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Helen Chapman South East Water by Email Only

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Helen Chapman South East Water by Email Only T: 03459 335577 [email protected] www.gov.uk/defra Helen Chapman South East Water Date: 8 February 2019 By email only: [email protected] Dear Helen, South East Water draft WRMP19: further information in support of your statement of response Thank you for submitting the statement of response (SoR) to South East Water’s consultation on its water resources management plan. We have been reviewing the revised draft plan, SoR and advice from the Environment Agency prior to submitting the documents to the Secretary of State for a decision on next steps. However, before we can refer your plan to the Secretary of State for a decision we would like you to provide some further information in support of your plan. The information requested is enclosed. The additional information should be sent to: [email protected]; water- [email protected]; [email protected] Any further information will form part of your statement of response prepared under Regulation 4 of the Water Resources Management Plan Regulations 2007 and as such it should be published on the water company’s website and a copy sent to those that made representations on the draft Plan. This is to enable stakeholders to understand, fully, the company’s proposals and to ensure that all information informing the Secretary of State’s decisions is in the public domain. I would be grateful if you could let me have this further information as quickly as possible, but in any case no later than 5 April 2019. I am copying this letter to Paul Butler, Paul Hickey at the Environment Agency and Colin Green at Ofwat. Yours sincerely Margaret Read Deputy Director – Water Services T: 020 8026 3611 E: [email protected] Annex A – further information required from South East Water to support a decision on the Water Resources Management Plan Monitoring and managing the demand management programme South East Water has included commendable and significantly more ambitious levels of demand management including significant reductions in per capita consumption (pcc) and leakage in response to representations received. As a result, the company has removed a number of large supply-side options from its preferred programme later in the planning period, including Goose Green reservoir, effluent reuse options, desalination options and several water transfer options. The inclusion of more ambitious levels of demand management in its preferred plan is a significant improvement on the company’s draft WRMP. As part of its demand management programme the company is significantly reducing its high level of per capita consumption. Delivering this per capita consumption reduction may be difficult due to the already existing high level of metering (87-89%) along with dependencies on factors outside the company’s control. The company states that it will, for example, need government intervention without specifying the nature of these interventions. The company has not identified adequate alternative options it could use in the medium term (next 10-15 years) if it is unable to achieve its ambitious level of demand management. South East Water should provide further detail on its water efficiency programme to give more confidence that the levels of demand management will be achieved. The company should provide a clear demand management strategy. The company should also demonstrate how it will monitor its water efficiency programme and provide an adaptive plan that shows the action it will take if the savings are not achieved, particularly if these occur in the early part of the plan in water resource zones 2 and 3. The adaptive plan should clearly show the twin track approach to demand management and resource development. It should include pre-planning of supply options needed to address a shortfall in the demand management programme and that they can be implemented in time to address supply demand balance issues. This information should be included in the company’s final plan. We recommend the company reports its progress with demand management in the annual review of its WRMP. Ensure transfers align with neighbouring companies The rates and volumes for a planned export from SES Water to South East Water do not align. The transfer is required by South East Water by 2042 and not 2035 and/or 2041 as stated by SES Water. The revised draft WRMP states that the transfer is for 9 megalitres per day (Ml/d) in a critical period; SES Water states that it is 10Ml/d. Both companies should align the timing and volume of this transfer in their final plans. WRMP Direction compliance South East Water must demonstrate compliance with Directions 3(c) and 3(e)(i) in its final plan. 3 (c) the assumptions it has made to determine the estimates of risks under sub-paragraph (b), including but not limited to drought severity; The company has provided further details of assumptions used to calculate demand savings associated with restrictions, however it is still unclear how the company has calculated and assessed its planned risk of restrictions. The company must set out the assumptions and methodology used to estimate the planned annual risk of (i) temporary water use restrictions; (ii) ordinary drought orders; and (iii) emergency drought orders set out under Direction 3(b). The company must include assumptions about drought severity and reference the percentage risk of restrictions to meet direction 3(c). 3 (e) the assumptions it has made as part of the supply and demand forecasts contained in the water resources management plan in respect of— (i) the implications of climate change, including in relation to the impact on supply and demand of each measure which it has identified in accordance with section 37A(3)(b); The company has updated its preferred plan section of its revised draft WRMP, however it has not assessed and described a numerical estimate of the impact of climate change on its future operations for each supply and demand measure. The company must clearly state the impact of climate change on each preferred (final plan) supply and demand option individually, including the assumptions made in the assessment, to meet Direction 3(e). .
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