Agenda Item No: N/A Report No: N/A

Report Title: Response to consultation on the South East Water Draft Water Resource Management Plan Report To: Cabinet Member for Date: 25th July 2013 Planning

Cabinet Member: Cllr Tom Jones

Ward(s) Affected: All

Report By: Director of Planning and Environmental Services

Contact Officer(s)- Name(s): Robert King Post Title(s): Senior Planning Officer E-mail(s): [email protected] Tel No(s): 01273 484410/17

Purpose of Report: To consider the Draft Water Resource Management Plan published for consultation purposes by South East Water and submit a response to the Secretary of State by the consultation deadline.

Officers Recommendation(s):

1 To endorse the comments at Section 5 of this report as the Council’s response to the South East Water Draft Water Resource Management Plan

Reasons for Recommendations

1 To ensure that that the Secretary of State is informed by the Council’s views prior to directing South East Water with regard to the preparation of its Water Resource Management Plan 2014.

1 Introduction

1.1 Water companies have a statutory duty to prepare, consult, publish and maintain Water Resource Management Plans (WRMPs). These documents demonstrate how sufficient water will be provided to meet the demands of customers over the period 2015 to 2040. The water companies consult with regulators and stakeholders during the preparation of their plans and then publish a draft for wider consultation. Any representations must be considered and responded to in a Statement of Response, which is also published. The Page 1 of 6 Secretary of State for Environment, Food and Rural Affairs will then decide whether the plans can be finalised or whether a hearing or inquiry should be held beforehand.

1.2 South East Water, who supplies water to the majority of , has been collaborating on the development of its draft WRMP alongside the eight other water companies who supply the South East region through the Water Resources in the South East (WRSE) working group. This group works collectively to identify optimum solutions to address issues of water stress, meeting future water needs and providing greater resilience through a variety of water supply options, including the transfer of water between neighbouring water supply companies.

1.3 South East Water also established an Environment Focus Group, which comprises representatives from local planning authorities, statutory bodies, regulatory authorities, environmental organisations and local interest groups, to scrutinise and challenge its work as the company developed its WRMP. The District Council has been an active member of this group since its inception in January 2012. A separate and independently chaired Customer Challenge Group was also set up to scrutinise the company’s business plan 2015 to 2020.

2 South East Water’s Preferred Plan

2.1 The challenges facing the water industry in the South East include the growth in population and households, the effects of climate change, and required reductions in abstractions from sensitive environments. In order to meet these challenges, South East Water is pursuing a ‘twin-track’ approach of reducing demand for water through demand management measures and the development of new water resources as required.

2.2 In terms of demand management, the company proposes:

 Completion of the customer metering programme so that 90% of its customers are on a meter by 2020  further leakage control  Delivering enhanced water efficiency programmes to drive individual water use down

2.3 However, these demand management measures will not be enough on their own to provide sufficient additional water and South East Water predicts that there will be a significant shortfall in available water supply by 2040. The company has therefore investigated a wide range of options for developing new water supplies and, following an extensive screening and assessment process, the draft WRMP puts forward the following preferred water resource options:

 Developing five groundwater sources in , Kent and Hampshire and improving two existing water treatment works at Barcombe in East Sussex and Bray in Berkshire by 2020

Page 2 of 6  Developing six water transfer schemes to share water with other companies between 2020 and 2040  Two new water re-use schemes at Peacehaven in East Sussex and Aylesford in Kent between 2025 and 2030  A new reservoir at Broad Oak in Kent between 2030 and 2035  A new desalination plant at Reculver in Kent between 2030 and 2035  Extending the existing Arlington Reservoir in East Sussex between 2035 and 2040

Some of these schemes will be subject to further feasibility testing and Habitats Regulation Assessment. The draft WRMP sets out possible alternative options to demonstrate that there is sufficient flexibility to adapt and respond to changing circumstances.

4 Implications for Lewes District

4.1 South East Water’s supply area is divided into eight Water Resource Zones, each relating to different water catchment areas. Lewes District falls within Zone 2, which in combination with the adjacent Zones 1 and 3, is predicted to have the biggest shortfall in water supply of all the zones by 2040 (a shortfall of 39 million litres per day on average and 56 million litres per day at peak times). In order to increase supply and the overall resilience to changes in supply in the future, new sources or increased capacity in water supply are needed.

4.2 There are three key proposals in the draft WRMP which are likely to have an impact within the District, as follows:

Peacehaven Water Re-use Scheme

4.3 This scheme involves using fully treated wastewater as a source of water supply and is expected to yield 25 million litres per day by 2030. It will involve transferring water from the Peacehaven Waste Water Treatment Works to Newhaven Waste Water Treatment Works, where a new tertiary treatment plant would be constructed. The treated wastewater would then be piped inland for release into the River Ouse and abstraction at the existing downstream water treatment works at Barcombe, where it would be treated again.

4.4 Water re-use schemes have the benefit of maximising the water available for public water supply, particularly in areas of water stress and environmental sensitivity, and the Environment Agency encourages water companies to consider their use as an option where a deficit in water supply is forecast. They can be more cost-effective than building new reservoirs, prevent environmental damage at new sources of supply, are resilient to long-term climate change and can also be operated when required rather than all the time. Such schemes are already widely used internationally to increase water supply and a number are already in operation in the UK, particularly in the South East. Page 3 of 6

4.5 The Peacehaven scheme would require the construction of an extensive pipeline along the Ouse valley, with a significant section passing through the South Downs National Park. Construction could temporarily result in noise, dust and disturbance to residents and businesses, increased heavy vehicle traffic on local roads and access disruption. There is also potential for the construction of the pipeline to impact on a number of sites designated for their biodiversity value, including and SSSIs.

4.6 Operational impacts of the scheme include the on-going carbon emissions associated with the energy required for treatment and pumping, and possible impacts on the local marine environment and fisheries in Seaford Bay resulting from brine discharges to the sea. There may also be potential impacts on aquatic biodiversity and fishing on the River Ouse due to temperature and water quality changes, although there could also be benefits in terms of supporting river flows and the resultant dilution of nutrient pollutants. There are also potential health concerns in relation to chemicals not removed by wastewater treatment processes.

New Arlington Reservoir

4.7 The proposed new reservoir at Arlington, immediately north of the existing reservoir, is located within but will be fed from the River Ouse via a 12.5 km intake pipeline near Barcombe Water Treatment Works. It should be noted that South East Water has now rejected the option of constructing a new reservoir at Clay Hill, near Ringmer, which featured in its approved WRMP for the period 2010-2035. However, an alternative option of constructing a bunded reservoir on the River Ouse has been included within the draft WRMP in the event that the new reservoir at Arlington transpires not to be deliverable.

4.8 The new Arlington reservoir would store water during periods of high river flow on the Ouse, which would allow it to maintain supply during periods of low flow. However, there is potential for long-term adverse impacts on water quality status as a result of the abstractions. The construction of the pipeline from the River Ouse to the new reservoir could also temporarily result in noise, dust and disturbance to residents and businesses in Lewes district, increased heavy vehicle traffic on local roads and access disruption. Whilst the pipeline would not pass through any national landscape designations, there are extensive areas of ancient woodland, an irreplaceable habitat of national importance, between Barcombe and Arlington.

Improving Barcombe Water Treatment Works

4.9 This improvement scheme involves the recovery of water currently lost through the treatment process and returning this water to the river rather than discharging it as waste. There would only be very localised impacts during the construction phase.

Page 4 of 6 5. Comments to the Secretary of State

5.1 The Council welcomes the emphasis in the Draft WRMP on the need for an ambitious demand management programme, as well as the requirement to build further new resource capacity. This ‘twin-track’ strategy is supported as an intelligent approach to meeting the future challenges to the provision of water resources

5.2 The Council considers that South East Water has carried out a thorough assessment of options and is to be congratulated for seeking proactive ways of managing demand as well as investing in new infrastructure to support population and housing growth, reduce reliance on groundwater, and improve resilience to the impacts of climate change.

5.3 The Council would commend the approach taken by South East Water to ensure transparency has been achieved in the WRMP process and particularly appreciates the opportunity to be represented on the Environment Focus Group along with other stakeholders and interested parties. The Council’s participation in this Group, and the opportunity to scrutinise and challenge the company’s work, has given added confidence that the draft WRMP will be cost effective, environmentally sustainable and resilient to risk.

5.4 The Council notes that the water re-use scheme at Peacehaven would require the construction of a pipeline along the valley of the River Ouse. It considers that very careful consideration of the route of the proposed pipeline will be necessary in order to minimise any potentially adverse impacts on biodiversity, landscape and cultural heritage, particularly in relation to the section through the South Downs National Park. The Council also expects good construction practice to be followed in order to mitigate the effects of noise, dust, disturbance and heavy traffic movement on local communities.

5.5 The Council has concerns about the possible long-term impacts on water quality and aquatic biodiversity in the River Ouse and also the potential impact from brine discharge on the marine environment and fisheries in Seaford Bay. These impacts need to be investigated further and necessary operational restrictions implemented to ensure that any adverse effects are reduced to an acceptable level. The Council also wishes to be assured that the public health risks from potentially pathogenic micro-organisms and endocrine disrupting chemicals, such as hormones and pharmaceuticals, can be satisfactorily addressed by the proposed treatment system

5.6 The Council is aware that water re-use schemes are generally very energy intensive and would expect South East Water to seek early engagement with the relevant power supplier to ensure that the electricity distribution network in the Newhaven area has sufficient capacity to cope with the increased demand.

5.7 The Council welcomes and supports the proposed extension to Arlington reservoir, which it believes is the most acceptable option of all the alternatives considered in this locality. However, it does have concerns about the potential

Page 5 of 6 for long-term impacts on river water quality status due to abstractions from the River Ouse, particularly in combination with the potential impacts from the Peacehaven water re-use option.

5.8 In the light of the above concerns, the Council would expect that the operational management of the new Arlington reservoir will limit water abstraction from the River Ouse to within environmentally acceptable flow conditions, taking account of fish migration requirements and timing. The Council also considers that very careful consideration of the route of the proposed pipeline from the River Ouse to the new reservoir will be necessary in order to minimise any potentially adverse impacts on biodiversity, landscape and cultural heritage.

5.9 Finally, the Council would encourage early liaison by South East Water to ensure that any requirements for safeguarding necessary sites for water resource infrastructure within Lewes District through the local plan process can be understood at the earliest opportunity.

6 Financial Appraisal

6.1 There are no direct financial implications of approving the Council’s comments on the draft WRMP.

7 Sustainability Implications

7.1 I have completed the Sustainability Implications Questionnaire and there are no significant effects as a result of these recommendations.

8 Equality Screening

8.1 I have completed an equalities initial screening. As no potential negative impacts were identified, a full equality impact assessment is not required.

Background Papers

South East Water Draft Water Resources Management Plan 2014

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