or Moderate loss Minor loss or No discernible Minor Moderate Major creation / value/ change to or change to change to loss or change to enhancement to enhancement to enhancement to sensitivity receptor receptor receptor receptor receptor receptor receptor

High XXX XX X 0   

Moderate XX XX X 0   

Low X X X 0   

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April 2017 6.5.5 Integration of ecosystems approach and environmental and social valuation As identified in section 1.2.5, an approach that considers ecosystem services has been included to inform the assessment of individual options and option portfolios alongside the SEA. This forms part of the environmental and social costing process providing a valuation of a wide range of impacts.

Ecosystems and the services they provide have been considered as part of the SEA baseline and assessment approach. The understanding of ecosystem services has been incorporated to identify the important habitats across the WRZs and then consider which ecosystem services within those habitats are at risk of degradation as a result of options or the plan as whole.

The aim was to quantify and monetise the effect on identified ecosystem services in line with the approaches highlighted in the recent valuation guidance as discussed in section 1.2.5. However, in recognition of limitations with data and tools available, a framework approach has been applied starting from the more established environmental and social costing methodology but with the intention of providing building blocks for further development towards ecosystems assessment and natural capital accounting. The approach includes valuation of both supply resource options and demand management options including valuation of water savings. This provided a more complete and balanced approach than that undertaken for WRMP14. These values were fed into the option costings used in the WRMP supply demand modelling to generate portfolios of options under different scenarios. The methodology and the option costings are reported in the dWRMP19 appendices. This valuation sits alongside the SEA but has only been used directly to inform the SEA for carbon emissions where carbon costs provide a useful way to consider total combined carbon footprint for different portfolios. For the WRMP19 the ecosystem service approach for portfolio analysis was limited to a high level qualitative analysis for the preferred plan against the least cost plan. This was undertaken as part of exploring the potential for new valuation approaches and to help to identify how this could be developed further in the future.

6.5.6 Assessment of options and portfolios The SEA options assessment provides an assessment against each SEA objective and an overall environmental risk category based on the significance of residual effects taking account of the mitigation recommended for each option. This objective based and overall environmental resilience risk assessment fed into an overall MCA analysis informing the decision-making. This provided a flexible approach to generating potential option portfolios for comparison. For example:

 Environmental and social costing inputs to the economic modelling element of the decision- making following WRMP guidelines e.g. to consider the lowest overall environmental and social cost portfolio, and lowest overall carbon cost portfolio

 SEA qualitative assessment using environmental resilience risk categories to avoid double counting with environmental and social costings and as a basis for excluding the highest risk options from the modelled.

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April 2017 This approach was used to add to the range of portfolios (combinations of options) generated to meet the deficit under different plan scenarios and to allow comparison in developing the best overall plan. The option portfolios covered:

 Do minimum – this represents a continuation of the baseline for comparison with the other portfolios. It looks at what will happen to the baseline and deficit in the absence of implementing new option investment but continuing with current schemes

 least cost no constraints portfolios – no constraints are placed in the model, so this gives the least cost (lowest bills) options for reducing the deficit – however, it does not fully reflect optimisation against risks for deliverability or supply resilience or environmental impacts

 generation of alternative WRMP19 portfolios – a range of portfolios were generated to examine different environmental, risk and uncertainty issues these included portfolios taking account of SEA options assessment findings, sustainability reduction scenarios, leakage reduction levels and resilience levels along with further testing to see the effect of excluding specific options

 sensitivity and scenario testing - other detailed portfolios and scenario sensitivity testing to be considered includes for example climate change or demand scenarios, high supply resilience.

The resulting combinations of plan options or programmes were then compared against the SEA objectives informed by the individual options assessments and cumulative effects assessment described in 6.4.6 below.

6.5.7 Cumulative effects The SEA Directive requires SEA to include consideration of secondary or indirect effects, cumulative effects and synergistic effects in the assessment of a proposed plan. The ODPM Practical Guide15 describes these as follows:

 Secondary or indirect effects are effects that are not a direct result of the plan, but occur away from the original effect or as a result of a complex pathway. Examples of secondary effects are a development that changes a water table and thus affects the ecology of a nearby wetland; and construction of one project that facilitates or attracts other developments

 cumulative effects arise, for instance, where several developments (such as multiple options) each have insignificant effects but together have a significant effect; or where several individual effects of the plan (e.g. noise, dust and visual) have a combined effect (in combination effects)

 synergistic effects interact to produce a total effect greater than the sum of the individual effects. Synergistic effects often happen as habitats, resources or human communities get close to capacity. For instance, a wildlife habitat can become progressively fragmented with limited effects on a particular species until the last fragmentation makes the areas too small to support the species.

15 ODPM (2005). A Practical Guide to the Strategic Environmental Assessment Directive. Produced jointly by Office of the Deputy Prime Minister, the Scottish Executive, Welsh Assembly Government and the Department for the Environment, Northern Ireland. Available at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/7657/practicalguidesea.pdf

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April 2017 The guidance notes that the term cumulative effects is often taken to include secondary and synergistic effects. The guidance on SEA identifies that assessment of cumulative effects should be part of the SEA and plan preparation and not a separate process.

Natural England identified shortcomings in consideration of the cumulative or in combination environmental effects on a regional basis, within the 2014 WRMPs produced in the south-east region due partly to the water companies developing and publishing their plans in parallel. To address this the water resources south east group (WRSE) (Affinity Water, Portsmouth Water, South East Water, Southern Water, SES Water (formerly Sutton and East Surrey Water) and Thames Water) commissioned a report entitled “Environmental Information to Inform Water Company SEAs” (2016)16. It was intended that this document would represent a technical guidance document for water companies and provide an assessment based on the options selected for WRMP14.

The cumulative effects assessment within this SEA is aligned with the approach recommended within WRSE document (2016) and updates to ensure a consistent and robust approach which will enable consideration of effects on a regional basis and a starting point through reference to the assessment undertaken based on the water companies WRMP14 options.

The principles to be applied in the cumulative effects assessment include:

 Assessment against the SEA objectives and significance criteria and the overall plan objectives

 focus on identifying the total effect of both direct and indirect effects on receptors such as natural resources (e.g. air, water, soil, landscape), sections of the population (e.g. people living in particular areas or vulnerable members of the community) or ecosystems and species (e.g. heathland)

 consideration of the nature and extent of the receptors, such as ecosystems and communities

 adoption of a systematic approach in defining cumulative effects and impact relationships

 consideration of potential cumulative effects of the plan and other plans and actions that are likely to affect important or valued environmental resources

 mitigation measures: identification of mitigation measures for cumulative adverse effects and suggest enhancement measures for valued resources. Assess the significance of residual impacts after mitigation and incorporation of these in the overall SEA mitigation proposed

 monitoring and management: monitoring of significant cumulative effects will be included as part of the overall SEA monitoring proposals for impacts of the plan.

The SEA includes cumulative effects assessment for ‘within plan’ effects and also for the proposed WRMP19 in-combination with other plans and programmes as described below.

16 WRSE: Environmental Information to Inform Water Company SEAs (RicardoAEA Ltd) 2016

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April 2017 Within plan cumulative effects

These are considered in terms of:

 Option level: identification of mutually exclusive or dependent options

 alternative option portfolios: cumulative effects assessment.

The options selected for the preferred plan are assessed in terms of their cumulative impacts to determine which may cause adverse effects if deployed or constructed together within the plan period.

WRMP19 with other plans/programmes cumulative effects

To meet the requirements of the SEA Directive, the cumulative effects of the proposed WRMP19 with other relevant plans or programmes are also be assessed.

Cumulative effects with non-water resources related plans and programmes will have, to some extent, been considered in the review of other plans and programmes through consideration of their implications for the WRMP19. However, any potential for wider cumulative effects between the WRMP19 and other plans or projects are assessed, particularly in the context of spatial and temporal proximity. Cumulative, or in-combination, assessments are undertaken with the following plans or programmes:

 RBMPs

 regional strategies (e.g. biodiversity, energy, air, waste)

 Environment Agency regional water resources action plans

 abstraction licensing strategies (ALS)

 catchment flood management plans

 local land use plans, sectoral plans (e.g. waste plans) and development plans

 relevant management plans (e.g. for areas of outstanding natural beauty (AONBs), National Parks and water dependent Natura 2000 sites)

 major projects including nationally significant infrastructure projects (in public domain)

 other water company draft WRMPs (where available)

 our drought plan

 other water company drought plans.

This is considered as part of the assessment of cumulative effects for the preferred plan which includes the identification of mitigation requirements to feed into the overall assessment, mitigation and monitoring requirements.

The qualitative and quantitative analysis undertaken for ecosystems services assessment/ environmental and social valuation for the portfolio comparison is also used as a basis for considering cumulative effects to inform the SEA as an alternative analysis.

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April 2017 6.5.8 Water Framework Directive assessment approach Our Water Framework Directive (WFD) assessment follows the method recommended in regulatory guidelines. The approach and assessment is provided in Appendix F. This considered the potential adverse and beneficial effects associated with the feasible options and the preferred plan for both operational and construction stages. The WFD assessment takes into consideration the requirements of the WFD river basin management plans (RBMPs) for the Thames and South East river basin districts.

The WFD assessment followed three key steps:

1. Coarse and fine screening options appraisal process to eliminate unsuitable options based on risk to WFD objectives including taking into account Water Industry National Environmental Programme (WINEP) sustainability reduction risk information.

2. WFD risk screening of feasible options feeding into modelling scenarios.

3. WFD assessment of the preferred plan and potential for cumulative effects with other company options.

The feasible options were considered individually and in combination (for the preferred plan) in relation to the overarching objectives of the WFD as well as those set out in the relevant RBMPs. The assessment takes into consideration the potential risks of adverse effects upon surface water, groundwater, transitional and coastal water bodies. Options that would not result in direct effects upon WFD objectives such as reducing leakage or water efficiency improvements were not included in this assessment. However, their indirect benefit overall is acknowledged in relation to reducing the pressure on existing water resources across the region.

Our assessment has taken into consideration the sensitivity of each water body which may be affected by the proposed options. This has been determined by the baseline condition of water bodies reported by the Environment Agency for cycle two of river basin planning on their catchment data explorer (http://environment.data.gov.uk/catchment-planning/).

6.5.9 Habitat Regulations Assessment approach All Natura 2000 sites (SPAs, SACs, including candidate and potential sites) and Ramsar sites will be the subject of a separate strategic Habitat Regulations Assessment (HRA), in accordance with the HRA Regulations (2017 as amended). This is carried out in parallel with the SEA and has fed into the SEA on Natura 2000 site issues. The HRA findings are reported in a standalone report for consultation. This is a draft HRA report based on the preferred plan in the WRMP19. The HRA will be revised and developed as the WRMP19 is finalised. A summary of the draft HRA report is provided as an appendix to SEA Environmental Report (see Appendix A).

The HRA includes a screening stage undertaken through a number of iterations with a first screening assessment used to highlight possible conflicts to influence the options list and option definition and to inform the SEA. A final screening has been undertaken on the WRMP19 including alone, in combination (including cumulative) effects in accordance with guidance on HRA. The results of the HRA inform the SEA including the SEA cumulative effects assessment. Natural England will be consulted on the HRA findings through the WRMP19 and SEA consultation stages.

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April 2017 6.6 Uncertainty and limitations Key areas of uncertainty and limitations to the assessment undertaken include:

 Data limitations completeness and updating of datasets across used for mapping and analysis to include further cross checking against aerial or satellite imagery

 level of information on options limited in many cases as locations were indicative or very preliminary therefore precautionary risk based approach has been taken for the assessment but recognising in some cases where there is scope for improved siting or routing. In some cases uncertainty related to the technology or level of treatment as part of the option definition

 uncertainty over the options being included in other company dWRMPs due to these being developed in parallel with our dWRMP19

These are proposed to be addressed through:

 Continual updating of GIS database layers throughout the SEA process going forward and updating of dossiers and assessments as required

 additional studies to be undertaken on potential schemes including detailed baseline data collection outlined in the environmental action plan section 9

 additional siting and routing studies and option design development as outlined in the environmental action plan section 9

 undertaking a final cumulative effects assessment for the final adopted WRMP19 and reporting as part of the SEA statement published with the final WRMP19

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April 2017 7. Environmental assessment of options and portfolios

7.1 Option alternatives The water resource management plan (WRMP19) includes a combination of demand management and supply measures. Table 7.1 considers the main option groups and types of measures that are included in these option groups and considered through the WRMP19 options screening and appraisal process.

Table 7.1 Categorisation of water resource options Main option Option type Further breakdown of option types and description group Demand Leakage reduction Assessment and repair of pipelines to reduce leakage from management existing network

Pressure Pressure reduction programmes management

Metering Installation of water meters

Recycling and re-use Recycling and reuse of “grey water”

Water efficiency Methods of reducing water wastage

Drought Drought permit Use of permits or orders during drought conditions to provide measures additional sources of water or increase above existing abstraction Drought order licenses

Groundwater Aquifer storage Storing of water in groundwater aquifers for extraction during recovery increased demand periods

Groundwater ‘Closing the gap’ - Increasing abstraction within licence by enhancement addressing an existing constraint.

New groundwater ‘Beyond the licence’ - extend an existing licence to allow for further abstraction (new licence required)

New groundwater source (new licence required)

Groundwater New catchment management measures to prevent outages and catchment reduction in deployable output management

Licensing License trading Underused licences or licences no longer required by licencee – potentially available

Water treatment Water treatment works Improving the water treatment works capacity to remove works expansion constraint on abstraction within licence

Water treatment works Improving the water treatment works efficiency to reduce water process losses losses

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April 2017 Main option Option type Further breakdown of option types and description group Water transfer Inter-company / Transfers of water from/to outside the company on an inter- regional transfers company or regional scale

Company transfers Transfers of water within our company area

National transfers National bulk transfers

International import International importing of water

Water reuse Water reuse Reverse osmosis (treatment technology)

Conventional (treatment technology)

Conjunctive use Conjunctive use Combining surface water abstraction and groundwater abstraction to allow periods for aquifer recovery and avoid surface water abstraction in low flow periods.

Desalination Desalination Estuarine - taking estuary water

Coastal - taking coastal water Brackish abstraction – boreholes near the coast or estuaries

Reservoirs Reservoirs Bunded - man made banks all round

Bankside - partially bunded with natural topography

Impoundment - dam and natural topography

Existing reservoir - reservoir extension or raising

Surface water New surface water New locations for surface water abstractions

Surface water Increasing abstraction within licence limits by removal of enhancement constraints

Surface water New catchment management measures to prevent outages and catchment reduction in deployable output management

7.2 Option development and appraisal

7.2.1 Identification and screening of options The first step in developing options for the WRMP19 was the identification of an extensive “unconstrained” list of options that could potentially increase the supply of water or reduce water demand. The options identified for WRMP14 provided a starting point for this unconstrained list, but other options have been identified through a variety of means including stakeholder consultation and options identified through our WINEP on potential catchment management.

Two stages of screening the options (‘coarse screening’ and ‘fine screening’) have been undertaken in order to identify ‘feasible’ options to take forward for further consideration as part of the dWRMP19 development. Figure 7.1 illustrates this process.

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Unconstrained Options Starting list of possible options and List identification of options based on options review and stakeholder input

Identifying environmental and social, Coarse Screening resilience, promotability and deliverability ‘show stoppers’

Options to be taken forward for the fine Constrained Options List screening process – further option definition and data collection

Multi-Criteria Analysis – assessment considering a range of technical, Fine Screening environmental (against SEA objectives) economic and deliverability issues with further removal of unacceptable options

Feasible Options List Options used as basis for modelling/decision making selection including costing and MCA informed by SEA qualitative assessment and environmental valuation

Figure 7.1 WRMP19 screening process

Coarse screening

The coarse screening process took the ‘unconstrained’ list of options and sought to identify options for which there were easily identifiable likely “showstoppers” against the following four broad categories of criteria:

• Resilience (for example options that are vulnerable to drought and so unlikely to address the supply-demand problem would be rejected)

• deliverability (for example options that carry significant risk in terms of the reliability of the technology required, or dependency on third parties would be rejected)

• promotability (for example options that are likely to attract public or planning resistance)

• environmental and social acceptability (for example, options for which there are readily identifiable environmental constraints or unacceptable environmental impacts based around the SEA objectives with focus on environmental resilience).

Cost considerations were not applied at the coarse screening stage. Evaluation worksheets for the unconstrained options were completed, setting out the evidence used during the coarse screening and recording any reasons for rejecting the option. Where an option was considered feasible, or there was insufficient information available to answer the evaluation criteria at the coarse screening stage, the option was taken forward to the fine screening stage to be considered in more detail and identifying further information required to inform the appraisal of that option.

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April 2017 For the environmental and social acceptability criteria, the aim was to screen-out options which are likely to have unacceptable, un-mitigatable environmental impacts for which there is no scope to avoid by reducing size or making detailed adjustments. The approach recognised the uncertainty over many of the options in terms of siting, design and technology. Locations for options were indicative in some cases, leaving scope for some potential issues to be addressed through more detailed siting and design. The options were considered in relation to the following environmental constraints:

• Nature conservation: ecologically designated areas of international and national importance (special protection areas (SPAs), special areas of conservation (SACs), Ramsar sites, sites of special scientific interest (SSSIs) and national nature reserves (NNRs)

• ancient woodland

• water sources likely to be subject to sustainability reductions in the future based on confirmed high risk

• Water Framework Directive (WFD) water body status where a high risk of deterioration or meeting objectives from an option could be identified with option risks cross checked against the sustainable abstractions review submitted to the Environment Agency in March 2017

• agricultural land classification (ALC) Grade 1 and 2, where there is a high potential for loss of the best and most versatile land (combined with other environmental issues)

• areas of outstanding natural beauty (AONBs) and national parks where visual impacts and/or recreational land loss are expected to be unacceptable

• statutory heritage designations such as world heritage sites (WHS) and scheduled monuments (SMs)

• land uses such as historic landfill sites

• settlements, or strategic infrastructure conflicts

• registered historic parks and gardens, registered battlefields and heritage coast.

The environmental designations and information were mapped as GIS layers using our database against option locations and used to inform the screening process together with the option description. In addition, the mapping for options was cross-checked where appropriate with aerial photographs / satellite imagery to confirm if there were any other specific land-use conflicts that could inform the coarse screening stage.

This included for example, checks for discrepancies between mapped data, such as areas of woodland, and new development locations visible from aerial photographs.

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April 2017 Table 7.2 Coarse screening results Option type No. options No. options Comment removed removed for principally for deliverability / environmental / promotability / or social reasons resilience Environmental reasons were principally due to concern over sustainability of abstraction in terms of avoiding environmental deterioration, for example Groundwater 20 8 options where existing abstractions were subject to restoring sustainable abstraction studies were removed or where new abstractions were proposed from chalk aquifers.

Licence trading Non deliverability due to lack of response from - 22 licence holder main reason for removal of option.

Water treatment Water treatment works option removed where this works 1 5 relied on increased abstraction of source which was considered unsustainable.

Water reuse Water reuse options were rejected where impact on rivers were identified as likely to be unacceptable or 14 5 infrastructure such as long pipelines were required in sensitive areas for small yield.

Desalination Desalination requiring infrastructure and pipeline 2 - through historic and built up urban area.

Surface water None removed at coarse screening but issues were - - abstraction flagged for further consideration at fine screening.

Surface water Surface water reservoirs were rejected where a reservoir combination of environmental issues likely to be unacceptable and difficult to avoid or mitigate were 11 - identified such as loss of a number of designated cultural heritage assets or ancient woodland or location within protected landscape areas.

Conjunctive use Options removed as considered unsustainable in 6 1 terms of water abstraction or required significant construction within South Downs National Park.

Water transfers No transfer options were excluded on environmental grounds at this stage as initial option routing was - - undertaken to minimise environmental impacts. Regional transfers from the WRSE process were added into the options list.

Catchment No overriding environmental acceptability issues management, identified at coarse screening and options were demand considered generally beneficial through water quality - - management: water improvement or water savings. efficiency and leakage management

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April 2017 From a total of 510 options, 54 options were removed from the resource options during coarse screening partly or wholly on environmental grounds. A further 40 were removed for other reasons such as deliverability. Table 7.3 provides an overview of coarse screening results by option type. In total 416 options were taken forward to fine screening.

Fine screening

The fine screening stage of the options appraisal process involved further data collection for the options in the constrained list and further analysis of options against a range of issues or criteria, with the aim to reduce the list further to identify a shorter feasible list of options for more detailed studies.

The assessment for fine screening included three steps:

1. SEA objectives-led approach for a qualitative assessment of the constrained options list. This was undertaken as part of a multi-criteria analysis (MCA) with options assessed against the same set of over-arching principles as used for coarse screening (cost, resilience, feasibility / flexibility, promotability, environmentally / social acceptability) but using quantitative and qualitative assessment. This provided simple high, moderate, and minor scores, both positive and negative, for each objective for the MCA.

2. This assessment identified options likely to be detrimental to environmental resilience. During fine screening, the following options were removed:

– Options considered to have high, difficult to mitigate impacts on designated sites

– options that relied on sources already in WINEP for investigation based on current levels of abstraction

– options likely to cause deterioration for a planned increase in abstraction (this encompassed where lack of available water was reported or the option was considered unsustainable in water abstraction terms).

Screening decisions were recorded within a performance matrix along with a narrative for the basis of the decision.

An environmental resilience risk category was also identified from the fine screening assessment for the remaining feasible options. This focused on strategic environmental assessment (SEA) objectives related to the WISER objectives for enhancing the environment and improving resilience, and avoided double counting with the environmental and social costings within the feasible options costing. The risk category allowed recognition that for many options there would be considerable uncertainty over the impact and potential for mitigation, and therefore meant some options were not screened out but instead identified as high risk.

The feasible option list was reviewed by the Environment Agency, Natural England and the EFG during August / September 2017. Feedback received helped us further refine the feasible options list to ensure that only realistic options were taken forward. Reasons for exclusion from the list included insufficient yield, rejection by the EFG, environmental sensitivities and conflicts with other options.

The SEA influenced the fine screening by identifying additional options to be removed from the feasible options list, as an input to the MCA to inform option selection during the modelling and directly by identifying the higher risk options for the modelling.

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April 2017 Table 7.3 Fine screening results No removed No removed for principally for Deliverability / Option type Comment environmental / promotability / or social reasons resilience Environmental reasons for removal were principally due to concern over sustainability of abstraction this followed more detailed consideration including information on WINEP 1 Groundwater 39 16 classification. A number of options were identified as linked to other options and options were consolidated so option numbers also reduced for this reason.

Licence trading Non-deliverability due to lack of response from licence holder was the main reason for removal of 1 2 options. One option was removed from the feasible list as it was considered to be unsustainable.

Water treatment Water treatment works options removed where works water savings were unlikely or limited or water 2 18 quality discharge was considered likely to be unacceptable and there was limited scope to treat discharge.

Water reuse Water reuse options were rejected where flow 2 8 capacity within receiving river was considered limiting.

Desalination Desalination option was removed where offshore desalination and infrastructure required was considered higher risk to coastal designated sites than a land based option. Desalination options 1 - were based on concept rather than specific site locations leaving potential for siting and design and technological solutions open for further investigation.

Surface water Surface water reservoirs were removed where reservoirs they were considered mutually exclusive to other options on the list and considered to be 6 - comparatively higher impact options however they are kept as reserve and alternative options for additional study along-side any linked option taken forward.

Surface water Option removed for water availability concerns. abstractions 1 1 Separate Drought Permit options were also grouped.

Conjunctive use Options removed on deliverability due to lack of 2 - groundwater or surface water availability (linked to environmental grounds).

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April 2017 No removed No removed for principally for Deliverability / Option type Comment environmental / promotability / or social reasons resilience Water transfers Transfer options removed on environmental grounds where pipeline routing unavoidably crossed SSSI and SPA and impacts were considered difficult to mitigate and alternatives 5 34 options were available. Transfers were removed on other grounds mainly where these were found not to be deliverable due to lack of water surplus available for regional transfers or duplication with other options.

Groundwater Although these options are considered catchment environmentally beneficial they were considered management unlikely to provide additional water resource.as - 2 actions were already in place to address water quality issues. However, these are key environmental resilience projects and are included in our 2020 to 2025 Business Plan.

Demand Removal of No environmental acceptability issues identified at management: water options fine screening. efficiency and - considered leakage unlikely to provide management water savings

A total of 55 options were removed during fine screening partly or wholly due to environmental issues identified during a high level options assessment against SEA objectives. The options assessment for assigned a high (red), medium (amber) or low (green) environmental risk category to each option. The assessment was also incorporated into the MCA of options to influence the portfolio and scenario testing through the supply demand modelling. Overall the options list was reduced from 416 to 175 feasible options (Table 7.4).

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SEA Environmental Report Table 7.4 Summary of screening and input to modelling April 2017 No. of feasible options for modelling No of unconstrained Screened out for Constrained Screened out for Option type Total Red Amber Green options environmental reasons Options environmental reasons

Groundwater 97 70 Abstraction and aquifer 4 - 2 2 storage 20 39

Catchment management 4 3 2 - - 2

Licensing 26 - 5 1 1 0 1

Water Treatment 28 1 27 2 6 - 3 3

Water reuse 39 14 19 2 11 6 5

Desalination 19 2 16 1 15 7 8

Surface water 18 - 18 2 4 4

Surface water storage 10 28 11 17 6 2 7 1 reservoirs

Conjunctive use 13 6 6 2 4 - 4

Water transfers

Company and Inter- company 87 82 32 3 21 8 (Zonal strategies) - 5

(51) (51) (51)

Demand management - 27 - 27 - 16 - - 17 Water efficiency

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SEA Environmental Report No. of feasible options for modelling No of unconstrained Screened out for Constrained Screened out for Option type April 2017 Total Red Amber Green options environmental reasons Options environmental reasons

Metering 6 - 6 - 2 - - -

Leakage 53 - 53 - 10 - - 8

Drought measures 10 10 3 7 7

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April 2017 Option assessment

Following the fine screening process, 175 feasible options were then taken forward for inclusion in the WRMP19 decision making process (Table 7.4). The individual feasible options were assessed further in terms of potential impacts on the environment based on preliminary design information for the options, environmental baseline data and potential for mitigation. This is captured in the option dossiers and constraints maps (the dossiers and maps are not included in the WRMP but are available for viewing on request at our head office). Environmental issues were taken into account in three ways at this stage:

1. Providing input to option refinement and high-level design of the options in the feasible options list and understanding the scope for design or route development

2. Assessment against the SEA objectives to determine likely significant effects if implemented as an individual scheme and identify any potential requirements for mitigation

3. Input into costings, which were reviewed to ensure sufficient provision was made for environmental mitigation requirements. Also input into lead in times to ensure sufficient time was allowed for adequate design development for mitigation as well as for approval and licensing processes.

This step-by-step process facilitated identification of environmental constraints and opportunities, identification of mitigation requirements and opportunities for environmental enhancement, and integration of these into the scheme costings and initial scheme designs. Mitigation and enhancement considerations included:

• Prevention – changing the option design, location or operation to avoid significant effects

• reduction – reducing risks to the environment and minimising the level of effects

• opportunities for enhancement – identifying the potential to improve environmental conditions.

In some cases, potential variants to options have been identified which could be investigated further at later design stages, but generally the ‘worst case’ has been considered for assessment and potential for mitigation has been taken into account.

Each option assessment is recorded in an assessment sheet which identifies the relevant assessment criteria and the significance of effects. The effects have been identified both without and with (residual effects) mitigation, as occurring in the short or long term, and as being temporary or permanent. Uncertainties in the assessment are highlighted. The assessment results were brought together in a summary matrix which allows results to be compared and cumulative impacts considered (see Appendix E).

7.3 Assessment of portfolios The WRMP process involves identifying combinations of options that can together meet water supply demand over the planning period. Part of this involves predicting the both the baseline supply and forecasting demand to provide a realistic basis for determining the additional resources required through modelling. This is described in detail in the

WRMP19.

The SEA considers environmental change (i.e. the potential for effects) in relation to an environmental baseline situation. This baseline includes how the environment is likely to evolve over the WRMP19

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April 2017 period without the WRMP19 in place, including the various pressures and trends that might influence this. This is known as the ‘do minimum’ scenario (i.e. business as usual).

The baseline water supply-demand balance represents the continuation of the current water supply situation without any additional investment in water supply, demand management or leakage reduction. It combines the predicted population and household growth for the WRZs with changes to the rates of household and non-household water consumption (i.e. the average volume per day). Environmental aspects potentially affecting the forecast water supply are also taken into account (such as climate change and the sustainability reductions and water quality discussed below).

One of our key objectives is to develop an environmentally resilient WRMP and to develop a sustainable water supply for both current and future customers. In relation to environmental resilience, consideration has been given as to how the WRMP can influence the sustainability of the ecosystems within the supply area. Resilient ecosystems are those that are more able to adapt to, absorb and recover from disturbance events by resisting damage and recovering quickly; and are able to adapt to long-term changes.

In relation to our operations, the damage to ecosystems can result from for example:

• Point-source and diffuse pollution

• over-exploitation of natural resources including unsustainable abstraction

• human-influenced and natural climate change

• altered land management practices

• decline in biodiversity

• the cumulative impacts with other water companies’ WRMPs.

The selection of options to form the WRMP19 has been undertaken through a number of steps to understand the level of supply required including assessing how resilient our current abstractions are by analysing:

• Vulnerability of water supply to climate change

• sustainability of our current abstractions in terms of impacts on existing water dependent habitats and species

• vulnerability of water to the effects of pollution, land use change and a decline in biodiversity.

7.3.1 Climate change The most likely climate change scenario is that there will be less rainfall in summer and increased rainfall in winter, together with greater variability of weather events. This could adversely impact on current levels of available water in our surface and groundwater sources and affect ecosystems dependent on these water sources.

Through detailed modelling carried out with the Met Office and HR Wallingford we have assessed and quantified the impact of climate change on future water availability within the supply area. This allowed identification of the different sensitivities of each water resource zone to climate change to be taken into account in both the identification of effects on water demand, and the scenarios considered in the modelling (described further in section 4.9.1 and Appendix 4A of the WRMP19).

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April 2017 7.3.2 Sustainability of current abstractions South East Water operates their abstractions within the limits of existing abstraction licence conditions. These licences are subject to regular review to determine compliance both with the current and forthcoming environmental legislation. One example of such a review is connected with investigations to understand the sustainability of abstractions in relation to WFD and the deterioration of waterbodies.

As discussed earlier in section 1.3, through the Water Industry National Environment Programme (WINEP), the Environment Agency has highlighted a number of water bodies at risk of deterioration in WFD terms. In October 2016, the Environment Agency released a list of sustainable catchments, and also listed abstractions either thought to be causing serious damage under existing abstraction rates or likely to cause deterioration if abstraction were increased to fully licensed volumes. We were asked to ensure that any new or planned increases to abstraction did not cause a deterioration in the environment from which we were abstracting water.

The Environment Agency developed this list using their modelling tools for reviewing the sustainability of current abstractions. Although the outputs of this modelling are not fully confirmed, they provide a good first step in understanding the current and future sustainability of our sources. This has been considered important to take into account in the development of WRMP19 as it can take a long time to develop new resources to replace any lost through sustainability reductions. It was also considered important to understand how the environmental impact of the new replacement resources compare with the impacts of current licensed abstractions.

However, it is acknowledged that the information provided by the Environment Agency is ‘modelled data’, and the true sustainability of our sources can only be established through detailed on-site investigations. These investigations take a number of years to complete using live on-site data and abstraction pump tests and are completed as part of our WINEP. Where abstractions are found to be unsustainable, we will undertake an exercise (known as options appraisal) to establish what levels of abstraction are sustainable or if there are any other available options to mitigate the impacts of our abstraction (e.g. river habitat enhancement). Once the options appraisal is complete and a sustainable level of abstraction has been agreed, the deployable output of the source will be reduced to the sustainable level. This is known as a sustainability reduction to deployable output for supply.

The status of the WINEP RSA schemes are described in Appendix 10, A7 of our business plan.

The full sustainability reductions for 2025 have been taken into account in all scenarios as these are based on detailed site investigations. The implications of further sustainability reductions beyond this have been explored as part of the scenarios modelled as part of our WRMP.

7.3.3 Water quality We carefully monitor underlying water quality trends through our drinking water safety plans and catchment management programmes (which also form part of our WINEP). Land use change, declines in biodiversity and pollution all have the potential to affect raw water quality and can result in a less environmentally resilient abstraction source.

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April 2017 Our current WINEP (2015-2020) is investigating a number of deteriorating water quality trends, primarily through catchment management programmes. These are currently addressed by:

• Managing the catchment responsibly to ensure that water quality is maintained

• working with landowners to maintain water quality and improve it over time

• payments to landowners to seek improvements to water quality

• changes to operational regimes, such as not abstracting from river sources when there is a high chance of pesticides in the raw water (e.g. plumes of Metaldehyde in surfacewater following application and overland run-off following heavy rainfall).

• improvements to the water treatment process

• improvements to the water treatment process.

We have not applied reductions to our deployable output from water quality impacts as we will address water quality deterioration through our catchment management programme (delivered through our WINEP) or through additional treatment processes, if a catchment solution cannot be found. We believe catchment magagement is a proactive approach to understanding and addressing the underlying causes of water quality deterioration and will reduce the need for existing or future treatment in the longer term.

If there is a chance that water quality could affect the supply-demand balance in the future, changes to deployable output will be picked up through the re-assessment of WRMP24 delpolyable output values. Further information regarding our investigations into raw water quality deterioration within our supply area and our WINEP commitments are provided in Appendix I.

7.4 Do minimum scenario The projected supply demand balance suggests that our supply area would be in deficit from 2045, with the degree of shortfall increasing steadily for the rest of the planning period. Whilst not in deficit prior to 2045, our supply would be less resilient than it currently is. Table 7.5 presents the projected ‘do minimum’ supply-demand balance in a ‘dry year and for peak summer demand). It shows three WRZs (2, 6 and 7) in deficit for a dry annual average year in 2020 onwards and all but RZ1 Tunbridge Wells and RZ5 Farnham in deficit by 2080. Similarly, two WRZs would be in deficit for peak summer demand by 2020, and all but three WRZs in deficit by summer 2045. Overall, the projected supply-demand balance shown in Table 7.5 indicates that we would not be able to meet our statutory and legal obligations for water supply and would not achieve the objectives of WRMP19 without taking action to either increase supply or reduce demand.

In terms of socio-economic effects, the ‘do minimum’ scenario would be likely to lead to reduced levels of service, with significant adverse effects on communities and public health. The reduced levels of service would be expected to affect domestic customers and businesses, but with more severe impacts on vulnerable sections of the community. In terms of environmental effects, this is also likely to lead to greater use of emergency measures which are also more likely to have adverse impacts on the environment in times of environmental stress. Given both the legal obligations and the unacceptability of potential effects, this scenario is not considered as an alternative to the plan, but rather is a basis for comparison and to determine the additional resource required to balance supply and demand.

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April 2017 Table 7.5 Baseline (i.e. ‘do minimum’ / ‘without Plan’)

18BL Supply Dry Year Annual Average (Ml/d) Summer Peak Period (Ml/d) Demand Balance 2020 2025 2045 2080 2020 2025 2045 2080

RZ1: Tunbridge Wells 8.3 7.2 1.9 -2.8 5.3 3.8 -3.7 -12.6

RZ2: Haywards Heath -3.8 -10.6 -19.3 -32.4 3.2 -9.8 -24.6 -44.5

RZ3: Eastbourne 12.9 11.2 -9.0 -21.7 14.3 13.5 -7.7 -22.9

RZ4: Bracknell 42.1 37.8 4.2 -22.5 35.0 29.0 -11.9 -51.7

RZ5: Farnham 12.6 12.4 7.8 3.1 13.1 12.5 6.8 -1.0

RZ6: Maidstone -3.2 -6.7 -17.5 -29.1 -11.6 -14.2 -28.0 -42.8

RZ7: Cranbrook -9.9 -10.7 -13.7 -16.2 -7.8 -8.8 -13.1 -17.6

RZ8: Ashford 16.0 14.7 -14.2 -25.8 25.0 23.1 -7.6 -23.5

Total 74.9 55.2 -59.8 -147.4 76.6 49.2 -89.8 -216.6

7.5 Scenario comparison A bespoke modelling tool based on economics of balancing supply and demand (EBSD) was used to support decision making by optimising the timing and combination of options against the different scenarios considered. The model ran multiple and wide-ranging future scenarios over a 60 year period and generated a least-cost plan to resolve each scenario. The term ‘least cost’ in this context includes financial, environmental, social and carbon costs, and included MCA for all feasible options. The criteria scoring included total net present value cost (NPV), positive and negative SEA score, promotability, deliverability and option level resilience so that we could identify the best value plan that performed well under a range of scenarios. In addition, we ran the advanced decision making method, known as Info- Gap analysis which was used to stress-test potential plans to a range of increasing and plausible future uncertainties. This enhanced the decision making process, especially around the balance between cost, levels of resilience and adaptability.

The process of developing the WRMP involved five steps as set out in the following paragraphs. The first three steps were used to develop the dWRMP and step 4 and 5 involved response to the consultation process then further analysis and modelling to produce the WRMP and is described further in Appendix 8B of the WRMP. The main steps are summarised below:

Step 1: Developing a conventional best plan

The first step of decision making for the WRMP was to determine scenarios for comparison. This considered:

• The level of leakage reduction

• how to take account of SEA requirements including how to best account for sustainability reductions

• how to ensure alignment with customer preference and willingness to pay.

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April 2017 Step 2 Advanced decision making: consideration of a wider range of future uncertainty

This involved considering uncertainty, assessing resilience to drought and stress testing the plan.

Step 3: Comparison of plan with WRSE

Comparison of results with WRSE regional modelling.

Step 4: Consultation on dWRMP

Analysis of responses to consultation to determine approach for the WRMP.

Step 5:Developing a best value plan for the WRMP

Incorporation of more ambitous demand management targets with new model runs and scenario testing.

The key scenarios are listed in

Table 7.6 and identified as model run numbers one to fourteen. Model runs one to seven are associated with step one, and model runs 13 and 14 were undertaken for step five. These are summarised in Table 7.6.

These model runs varied in terms of:

• The level of drought from ‘worst historic’ (1:100 or one per cent annual probability of occurring) to ‘severe’ drought (1:200 or 0.5 per cent annual probability of occurring)

• the extent and timing of sustainability reductions to 2030 or 2035, and whether they were based on the extreme case (taking the Environment Agency modelled results, and assuming all would be required) or a more likely level (based on experience of WINEP investigations to date and our own review of the sustainability risk for their existing abstractions)

• inclusion or not of high risk environmental options, or imposition of timing restrictions to the model to reflect the risk and requirement for additional time for further studies or due to cumulative impact concerns

• degree of priority given to leakage and water efficiency to reflect national targets, customer preferences and SEA objectives

A summary of the results of all fourteen model runs is described in detail in Appendix 8B of the WRMP19 and a summary of which options are selected across each of the fourteen model runs is provided in Appendix 8B-2 of the WRMP19.

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April 2017 Table 7.6 Modelled scenarios

Model run no. Model run no. 1 Model run Model run Model run Model run Model run Model run Model run 13 Model run no. 2 no. 3 no. 4 no. 5 no. 6 no. 7 14 SR run 5 SR Run 1 SR Run 2 SR run 3 SR run 4 (SR run 4) (SR run 5)

Summary of model run Worst historic 1:200 1:200 SEA 1:200 SEA 1:200 SEA 1:200 SEA 1:200 SEA 1:200 SEA 1:100 SEA (1:100) Least cost SR-2030 SR-2030 SR-2035 SR-2035 SR-2035 / + 50 % + 50 % SR - 2030 Reference Advizzo leakage leakage

Model dWRMP SR-2035 / SR-2035 / SR -2030 Advizzo Advizzo rWMRP19

Demand forecast DI_Medium DI_Medium DI_Mediu DI_Mediu DI_Medium DI_Mediu DI_Mediu DI_Medium DI_Mediu m m m m m

Drought level DR_Worst DR_Severe DR_Sever DR_Sever DR_Severe DR_Sever DR_Sever DR_Severe DR_Worst Historic e e e e Historic

Sustainability reductions SR_Extreme SR_Extreme SRxtreme SR_Likely SR_Extrem SR_Likely SR_Likely SR_Likely SR_Likely e

Water quality WQ Confirmed WQ WQ WQ WQ WQ WQ WQ WQ Confirmed Confirmed Confirmed Confirmed Confirmed Confirmed Confirmed Confirmed

Climate change forecast CC_Med CC_Med CC_Med CC_Med CC_Med CC_Med CC_Med CC_Med CC_Med scenario

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April 2017 7.6 Drought selection To comply with the latest guidelines, we ran the model to establish any resilience options required to deliver least cost plans capable of meeting both the worst historic drought and Defra’s one in 200 reference levels of resilience.

7.6.1 Supply schemes The model results showed that, across all regions, planning to a more resilient 1:200 drought severity (compared with a worst historical drought) had little effect on schemes selected. The main effect was in the timing of the schemes.

7.6.2 Demand management For demand management schemes, the impact of moving to Defra’s 1:200 year reference level of resilience was marginal; with slightly higher levels of leakage savings in the shorter term (2020-25); the same levels of metering; and slightly lower levels of savings from conventional water efficiency initiatives.

7.6.3 Selected drought level Overall, in terms of meeting SEA objectives, the water supply provision against a 1:200 drought was considered preferable compared to the 1:100 drought scenario as this would reduce the probability of recourse to drought permits and orders and would therefore be supportive of environmental resilience also. For this reason the 1:200 drought level has been taken as the reference least cost scenario, and was used as the basis for further investigation of possible option combinations to reduce environmental impacts.

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April 2017 7.7 SEA model runs The MCA scoring of options and environmental and social costings were used within the model to reflect environmental assessment undertaken, and also to track how moving from the least cost plans to a best value plan improved the overall MCA score and environmental and social costs (including carbon costs). In addition, the options assessment for the MCA was used as a basis for assigning high (red) medium (amber) and low (green) environmental risk categories to each option to provide a way to input directly into generation of options for different scenarios. The risk categories were focused on risk in terms of environmental resilience, reflecting the importance given to this aspect in the water industry strategic environmental requirements (WISER) document.

The input to the modelling was undertaken through an iterative process with the analysis of each model scenario feeding back into further model runs. The starting point was to exclude all options identified as high risk environmental resilience or ‘red’ options. This was followed by further subsequent SEA runs (model runs no four to fourteen) keeping the high risk options out where this allowed the demand to be met, but also aiming to improve the balance and minimise the overall environmental risk for the combined portfolio of options by constaining higher risk options to the latter end of the planning period in order to provide time for new treatment options to emerge and to investigate alternatives options and variants to avoid adverse impacts on designated sites. The assessment of the plan scenarios included a more detailed analysis based on individual option assessment matrices and cumulative assessment and is summarised in Table 7.7.

This approach avoided double counting with the environmental, social and carbon costs already included in the modelled costs particularly with respects to carbon and traffic impacts.

7.8 Demand management (company level) During development of the dWRMP the demand management options were considered beneficial in terms of meeting SEA objectives and while the exclusion of the high risk options had little effect on the selection of demand management schemes – subsequent iterations to optimise the benefit from these schemes were considered supportive in terms of a producing a better environmental plan.

The development of the WRMP responds to consultation comments and is more ambitious on per capita consumption

7.9 Sustainability reductions A key question within the SEA process was how to model the impact of sustainability reductions while minimising inclusion of options with higher environmental risk. Sustainability reductions to our existing sources proposed by the Environment Agency are a key driver for future investment in the short (2020- 25) to medium (2025-45) term.

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April 2017 The data provided by the Environment Agency was used to understand both the current and future sustainability of our sources by undertaking a number of modelling scenarios; these determined the investment required and clarified the scale and timing of the sustainability reductions. Four sustainability reduction scenarios were modelled with high risk environmental options removed and the least cost plans from each of these were assessed against the SEA objectives. This approach was used due to the uncertainty around what the final scale of the sustainability reductions might be, and enables us to understand how best to achieve an environmentally resilient plan whilst minimising costs to customers using the following scenarios:

• SR Scenario 1 (WRMP): 100% of future potential sustainability reductions to 2030

• SR Scenario 2 (WRMP): 100% of future potential sustainability reductions to 2025 plus 50% of future potenial sustainability reductions by 2030

• SR Scenario 3 (WRMP): 100% of future potential sustainability reductions to 2025 plus 100% of future potenial sustainability reductions by 2035

• SR Scenario 4 (WRMP): 100% of future potential sustainability reductions to 2025 plus 50% of future potential sustainability reductions by 2035

• SR Scenario 5 (WRMP): as for 4 but with 15% leakage reductions by 2025 (in response to the leakage reduction targets set out in the Government’s 25 year environmental plan, discussed further in following paragraphs) and 50% leakage reductions by 2050 included

Achieving 100% of sustainability reductions by 2030 (Scenario 1) and 2035 (Scenario 3) brings forward several new water resource developments. A number of these, for example desalination plants, are generally considered higher risk options in terms of our SEA as they have potential for high environmental impacts and low cost-benefit. Model runs two, four and five (achieving 50 per cent sustainability reductions by 2030 and 2035 respectively) were more advantageous in both SEA and cost terms.

Optimising demand management

During development of the WRMP we took account of customers preferences identified through WRMP19 research and also during the pilot of a behavioural economics approach to reduce demand with 22,000 households (described in WRMP section 1.4.1), and tested a more ambitious long term behavioural change and demand management savings for the dWRMP which was aligned with SEA objectives.

Modelling of a best value plan had up to this stage been constrained to selecting more conventional water efficiency initiatives, and led to multiple small options being selected at high cost and generating low levels of future demand management savings. To support decision making, we re-ran the best value model run six together with the option of a more innovative water efficiency option that bundles the existing selected conventional water efficiency initiatives with the roll out of a behavioural economics programme based on our innovative and award winning work in partnership with Advizzo. This formed the basis of model runs seven.

Following consultation on the dWRMP our per capita consumption and demand forecast was further revised and this was incorporated into further model runs to develop the WRMP.

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April 2017 7.10 Developing the WRMP In its draft methodology for PR19 price review17, Ofwat included an expectation for companies’ performance on leakage to either include a reduction in leakage by 15 per cent by 2025 or performance to be within upper quartile of industry performance on leakage per property per day.

The analysis of the relative performance shows that our leakage performance is already within the upper quartile and our leakage level is 22.6 Ml/d below the sustainable level of leakage (for details see Appendix 5D, Leakage of the WRMP19). The regulatory response to our draft plan identified the requirement to meet the 15% leakage target in line with the Government’s 25 year environmental plan. Therefore additional modelling was undertaken to further consider this the 15 per cent leakage reduction (from current baseline levels) and also to determine the implications of achieving 50 % leakage reductions by the end of the supply period (2090). The options presented as scenario 14 will meet the Ofwat leakage reduction and water efficiency objectives for 2025 and also result in a 50 % reduction in leakage by the end of the supply period. Key concerns are the increased construction works along the network which could have effects on road users with potential for increased traffic congestion and air quality effects related to this but the potential benefits outweigh these effects in the longterm as number of major new schemes identified as high risk through the SEA are no longer required. A summary of the key scenario comparisons is provided in Table 7.7.

17 Delivering Water 2020: Consulting on our methodology for the 2019 price review. Ofwat, July 2017

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Table 7.7 SEA objectives scenario comparison April 2017

Scenario

1:200 SEA 1:200 SEA 1:100 SEA Least cost + 50 % leakage SEA objective Do nothing 1:200 SEA 1:200 SEA 1:200 SEA SR-2035 / Advizzo 1:200 Reference + 50 % leakage SR-2030 SR-2035 SR-2035 (7th Run) SR-2035 / Advizzo SR -2030 (3rd Run) (5th Run) _v1 (6th Run) _v1 SR-2035 / Advizzo (2nd Run) (13th Run ) dWRMP19 (14th Run ) rWMRP19

1. Protect No change from This scenario would As described As described Pipeline As described against Considerable As described against public health current water meet the predicted against the against the installation the 1:200 SEA SR- increase in level of 1:200 + 50 % and promote resource supply-demand balance Least Cost Least Cost 1:200 within both 2035 (6th Run) _v1. pipeline works along leakage SR-2035 / wellbeing management over the supply period. 1:200 Reference SR- urban and network with Advizzo (13th Run) would Reference SR- 2030 (2nd Run). rural areas is potential for traffic rWMRP19 except Pipeline installation eventually 2030 (2nd Run). reduced by congestion for works with reduced would cause temporary result in approximately withn road corridors resilience of supply disruption for users of demand 25% and resulting effects to drought conditions minor roads, particularly outstripping compared to on access, traffic and attendant within urban areas. supply, with previous disruption, travel increased risks to Footpaths/bridleways resultant water scenarios, time increases and public health and and recreational areas shortages of decreasing the possible associated wellbeing. would be affected mainly increasing risk of local air quality within rural areas. frequency with disruption impacts. Potential time and we Reservoir construction during for in combination would not be would result in the construction. effects for works on able to meet permanent loss of the road network. Otherwise, customer footpaths within reservoir effects would supply footprint. However, in the be as requirements long term these options described with adverse provide significant against the impacts on potential for new and Least Cost public well- enhanced recreational 1:200 being. facilities, with an overall Reference SR- Therefore not beneficial effect. 2030 (2nd an acceptable Run). scenario.

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Scenario April 2017

1:200 SEA 1:200 SEA 1:100 SEA Least cost + 50 % leakage SEA objective Do nothing 1:200 SEA 1:200 SEA 1:200 SEA SR-2035 / Advizzo 1:200 Reference + 50 % leakage SR-2030 SR-2035 SR-2035 (7th Run) SR-2035 / Advizzo SR -2030 (3rd Run) (5th Run) _v1 (6th Run) _v1 SR-2035 / Advizzo (2nd Run) (13th Run ) dWRMP19 (14th Run ) rWMRP19

2. Protect and No options/not There would be Effects would Effects would be This scenario The dWRMP would Reduced new As described against where taking any temporary disruption to be as as described would require require a reduced infrastructure 1:200 + 50 % appropriate action would the strategic road and described against the approximately number of major facilities and leakage SR-2035 / enhance, built result in no rail network associated against the Least Cost 1:200 25% fewer road and rail associated pipelines Advizzo (13th Run) and natural significant effect with pipeline installation. Least Cost Reference SR- major road crossings than early although increased rWMRP19 except assets and under this SEA 1:200 2030 (2nd Run). (motorway or scenarios, and a works on the with reduced Whilst construction of reduce waste objective from Reference SR- A-road) and reduced number of existing network resilience of supply the new reservoirs and the WRMP if 2030 (2nd rail crossings effluent treatment compared to the to drought conditions new water treatment ‘do nothing’ Run). than early options (as dWRMP plan for water dependent infrastructure required to were adopted. scenarios. described against options. built and natural support the effluent 1:200 SEA SR-2035 assets. treatment and This scenario (5th Run) _v1). desalination options includes would require between 1 and earthworks, the aim 3 fewer would be to achieve cut- effluent fill balance for all treatment options. options than other Water reuse and scenarios. For desalination options this reason, generate relatively high waste levels of operational generation waste compared to associated conventional surface with the water or groundwater operation of abstraction or transfer options sources. included within this scenario is also anticipated to be lower than

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Scenario April 2017

1:200 SEA 1:200 SEA 1:100 SEA Least cost + 50 % leakage SEA objective Do nothing 1:200 SEA 1:200 SEA 1:200 SEA SR-2035 / Advizzo 1:200 Reference + 50 % leakage SR-2030 SR-2035 SR-2035 (7th Run) SR-2035 / Advizzo SR -2030 (3rd Run) (5th Run) _v1 (6th Run) _v1 SR-2035 / Advizzo (2nd Run) (13th Run ) dWRMP19 (14th Run ) rWMRP19

previous scenarios.

3. Protect and No options/not Current pipeline routing This scenario Effects would be Effects would The dWRMP19 The WRMP reduces As described against enhance taking any indicates that pipeline does not as described be as preferred plan also risk to the water 1:200 + 50 % biodiversity action would installation will affect include an against the described includes one less environment by leakage SR-2035 / and result in no terrestrial designated effluent re-use Least Cost 1:200 against the desalination plant removing the Advizzo (13th Run) contribute to significant effect sites, areas of priority scheme which Reference SR- Least Cost than the 1:200 SEA desalination rWMRP19. resilient under this SEA habitat (particularly involved 2030 (2nd Run) 1:200 SR-2035 (5th Run) schemes and ecosystems objective from deciduous woodland and discharge of scenario. Reference SR- _v1 scenario and effluent reuse the WRMP if undetermined grassland) treated effluent 2030 (2nd Run) therefore waste schemes and the ‘do nothing’ and ancient woodland. It directly to the scenario. generation during new groundwater were adopted. is anticipated detailed operation is option at the existing routing studies will be SSSI. anticipated to be Cemex site. The undertaken to remove lowest under the number of transfer, these risks. dWRMP19 preferred zonal and water plan. treatment works For the marine options are also environment, abstraction reduced. and disposal pipeline associated with the Net gain principles desalination options at included across all Newhaven and infrastructure Eastbourne are routed schemes including through Beachy Head pipelines as well as West MCZ and/or Broad Oak reservoir supporting habitats. The and new Arlington Eastbourne pipelines reservoir. would also affect Dungeness, Romney Marsh and Rye Bay pSPA. Brine disposal

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Scenario April 2017

1:200 SEA 1:200 SEA 1:100 SEA Least cost + 50 % leakage SEA objective Do nothing 1:200 SEA 1:200 SEA 1:200 SEA SR-2035 / Advizzo 1:200 Reference + 50 % leakage SR-2030 SR-2035 SR-2035 (7th Run) SR-2035 / Advizzo SR -2030 (3rd Run) (5th Run) _v1 (6th Run) _v1 SR-2035 / Advizzo (2nd Run) (13th Run ) dWRMP19 (14th Run ) rWMRP19

pipelines for the brackish groundwater desalination scheme at Reculver would affect Thanet Coast and Sandwich Bay SPA, Ramsar site, shellfish waters at Swalecliffe and Thanet Coast MCZ. There is limited opportunity to avoid these marine designations.

There is uncertainty regarding risks to marine ecology or aquatic ecology associated with hypersaline brine disposal from the desalination options and risks to aquatic ecology associated with discharge of treated effluent to the river environment.

Whilst the new Arlington reservoir is located within the Arlington reservoir SSSI and NNR, long term effects would beneficial as the

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Scenario April 2017

1:200 SEA 1:200 SEA 1:100 SEA Least cost + 50 % leakage SEA objective Do nothing 1:200 SEA 1:200 SEA 1:200 SEA SR-2035 / Advizzo 1:200 Reference + 50 % leakage SR-2030 SR-2035 SR-2035 (7th Run) SR-2035 / Advizzo SR -2030 (3rd Run) (5th Run) _v1 (6th Run) _v1 SR-2035 / Advizzo (2nd Run) (13th Run ) dWRMP19 (14th Run ) rWMRP19

scheme offers significant opportunities for habitat creation and enhancement.

4. To protect No options/not Short term effects As described As described Effects would The dWRMP Reduced As described against landscapes, taking any include visual against the against the be as preferred plan does construction of new 1:200 + 50 % townscapes action would disturbance/loss of Least Cost Least Cost 1:200 described not include the schemes including leakage SR-2035 / and visual result in no natural landscape 1:200 Reference SR- against the desalination scheme pipelines and Advizzo (13th Run) amenity significant effect features during Reference SR- 2030 (2nd Run). Least Cost at Newhaven, transfers so reduced rWMRP19 under this SEA landscape features. 2030 (2nd Run). This scenario 1:200 removing the potential for objective from There are 14 options This scenario involves the Reference SR- potential for cumulative impacts the WRMP if included within this involves the greatest number 2030 (2nd cumulative impacts on landscapes ‘do nothing’ scenario which involve greatest of options (15) Run), however on Beachy Head compared to were adopted. pipelines routed through number of which include this scenario East MCZ with the dWRMP. sensitive landscape options (15) pipeline involves the desalination scheme areas including High which include installation within lowest number at Eastbourne. Weald AONB, Kent pipeline sensitive of options (12) Downs AONB and South installation landscape which include Downs National Park. within sensitive areas. pipeline landscape installation Long term effects are areas. within principally associated sensitive with the visual impact of landscape new bunded reservoirs areas than at Arlington and Goose previous Green within rural scenarios. landscapes. Potential benefits are associated with the landscape change with Broad Oak reservoir and extensive

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Scenario April 2017

1:200 SEA 1:200 SEA 1:100 SEA Least cost + 50 % leakage SEA objective Do nothing 1:200 SEA 1:200 SEA 1:200 SEA SR-2035 / Advizzo 1:200 Reference + 50 % leakage SR-2030 SR-2035 SR-2035 (7th Run) SR-2035 / Advizzo SR -2030 (3rd Run) (5th Run) _v1 (6th Run) _v1 SR-2035 / Advizzo (2nd Run) (13th Run ) dWRMP19 (14th Run ) rWMRP19

woodland establishment, meadow and wetland provision in the long term.

5. Reduce No options/not Construction and As described As described Construction Otherwise, effects Reduced carbon due As described against greenhouse taking any operation carbon costs against the against the and operation would be as to improved 1:200 + 50 % gas action would would be higher than the Least cost Least cost 1:200 carbon costs described against efficiency with water leakage SR-2035 / emissions result in no 1:200 SEA SR-2035 (6th 1:200 Reference SR - would be lower 1:200 SEA SR-2035 savings and reduced Advizzo (13th Run) significant effect Run) v1 scenario and Reference SR 2030 (2nd Run) than for the (6th Run) _v1 construction and rWMRP19. under this SEA 1:200 SEA SR-2035 / -2030 (2nd scenario. 1:200 scenario. associated objective from Advizzo (7th Run) Run) scenario. Reference SR embodied carbon. the WRMP if scenario (the preferred -2030 (2nd ‘do nothing’ plan). Run) scenario were adopted. (the Least Cost plan).

6. Contribute No change from The scenario provides As described As described As described As described against Improved resilience Reduced resilience to current water both increased resilience against the against the against the the 1:200 SEA SR- through increased to drought conditions environmental resource of supply and reduced Least cost Least cost 1:200 Least cost 2035 (6th Run) _v1 water savings and relative to 1:200 climate management burden on surface water 1:200 Reference SR - 1:200 scenario. reduced reliance on SEA +50% leakage change would and groundwater Reference SR 2030 (2nd Run) Reference SR new abstraction from SR 2035/Advizzo resilience eventually through increased use of -2030 (2nd scenario. -2030 (2nd rivers and (13th Run). result in storage (reservoirs Run) scenario. Run) scenario. groundwater while demand aquifer storage and increasing source outstripping recharge), transfer diversity. supply, with (company and regional) resultant water and effluent options in shortages of preference to new or increasing extended groundwater frequency with and surface water

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Scenario April 2017

1:200 SEA 1:200 SEA 1:100 SEA Least cost + 50 % leakage SEA objective Do nothing 1:200 SEA 1:200 SEA 1:200 SEA SR-2035 / Advizzo 1:200 Reference + 50 % leakage SR-2030 SR-2035 SR-2035 (7th Run) SR-2035 / Advizzo SR -2030 (3rd Run) (5th Run) _v1 (6th Run) _v1 SR-2035 / Advizzo (2nd Run) (13th Run ) dWRMP19 (14th Run ) rWMRP19

time. Water abstractions. shortages of Desalination and effluent increasing options make use of a frequency into highly resilient water the long term resource not susceptible would reduce to drought and provide climate change increased flexibility. This adaptability of however potentially the environment creates a higher burden and stress from on estuarine and marine existing options environments including is likely to marine protected areas increase. in terms of the location of waste effluent discharges.

7. Protect and No options/not There is uncertainty This scenario Effects would be Effects would As described against Abstraction pressure As described against improve taking any regarding effects on does not as described be as the 1:200 SEA SR- for groundwater and 1:200 + 50 % surface water action would chemical water quality include a against the described 2035 (6th Run) _v1 rivers is reduced leakage SR-2035 / and result in no resulting from brine licence trading Least Cost 1:200 against the scenario. with Goose Green Advizzo (13th Run) groundwater significant effect disposal from scheme for Reference SR- Least Cost reservoir, aquifer rWMRP19 status under this SEA desalination and effluent which potential 2030 (2nd Run) 1:200 storage, conjunctive objective from treatment options, environmental scenario. Reference SR- use options and new the WRMP if discharge of treated impacts were 2030 (2nd Run) groundwater option ‘do nothing’ effluent into river considered scenario. at the existing were adopted. watercourses, and high risk due to Cemex site effects on groundwater impacts on removed. chemistry and flow spring fed associated with aquifer streams storage and recharge A conjunctive schemes. use scheme on

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Scenario April 2017

1:200 SEA 1:200 SEA 1:100 SEA Least cost + 50 % leakage SEA objective Do nothing 1:200 SEA 1:200 SEA 1:200 SEA SR-2035 / Advizzo 1:200 Reference + 50 % leakage SR-2030 SR-2035 SR-2035 (7th Run) SR-2035 / Advizzo SR -2030 (3rd Run) (5th Run) _v1 (6th Run) _v1 SR-2035 / Advizzo (2nd Run) (13th Run ) dWRMP19 (14th Run ) rWMRP19

Desalination involving the river Ouse groundwater abstraction was from the brackish aquifer introduced, at Reculver and the which involves conjunctive use within a low risk of the Ouse catchment are saline intrusion associated with a low to the risk of saline intrusion. groundwater source

(Seaford Chalk Block). associated with increased rates of groundwater abstraction.

8. Avoid flood No options/not Minor permanent loss of As described As described As described Construction carbon As for dWRMP – all As described against risk taking any floodplain from against the against the against the costs would be schemes to be 1:200 + 50 % action would infrastructure required to Least Cost Least Cost 1:200 Least Cost similar to those developed with no leakage SR-2035 / result in no support the desalination 1:200 Reference SR- 1:200 anticipated for 1:200 net loss of flood Advizzo (13th Run) significant effect at Newhaven. New Reference SR- 2030 (2nd Run). Reference SR- SEA SR-2035 (6th plain storage and rWMRP19 under this SEA Arlington reservoir is 2030 (2nd Run). 2030 (2nd Run) _v1. This risks from flood risk objective from close to flood plain but Run). scenario has the taken into account. the WRMP if can be sited to avoid lowest operating ‘do nothing’ loss. carbon costs. were adopted.

9. Protect and No options/not Four transfer options are As described As described As described As described against Reduced reliance on As described against where taking any routed close or through against the against the against the the Least cost 1:200 new abstractions 1:200 + 50 % appropriate, action would Registered Park and Least Cost Least Cost 1:200 Least Cost Reference SR -2030 from river and leakage SR-2035 / enhance result in no Gardens and will need 1:200 1:200 (2nd Run) scenario. groundwater

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Scenario April 2017

1:200 SEA 1:200 SEA 1:100 SEA Least cost + 50 % leakage SEA objective Do nothing 1:200 SEA 1:200 SEA 1:200 SEA SR-2035 / Advizzo 1:200 Reference + 50 % leakage SR-2030 SR-2035 SR-2035 (7th Run) SR-2035 / Advizzo SR -2030 (3rd Run) (5th Run) _v1 (6th Run) _v1 SR-2035 / Advizzo (2nd Run) (13th Run ) dWRMP19 (14th Run ) rWMRP19 cultural significant effect further refinement of Reference SR- Reference SR- Reference SR- The timing of new sources, within Advizzo (13th Run) heritage under this SEA pipeline routing. It is 2030 (2nd Run). 2030 (2nd Run). 2030 (2nd desalination and licence abstraction rWMRP19 assets objective from anticipated that detailed Run). water reuse options increases dependent the WRMP if routing will eliminate is late in the on wider water ‘do nothing’ direct effects on heritage planning period quality were adopted. assets (SMs, Registered providing more time improvements from Park and Gardens and to address the catchment listed buildings). uncertainty over the management impacts against Permanent loss of a expected listed building within the developments in the footprint of Broad Oak technologies and reservoir. mitigation that can be applied.

10. Protect No options/not Permanent significant As described As described As described As described against As described against As described against quality and taking any effects would be limited against the against the against the the 1:200 SEA SR- the 1:200 SEA SR- 1:200 + 50 % function of action would to permanent loss of Least Cost Least Cost 1:200 Least Cost 2035 (6th Run) _v1 2035 (6th Run) _v1 leakage SR-2035 / soils result in no approximately 36ha of 1:200 Reference SR- 1:200 scenario. scenario. Advizzo (13th Run) significant effect best and most versatile Reference SR- 2030 (2nd Run). Reference SR- rWMRP19 under this SEA agricultural land within 2030 (2nd Run). 2030 (2nd objective from the footprint of Broad Run). the WRMP if Oak reservoir. ‘do nothing’ were adopted.

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April 2017 7.11 Ecosystems services assessment A high level ecosystems services comparison was undertaken between the least cost reference plan (model run two) and the preferred plan (model run thirteen). Results of the two scenarios are presented below in Tables 7.9 and 7.10 respectively.

Table 7.8 Ecosystem services least cost plan

Impact of Type Components Scheme abstraction Water Sources Water New Building/road construction repair & laying pipeline efficiency water measures metering Leakage reuse Water Desalination Ecology and Provisioning water body Services status

Disamenity

Heritage &

Archaeology

Angling

Informal

recreation Cultural Services In-stream

recreation

Traffic related impacts

Social equity

Regulating Global

Services warming

Key Higher impact

Lower impact

Benefit

No impact

expected

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April 2017 Table 7.9 Ecosystems services preferred plan

Type of Impact of Type Components Scheme abstraction Water Sources Water New construction building/ repair & laying pipeline efficiency water measures metering Leakage reuse Water Desalination Ecology and Provisioning water body Services status

Disamenity

Heritage &

Archaeology

Angling

Informal

recreation Cultural Services In-stream

recreation

Traffic related impacts

Social equity

Regulating Global

Services warming

Key Higher impact

Lower impact

Benefit

No impact

expected

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April 2017 The qualitative assessment developed from the ecosystems services framework used for individual option environmental and social costings indicated that there are significant environmental and social impact (including carbon) differences between the least cost plan and the preferred plan. Due to the inclusion of water reuse and desalination options, the least cost plan would contribute to considerably higher carbon emissions, both as capital and operational expenditure. In addition to the increased carbon impact these options present a high risk in relation to the impacts on provisioning and cultural services. In contrast the increased number of leakage reduction and improved effectiveness for water efficiency options incorporated into the preferred plan are expected to reduce the frequency and magnitude of environmental and social impacts overall.

This qualitative assessment is a first stage ecosystems assessment for combined options and is intended to provide an approach which can be built upon for future analysis. As part of taking the approach forward an initial quantitative analysis was also undertaken. The analysis supports the conclusions for the qualitative assessment and also provides a good basis for applying ecosystem services assessment in the future..

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April 2017 7.12 Comparison of dWRMP preferred plan with preferred plan The changes to the baseline demand forecast and the increased demand management scenario used mean that there are significant changes between the dWRMP and WRMP. These changes have allowed the higher risk environmental schemes to be avoided. These are shown in Table 7.10.

Table 7.10 Key changes between options in the dWRMP and WRMP

Option dWRMP19 WRMP19

Leakage reduction 4 Ml/d reduction in total leakage by 2025 13.3 Ml/d reduction by 2025 and 43 and 14 Ml/d reduction by the end of the Ml/d reduction by 2050 planning period

Water efficiency 21 Ml/d over the planning period 24.2 Ml/d by 2025 and 152 Ml/d over the planning period

Catchment Management CGW-3 Pembury (2034) No change CGW-2 Woodgarston (2035)

Company transfers CTR-18 Kippings to Pembury (2025) Not required

CTR-14 Bewl to Best Beech (2026) Not required

CTR-39 Aylesford to Blackhurst (2026) Not required

CTR-13 Best Beech to Bewl (2032) Not required

CTR 36 Arlington to Barcombe (2051) Required at 2070

CTR-44 Burham to Bewl (2058) Not required

Not required CTR-17 Blackhurst to Bewl (2068)

Conjunctive Use CON-7 Conjunctive use of surface water Not required and groundwater - River Ouse (2075)

Desalination DES-12 Desalination of River Medway Not required tidal water at Aylesford/Snodland (2054)

DES-19 Eastbourne desalination with Not required biomass plant (2049)

DES-14 Reculver desalination of brackish Not required water (2071)

Water reuse EFF-35 Effluent re-use to River Ouse: Alternative option to Arlington Peacehaven (2028) Reservoir

EFF-37 Aylesford effluent reuse (2038) Bulk supply from Southern Water is an alternative to Broad Oak reservoir

EFF-38 Indirect use of effluent from Not required Weatherlees WwTW into the Great Stour (2042)

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Option dWRMP19 WRMP19

Groundwater NGW-44 Aylesford Newsprint (2023) No change

LIC-20 Groundwater licence trade: Halling Not required (2035)

NGW-32 Confined chalk around Not required Farnborough (2057)

ASR-4 ASR chalk confined aquifer Not required (Beenhams Heath/White Waltham) (2067)

Regional Transfers (Imports) RTR-94 SESW to South East Water Now required 2054 transfer - Bough Beech to River Hill (2036)

RTR-15 PRT to WRZ5 transfer (2058) Not required

RTR-79 TWU to WRZ4 (2045) Not required

Reservoir RES-31 Broad Oak Reservoir (2033) No change

RES-24 New Arlington Reservoir (2032) Now 2035

RES-27 Goose Green reservoir (2060) Now an alternative scheme for Arlington Reservoir

Surface Water NGW-15 New raw water abstraction from Not required the River Thames upstream of Maidenhead (2069)

Treatment WTW-29 Bewl-Darwell option Bewl No change Expansion and transfer to Hazards Green (2025)

WTW-4 Release surplus yield at Ford Not required through treatment works upgrade (2027)

WTW-22 Bewl Bridge WTW expansion Not required (2058)

7.12.1 Alternative schemes In the early years of the planning period our plan is built around the Aylesford Newsprint scheme (NGW- 44) and combined leakage reduction and water efficiency. We have been working on the Aylesford Newsprint Scheme for some years and believe it is a low-risk scheme. Similarly, we are confident we can achieve the leakage reduction in our final planning demand forecast and our work with Advizzo suggests that the PCC reductions in the first five years of our WRMP19 are realistic.

There is uncertainty beyond then and we have considered the alternative schemes which are available to us to demonstrate the flexibility and robustness of our preferred plan to changing circumstances. The options provided in the sections below were previously included in our dWRMP and as such were part of the consultation process.

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April 2017 Table 7.11 Plan alternative options

Preferred Plan Scheme Alternative Scheme

RES-31 Broad Oak Reservoir Bulk supply from Southern Water at Aylesford or RES-27 Goose Green

RES-24 Arlington Reservoir RES-27 Goose Green Reservoir

EFF-35 Effluent Re-use to River Ouse at Peacehaven

7.13 Summary of reasons for selecting the preferred plan The preferred plan identified for the WRMP19 has been selected for the following reasons:

• Provides the best balance of options compared to other possible plan portfolios meeting the demand deficit, in terms of the SEA objectives

• meets Ofwats 15% leakage reduction targets with benefits associated with water savings for treatment, with 50% leakage reduction achieved by 2050

• supports supply resilience by meeting Defra’s 1: 200 year reference levels of resilience between 2020 and 2025

• supports environmental resilience by further reducing dependency on freshwater resources vulnerable to climate change and other pressures and increasing use of winter water storage capacity and use of waste water reuse and desalination

• provides a basis for adapting to a range of likely sustainability reductions that we expect will become more certain following further investigations planned for completion between 2020 and 2025

• makes use of our innovative behavioural economic methods aiming to achieve ambitious levels of future demand management savings and per capita consumption (PCC) reductions

• adopts a balance of demand management and supply side options

• provides lower overall carbon emissions compared to the least cost reference and dWRMP plan

• provides a mix of options more in line with customers’ preferences than comparative plan scenarios and the dWRMP

• removes water reuse and desalination schemes from the preferred plan although includes one water reuse option as an alternative for further study and overall reduces environmental risks to the coastal and marine environment compared to the dWRMP

• provides a cost effective plan and avoids a high cost plan which could affect customer affordability.

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April 2017 8. Environmental assessment of the preferred plan

8.1 Preferred plan options Table 8.1 lists the options included in the preferred plan by water resource zone (WRZ) and by plan period (2020-2025, 2025-2045, and 2045-2080).

Table 8.1 Our preferred plan by water resource zone

WRZ 2020-2025 2025-2045 2045-2080

All WRZs Water efficiency

Leakage

Tunbridge Wells Catchment management in Regional transfer from SES Water (WRZ1) the Pembury area

Haywards Heath Water reuse at Improved connectivity between (WRZ2) Peacehaven (plan zones 2 and 3 alternative option) Goose Green Reservoir (plan alternative option)

Eastbourne (WRZ3) Leakage New Arlington Reservoir Expansion of Bewl water treatment works with improved transfer links Improved connectivity within the zone

Bracknell (WRZ4) Reduced transfer Catchment management at from WRZ4 to Woodgarston Affinity Water – Egham to Surrey Hills

Farnham (WRZ5)

Maidstone (WRZ6) Aylesford Bulk supply of water from Newsprint - use of Southern Water’s water existing reuse scheme at Aylesford groundwater (plan alternative option) sources Improved connectivity within the zone

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WRZ 2020-2025 2025-2045 2045-2080

Cranbrook (WRZ7) Internal transfer from WRZ 1 to WRZ 7 Ashford (WRZ8) Broad Oak reservoir

Improved connectivity within the zone

Our preferred plan for the period 2020 to 2025 includes a mix of demand management initiatives (leakage and water efficiency) (see Table 1.1) that provide an additional 17.3 Ml/d above the assumptions already included baseline activities (see Table 8.2). On their own, these types of initiatives would not be enough to meet the deficits, and therefore for the period 2020 to 2025, the preferred plan includes a new water supply option in water resource zone six to construct a water treatment works at the former Aylesford Newsprint site that would provide an additional 18.2 Ml/d and a pipeline improvement scheme within WRZ 6 (see Table 8.2).

Table 8.2 WRMP19 preferred plan by option type

Receiving Year Option Option type Option reference Option name WRZ activated yield (Ml/d)

Catchment SEW-RZ1-CGW-3 Targeted catchment 1 2035 0.3 management management interventions in the Pembury area

SEW-RZ4-CGW-2 Catchment Management 4 2034 3.0 Interventions at Woodgarston

Company SEW-RZ7-CTR-17 SEW SEW RZ1 to RZ7 7 2028 4.0 transfers Transfer - Blackhurst to Bewl

SEW-RZ2-CTR-36 SEW RZ3 to RZ2 Transfer - 2 2070 10.0 Arlington to Barcombe

Groundwater SEW-RZ6-NGW-44 Aylesford Newsprint - use 6 2023 20.0 of existing groundwater sources

Leakage Various Leakage All 2020 43.4 by 2079

Regional SEW-RZ1-RTR-94 SESW to South East Water 1 2042 10.0 transfers WRZ1 Transfer - Bough Beech to Blackhurst SR {Imports}

Reservoir SEW-RZ8-RES-31 Broad Oak reservoir 8 2033 22.0

SEW-RZ3-RES-24 New Arlington reservoir, R. 3 2035 18.0 Ouse

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Receiving Year Option Option type Option reference Option name WRZ activated yield (Ml/d)

SEW-RZ2-RES-27 Goose Green Reservoir, 30 2 N/A – plan 7.2 m AOD - 7,200 Ml alternative option

Treatment SEW-RZ3-WTW-29 Bewl-Darwell Option: Bewl 3 2025 8.0 water treatment works expansion and transfer to Hazards Green

Water reuse SEW-RZ2-EFF-35 Effluent reuse to River 2 N/A – plan 25 Ouse: source – alternative Peacehaven (25Ml/d option Option)

Water Various Water Efficiency All 2020 153.5 (by efficiency 2079)

SEW-RZ3-ZON-12 RZ3 Zonal Scheme - [RES- 3 2025 N/A 24/RES-25/RES-30] - Arlington to Folkington Reservoir Reinforcement

SEW-RZ6-ZON-52 RZ6 Zonal Scheme - 6 2025 [NGW-44] - Mains from Zonal schemes Aylesford to Kingshill booster and Kingshill booster to Beech

SEW-RZ8-ZON-22 RZ8 Zonal Scheme - [RES- 8 2033 23/RES-31] - Distribute extra water from Broad Oak

During the period 2025 to 2045 the demand management initiatives will continue to achieve further leakage and water efficiency savings. However, by this stage the following additional water supply options (see Table 8.1) are required to meet the increase in shortfall in the supply-demand balance:

• developing a regional water transfer scheme from SES Water (9 Ml/d)

• carrying out a targeted catchment management programme in the Pembury and Woodgarston areas, Kent (3.3 Ml/d)

• building a new reservoir at Broad Oak, Kent (19.6 Ml/d)

• building a new reservoir adjacent to our existing Arlington reservoir, East Sussex, (16.1 Ml/d)

• two improvement schemes to our pipe networks in WRZ 3 and WRZ 8 to improve the connectivity within our supply area

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April 2017 We have also identified three alternative plan options that could be implemented in the event that, following further studies, the higher risk Broad Oak and Arlington Reservoir schemes could not be progressed. These alternative options were included within our dWRMP, and as such were part of the consultation process. These include a bulk transfer from Southern Water’s water reuse scheme at Aylesford, a water reuse scheme at Peacehaven and a new reservoir at Goose Green.

The water resource management plan (WRMP19) considered options that would be needed to deliver to avoid a deficit in the supply demand balance over a 60 year period. Water supply option required for this period include three transfer options, one of which involves a bulk supply from SES Water.

Further information regarding the timing of implementation and yield of the above options are given in Table 8.2. A schematic diagram showing the location of preferred plan options and alternatives is shown in Figures 8.1 and 8.2 below. The locations of the preferred plans options and alternatives relative to landscape, human health and population and water environmental constrains are shown in Figures 5.1.1-5.3.8 (Appendix J).

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Figure 8.1 Preferred plan options: western region

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Figure 8.2 Preferred plan options: eastern region

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April 2017 8.2 Components of the preferred plan This section considers the components of the preferred plan and alternative plan by each of the option types.

8.2.1 Leakage The preferred plan includes 13.3 Ml/d of further leakage savings beyond current baseline reductions during the first five years to 2025 and a further 29.7 Ml/d by the end of the planning period (2080). This would be achieved through a combination of measures including:

 Boosters for customers

 calm networks programme

 communication pipe replacement

 DMA remainder improvement

 new technology implementation

 smart networks programme

 trunk main metering mprovements

 mains replacement

8.2.2 Water efficiency A total of 24.2 Ml/d of water efficiency savings would be achieved through water efficiency measures between 2020 and 2025, with a total of 152 Ml/d of water efficiency savings achieved by 2080. Water efficiency measures included within the preferred plan are:

Household

 Household behavioural change water efficiency savings

Non-household

 Water efficiency audits

 leak detection sensors

 online water efficiency audit tool

 leaking toilets

8.2.3 Groundwater The preferred plan includes a groundwater scheme delivering 8 Ml/d by 2025. This is considered to be a sustainable option and can be delivered with low risk of environmental impacts.

Using experience of the most recent drought and susceptibility of groundwater to period of low levels of recharge, our aim has been to develop a dWRMP19 that provides more resilience and less dependency on groundwater. Given the Environment Agency’s guidelines to ensure existing and future sustainable abstractions, many groundwater development options have been considered too risky on deliverability

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April 2017 and sustainability grounds to be included in the preferred plan and this was reflected in the option screening process.

8.2.4 Catchment management The preferred plan includes two catchment management schemes to re-deliver 3.3 Ml/d of existing groundwater sources by the end of the planning period.

The preferred option for targeted catchment management in the Woodgarston, WRZ 4 (Bracknell) area would educate educate farmers and land managers about Nitrate Vulnerable Zone Regulations and best practice nutrient management and land owners about their septic tank / cess pit discharges to groundwater. This scheme would help reduce nitrate seasonal peaks and aim to re-introduce the currently unavailable groundwater yield of 3 Ml/d at Woodgarston water treatment works.

In the Pembury area, we would carry out targeted catchment management to remediate areas of contaminated land impacting on water quality, educate farmers and land managers about pesticide management best practice and storage of chemicals, and implement measures to deter fly-tipping. This scheme would help to prevent a water quality failure and potential loss of up to 0.3 Ml/d from an existing groundwater source at Pembury water treatment works.

8.2.5 Regional transfers The preferred plan includes a new regional transfer schemes delivering 9 Ml/d transfer capacity by 2054. Initial discussions have taken place with SES Water to reach a level of understanding about the availability of these transfers during the planning period. There is a degree of flexibility about the precise route of this transfer option and further work is required to ensure environmental impacts are avoided or minimised; and ensure that this scheme is deliverable.

8.2.6 Reservoirs The preferred plan includes two reservoirs delivering 40 Ml/d of new surface water sources by the end of the planning period. Firstly, the development of a reservoir at Broad Oak, near Canterbury, with an intake on the Great Stour, yielding 22 Ml/d by 2033. Secondly, an extension to the existing reservoir at Arlington, East Sussex with an intake on the River Ouse yielding 18 Ml/d by 2035.

The inclusion of the Broad Oak reservoir in the preferred plan is a long standing option for which South East Water own the necessary land. The dWRMP19 includes a larger size reservoir than previously proposed in WRMP14 (5,126 Ml capacity compared to 2,815 Ml in WRMP14). During the period 2015 to 2020 we have undertaken further work to carefully assess the extent of a proposed new larger reservoir including the need to avoid any inundation of the SSSI and areas of adjacent ancient woodland, the presence of protected species and visual impact. This study demonstrated that there is considerable potential to create a new open water habitat and compatible recreational facilities. There is also significant potential for enhancement of the biodiversity of the area through advanced habitat creation on land owned by South East Water outside the area required for a reservoir and connecting isolated woodland blocks.

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April 2017 We consider that the preferred option to extend the existing reservoir at Arlington through the creation of a bunded reservoir north of the existing site is a more acceptable option than other reservoir options considered. There could be significant benefits associated with this reservoir option to create new habitats and recreational opportunities, building on the experience and local knowledge gained from managing the existing reservoir, which has been designated a site of special scientific interest (SSSI) since shortly after its construction. During the period 2015 to 2020 we have undertaken further work to develop the understanding of the issues involved with this scheme including reducing impact on the designated sites nearby, the presence of protected species and the need to move overhead power lines.

The long lead in time for the development of reservoir options provides sufficient time available for further assessment work during the 2020 to 2025 period.

8.2.7 Water treatment works The preferred plan includes improvements to an existing water treatment works at Bewl, delivering 8 Ml/d of new water by the end of the planning period. This would replace an existing raw water transfer of 8 Ml/d with the a treated transfer to remove the risk of transfer of INNS through the movement of raw water between catchments. This water would be transferred to WRZ3 where it will be used in place of the existing Southern Water Bewl-Darwell raw water supply when this terminates in 2025.

8.2.8 Company transfers The preferred plan includes two company transfers, providing an additional company transfer capacity of 14 Ml/d by the end of the planning period. As with the preferred regional transfer options, the precise routing of these company transfer options requires further work to take account of environmental constraints.

8.2.9 Zonal schemes In addition to regional and company transfers, we will also look to improve the water network within each water resource zone. The preferred plan includes three zonal transfers by the end of the planning period. This reflects the new approach taken for the WRMP19 and Strategic Environmental Assessment (SEA) which is to identify all enabling works required to connect new schemes to the existing network so that these are assessed with the resource options.

8.2.10 Plan alternative options We have identified three plan alternative options which could be implemented in the event that one or more of the higher risk options included within the preferred plan (such as Broad Oak and Arlington Reservoirs) cannot be progressed.

The Peacehaven water re-use plan alternative option comprises a transfer pipeline from Southern Water’s Peacehaven wastewater treatment works to Newhaven where a new treatment plant including a reverse osmosis treatment plant would be sited. The treated effluent would then be transferred inland for release into the River Ouse and abstraction at Barcombe water treatment works.

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April 2017 The Southern Water bulk transfer option is only considered to be available if Southern Water take forward their Aylesford water reuse scheme and assuming that Southern Water obtain the necessary planning approvals and undertake HRA. The bulk supply is assumed to use existing South East Water infrastructure. If this bulk supply scheme is not available however, Goose Green Reservoir would be an alternative option also. Goose Green Reservoir option is located on a greenfield site with relatively few environmental constraints compared to other reservoir options.

These alternative options will be subject to further study along-side the development of the preferred plan schemes.

8.2.11 Additional schemes relevant to WRMP Additional schemes which are of relevance to rWMRP19 are those associated with our abstractions at Darwell and Greywell they have either generated options for inclusion in the modelling as in the case for Darwell raw water transfer replacement or have associated implications for enabling infrastructure required to support the WRMP19 preferred plan.

Darwell raw water transfer

As part of our water industry national environmental programme (WINEP) for this planning period (2020- 2025), an investigation has been undertaken into the risk of the spread of invasive non-native species (INNS) related to the South East Water raw water transfer in East Sussex. This risk results from an existing raw water bulk supply at Darwell reservoir from the river Medway. This scheme is known as the Bewl-Darwell transfer scheme and is operated by Southern Water. We have consulted with Southern Water throughout the scheme investigation and dWRMP19 process. The raw water crosses a number of catchments and provides a potential pathway for INNS to the Natura 2000 protected site at Pevensey Levels in East Sussex.

Our investigation has found that existing and future INNS pose a significant risk to the features of the Natura 2000 protected site. This investigation examined a number of options to reduce this risk and find the most environmentally resilient, economic method of replacing this bulk supply. The preferred solution was the treatment of the raw water to drinking water standards.

As a result of this study, the preferred replacement option involves an upgrade to our water treatment works at Bewl together with improvements to the water distribution network. Water will be treated at Bewl water treatment works and transferred to WRZ 3 (Darwell supply area) where it will be used in place of the existing bulk supply arrangement when this terminates in 2025. We have agreed with Southern Water that, from 2026 onwards, Darwell will not be refilled via the Bewl-Darwell raw water transfer.

The outputs of our WINEP investigation for Darwell have been included in this dWRMP and the replacement removing the INNS risk involving a transfer and water treatment works expansion are included in the preferred plan.

Groundwater abstraction at Greywell

We investigated the sustainability of our Greywell abstraction through the 2010-2015 WINEP. The abstraction was demonstrated to be unsustainable as it was causing deterioration to the SSSI features of . Therefore, in WRMP14 we made a commitment to cease abstraction at Greywell in 2020 subject to being able to replace the water source and upgrade our distribution network.

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April 2017 During this planning period (2020-2025) we are developing a surface water source in the Thames area to replace Greywell. However, improvements to the distribution network have been problematic as mains need to be upsized in two areas that are particularly environmentally sensitive and constricted. The option assessment for the Surrey Hills to Fleet and Fleet to Greywell reinforcement mains is provided in Appendix 4 to the WRMP19. To secure development consent for these mains we have investigated a number of alternative route options and concluded that one of only two feasible options available is via a wetland SSSI with the other being a road based route predominantly via the A30. We are currently conducting detailed scientific studies to establish the possible scale and duration of impact that constructon and operation of a new pipeline could have on this SSSI. We are also in discussions with the local highways authorities and Highways England regarding the road route and the likely impacts. Because of the uncertainty around this, we will not be able to close the Greywell source by 2020, and for this reason the zonal strategy associated with it is included within WRMP19.

We have consulted Natural England and the Environment Agency and have agreed to continue to abstract at Greywell until 2023. The WRMP19 models the closure of Greywell by 2025.

8.3 Overall preferred plan assessment against SEA objectives The individual options of the preferred plan (and also the water reuse at Peacehaven and Goose Green reservoir alternatives) have been assessed using the approach and method described in Chapter 6. As described in chapter 6, where it is known that standard procedures are already in place to manage the impacts, or there is legislation in place to protect the receptor against the identified potential impacts, this is also recorded and taken into account during the assessment. Standard mitigation measures identified are shown in Table 6.4.

The assessment of individual options following implementation of standard mitigation resulted in the identification of a number of areas of potential adverse and beneficial effects for each option, as shown in Table 8.3 for leakage reduction and water efficiency options and Table 8.4 for water supply options. These results have been used in order to identify mitigation measures which are appropriate to each option at this stage (i.e. prior to the pursuit of any design, detailed routing or siting where required). Residual effects identified take account of the mitigation put forward, and focus on those adverse effects which will not be readily eliminated – i.e. avoided, fully remedied or fully compensated for. While such effects may not be readily eliminated, it must be recognised that with future additional investigation, project planning and design, there remains the possibility that they can indeed be avoided or reduced to net negligible effects. The SEA applies the precautionary principle, and aims to ensure that significant risks remain highlighted in this assessment.

In addition to the information provided below, a summary assessment matrix for the water supply options is provided in Appendix E.

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SEA Environmental Report Table 8.3 Assessment of leakage management and water efficiency measures to be implemented between 2020 and 2070 April 2017 Option Start year Description Potential effects SEA mitigation Residual effects name/type

All Water Resource Zones

Leakage Various Various leakage Effects relate to works to undertake repairs. Review of proposed works Short term management between management schemes such Generally temporary short-term and small-scale locations to identify any moderate adverse 2020 and as pressure reduction, within the existing network – uncertainty over potential sensitive effects associated 2079 improved leakage detection, location for specific works and some could be environments and to ensure with from traffic and identification of leakage within sensitive areas. Leakage repairs are likely to appropriate measures are disruption include work within or alongside highways and can hotspots taken cause traffic disruption and associated impacts Long term during repairs beneficial effects. Potential for long-term significant benefits for Would result in sustainable resource use and carbon foot print reductions through water and energy savings. water and energy savings.

Water Various Includes such measures as; • Voluntary schemes minimising disruption to Initiatives should be Long-term efficiency between water efficient products; customers accessible to as wide a beneficial effects. 2020 and property audits and discount range of population as Would result in • long-term beneficial water and energy / carbon 2076 vouchers; water and energy possible. Uncertainty over water and energy emission savings efficient retrofit; school water uptake. Need to monitor savings. audit and retrofit. • potential benefits through savings for customers uptake and effectiveness. Can help to raise • opportunity to raise awareness, with knock-on Review of proposed works water conservation benefits to conserve further water locations to identify any awareness • options combine to reduce need for new potential sensitive generally, having resource supply and delay the timing that new environments and to ensure wider benefits. resource need to come in. appropriate measures are taken.

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SEA Environmental Report Table 8.4 Assessment of resource zone specific options April 2017 Option Potential effects (after standard Start year Description SEA mitigation Residual effects name/type mitigation)

Water Resource Zone 1

CGW-3 2034 Contaminated land Long term minor positive effects on Additional monitoring to Long term minor positive effects on remediation. Educate aquatic ecology, groundwater Water confirm water quality aquatic ecology, groundwater Water Targeted farmers and land Framework Directive (WFD) status improvements to be agreed. Framework Directive (WFD) status catchment managers about and soil quality. Water quality and soil quality. Water quality effects management pesticide management effects are expected to contribute to are expected to contribute to wider interventions in best practice and wider environmental improvements environmental improvements – the the Pembury storage of chemicals. – the scheme responds to WINEP scheme responds to WINEP study area Implementation of study which identified water quality which identified water quality as issue measures to deter fly- as issue requiring action. This requiring action. Low risk of WFD tipping. option avoid potential loss of deterioration from avoiding loss of existing water abstraction. Long existing abstraction. Major positive term major positive effect on effect on environmental climate environmental climate change change resilience as option protects resilience as option protects existing resources for abstraction and existing resources for abstraction environment. and environment.

Water Resource Zone 2

CTR-36 2070 Company transfer In addition to effects common to all • Further refinement to Short term moderate to minor transfer options, also: pipeline routing to avoid adverse effects associated with SEW RZ3 to priority habitat where disruption for users of minor roads, RZ2 Transfer - • Short to medium term temporary possible and utilise PRoW and recreational facilities and Arlington to reduction in recreational amenity existing tracks within impact on Arlington Reservoir SSSI Barcombe of Arlington Reservoir Arlington Reservoir SSSI (10Ml/d) site. Long term minor beneficial effect • Long term or permanent for climate change resilience as degradation/loss of sensitive • careful timing of transfer options provide potential to ecological receptors including construction to minimise

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation) Arlington Reservoir SSSI and disturbance to reduce demand on stressed water LNR, priority habitat (deciduous overwintering and resources by utilising alternative more woodland, semi-improved migratory bird populations resilient sources. grassland and coastal and at Arlington Reservoir. floodplain grazing marsh) and other habitat types such as hedgerows and streams

EFF-35 N/A – plan Water reuse: Reverse • Short term, temporary disruption • Detailed routing to avoid Short term moderate to minor alternative Osmosis (RO) for users of minor roads and Lewes Downs SSSI (or adverse effects from disruption for Water reuse to option treatment of effluent footpaths/bridleways use trenchless installation) users of minor roads and PRoW, risks River Ouse: minimise impacts on from Peacehaven • strategic road network crossings to the strategic road and rail network, source – waste water treatment priority habitats and and loss/degradation of priority • short term, temporary visual archaeological desk study Peacehaven works, with RO plant habitat. impact of construction works to be carried out in (25Ml/d Option) located at Newhaven within sensitive landscape area agreement with county and pipeline to Long-term moderate to minor (South Downs National Park) archaeologist to inform adverse effects. Energy-intensive discharge upstream to pipeline routing to avoid • permanent loss or truncation of and results in the discharge of reverse River Ouse with any areas of high risk buried archaeological remains. osmosis-treated water into the River abstraction at water and/or appropriate Ouse and brine to the marine treatment works (RZ2). • short to medium term degradation intrusive investigations Brine discharge to sea of SSSIs (Lewes Brooks and and mitigation environment. Effects on water body Brighton to Newhaven Cliffs) and status, aquatic ecology and fisheries via long outfall. • careful timing of long term of permanent are the main concerns, and these construction works to degradation or loss of priority need to be studied further and avoid disturbance to bird habitat (coastal and floodplain mitigation measures and operational colonies at Brighton to grazing marsh, coastal vegetated Newhaven Cliffs and restrictions are expected to ensure the shingle, semi-improved further geotechnical effects are minimised to an acceptable grassland) and studies to ensure no risk level. hedgerows/streams, and to structural integrity of cliff disturbance of wildlife (including features Long term moderate beneficial protected species) effect for climate change resilience. • landscape elements or • potential permanent adverse features restored in effects on aquatic ecology and agreement with South

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation) WFD status of the Ouse related Downs National Park to the differing chemical Authority/visual composition and character of the appearance of new treated effluent, and also on effluent treatment plant at marine ecology resulting from Newhaven agreed with potential brine disposal at sea South Downs National (location unknown) Park Authority • permanent degradation of • potential restrictions on previously undisturbed use in very low flow or at land/productive agricultural land fish migration times –when effect of temperature and • permanent loss of a small amount chemistry changes will be of productive agricultural land greatest would occur due to construction of the new reverse osmosis (RO) • use of cascade to plant at Newhaven oxygenate discharged effluent flow amd re- mineralisation of treated effluent to improve buffering capacity if required • reduce effluent discharge rates during periods of low flow • brine dispersal pipeline to be designed to ensure adequate dispersion – potentially colocated with existing Peacehaven outfall to increase dilution • consider alternative locations for siting of effluent discharge point

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation)

• prepare a soil management plan and carry out works using methods that protect the structure and composition of soils and design maintenance access to minimise impacts on soils.

RES-27 N/A – plan New reservoir • Temporary, short term disruption • Refine pipeline routing to Long term minor adverse effects with alternative in access for users of minor roads avoid areas of ancient potential beneficial effects for Goose Green option and PRoW woodland and priority recreation reservoir habitat • permanent visual impact of reservoir within rural landscape • additional informal recreational access to be • long term or permanent provided to new loss/degradation of ancient waterbody such as woodland, priority habitat footpaths around (deciduous woodland) and reservoir. Opportunities for hedgerows/streams further recreational • permanent loss/truncation of benefits could be explored buried archaeological remains • reservoir design to ensure • permanent loss of productive potential for creation of agricultural land within the valuable new habitat for footprint of the reservoir and overwintering birds is degradation of productive included agricultural land during pipeline • reservoir design to installation. minimise visual impact, • potential permanent long term including use of landscape changes in the screening if appropriate hydromorphological regime of the • archaeological desk study Adur downstream of the reservoir and investigation as intake, with attendant adverse

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation) effects for WFD status and agreed with county aquatic ecology. Scour at the archaeologist drawdown outlet could also affect • prepare a soil rive hydromorphology. management plan and carry out works using methods that protect the structure and composition of soils and design maintenance access to minimise impacts on soils • stream realignment designed to minimise adverse effects on downstream watercourses and habitat loss (further detailed study required to inform mitigation design) • abstraction operating conditions to include limitations on abstraction volumes to avoid WFD deterioriation (further detailed study required to inform mitigation design)

• reservoir detailed design to include measures to reduce risk of scour at drawdown outlet

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation)

Water Resource Zone 3

RES-24 2035 Storage reservoir: new Short term to medium term effects • Archaeological desk study Short-term moderate adverse reservoir adjacent to associated with construction of the and intrusive investigation effects due to temporary disruption for New Arlington existing reservoir at new reservoir and associated as agreed with county users of minor roads and PRoW, risks Reservoir, R. Arlington with infrastructure would include: archaeologist to the strategic road and rail network, Ouse - 26m abstraction from the • Temporary disruption for users of • further refinement to impacts on landscape, sensitive AOD - 3,900Ml River Ouse. minor roads and pipeline routing to avoid ecological receptors, and impact on footpaths/bridleways areas of priority habitat the water quality/hydromorphological (semi-improved grassland regime of nearby surface water • strategic road network crossing and coastal and floodplain courses. (A26) grazing marsh) and utilise • loss/degradation of priority habitat existing tracks within Long-term minor adverse to (semi-improved grassland and Arlington Reservoir SSSI negligible effects associated with coastal and floodplain grazing site impacts on setting of nearby marsh) scheduled monument and loss of • careful timing of productive agricultural land within • degradation of previously construction to minimise reservoir footprint. undisturbed land/productive disturbance to agricultural land. overwintering and Potential beneficial effects for migratory bird populations Long term or permanent potential at Arlington Reservoir recreation, biodiversity and resilience effects would include: to climate change. • reservoir design to • Loss/degradation of Arlington minimise visual impact, reservoir SSSI/LNR and including use of landscape disturbance/mortality of wildlife screening if appropriate (including protected species) • work with AONB units and • visual impact of the new reservoir National Park authorities structure within a rural to identify potential for environment landsape improvements through habitat enhancements

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation)

• loss of a small area of productive • additional informal agricultural land within the recreational access to be footprint of the reservoir provided to new waterbody, such as • changes to the footpaths around the hydromorphological regime of the reservoir. Opportunities for Ouse downstream of the new further recreational reservoir, with potential adverse benefits will be explored effects on the aquatic ecology with stakeholders, linking and WFD status of the Ouse with existing recreational • low risk of INNS transfer during use of adjacent Arlington emergency drawdown site. • reservoir design to ensure potential for create valuable new habitat is included, include measures to avoid emergency drawdown risk of invasive species transfer e.g. return through intake pipe • operational rules to include any restrictions to abstraction needed to avoid impacts on fish migration • scope for advance habitat creation on surrounding land. Overall potential to add to habitat/species value of adjacent SSSI. Reservoir design should be agreed with Natural

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation) England and the Environment Agency • stream realignment designed to minimise adverse effects on downstream watercourses and habitat loss (further detailed study required to inform mitigation design) • prepare a soil management plan and carry out works using methods that protect the structure and composition of soils and design maintenance access to minimise impacts on soils

WTW-29 2025 Water treatment works: • Temporary disruption for users of In addition to mitigation Short and medium term moderate abstraction from Bewl minor roads and common to all transfer to minor adverse effects associated Bewl-Darwell reservoir replacing footpaths/bridleways, and in options, also: with disruption in access for users of Option 1c: amenity of Bewl reservoir as a existing raw water • Ensure that route of new minor roads footpaths/bridleways, Transfer of recreational resource transfer pipelines follows existing risks to the strategic road and rail 8Ml/d from Bewl • strategic road network and rail transport routes where it network, and impacts on landscape, to Hazards network crossings passes through areas of biodiversity and buried archaeology. Green via a ancient woodland and Southern Route • long term or permanent priority habitat Long term moderate beneficial degradation or loss of priority effect as this option replaces an • design of abstraction habitat (semi-improved grassland, INNS risk raw water transfer deciduous woodland, coastal and infrastructure at Bewl floodplain grazing marsh), habitat Reservoir to include types such as hedgerows and appropriate measures to

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation) streams that intersect with avoid risk of fish pipeline route entrainment • temporary short to medium term • design of new plant at disturbance of wildlife, including Bewl water treatment protected species works and appropriate screening to be agreed • risk of permanent with High Weald AONB disturbance/truncation of buried unit. Landscape archaeological remains within restoration as agreed with areas of previously undeveloped High Weald AONB unit. land • long term or permanent degradation of previously undisturbed land/productive agricultural land: • permanent visual impact of construction works and new built infrastructure (reservoir and new plant at Bewl water treatment works) within sensitive landscape area (High Weald AONB). • replaces raw water transfer with INNS risk

ZON-12 2035 New mains pipeline • Temporary, short term disruption • Use of trenchless Short to medium term minor construction for users of minor roads installation methods to adverse effects associated with RZ3 Zonal avoid direct effects on disruption for users of minor roads and • short to medium term direct Scheme - [RES- priority habitat (deciduous impacts on sensitive ecological 24/RES- adverse effects on Folkington woodland) adjacent to Reservoir SSSI receptors. 25/RES-30/EFF- Chilver Bridge Road. 25] - Arlington to Utilise existing transport Windover routes within Folkington reservoir site to avoid

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation)

Transfer (GR- • temporary visual impact of direct impacts on SSSI or RZ3-EB-2) construction works within South priority habitat. Downs National Park • restoration of landscape • long term to permanent features as agreed with degradation/loss of priority habitat South Downs National (deciduous woodland and lowland Park Authority. meadows), trees, hedgerows, streams/ponds/rivers and other potential habitat types • temporary, short to medium term disturbance of wildlife, including protected species

Water Resource Zone 4

CGW-2 2035 Septic tanks / cess pit Avoids loss of existing abstraction Monitoring to confirm Long term moderate to minor discharge to or requirement for nitrogen benefits to be agreed. beneficial effects for climate change Catchment Woodgarston reduction treatment plant. resilience and surface Management to water/groundwater WFD status. reduce nitrates The scheme is linked to water in the quality issues identified through Woodgarston WINEP scheme. Catchment

Water Resource Zone 6

NGW-44 2023 Groundwater Low risk of long term or permanent Abstraction operating Residual effects negligible. abstraction from potential adverse effects on WFD conditions to minimise risk of Aylesford existing source and status of source aquifer and Ditton reduction in WFD status for Newsprint - use surface water stream resulting from increased groundwater and surface of existing abstraction. abstraction from existing water sources or ecology of

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation) groundwater Construction of new groundwater source and new Medway. This may include sources water treatment works. abstraction from Ditton stream. limits on abstraction volumes, particularly during summer months or low flow conditions.

ZON-52 2025 New mains pipeline Temporary disruption for users of None identified Minor adverse to negligible effects in installation minor roads. Disturbance to local the short term RZ6 Zonal communities from noise and visual Scheme - impact of construction [NGW-44] - Mains from Aylesford to Kingshill booster and Kingshill booster to Beech (GR-RZ7- WD-104)

CTR-17 2028 Company transfer: Effects as common to all transfer Mitigation as common to all Minor adverse to negligible short pipeline options. transfer options. and long term effects, with minor SEW RZ1 to beneficial effect on climate change RZ7 Transfer - In addition to effects common to all In addition to mitigation as resilience Blackhurst to transfer options, also: commont to all transfer Bewl (4Ml/d) options, also: • Long term or permanent loss or degradation of ancient woodland • detailed pipeline routing to and priority habitat (deciduous avoid areas of priority woodland and lowland heathland) habitat and ancient woodland • medium to long term temporary effects on High Weald Area of Outstanding Natural Beauty

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation)

(AONB) associated with the noise • landscape restoration as and visual impact of pipeline agreed with High Weald installation and loss or AONB Unit. degradation of natural landscape features such as field boundaries and ancient woodland.

Water Resource Zone 8

RES-31 2033 New reservoir • Temporary disruption in access • Additional informal Long-term minor adverse and along minor roads and recreational access to be beneficial effects. Broad Oak footpaths/bridleways during provided to new reservoir - 36m construction and loss of footpaths waterbody such as Long term moderate adverse effect AOD - 5,126 Ml - within footprint of the reservoir footpaths, bridleways and to soils, given potential impacts on Larger Size cycle paths around grade 2 land in the ‘best and most permanent visual impact of • reservoir. Opportunities for versatile’ category. reservoir within sensitive further recreational landscape area (Blean Woods Long term moderate to major benefits will be explored beneficial effects Overall net special landscape area (SLA)) with stakeholders. and loss/degradation of important benefits to recreation and biodiversity landscape features such as field • further refinements to and contribution to environmental boundaries pipeline routing or use of climate change resilience. Large scale trenchless installation habitat and informal recreational long term or permanent • methods to avoid loss of enhancement. loss/degradation of sensitive ancient woodland and ecological receptors including woodland during pipeline SSSI (West Blean and Thornden installation Woods), ancient woodland, priority habitat (deciduous • reservoir design to avoid woodland) and significant impacts on hedgerows/streams within the SSSI and ancient footprint of the reservoir woodland and provide woodland block connectivity through sensitive advance planting

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation)

• permanent loss of grade II listed and to minimise visual buildings and loss/truncation of impact, address grade II buried archaeological remains listed building loss and provide historical • permanent loss of productive interpretation as part of agricultural land (best and most visitor information, and versatile- ALC grade 2) within the ensure potential for footprint of the reservoir and creation of valuable new degradation of productive habitat for overwintering agricultural land due to pipeline birds is included installation. • work with AONB units and • potential for long term changes in National Park authorities the hydromorphological regime of to identify potential for the tidal Stour downstream of the landscape improvements Plucks Gutter, with potential risk through habitat for WFD status but depends on enhancements. operational abstraction limitations. Scour at the • archaeological desk study drawdown outlet could adversely and investigation as affect WFD status. agreed with county archaeologist • prepare a soil management plan and carry out works using methods that protect the structure and composition of soils and design maintenance access to minimise impacts on soils • stream realignment or compensation flow and WFD measures are to be determined and will need

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation) to be designed to minimise adverse effects on downstream watercourses and habitat loss and to maintain fish migration (further detailed study required to inform mitigation design) • abstraction operating conditions to include limitations on abstraction volumes to high flows (further detailed study required to inform mitigation design)

ZON-22 2033 New mains pipeline • Temporary disruption for users of • Use of rerouting along Short term moderate to minor installation minor roads. Disturbance to local road and/or trenchless adverse effects associated with RZ8 Zonal communities from noise and installation methods to disruption to road traffic and potential Scheme - [RES- visual impact of construction avoid/minimise direct effects on sensitive ecological 23/RES-31] - works. impacts on priority habitat receptors and buried archaeology. Distribute extra and ancient woodland • Long term or permanent water from loss/degradation of notified • archaeological desk study Broad Oak (GR- features of West Blean and to be carried out in RZ8-CB-4) Thornden Woods SSSI, priority agreement with county habitat (deciduous woodland), archaeologist to inform ancient woodland and pipeline routing to avoid loss/degradation of habitat types any areas of high risk such as trees, hedgerows and and/or appropriate streams intrusive investigations and mitigation • short to medium term disturbance of wildlife, including breeding birds at West Blean and

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Option Potential effects (after standard Start year Description SEA mitigationApril 2017 Residual effects name/type mitigation) Thornden Woods and protected species • permanent loss/truncation of buried archaeological remains

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April 2017 8.4 Cumulative effects within the WRMP The cumulative effects of the combination of schemes within the WRMP19 have been considered in terms of the following:

• Proximity for construction disturbance with possible effects on traffic and people and effects on the same area or road routes

• effects on the same receptor such as river or catchment

• combined effects on the same type of receptor (e.g. overall loss of particular habitat types or protected landscape)

8.4.1 Cumulative impacts associated with construction effects Table 8.5 shows where there are potential cumulative effects associated with new infrastructure construction, including pipeline installation. The main potential for cumulative effects occurs where the construction effects are occurring in the same water resource zone over a similar time period (as indicated in Table 8.5). These effects would include noise and visual impact of the construction works for local communities, and in disruption in access for vehicle travellers and pedestrians/cyclists using the local road network. Some transfer options involve pipeline installation in more than one WRZ, and therefore Table 8.5 also indicates where spatial and temporal overlap between construction periods of transfer options routed through more than one WRZ may occur.

Table 8.5 Potential cumulative effects associated with pipeline installation and construction of new infrastructure

Temporal overlap Spatial and temporal Potential for WRZ Option name with other options overlap with options cumulative within WRZ in other WRZ effects

All Leakage reduction involving pipe Y Y repair works

2 CTR-36 N N N SEW RZ3 to RZ2 Transfer - Arlington to Barcombe (10Ml/d) (2070)

RES-27 (alternative option) N – mutually N N exclusive with EFF- Goose Green Reservoir, 30 m 35 AOD - 7,200 Ml (exact date unknown, period 2025-2045)

EFF-35 (alternative option) N – mutually N N exclusive with RES- Effluent reuse to River Ouse: 27 source – Peacehaven (25Ml/d Option) (exact date unknown, period 2025-2045)

3 RES-24 Y N Y New Arlington Reservoir (2035) ZON-12

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Temporal overlap Spatial and temporal Potential for WRZ Option name with other options overlap with options cumulative within WRZ in other WRZ effects Arlington to Folkington Reservoir Reinforcement (2035)

WTW-29 Y N Y Bewl to Hazards Green via a Southern Route (2025)

7 CTR-17 N Y – CTR-14 Y SEW RZ1 to RZ7 Transfer - Blackhurst to Bewl (4Ml/d) (2068)

8.4.2 In-combination effects on the water environment In-combination effects on the water environment could occur where the water quality or availability of a surface or groundwater body within a given catchment is affected by more than one water resource option.

Adur and Ouse

There are two preferred plan options and one alternative plan option located within the Adur and Ouse catchment. The new Arlington Reservoir scheme and water reuse scheme at Peacehaven (preferred plan alternative) both involve abstraction and/or discharges to the Ouse, however these options are mutually exclusive and therefore no in combination effects on the Ouse are anticipated. The third option located within this catchment, Goose Green Reservoir, involves astraction from the Adur.

Medway

There are two preferred plan options located in the Medway catchment. However, one of these options (WTW-29 Bewl-Darwell Option 1c: Transfer of 8Ml/d from Bewl to Hazards Green via a Southern Route) is not anticipated to generate significant effects on water quality or availability, and therefore no in combination effects are anticipated.

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Figure 8.3 Preferred plan and water environment: western region

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Figure 8.4 Preferred plan and water environment:eastern region

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8.4.3 In combination effects on landscape receptors High Weald AONB and South Downs National Park would be affected by more than one preferred plan option (or alternative plan option). Table 8.6 indicates which options are anticipated to affect each of these designations. Effects on these landscape receptors would largely be related to the temporary noise and visual impact of construction works, including loss or degradation of built and natural landscape features (e.g. woodland, hedgerows, field boundaries) during pipeline installation. Our ZON-12 scheme and water reuse at Peacehaven (EFF-35) are mutually exclusive, and therefore no cumulative impact on South Downs National Park is anticipated. In addition to the use of good construction management practices, mitigation required to address cumulative effects on designated landscape receptors includes the development of protected landscape strategies for the works within AONBs and National Parks in consultation with stakeholders (as recommended by Natural England).

Table 8.6 In-combination effects on landscape receptors

South High Downs WRZ Option name Weald National AONB Park

1 RTR-94 SESW to SEW RZ1 Transfer - Bough Beech to Riverhill SR (10Ml/d) (2054)

CGW-3 Catchment management schemes in Pembury area (2034)

2 EFF-35 (alternative option) Effluent reuse to River Ouse: source – Peacehaven (25Ml/d Option) (exact date unknown, period 2025-2045)

3 WTW-29 Bewl-Darwell Option 1c: Transfer of 8Ml/d from Bewl to Hazards Green via a Southern Route (2025)

ZON-12 RZ3 Zonal Scheme - [RES-24/RES-25/RES-30] - Arlington to Folkington Reservoir Reinforcement (GR-RZ3-EB-5)) (2035)

7 CTR-17 SEW RZ1 to RZ7 Transfer - Blackhurst to Bewl (4Ml/d) (2068)

Key

No impact on receptor

Potential impact on receptor

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April 2017 8.4.4 In-combination effects on ecological receptors There are two statutory designated sites that would be affected by two or more plan options. In addition, several of the options which require new pipeline installation would involve some loss of priority habitat, ancient woodland and non-designated habitat types such as woodland and hedgerows (see Table 8.7 and Table 8.8). As most of the options are not supported by detailed design proposals (e.g. final pipeline routes have not yet been confirmed, or construction techniques and timings have not been agreed), there are opportunities to implement ‘standard mitigation’ or specific targeted mitigation to ‘design out’ the potential for significant effects to protected sites and priority habitat types (e.g. changing a pipeline route so that it goes around a receptor as opposed to through one; timing construction works to avoid sensitive periods of the year; restricted construction activity to habitats or areas that are not integral to the maintenance of a site’s favourable conservation status).

Arlington Reservoir SSSI and LNR

The Arlington Reservoir option (RES-24) and it’s supporting zonal scheme (ZON-12) and the Arlington to Barcombe company transfer (CTR-36) all have potential to generate a significant adverse effect on Arlington Reservoir SSSI (also designated as a LNR). Mitigation will include further refinement to pipeline routings to use existing tracks within the SSSI site where possible and avoid loss of habitats of importance to overwintering and migratory bird populations, and careful timing of construction works to minimise disturbance to over wintering and migratory birds.

West Blean to Thornden Woods SSSI

The Broad Oak Reservoir option (RES-31) and it’s supporting zonal scheme (ZON-22) could both result in damage or loss to the notified features of West Blean and Thornden Woods. Mitigation for impacts associated with the zonal scheme would include the use of trenchless installation methods. Impacts associated with the reservoir would include further refinement to the pipeline routing to utilise existing tracks andtrenchless installation methods where possible. In addition, construction timings would be managed to minimise disturbance to breeding bird populations.

Priority habitat, ancient woodland and non-designated habitat types

Table 8.7 shows where options included in the preferred plan would have adverse effects on areas of priority habitat, and Table 8.8 shows where adverse effects on ancient woodland or other habitat types such as woodland and hedgerows would occur. Cumulative effects have been identified for three types of priority habitat (semi-improved grassland, deciduous woodland and coastal and floodplain grazing marsh), ancient woodland and non-designated habitat types such as woodland, hedgerows and grassland which would each be affected by the construction or operation two or more options as indicated in Table 8.7 and Table 8.8.

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April 2017 Table 8.7 In combination effects on priority habitats

Priority habitat

WRZ Option ref Option name Semi- Deciduous Coastal and improved woodland floodplain grassland grazing marsh

1 RTR-94 SESW to SEW RZ1 Transfer - Bough Beech to Riverhill SR (10Ml/d)

2 CTR-36 SEW RZ3 to RZ2 Transfer - Arlington to Barcombe (10Ml/d)

EFF-35 Effluent reuse to River Ouse: source (alternative – Peacehaven (25Ml/d Option) option)

RES- Goose Green Reservoir, 30 m AOD 27(alternative - 7,200 Ml option)

3 RES-24 New Arlington Reservoir, R. Ouse - 26mAOD - 3,900Ml

ZON-12 RZ3 Zonal Scheme - [RES-24/RES- 25/RES-30] - Arlington to Folkington Reservoir Reinforcement (GR-RZ3- EB-5))

WTW-29 Bewl-Darwell Option 1c: Transfer of 8Ml/d from Bewl to Hazards Green via a Southern Route

7 CTR-17 SEW RZ1 to RZ7 Transfer - Blackhurst to Bewl (4Ml/d)

8 RES-31 Broad Oak Reservoir - 36mAOD - 5,126 Ml

ZON-22 RZ8 Zonal Scheme - [RES-23/RES- 31] - Sturry Remainder Reinforcement & Broad Oak Mains (GR-RZ8-CB-4)

Key

No impact

Potential impact on priority habitat

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April 2017 Table 8.8 In combination effects on ancient woodland and non-designated habitat types

Woodland, hedgerows Ancient WRZ Option ref Option name and other woodland habitat types

1 RTR-94 SESW to SEW RZ1 Transfer - Bough Beech to Riverhill SR (10Ml/d)

2 CTR-36 SEW RZ3 to RZ2 Transfer - Arlington to Barcombe (10Ml/d)

EFF-35 Effluent reuse to River Ouse: source – Peacehaven (25Ml/d Option)

RES-27 Goose Green Reservoir, 30 m AOD - 7,200 Ml

3 RES-24 New Arlington Reservoir, R. Ouse - 26mAOD - 3,900Ml

ZON-12 RZ3 Zonal Scheme – [RES-24/RES-25/RES-30] – Arlington to Folkington Reservoir Reinforcement (GR-RZ3-EB-5))

WTW-29 Bewl-Darwell Option 1c: Transfer of 8Ml/d from Bewl to Hazards Green via a Southern Route

6 ZON-52 RZ6 Zonal Scheme - [NGW-44] - Mains from Aylesford to Kingshill booster and Kingshill booster to Beech (GR-RZ7-WD- 104)

7 CTR-17 SEW RZ1 to RZ7 Transfer - Blackhurst to Bewl (4Ml/d)

8 RES-31 Broad Oak Reservoir - 36mAOD - 5,126 Ml

ZON-22 RZ8 Zonal Scheme - [RES-23/RES-31] - Sturry Remainder Reinforcement & Broad Oak Mains (GR-RZ8-CB-4)

Key

No impact

Potential impact on receptor

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Figure 8.5 Preferred plan and biodiveristy and landscape constraints: western region

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Figure 8.6 Preferred plan and biodiveristy and landscape constraints:western region

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April 2017 In addition to the use of good construction management practices and implementation of standard mitigation such as full habitat restoration, cumulative effects on ancient woodland, priority habitats (coastal and floodplain grazing marsh, deciduous woodland and semi-improved grassland) and other potential habitat types would be mitigated through further refinement of pipeline routing for the relevant options or the use of trenchelss installation techniques to avoid direct impacts on habitats where possible. Enhancement measures will ensure no net loss of priority habitats and, where practicable, opportunities for net gain will be pursued.

The overall approach to mitigation should be informed by national environment programme work on chalk grassland habitat restoration in the investment period 2015 to 2020. We will work with Natural England and the relevant AONB units and National Park authority to identify potential opportunities to contribute towards strategic landscape and biodiversity initiatives (such as the Woodland and Downland Focus Areas) through our enhancement measures. In addition, we will engage with local local authorities and Highways England to identify how and where biodiversity gains can be incorporated into smaller scale infrastructure and pipeline installation works where appropriate. This could include measures such as creation of grass verges and tree planting where pipelines would be installed alongside the highway, reinstatement of grassed areas using wild flower or species rich seed mixes, provision of hard engineered bat, bird and mammal boxes and hedgerow augmentation.

8.5 Cumulative effects with neighbouring water company plans Options included within the water resources management plans of neighbouring water companies may interact with options included within our dWRMP19 to generate combined effects. Neighbouring water companies include:

• Thames Water

• Affinity Water

• SES Water

• Southern Water

• Portsmouth Water

A stage 1 and stage 2 screening process has been undertaken to identify where there could potentially be an interaction during construction and operation, and to focus the assessment on options that would need to be assessed further. This was carried out by considering:

Potential for direct interaction:

• Location within the same river catchments or groundwater aquifer

• close proximity (within approximately 5km), even if in different catchments (to capture potential cumulative construction disturbance with possible effects on traffic and people and effects on the same area or road routes)

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April 2017 Impacts on receptors:

• Options affecting the same types of protected landscapes and habitats even if independent of any direct interaction, for example the combined number of transfers passing through AONB or resulting in the loss of ancient woodland

• options within the same river catchment, in close proximity to one another, or affecting the same receptors were then assessed further to determine potential for cumulative effects

8.5.1 Construction disturbance Two of our preferred plan options (RES-31 Broad Oak Reservoir and RTR-94 SESW to SEW RZ1 Transfer - Bough Beech to Riverhill SR) and two of our alternative plan options (RES-27 Goose Green Reservoir and EFF-35 water reuse at Peacehaven) are located within or in close proximity to other water company supply areas, and therefore it is considered likely that cumulative effects associated with construction disturbance could occur between these options and other water company supply options . These effects would include noise and visual impact of the construction works for local communities, and in disruption in access for vehicle travellers and pedestrians/cyclists using the local road network.

Southern Water’s SWA_Plu (Stourmouth WSW) was not included within their dWRMP, however, as part of information provided to Ricardos in order to inform their initial revised assessment of cumulative impacts between Water Resources in the South East (WRSE) group WRMPs Southern Water have indicated that SWA_Plu may form part of their WRMP. Southern Water’s SWA_Plu option and our RES- 31 option are located within 5 km of eachother, and therefore there is potential for cumulative effects on local communities and travellers if these options are constructed within a similar time frame.

Mitigation for these effects would include liaison with Southern Water and SES Water to ensure that construction timings are such that cumulative effects on amenity for local communities and access/amenity for travellers is minimised as far as possible.

8.5.2 Water environment Surface water

Adur and Ouse

There is a potential cumulative effect on the Sussex East coastal waterbody arising from our water reuse at Peacehaven (EFF-35) plan alternative option and Southern Water’s Coastal Desalination – Shoreham Harbour (DES_Sho10). Both of these options involve brine discharge to the Sussex East coastal waterbody. None of these options are anticipated to have significant adverse impact on the waterbody in isolation, however as a precaution, further study (such as brine dispersion modelling) in conjunction with Southern Water should be undertaken to determine whether there is a significant cumulative effect on this waterbody.

Medway

In the Medway catchment the proximity and potential interactions between the proposed South East Water new groundwater option (NGW-44) and the Southern Water effluent reuse scheme at Aylesford (PWR_WR40) should be considered further in relation to flows and water quality of the Medway.

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April 2017 Stour

Southern Water’s SWA_Plu (Stourmouth WSW) was not included within their dWRMP, however, as part of information provided to Ricardos in order to inform their revised assessment of cumulative impacts between Water Resources in the South East (WRSE) group WRMPs Southern Water have indicated that SWA_Plu may form part of their WRMP. There is a potential in combination effect on the water quality of the river Stour as a result of Southern Water’s SWA_Plu option and our Broad Oak Reservoir (RES-31) option which are located within 5 km of one another and both involve abstraction from the river Stour.

Groundwater

Our groundwater abstraction scheme at Aylesford Newsprint (NGW-44), Southern Water’s Refubishment of Rogate and BH rehabilitation (BR_Rog), Scheme to bring West Chiltington back into service (BR_Smo), Sussex Coast_Lower Greensand (ASR_SCL1) and Affinity Water’s Canal and Rivers Trust and SGSK Boreholes (AFF-NGW-WR4-0624) all involve abstraction from the Lower Greensand aquifer. As our groundwater abstraction scheme (NGW-44) involves continuation of an existing licence and given the distances between our option and Southern Water and Affinity Water options, cumulative effects on the Lower Greensand aquifer are considered unlikely. Sensitive landscape areas

Table 8.9 is based on Table 1 of the WRSE draft CEA,and lists those options which have been identified as having potential significant effects on protected areas in other water company dWRMPs grouped according to receptor.

Effects on North Wessex Downs, High Weald and Kent Downs AONBs and South Downs National Park associated with our WRMP19 options listed in Table 8.9 would mainly include short term noise and visual effects of construction, and short to medium term effects associated with vegetation loss during pipeline installation. There would be long period of elapsed time between implementation of our options located within North Wessex Downs AONB and Kent Downs AONB and other water company options located within these areas, and hence cumulative effects are considered unlikely. Mitigation for cumulative effects on High Weald AONB and South Downs National Park would include liaison with Southern Water and Portsmouth Water to manage construction timings such that noise and visual disturbance is minimised and reinstatement of habitats and landscape features that avoids net loss. Mitigation for adverse effects would include development of protected landscape strategies for the works in consultation with stakeholders (as recommended by Natural England).

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April 2017 Table 8.9 Potential in combination effects on landscape receptors

Water Receptor Option ID Options Name Company

South Downs Portsmouth R013 Havant Thicket (23 Ml/d) (2029) National Park B5290 Clanfield to Tilmore Bulk Transfer (unknown)

South East ZON-12 RZ3 Zonal Scheme - [RES-24/RES-25/RES-30] - Arlington to Folkington Reservoir Reinforcement (GR- RZ3-EB-5) (2035)

EFF-35 EFF-35 ( alternative option) Effluent reuse to River Ouse: source – Peacehaven (25Ml/d Option) (2025-2045, exact timing unknown)

North Wessex South East CGW-2 Septic tanks / cess pit discharge to Woodgarston (2035) Downs AONB Thames RES-GW- Moulsford 1 (2065) MOU1-3.5

High Weald South East CGW-3 Targeted catchment management interventions in the AONB Pembury area (2034)

CTR-17 SEW RZ1 to RZ7 Transfer - Blackhurst to Bewl (4Ml/d) (2068)

WTW-29 Bewl-Darwell Option 1c: Transfer of 8Ml/d from Bewl to Hazards Green via a Southern Route (2025)

Southern RES_RaB Raising Bewl by 0.4m (prior to 2030)

Kent Downs Southern BS_Win South East Water to Kent Thanet (Birchington) (2029) AONB IZT_Sel3 Selling-Fleete Main – maximise capacity (2027)

South East RTR-94 SESW to SEW RZ1 Transfer - Bough Beech to Riverhill Water SR (10Ml/d) (2054)

8.5.3 Ecological receptors No potential in combination effects on protected sites with other water company dWRMP preferred plan options have been identified.

8.6 Cumulative effects with other plans or programmes In terms of other plans and programmes, most relevant plans have been included in the policy, plans and programmes (PPP) review and have been taken into account in the options assessment. Relevant plans will need to be kept under review and updated through the WRMP process and as options are taken forward including specific locally relevant plans as appropriate. The larger infrastructure options occur later in the programme and will all be subject to a further WRMP and SEA review cycle and will need to be developed and investigated further. The potential for cumulative effects should be considered as part of this process. The key plans taken into account are described below.

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April 2017 8.6.1 River basin management plans The river basin management plan (RBMP) approach was established under the WFD, and promotes a joined-up approach to the delivery of WFD compliance. The key issues that arise from this are that there has to be a coordinated approach (water operators have a part to play in the delivery of WFD), and measures have to be taken to ensure water bodies achieve ‘good-status’ and all future projects and current operational activities must ensure ‘no deterioration’ of water bodies (in WFD terms).

The inclusion of a statutory requirement in WFD to prevent deterioration is one which will have a potential impact on new source development (even if sources are developed within the headroom of current abstraction licences). As a statutory requirement, WFD no deterioration schemes are not subject to assessment of affordability. Water bodies are not permitted to deteriorate from the baseline status reported in the first RBMPs published in December 2009. RBMPs set out an objective for each water body and summarise programmes of measures which will be implemented to achieve this. The current RBMPs were published in 2015 and cover the period 2015-2021. Waterbody objectives within the 2015 RBMPs are set no lower than the 2015 WFD classification for the waterbody.

The Thames and South East RBMPs have been taken into account in the WRMP19 WFD assessment (see Appendix F), which has been incorporated into the overall SEA. The WFD assessment finds that the preferred plan options are compliant with the relevant RBMP objectives, assuming that local measures identified within the relevant RBMP and delivered through environmental permitting are not compromised, and are provided as mitigation wherever cost effective and multiple benefits can be achieved. Further information is provided in Appendix F.

8.6.2 Drought plans The cumulative effects assessment has focussed on our drought plan options and Thames Water, Affinity Water, SES Water, Southern Water and Portsmouth water drought plan options where new options are proposed as part of the drought plan e.g. new abstractions or pipeline routes. No specific options with potential for cumulative effects with our WRMP have been identified within the Thames Water, Affinity Water and Portsmouth Water drought plans. SES Water’s drought plan includes fast tracking of infrastructure improvements in critical areas where demand is greatest are also considered, but these are mainly network improvements and cumulative effects associated with construction disturbance during pipeline installation are discussed in section 8.4.1.

Our drought plan includes two options involving abstraction from the Ouse during winter (Ardingley Reservoir) and summer (Barcombe Mills) which are extensions of existing licences. Impacts on the Ouse associated with these options would be short to medium term in duration, and it is anticipated that cumulative effect on the Ouse from these drought plan options and our Arlington Reservoir (RES-24) or water reuse at Peacehaven (EFF-35) WRMP options could likely be mitigated through careful operational management and therefore significant adverse cumulative effects are unlikely.

The SEA for the Southern Water drought plan identifies the need for further assessment of two abstraction options within the eastern area, Plucks Gutter and Powdermill, in the lead up to drought conditions. Interaction between the Southern Water abstraction at Plucks Gutter and our Broad Oak Reservoir WRMP option (RES-31) is unlikely given that Broad Oak Reservoir is a winter storage option abstracting under high flow conditions. Potential cumulative effects between our drought plan options, WRMP19 options and Southern Water schemes will need to be considered further as part of the East Kent strategy.

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April 2017 8.6.3 Shoreline management plans and flood risk management plans There are no coastal schemes within our WRMP and no interactions with shoreline management plans are anticipated. No conflicts with proposals within the South East Flood Risk Management Plan have been identified for the plan alternative option water reuse at Peacehaven (EFF-35), however if this scheme is implemented then the flood risk plan should be reviewed further as option design develops and considered in relation to scheme operation.

8.6.4 Local development plans and planned major infrastructure Local development plans and key proposals have been considered during development of the WRMP.

Local development plans

No conflicts with proposals within local development plans are anticipated.

Major infrastructure projects

The potential interactions between National Grid’s Richborough Connection overhead distribution powerline and Broad Oak Reservoir and potential for cumulative or in combination impacts on the local environment have been discussed through the development consent order (DCO) inquiry process. As part of this process the Broad Oak Reservoir design was developed further to explore potential conflicts and mitigation required to ensure that the Richborough Connection did not prevent the development of the reservoir. This work also further clarified the environmental mitigation and enhancement opportunities from the reservoir. Based on recommendations from the Inspector’s Report the DCO granted on the 3 August 2017 for the Richborough Connection included amendments to the scheme on pylon location and requirements for National Grid to provide mitigation to avoid combined effects such as provision of bird diverters. The report also identifies that diversion of the Sarre Penne may not be possible given the need to accommodate the Richborough Connection structures and maintenance requirements, and therefore to allow both schemes to go head a WFD derogation may be required. Discussions with Environment Agency and the implications of the overhead line will need to be built into the future reservoir design development.

There are a number of national infrastructure projects which have been identified as having potential for significant effects on protected landscapes. These include Rampion Windfarm and the Southampton to London Pipeline (SLP) Project (South Downs National Park) and Cleve Hill Solar Park (Kent Downs AONB). These projects are currently at the scoping stage of environmental assessment and therefore the significance of the effects on these receptors, and potential for cumulative effects with the our WRMP19, are currently uncertain.

8.7 Summary of WFD and designated sites assessments

8.7.1 WFD assessment A WFD assessment was undertaken in parallel with the SEA, the outcomes of which have been incorporated into the SEA of individual options against SEA objective six and assessment of cumulative effects. The WFD assessment concluded that there are two preferred plan options and two alternative plan options which present a moderate risk at either construction and/or operation stages, with the remainder of options assessed as low risk. Further information is available within the WRMP WFD assessment report (see Appendix F). Catchment management, water treatment work upgrade and reservoir options also have potential to deliver additional WFD benefits.

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April 2017 As options progress towards delivery, the environmental permitting process will take into account any potential risks of water body deterioration or conflict with measures within the relevant 2015 RMBP, as well as identifying suitable mitigations either identified by sector or as catchment partnership measures included within part 1 of the relevant 2015 RBMPs. Identification and agreement of adequate mitigation measures will require further assessment, however recommended sector-based mitigations are likely to include:

• Operate winter storage abstractions during specified high flow conditions

• design to prevent or remove barriers to fish and eel migration and avoid entrainment

• further study of options for Broad Oak reservoir addressing conflict with Richborogh Connection as outlined in section 8.6 above, including potential WFD article 4.7 derogation

• optimise the timing of pipeline and infrastructure construction

• monitoring approaches to demonstrate no deterioration taking account of existing environment agency monitoring undertaken and relevat water industry national environment programme (WINEP) studies

8.7.2 SSSI screening assessment The SSSI screening assessment for the preferred plan comprised two stages, as set out below. More detailed information regarding the screening process and results is provided in Appendix G.

Stage one

The first stage of SSSI screening was to identify SSSIs that are located:

• Within 200 m of a pipeline

• within 2 km of an option location (excluding regional and company transfers and zonal schemes)

• can be influenced by changes in water quality and availability or channel morphology (as identified from the list of operations requiring consent available on the Natural England website) and are located downstream of proposed abstraction or discharge points from effluent reuse, groundwater abstraction and reservoir options

SSSIs identified as meeting the criteria set out above are considered those at risk of experiencing significant impacts following implementation of the standard mitigation measures set out in Table 6.4.

Stage two

The second stage of SSSI screening was to determine on an option-by-option basis whether there was a potential pathway for impact for those SSSIs identified as meeting the criteria set out above, taking into account the specific interest features of each site (as identified using site citations, operations requiring consent lists and summary condition information available on the Natural England website18), option design and standard mitigation measures proposed in Table 6.4.

18 If favourable condition tables can be made available by Natural England then this information could also be incorporated into the assessment process

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April 2017 Summary of SSSI screening results

A total of 25 SSSIs were considered at risk of experiencing significant effects following stage one of the SSSI screening procedure. In the majority of cases, significant impacts could be ruled out following stage two of the screening assessment for one of the following reasons:

 There is no hydrological connection between the site and target aquifer (for groundwater options) or surface watercourse from which an abstraction is proposed (for reservoir and water reuse)

 the notified features of a site are either not sensitive to changes in water availability or quality or changes in channel morphology, or are sensitive to these factors but are not influenced by the surface watercourse from which an abstraction or discharge is proposed (for desalination, reservoir and water reuse options)

 there would be no direct impact on the site as a result of pipeline installation, and it is considered that standard construction measures would adequately reduce the risk of harm to an acceptable level

Following stage two screening six preferred plan options that were identified as having potential to generate significant adverse effects on a total of six unique SSSIs. The relevant options and designated sites are listed in Table 8.10.

Table 8.10 SSSIs requiring further mitigation

Option SSSI

RES-24 Arlington Reservoir New Arlington Reservoir, R. Ouse - 26m AOD - 3,900Ml

RES-31 West Blean and Thornden Woods Broad Oak Reservoir - 36m AOD - 5,126 Ml

RTR-94 Hubbard’s Hill SESW to SEW RZ1 Transfer - Bough Beech to Riverhill SR (10Ml/d)

CTR-36 Arlington Reservoir SEW RZ3 to RZ2 Transfer - Arlington to Barcombe (10Ml/d)

ZON-12 Folkington Reservoir RZ3 Zonal Scheme - [RES-24/RES-25/RES-30] - Arlington to Folkington Reservoir Arlington Reservoir Reinforcement (GR-RZ3-EB-5)

ZON-22 West Blean and Thornden Woods RZ8 Zonal Scheme - [RES-23/RES-31] - Distribute extra water from Broad Oak (GR-RZ8-CB-4)

EFF-35 Lewes Brooks Effluent reuse to River Ouse: source – Peacehaven (25Ml/d Option) Brighton to Newhaven Cliffs

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April 2017 Where stage two of the screening assessment identified potential for significant effects on a SSSI following implementation of standard mitigation measures then further mitigation measures have been recommended in Table 8.4 (and set out in Appendix E).

8.7.3 HRA An HRA stage 1 and stage 2 assessment (see Appendix A) was undertaken in parallel to the SEA, with the HRA outcomes incorporated into the overall SEA. The HRA concluded that none of the WRMP preferred plan options have pathways which could result in the significant effects to a Natura 2000 site.

8.7.4 MCZ screening assessment The MCZ screening assessment has identified that one option included within the WRMP preferred plan, the water reuse at Peachaven (EFF-35) plan alternative option, could potentially pose significant risk to a MCZ (Beachy Head West) both alone and in combination with other plans or projects. In the event that this plan alternative option is implemented, then a down the line stage 1 MCZ assessment will be undertaken. Further information is provided in Appendix D.

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April 2017 9. Implementation and monitoring plan

9.1 Monitoring targets and indicators The strategic environmental assessment (SEA) regulations require that the significant environmental effects of the implementation of plans and programmes are monitored to identify at an early stage unforeseen adverse effects, and to be able to undertake appropriate remedial action. The environmental report is also required to provide a monitoring plan describing how the requirement to monitor will be implemented (stage E).

To meet this requirement indicators and targets have been set for each SEA objective, these are listed in Table 9.1. These will provide the basis for monitoring the effects of the plan against the objectives following implementation.

9.2 Monitoring plan The purpose of the monitoring plan is to enable a proactive approach by allowing us to review the predicted impacts of the water resource management plan (WRMP19) and to undertake additional mitigation if required. It also encourages continual improvement towards the environmental objectives. The monitoring results will provide information that can be used to inform the SEA during the next WRMP review in five years’ time.

It should be noted that the targets accompanying the indicators refer to the environmental effects of the options following the implementation of any required mitigation measures, rather than the effects associated with ‘unmitigated’ options. Where ‘zero’ targets have been proposed, this reflects the weight of legislation or policy which also relates to the receptors/issues encapsulated in the indicators.

The monitoring proposals for the WRMP will also be updated following consultation on this environmental report and will form part of the SEA post adoption statement which will be published with the final plan.

In most cases more detailed baseline collection and project studies will be required to confirm the significance of environmental effects and ensure appropriate mitigation is included as part of the option design. Option mitigation and monitoring arrangements proposed at this stage will need to be reviewed in the light of the findings of the detailed studies.

We have standard procedures in place where for the larger schemes further detailed work is undertaken and reviewed via the internal environmental team. If on site surveys reveal unforeseen environmental impact they would work with regulators and key internal and external stakeholders to discuss and develop the scheme further whilst also considering other alternatives.

Monitoring is in place for many indicators that are relevant to the SEA objectives in our annual Performance, People and Planet 2016/2017 Annual Report which can be accessed through the following link: corporate.southeastwater.co.uk/media/1599/sewpppreport2017v2.pdf

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April 2017 This monitoring reporting includes case studies on individual projects to provide feedback on key measures and develop good practice.

The draft monitoring plan in Table 9.1 therefore identifies where indicators are already reported and where additional monitoring is proposed.

9.3 Environmental action plan for implementation In addition to monitoring, there are a number of plan related actions required to ensure findings from the SEA are taken forward. This includes improving links between the SEA findings and recommendations to the Business Plan to ensure the SEA requirements for the plan and the options implementation over the next five-year period is supported with appropriate funding for monitoring, procedural improvements, further environmental studies and mitigation.

9.3.1 WRMP14/SEA actions The WRMP14 SEA environmental action plan identified the need to develop a process so that as individual schemes are brought forward for implementation they are reviewed using the information from the SEA process as a starting point. This included the baseline information, the design assumptions and mitigation measures and further studies recommended. This is now in place and all environmental decisions are recorded and approved via our internal environmental team. Key decisions throughout a project’s lifetime are documented via a project implementation document (PID) process. Projects are stopped at various gateways and cannot proceed to the next gateway until they have had environmental sign off.

These procedures are fully embedded in planning and operational practice and include mandatory links to the outputs of the SEA process via the option dossiers for individual schemes.

There have also been capacity building actions supporting planning and operational procedures through staff training from induction training to bespoke courses on protected species and development of bespoke guidance.

We continue to benefit from the involvement of the environment focus group (EFG) to provide challenge to both the creation and delivery of the WRMP via an expert group of informed stakeholders and this is to continue for WRMP19.

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April 2017 Actions completed over the last plan period which contributed to meeting SEA objectives (as reported in WRMP19) include:

• Installing more than 286,000 water meters and providing water efficiency advice and the offer of free water saving devices to all of those customers

• developing a “My Water Use Report” through partnership with Advizzo, an innovative behavioural economics company, which has seen a reduction in consumption of between one and two per cent during a pilot of 22,000 customers

• people are using less water, down from 172 litres per head per day (l/h/d) in 2011/12 to 151 l/h/d in 2016/17

• 90 per cent of reported leaks are now fixed within 48 hours an investment in technology to find more of the smaller leaks

• we were committed to reduce leakage to 90.9 Ml/d by 2016/17 but have outperformed this as our reported leakage figure for 2016/17 was 88.6 Ml/d

• we are on course to deliver the water industry national environmental programme (WINEP) by the agreed dates, including catchment management investigations and biodiversity reports

• five resource schemes, on course for delivery during the 2015 to 2020 investment period, including one where potential ancient woodland impacts have been avoided

Table 9.1 Monitoring plan

Targets Indicators

Objective 1: Protect public health and promote wellbeing

SEA topics: Population and human health

T.1 Maintain and improve access to affordable, Annual Reporting on environmental indicators in reliable drinking water meeting forecast demand Performance, People and Planet Re port Customer satisfaction monitoring T.2 Improve water affordability for vulnerable groups/ customers. Value for money Level of service T.3 Improve water access for vulnerable groups and general public. Cost per litre. Supply disruptions, taste, odour, colour etc. Service incentive Add to annual reporting: Vulnerable households.

T.4 Minimise extent and period of disruption to traffic Annual Reporting on environmental indicators in related to construction and maintenance. Performance, People and Planet Report: Add to annual reporting Number of highway notices for traffic works Number and duration lane closures or diversions

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Targets Indicators

T.5 Minimise, access restrictions and noise Annual Reporting on environmental indicators in disturbance to people and their private assets from Performance, People and Planet Report construction and operation of schemes Number of complaints received Proactive approach taken to communications planning for all construction and operational projects

T.6a No net permanent loss of important recreational Scheme monitoring amenity Public footpath/cycleway affected by works T.6b Minimise extent and period of temporary disruption to public open space areas related to construction and maintenance

T.7 Generation of new recreational facilities. Scheme monitoring Account taken of local views on new recreation provision

Objective 2: Protect, and where appropriate enhance, built and natural assets and reduce waste

SEA topics: Material assets

T.8 Minimise material consumption and waste during Scheme monitoring construction and operation of schemes. Materials and waste plans for schemes including identifying: Tonnes construction waste sent to landfill as a proportion of total waste produced Tonnes construction waste recycled on-site and off- site as a proportion of total waste produced.

T.9 No water treatment sludge sent to landfill Annual reporting on environmental indicators in Performance, People and Planet Report % tonnes sludge reused or recycled

Objective 3: Protect and enhance biodiversity and contribute to resilient ecosystems

SEA topics: Biodiversity, flora and fauna

T.12 No adverse effect on integrity of European Annual reporting on environmental indicators in (Natura 2000 and Ramsar), national or regional level Performance, People and Planet Report designation, and where feasible seek to contribute to Condition status of South East Water’s sites of special achieving favourable conservation status scientific interest (SSSIs) is reported Scheme monitoring Area of each designated site/ type affected, and likely impact. Actions taken to avoid, mitigate or compensate impact

T.13 Biodiversity net gain Scheme monitoring Area of ancient woodland lost /avoided

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Targets Indicators Length of mains rerouted or use of alternative installation methods to avoid ancient woodland losses Total area of priority habitat restored and created Number/linear metres of e.g verges creation, bird and mammal box installation/hedgerow augmentation Reporting on net gain at scheme and plan level and development of a tracking tool to capture net gain

T.14 No reduction in ecological value of rivers Annual reporting on environmental indicators in including fish migration Performance, People and Planet Report Water industry national environmental programme (WINEP) reporting e.g. including eel screens and sustainability investigations

Objective 4: Protect landscapes, townscapes and visual amenity

SEA topics: Landscape, cultural heritage, material assets

T.15 long term maintenance of landscape quality Annual reporting on environmental indicators in through landscape design and mitigation and Performance, People and Planet Annual Report enhancement Number of schemes in designated landscapes planned or under construction Scheme monitoring Development of protected landscape and biodiversity strategies to guide work in areas of outstanding natural beauty (AONBs) and national parks Land use/landscape features re-establishment monitoring over appropriate period - areas//km successfully restored to meet strategy requirements e.g. no of trees planted or hedge length

T.16 Agree design standards with AONB Annual reporting on environmental indicators in management units and South Downs National Park Performance, People and Planet Annual Report authority Number of schemes using agreed design standards

Objective 5: Reduce greenhouse gas emissions

SEA topics: Climatic factors

T.17 Minimise carbon emissions from construction Scheme monitoring Schemes including reviews of carbon footprint (total tonnes) of construction and any action taken to reduce embedded carbon e.g. linked to waste reduction, transport choices, material etc

T.18 Increase use of renewable/low carbon energy Annual reporting on environmental indicators in sources in new schemes Performance, People and Planet Report Average carbon emissions per customer Add to annual reporting

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Targets Indicators Number of South East Water sites using renewable sources of energy potential to accommodate for future higher energy intensive schemes Percentage of energy supply from renewable sources

T.19 Minimise the annual carbon emissions from Add to annual reporting operation (tonnes and t/Ml). Carbon footprint (total tonnes) per year, predicted over plan period

Objective 6: Contribute to environmental climate change resilience

SEA topics: Climatic factors, population and human health, biodiversity, water

T.20 Improve resiliency of the environment to climate Annual reporting on environmental indicators in change Performance, People and Planet Report WINEP implementation Add to annual reporting Balance of vulnerable and resilient water resources Water industry strategic environmental requirements (WISER) document indicator monitoring for enhancing environment and supply resilience

Objective 7. Protect and improve surface water and groundwater status

SEA topics: water, climatic factors, biodiversity

T.21 Contribute to achieving WFD quality/resource Annual reporting on environmental indicators in objectives for surface water bodies and groundwater Performance, People and Planet Report used for supply. WINEP implementation reporting Add to annual reporting and scheme monitoring Additional monitoring for relevant WRMP schemes agreed with the Environment Agency with respect to no deterioration or improvement objectives identified (where this is not already addressed through WINEP)

Objective 8: Avoid flood risk

SEA Topics: Water, population and human health, climatic factors

T.22 No net flood plain area (ha) lost as a result of Annual reporting on environmental indicators in this plan, and where possible increase functioning Performance, People and Planet Report flood plain Sites vulnerable to 1:200 flood risk Scheme monitoring Reduced groundwater flood risk Loss of flood plain of action taken to avoid or minimise compensation required or increased storage/ retention provided.

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Targets Indicators

Objective 9: Protect and, where appropriate, enhance cultural heritage assets

SEA Topics: Cultural heritage, material assets, landscape

T.23 Avoid impact on cultural heritage designated Add to annual reporting sites and settings and to minimise risks to buried Development of standard approach on addressing archaeology/palaeo-environmental remains. archaeological risk on projects underway and to be adopted. Scheme monitoring Case study reporting on approach to cultural heritage and actions taken to investigate cultural heritage and avoid impacts this can include reporting on: Identification of cultural heritage assets affected or avoided including setting and access impacts. Identification of action taken to investigate potential interest. and any positive measure taken to provide interpretation, improve access, record or incorporate cultural heritage aspects in scheme. Extent of rerouting or re-siting to avoid impacts and additional pipeline or additional cost

Objective 10. Protect quality and function of soils

SEA Topics: Soils, biodiversity, flora and fauna, landscape, water

T.24 No net loss of geological SSSI Scheme monitoring Report in scheme case studies if any adverse effects on geological SSSI affected by water resource options or actions taken to avoid impacts.

T.25 Minimum disturbance or loss of high quality land Annual reporting on environmental indicators in as a result of this plan and minimal net loss of soil Performance, People and Planet Report resources. Area of land subject to catchment management involving soil improvement, pesticide reduction or sediment retention Scheme monitoring Scheme reporting on agricultural land loss of best and most versatile land and use of scheme soil resources - or area of contaminated land remediated - reporting through case studies in annual reports.

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April 2017 9.3.3 WRMP19/SEA actions The key short-term and long-term actions are identified in the environmental action plan in Table 9.2. This incorporates the main WRMP14 SEA actions, and provides a brief update on progress and addition or amendment where needed to address findings from the WRMP19 SEA.

Table 9.2 Environmental action plan Including update on WRMP14

Reference Action from WRMP14 Target Monitoring number

Short term (during next five years) 2020-2025

EAP1 Robust procedures for developing projects and All schemes reviewed taking Update as incorporating SEA findings and mitigation into account any part of requirements assumptions and mitigation annual and further identified through report input Procedural actions from WRMP14 are fully in place the SEA and use as including a direct link for the PID to the option dossiers input into produced for the SEA/ WRMP to ensure any design next works improves the environmental impact in the WRMP and dossier rather than going backwards. Schemes are SEA now fully linked to relevant enabling works and potential interactions with other schemes from the cumulative effects assessment in the SEA. Develop scheme monitoring plans as part of process for taking SEA requirements forward taking account of monitoring data already collected and where additional information is needed.. Further action to be taken: develop approach for emergency or quick response actions on leakage reduction to flag sensitive sites, develop working procedures for sensitive sites

EAP2 Reference to Natural England's Standing Advice for Protected Species identified in WRMP14 and this is being developed further to include tailored guidance for South East Water activities. Capacity building training for good environmental practice within the internal environment team is in progress and will continue to be rolled out and developed to support project and operational work and to increase awareness of environmental issues across teams. South East Water will develop companywide licencing (an organisational licence) with Natural England for addressing protected species across projects in a consistent and clear way.

EAP3 Links to the WRMP14 SEA findings and Linking into to delivery and recommendations were incorporated into the South funding through the Business East Water Business Plan with the additional studies Plan undertaken on Broad Oak reservoir, New Arlington and Peacehaven - these were undertaken and fed into the WRMP19 SEA.

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Reference Action from WRMP14 Target Monitoring number

EAP4 Take account of WISER and Environment Agency Coordinated approach valuation document recommendations related to valuation in decision making valuing environment and integrating this further in and integrate consistent decision making - explore taking forward the natural approach across capital accounting and ecosystems services programmes and business assessment approaches. plan Develop the valuation framework used in the WRMP as a starting point to provide more complete environmental valuation for water resources and demand management and consider integrating in other work streams e.g. to value benefits of water savings, sustainability reductions and options appraisal.

EAP5 Implement the schemes as outlined in the WRMP19 to Schemes implemented 2025 with SEA taken into account. within asset management period take on board Surrey Hills to Fleet (Marshall Road to Crickethill relevant environmental Roundabout) pipeline – potential impact on wetland information and assessment SSSI - provide case study on how this is addressed from SEA and meet WINEP and action taken sustainability reduction Closure of Greywell abstraction - a WINEP commitments sustainability reduction scheme

EAP6 Develop additional mitigation for cumulative impacts Approaches and mitigation including protected landscape mitigation in for cumulative landscape consultation with the AONB units, South Downs impacts and habitat impacts, National Park authority and other stakeholders/ Link to water framework impacts to studies on chalk grassland restoration and effective be taken into account as approaches. individual schemes are developed. Undertake consultation on programme of works and interactions or combined effects from other company schemes.

EAP7 Undertake further studies on the preferred plan Develop best environmental schemes 2020- 2045 including preparation for solutions considered with planning consents: mitigation built into design and costing, and  Broad Oak reservoir opportunities for  new Arlington reservoir enhancement are included in option design through  pipeline transfers consultation with relevant Including: stakeholders  Developing the baseline information and Schemes designed so no undertaking additional water quality monitoring significant effects on SSSIs  detailed studies on option variants, pipeline Schemes are designed and routing (eg use approach applied to Peacehaven operated so no deterioration pipeline routing) along with further comparison of ecological WFD status or with relevant alternatives; contribute to RBMP  identify possible interaction with other potential measures schemes and include in overall studies – to ensure opportunities and constraints are covered

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Reference Action from WRMP14 Target Monitoring number

 mitigation and enhancement studies including consultation with local stakeholders for example on recreation provision at new reservoirs  water framework directive assessment where potential to cause deterioration needs to be ruled out and opportunities for contribution to WFD objectives of RBMP measures. Link to relevant WINEP studies and potential for conjunctive operation for overall benefit  work with the Environment Agency on options for Broad Oak with the Richborough connection design constraint on WFD mitigation.  undertaken further yield assessment studies for the reservoirs taking account of other schemes and potential cumulative effects /opportunities with other schemes  develop monitoring plans for WFD compliance where relevant liaising with the Environment Agency.

EAP8 Implementation of WINEP restoring sustainable AMP7 WINEP will be within abstraction programme. Review the output of this the South East Water programme and keep implications for future WRMPs business plan. under review. Identify schemes which may be at risk of future sustainability reductions.

EAP9 Review Annual Reporting People Places and Planet Annual monitoring as part of and add additional monitoring or reporting to address WRMP review and reporting monitoring plan and include case studies for schemes within five year WRMP cycle. to report on progress and how environmental impacts are addressed and any changes to future approaches recommended. Feed into lessons learned for the next WRMP

EAP10 Complete case study report to contribute to monitoring Feedback on completed or feedback on 2015 to 2020 projects - through annual ongoing schemes is report reported. Whitely Hill pipeline – potential ancient woodland impacts avoided by direct drilling Coggins Mill – currently subject to sustainability studies Forest Row - currently subject to sustainability studies

EAP11 Complete monitoring of time limited licences at: Feedback on time limited Aylesford licences provided White Waltham Eridge Saints Hill Lilly Farm Oakhanger Bewl and Witchling

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Reference Action from WRMP14 Target Monitoring number

Medium to long term (5-25 years) 2026-45

EAP12 Undertake the down the line assessments required in HRA issues addressed and Update as the Habitat Regulations Assessment (HRA) on options schemes taken forward required

identified and their potential alternatives. avoid significant adverse leading up effects on Natura 2000 and to next Ramsar protected sites. cycle.

EAP13 Review the SEA objectives and targets as part of SEA objectives, baseline and Update as lessons learned for next WRMP cycle and update option assumptions reviewed required baseline. as part of next WRMP cycle leading up and more developed options to next Feed information gathered through studies into the for consideration - to reduce cycle. next cycle of options identification and appraisal. assessment and delivery risk.

EAP14 Action results of catchment management Catchment management investigations and consider new options for future supporting water quality and WRMPs. resource sustainability

EAP 15 Consult with Environment Agency/ Natural Specific actions identified for England/Historic England/EFG and other the next plan cycle. stakeholders to identify constraints, requirements and opportunities for the next cycle.

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April 2017 10. Conclusions and summary

This environmental report is an assessment of the environmental effects of our water resources management plan (WRMP19). It provides a summary of the strategic environmental assessment (SEA) that has been undertaken as part of the WRMP19 to comply with the Environmental Assessment of Plans and Programmes Regulations (SI 1633 2004).

As part of the SEA, the baseline environment was reviewed and the likely trends and changes affecting the environment over the plan period were identified. Relevant legislation, policies, programmes and plans were considered in terms of the constraints, opportunities and priorities for the assessment. Together these provide the context for the assessment and were used to highlight key sensitivities within the SEA study area. The study area for the assessment covers an area wider than our supply area taking account of catchments and downstream water bodies and habitats.

A scoping report was issued to statutory consultees in May 2017, for a five-week consultation period. This document outlined the proposed SEA objectives and the scope of the assessment. The environmental report incorporates the comments provided through scoping where possible and relevant.

Environmental assessment was included from the start of the options selection and appraisal process and from over 510 options, 175 were selected as potential feasible options for the WRMP19 and this selection process included removing options performing poorly against environmental objectives.

These options taken forward were developed further and were assessed more fully against the SEA objectives and criteria, to identify potential significant effects and mitigation requirements. Each option was also given an environmental resilience risk level that was used to influence the least cost scenarios modelled.

A range of scenarios and sensitivity tests were run. The results were compared considering individual option and cumulative effects. The assessment of the model run outputs was undertaken as an iterative process which involved excluding high risk environmental options, providing for sustainability reductions beyond the planned commitments to 2025, optimising demand management and leakage reduction schemes, and balancing these with supply resilience and cost effectiveness to provide value for customers.

The Environmental Report was issued to statutory consultees in February 2018 and further consultation with stakeholders and members of the public undertaken during the 12 week period closing on 21 May 2018. Following consultation on our dWRMP further changes were made to the plan to increase water savings from leakage reductions and water efficiency measures. This also meant that many of the higher risk options included within the dWRMP, including water reuse and desalination schemes, were no longer required in order to meet supply-demand balance. Two higher risk options, Broad Oak Reservoir and new Arlington Reservoir, are maintained within the WRMP. These options have been subject to additional studies since WRMP14 so are associated with less uncertainty over their environmental effects where mitigation is required and environmental benefits can be provided.

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April 2017 The preferred plan is based on delivering sustainability reductions for existing abstractions where planned studies confirm these are required. These will provide benefits for meeting Water Framework Directive (WFD) objectives for groundwater and surface water and improved resilience for biodiversity. The plan includes a range of demand management options for both water efficiency and leakage reduction measures with innovative approaches to optimise the uptake for water efficiency and identification and targeting for leakage reduction. These measures have largely positive long term effects through water and energy savings. Leakage control measures will require approaches to minimise traffic disruption and reduce risks for works in sensitive areas. Other early options involve the development of water resources including use of an existing groundwater abstraction licence with new supporting treatment infrastructure. These options are considered low to moderate risk and with adequate monitoring and operational controls these can be reduced to minor or negligible effects. The environmental effects from WRMP19 options involving the improving network connectivity and resilience include new pipelines for transfers. Initial routing has been undertaken for these transfer pipelines but further route option studies will be required to avoid and minimise environmental impacts.

A number of water transfers are included in the WRMP19 both from within the company supply area and from neighbouring companies to allow water to be distributed to higher demand areas. These have mainly short-term construction disturbance effects but some could lead to permanent loss of important habitats including those with statutory landscape designations such as areas of outstanding natural beauty (AONBs) and the South Downs national park. These options will be assessed further in the next asset management programme (AMP) period to identify routes avoiding permanent losses to important habitats and other designated sites as well as considering further impacts on archaeological interests. A landscape protection strategy will be developed in consultation with the key stakeholders and this will take account of potential cumulative impacts with other water company proposals and other schemes. Our studies on the restoration of chalk grassland will also be fed into the strategy.

The WRMP19 includes two new reservoirs for storage of water from winter river flow (RES-24 Arlington Reservoir and RES-31 Broad Oak Reservoir). These reservoirs include potential significant environmental effects but these can be mitigated to reduce residual long term effects to moderate or minor effects with potential for significant benefits for biodiversity and recreation and well as providing scope to improve environmental resilience. These include a water re-use scheme at Peacehaven (EFF- 35) or new reservoir at Goose Green (RES-27) for Arlington Reservoir and a bulk transfer from South East Water’s water reuse scheme at Aylesford (if progressed by Southern Water) for Broad Oak reservoir. The preferred plan reservoir options and alternatives will be studied in more detail in the next asset management period.

The Habitats Regulations Assessment (HRA) (draft HRA stage 1 and 2 Report, Appendix A) found that none of the options included within the WRMP have potential to cause significant effects on Natura 2000 sites and therefore no further assessment is required.

The marine conservation zone (MCZ) screening assessment found that one option, the water reuse at Peacehaven (EFF-35, plan alternative option) has potential to generate significant effects on Beachy Head West MCZ. If this plan alternative option is progressed then a down the line stage 1 MCZ assessment would be undertaken.

A key area for potential cumulative impacts identified from the assessment is from pipeline construction within AONBs and the South Downs National Park over the plan period.

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April 2017 Cumulative impacts with the other water company draft plans were considered in terms of the schemes related to the supply of water for transfer included in the preferred plan. The potential for cumulative water resource issues identified include Southern Water options in the Medway,Adur and Ouse and Stour catchment.

There are also potential additional construction effects from Southern Water schemes within the High Weald AONB and the South Downs national park, in addition to the South East Water in-combination effects. Mitigation is proposed through the development of protected landscape strategies with the key stakeholders.

Cumulative impacts with other plans and programmes are also considered as part of the SEA. In particular the river basin management plans (RBMPs) have been taken into account in the WFD assessment and local development plan growth has been taken into account through the demand forecast based on predictions for population growth. Potential issues have been taken into account in the option assessment but additional mitigation and monitoring measures are identified and included in the SEA monitoring and action plan.

The SEA identified a range of mitigation measures and recommendations for further study to reduce potential impacts of the WRMP19. These are all incorporated into the SEA monitoring plan and environmental action plan and will also be used to ensure SEA findings are taken forward as part of the plan implementation, to provide additional information on the baseline environment and scheme environmental impacts to feed into future WRMP development.

Our WRMP19 (and business plan) support the Department for Farming, Environment and Rural Affairs (Defra) 25 year environmental plan as summarised in Table 10.1 below. Synergies between water industry strategic environmental requirements (WISER) expectations and our WRMP19 are set out in Table 10.2.

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April 2017 Table 10.1 Synergies between the Defra 25 year environment plan and our environmental resilience activities

25 year plan How our work can achieve those aspirations

Clean and By improving surface and ground waters to support environmental standards and plentiful water implementing the outcomes of our Water Resource Management Plan 2019 (WRMP19).

Thriving plants By making further reductions to unsustainable abstractions, implementing our work to and wildlife protect wildlife and enhancing biodiversity together with the delivery of our invasive non native species (INNS) programme.

Reducing the risk By ensuring we are more resilient to flood and drought events Our plans to reduce leakage of harm from by a further 15% and per capita consumption to 139 litres per head per day by 2025 are key environmental areas which will help to provide this resilience. hazards

Enhancing the Through careful design of our new infrastructure, working in partnership with our beauty, heritage stakeholders and by implementing our biodiversity, INNS, surface and groundwater and engagement catchment management programmes. with the natural environment

Mitigating and By delivering our WRMP19, ensuring our resources are sustainable and improving the mix adapting to of water resource options available to us. Through our carbon accounting programme and climate change associated reductions in carbon dioxide emissions.

Minimising waste Through our plans to reduce leakage by a further 15% and per capita consumption to 139 and using litres per head per day by 2025. resources more sustainably and efficiently

Managing Through our surface and groundwater catchment management programmes to protect raw exposure to water quality. chemicals

Enhancing By implementing our INNS programme and delivering a new treated water main from Bewl biosecurity to Hazards Green to remove the risk of the movement of INNS from the river Medway. (management of INNS)

Connecting By introducing performance commitments which are more clearly linked to enhancing our people to nature supply area’s natural capital assets and environmental resilience. and properly valuing it

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April 2017 Table 10.2 Synergies between the WISER expectations and our environmental resilience activities

WISER How our work can achieve those expectations

To ensure that Maintain and develop our current good environmental performance record. Identifying the environmental areas requiring improvement whilst ensuring appropriate training, management and performance is assessment is conducted to maintain the high level of performance across the workforce. excellent

Help protect and Looking beyond our own assets and landholdings where we can influence the protection of the enhance the environment. Catchment management programmes aimed at mitigating and reducing the wider impact of certain land uses. Working with other landowners and stakeholders during environment development to work in a considerate manner and provide beneficial reinstatement.

Further improve Resilience to flooding of our assets is managed though compliance with or regulatory resilience to requirements (security and emergency measures direction (SEMD)). drought and Our drought management plan is regularly reviewed. Long term and if possible live data is flooding constantly evaluated to assess levels of sources against demand. Our plans to reduce leakage by a further 15% and per capita consumption to 139 litres per head per day by 2025.

Work to control Continuing with our programme for discharge compliance. Adopting and aiding in local solar pollution, array ventures. working in Working in collaboration with local land owners to deliver our outcome delivery incentives (ODI) partnership with commitments with regards to catchment management. Partnership working via 2 Seas land managers European project to establish habitats which can provide catchment resilience to drought and and catchment flooding. partnerships

Demonstrate Natural capital accounting approach how nature is Protecting wildlife and enhancing biodiversity valued in decision making Catchment management programme

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April 2017 Glossary

Term Abbrevation Definition

Abstraction - The process of taking water from any source, including rivers and aquifers.

Abstraction ALS Abstraction licensing strategies set out how the Environment Agency licencing strategy manages abstraction licensing in a particular area. Each strategy provides information on what resources are available (where and when), what conditions might apply to new licences, whether time limited licences will be replaced with the same conditions, and what changes may need to be made to existing non-time limited licences.

Agricultural land ALC A classification system for grading land as a way of identifying higher classification quality land that should be protected.

Area of outstanding AONB A national designation to protect areas of the countryside of high scenic natural beauty quality that cannot be selected for National Park status due to their lack of opportunities for outdoor recreation (an essential objective of National Parks).

Aquifer - A water-bearing rock that groundwater can be extracted from.

Biodiversity action BAP An agreed plan for a habitat or species, which forms part of the UK’s plan commitment to biodiversity.

Catchment water - Man-made transfer of water from one natural catchment or system to transfer another.

Cumulative effect - The combined effects from several plans, programmes or policies.

Deficit - The amount of water shortage between supply and demand.

Department for Defra Department of Environment, Food and Rural Affairs environment, food and rural affairs

Deployable output DO The reliable output of an active source, or group of sources, or of a bulk supply of water, which is constrained by: environment; licence, if applicable; pumping plant and/or well/aquifer properties; raw water mains and/or aquifers; transfer and/or output main; treatment; water quality.

Drought order - An authorisation granted by the Secretary of State under drought conditions, which imposes temporary restrictions upon the use of water and/or allows for abstraction/impounding of water beyond the normal licences.

Drought permit - An authorisation granted by the Environment Agency under drought conditions, which allows for temporary abstraction / impounding of water beyond the normal licences.

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Term Abbrevation Definition

Economics of EBSD A method which economically assesses the balance of supply and balancing supply demand-side options. Any imbalance between supply and demand can and demand be met either by demand side options, such as metering, water efficiency and leakage, or by providing additional water resources – supply side options.

Environment - The government-appointed environmental regulator for the water Agency industry.

Environmental and - Environmental and social impacts can be valued in monetary terms so social costings that they can be added to, or subtracted from, other items with monetary value applied to them - such as capital and operating costs. A number of techniques exist for estimating the value that society has placed on the environment.

Environment focus EFG A group of key stakeholders that has advised and challenged us group throughout the preparation of WRMP19. This group includes representatives from our regulators, local and national interest groups and local planning authorities.

Environmental - The report that documents the effects of measures outlined in a plan. report

Flood risk zone - Areas within the catchment identified as being at significant risk from flooding or disruption from it.

Geomorphology - Processes of erosion, deposition and sediment transport that influence the physical form of a river and its floodplain.

Invasive non-native INNS Non-native species that out-compete native species to the detriment of species an ecosystem.

Irrigation - The artificial application of water to soil and land, in particular for agriculture.

Marine conservation MCZ A type of marine nature reserve in UK waters designated with the aim to zone protect nationally important, rare or threatened habitats and species.

Megalitres of water Mld Megalitres per day (a megalitre is a million litres). per day

National nature NNR National nature reserves in England are designated by Natural England reserve as key places for wildlife and natural features in England. They were established to protect the most significant areas of habitat and of geological formations.

Nitrate sensitive - A designation applied to areas of land where the underlying groundwater area is at risk of pollution from nitrate polluted water. The actions are voluntary and compensated.

Nitrate vulnerable NVZ A designation applied to areas of land that have surface and zone groundwater at risk from nitrate polluted waters. The actions are mandatory and uncompensated.

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Term Abbrevation Definition

Reverse osmosis RO A process by which a solvent passes through a porous membrane in the direction opposite to that for natural osmosis when subjected to a hydrostatic pressure greater than the osmotic pressure.

Plans, policies and PPP - programmes

Periodic review PR19 The 2019 price review process that determined the services and 2019 investment water companies would deliver during 2020 to 2025, and the level of customers’ water bills for the same period.

Office of Water Ofwat The independent economic regulator for the water industry. Services

Qualitative appraisal - Assessment based on expert judgement and objectives. This is used for effects that are difficult to assign a value to.

Quantitative - Assessment method that assesses the value of environmental features appraisal in monetary terms.

Ramsar site - A Ramsar Site is a wetland site designated of international importance under the Ramsar Convention. The Convention on Wetlands, known as the Ramsar Convention, is an intergovernmental environmental treaty which came into force in 1975.

River basin RBMP River basin management plans are a management tool in integrated management plan water resources management.

Special area of SAC An international designation for habitats and/or species under the EC conservation Habitats Directive.

Strategic SEA The application of EIA to earlier, more strategic, tiers of decision-making environmental policies, plans and programmes. The application has become statutory assessment under both UK and European legislation.

Special protection SPA A site of international importance for birds, designated as required by the area EC Birds Directive. SPAs are designated for their international importance as breeding, feeding and roosting habitat for bird species.

Scoping report - A document produced as part of an environmental assessment that sets out the scope of the potential effects.

Shoreline SMP A shoreline management plan (SMP) is a strategic document that sets management plan out policies to assist decision-making on flooding from the sea and coastal erosion risk management over the next 20, 50 and 100 years.

Site of special SSSI Nationally designated sites for their flora, fauna, geological or scientific interest physiographical features.

Sustainability SR The reductions in water abstraction which are required by the reduction Environment Agency to meet statutory and/or environmental requirements.

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Term Abbrevation Definition

Water industry WINEP The programme of environmental measures agreed for action between national Government, the Environment Agency, Natural England, Ofwat and the environmental water companies. programme

Water Framework WFD The Water Framework Directive 2000/60/EC is an EU directive which Directive commits European Union member states to achieve good qualitative and quantitative status of all water bodies (including marine waters up to one nautical mile from shore) by 2015.

Water resource - The management of water sources and demands to minimise any deficit management between the two.

Water resource WRMP The statutory 25 year plans that all water companies in England and management plan Wales are required to update, publish and consult on every five years. The plans show how companies intend to secure water supplies for current and future customers, at least cost to customers, society and the environment, while meeting all other environmental obligations.

United Kingdom UK CIP The Government-funded body responsible for disseminating climate Climate Impacts change and climate change impacts projections to stakeholders, Programme including water companies.

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