Revised Draft Drought Plan 2018-2023 Statement of response Draft Drought Plan 2017 Statement of Response December 2017
CONTENTS
1.0 INTRODUCTION ...... 2 1.1 OVERVIEW OF CONSULTATION ...... 2 1.2 OVERVIEW OF THE REPRESENTATIONS RECEIVED ...... 2 1.3 LAYOUT OF THE STATEMENT OF RESPONSE DOCUMENT ...... 4 2.0 REPRESENTATIONS FROM STATUTORY CONSULTEES ...... 5 2.1 ENVIRONMENT AGENCY ...... 5 2.2 NATURAL ENGLAND ...... 14 3.0 REPRESENTATIONS FROM OTHER ORGANISATIONS ...... 20
5.0 NEXT STEPS ...... 39 5.1 PUBLICATION OF THE STATEMENT OF RESPONSE ...... 39 5.2 PRODUCING A FINAL DROUGHT PLAN ...... 39
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Draft Drought Plan 2017 Statement of Response December 2017
1.0 INTRODUCTION
Water companies have a duty under Section 39B and 39C of the Water Industry Act 1991, as amended by the Water Act 2003 and the Water Act 2014, to prepare and maintain drought plans.
The water company drought plan process involves each of the water companies (in England):
Preparing a draft drought plan and submitting it to the Secretary of State within four years and three months after the date on which the last drought plan was published (for us this was April 2017). Publishing the draft drought plan and consulting on it (for us this was an eight- week consultation period in September/October 2017). Assessing the representations received and preparing a statement of response with a revised draft drought plan taking account of the representations received (for us this will need to be published within 15 weeks of publishing the draft plan for consultation so the date is 15 December 2017). After confirmation from the Secretary of State, publishing the revised draft plan as the final drought plan (for us this is likely to be in spring/summer 2018).
1.1 Overview of consultation
We consulted on our draft drought plan in autumn 2017 for eight weeks from the 4 September 2017 until the 29 October 2017. This document provides a statement of response to representations received during this period.
A copy of this plan was made available on our website (at www.southeastwater.co.uk) and hard copies were available at our head office in Snodland, Kent. We also sent copies directly to our consultees:
The Secretary of State for the Environment, Food and Rural Affairs Environment Agency Defra Ofwat Consumer Council for Water (CC Water) Natural England Affinity Water Portsmouth Water Southern Water Sutton and East Surrey Water Thames Water
We issued an email letter outlining the consultation and linking to the documents to more than 2,060 stakeholders within our region.
1.2 Overview of the representations received
Representations were received from 13 different organisations: three were from statutory consultees or Government agencies (Environment Agency, Natural England
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Draft Drought Plan 2017 Statement of Response December 2017 and Historic England), two were from water companies, seven were from local government or parish councils and one was from a charity. This information is summarised in Figure 1.1.
Figure 1.1 – Number and type of respondents to SEW’s draft drought plan
The sections of the draft drought plan to which each organisation’s representations relate are summarised in Figure 1.2. This provides an overall view of which areas consultees commented on.
Figure 1.2 – Proportions of representations received relating to each section of the draft drought plan
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Draft Drought Plan 2017 Statement of Response December 2017
1.3 Layout of the statement of response document
In order to prevent repetition within the document, the representations have been grouped and will be discussed in two parts:
Section 2 – Representations from statutory consultees Section 3 – Representations from other organisations
Each section contains a summary of all representations received, a summary of our response and details of whether the draft drought plan has been updated as a result of the representation(s). Where we are not intending to update the draft Drought Plan, reasons are provided.
Actions arising from responses to representations have been categorised according to the following list:
No change to draft Drought Plan: We acknowledge the representation but do not consider a change in the draft drought plan is appropriate. Minor change to draft Drought Plan: We will make a minor change to clarify the issue raised or address the minor amendment noted. Provision of further information: We will provide further information in response to the representation to support the way in which we propose to manage drought events. Major change to draft Drought Plan: As a result of the representation, we will consider making a significant change to our draft drought plan. This may have the potential to affect customers and other plans (e.g. the water resources management plan).
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Draft Drought Plan 2017 Statement of Response December 2017
2.0 REPRESENTATIONS FROM STATUTORY CONSULTEES
2.1 Environment Agency
The Environment Agency’s representation is shown in the table below. The colours reference Figure 1.2.
SoR Ref. Summary of representation Our Response Proposed change to draft drought plan (Note - some of the below points are an extract, and some have been summarised) EA(a)Testing Recommendation 1: We recommend that South East In our revised draft drought plan, we have undertaken Provision of further Water provides a range of worked examples that sets out the following clarifications and additions to our scenario information its triggers, timeline and sequence of supply and demand testing chapter (chapter 8), which is where we present actions under a range of different drought scenarios. worked examples of how our triggers operate and our drought management actions are sequenced under a South East Water has completed work on drought range of different drought scenarios: scenarios, testing and triggers, but it is unclear how this has been applied to the plan. The company has not - We have provided additional information in the clearly presented the actions it would undertake, and in timelines of actions associated with each scenario - what order, faced with a range of different droughts of these are presented in Tables 8.10-8.14. However, we differing magnitudes and duration. This includes the would act in accordance with the way in which the sequencing and frequency of applying for and Environment Agency would act in response to different implementing drought permits. South East Water should drought events as summarised in its document Drought provide a set of timelines to illustrate when and how it will response: our framework for England (Environment apply drought measures under a range of historic and Agency, June 2017) which states that "The sequence of synthetic drought scenarios of different magnitudes and actions will not always be the same: each event is duration, including droughts that are more severe than unique and is managed individually...When a trigger is experienced in the historic record. approached or crossed, local and national response teams decide what to do next from a range of predefined actions and measures. Each team considers present and forecast weather conditions before choosing a course of action...The timing of actions will be based on local expert judgement which our drought teams advise on." Therefore, while we have provided information on the range of drought management actions that we would have taken during the drought
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of representation Our Response Proposed change to draft drought plan (Note - some of the below points are an extract, and some have been summarised) scenarios that have been tested in the plan (considered by ourselves to be representative of the range of types and severities of drought events to which we might be subjected), we maintain, as stated in section 3 of our revised draft drought plan, that "We do not consider it appropriate to set a predetermined schedule for the implementation of every action (within the drought status groups of actions), because the timing, severity, nature and extent of drought can be dramatically different. There is a need for flexibility so that we can have a practical and timely response in a developing drought situation. Our Drought Management Team will also target the most at-risk resources and their supply areas within each drought region when implementing the drought region actions."
- We consider, and have now clarified using additional text around the scenario timeline tables, that our drought management actions are pre-emptive, giving us a wide window of time during which to prepare for and implement them. We have now cross-referenced the implementation timescales we estimate for each drought management action in the drought action timelines associated with each scenario. These refer back to Table 3.6 for implementation timescales for drought permits, and sections 3.1.4 and 3.1.5 for consultation timescales for temporary use bans and non-essential use bans. We have also clarified the text in sections 8.1.1 and 3.2.4 with the difference between when we would consider preparing for a drought permit application, and when we would actually apply for one.
- We have also provided some additional graphical outputs from our scenario modelling to demonstrate reservoir levels throughout the scenarios - timelines of
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of representation Our Response Proposed change to draft drought plan (Note - some of the below points are an extract, and some have been summarised) actions have been linked through to these. It should also be emphasised however, that the combined trigger score as shown in Tables 8.10-8.14 shows the overall picture of drought trigger breaches within our Water Resource Zones (WRZs), aggregated up to our three drought management areas, so reservoir and groundwater behaviour can be observed from this to some extent. EA(b)Testing Recommendation 1: The company should also include We have provided in Appendix T explanations of the Provision of further clear textual explanations of its scenario testing results in scenario testing results shown in Figures T.1 to T.6. information the appropriate appendix of its drought plan. EA(c)Testing Recommendation 1: The company has also not The stochastically generated drought scenarios Minor change to draft included sufficient scenario testing for its groundwater presented in our draft drought plan have been updated drought plan dominated zones which are critical to its security of for our revised draft drought plan to reflect work we supply. have undertaken for our draft water resources management plan (dWRMP19), submitted to Defra 1 December 2017. The stochastic drought events that have been selected to illustrate how we would respond to such events are the same as those used to inform our dWRMP19 to ensure consistency across our plans. These drought events have been selected based on water resource zone (WRZ) level deployable output impacts, i.e. the severity of the drought event on our whole area rather than simply level/flow metrics at specific points.
In our draft drought plan, we modelled nine drought scenarios for WRZs two and three (which include our surface water sources): these included 12, 18 and 24 month drought durations under each of the following three levels of drought impact: - worst historic (one in 100 year, one per cent probability of occurring each year) - severe (one in 200 year, 0.5 per cent probability of occurring each year)
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of representation Our Response Proposed change to draft drought plan (Note - some of the below points are an extract, and some have been summarised) - extreme (one in 500 year 0.2 per cent probability of occurring each year)
For our groundwater dominated WRZs (all except WRZ2 and WRZ3), since groundwater takes longer to respond to reduced recharge than surface water sources, drought durations of less than 24 months do not present the same level of risk as would be the case for surface water sources. This duration formed the basis of the scenario testing for each groundwater trigger site under each of the three drought severities (worst historic, severe and extreme).
In addition to the above scenarios, we have modelled a three dry winter scenario which assesses the response of both surface water and groundwater levels to the impacts of a prolonged drought event that spans three dry winters. This type of event is considered to sit between our severe and extreme scenarios in terms of severity.
We have clarified the reasoning behind selection of our surface water and groundwater droughts in section 8.2 of our revised draft drought plan. EA(d)Testing Recommendation 1: In particular, South East Water can - We have now presented a two dry winter scenario, Provision of further improve its scenario testing, sequencing and actions by: which we experienced between 2010 and 2012. We information - undertaking scenario testing of the impact of a second consider this drought to have been the worst drought in dry winter the historic record, broadly equivalent to a 1 in 100 year -including datasets from the 2011-12 drought in its event (i.e. with a one per cent probability of occurring reservoir scenario testing each year). - undertaking scenario testing of appropriate severity and duration for both its groundwater and surface water - We have provided additional text in chapter 8 to sources clarify, where relevant, how our historic drought - giving a clear indication of frequency of drought permit scenarios map across to our stochastic drought application and implementation scenarios, including the following points:
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of representation Our Response Proposed change to draft drought plan (Note - some of the below points are an extract, and some have been summarised) > where the 2010-12 historic drought is broadly equivalent to the one in 100 year stochastically generated 'worst historic' drought > where the other stochastically generated droughts we have tested are more severe than those experienced in the historic record > how these stochastically generated droughts map across to the scenarios we have presented in our dWRMP19 EA(e)Testing Recommendation 1: We also recommend that South Every drought is different. Drought permit/order Minor change to draft East Water further considers lead in times for some of applications would only be able to be made at the point drought plan their drought options and the associated environmental at which a serious deficiency of supplies is threatened monitoring and assessment required to ensure the likely or exists. However, we would commence preparation impact on the environment of these options are of the information required for drought permits/orders understood. when the previous drought status was moved into. The reservoir drought permits/orders require a much shorter lead-in time which is aligned with the faster response of the reservoirs to drought events, whereas the groundwater permits require that a longer preparation time is allowed for given the lead-in to a groundwater drought is longer. We have clarified the difference between when we'd start preparing for and when we'd actually apply for drought permits/orders in scenario narratives/timelines of actions in section 8 of our revised draft Drought Plan. EA(f)Actions Recommendation 2: We recommend that South East In this plan, more than any other plan, we've worked Provision of further Water clarifies within its drought plan how bulk supplies with relevant neighbouring companies to understand information with neighbouring water companies will operate during a the reliability of bulk supplies under different drought drought. Furthermore, within its plan the company refers severities, rather than just through simple pain share to potential loss of these bulk supplies but does not agreements. We have agreements in principle with clearly identify why this risk exists. other companies that the volumes we are stating in section 3.2.3 will be available in different droughts. We To ensure the company provides sufficient information on address security of supply issues relating to bulk its bulk supplies, we recommend that in its final plan supplies more generally in our draft WRMP19. South East Water:
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of representation Our Response Proposed change to draft drought plan (Note - some of the below points are an extract, and some have been summarised) - Clearly summarises the operating agreements it has in We acknowledge there is a risk that a neighbouring place for these bulk supplies with other water companies, company, upon whom we depend for a bulk supply, including the detail of how they will operate during a may be in a worse drought situation than us due to drought factors such as localised rainfall phenomena. This is - Clearly states how any changes to these agreed part of the justification for the override trigger we have transfers will affect security of supplies, the environment developed, it provides additional reassurance and and restrictions for its customers enables us to plan for a reduced bulk supply from a - Commits to update any associated drought actions particular company very early on during a developing following agreement on these bulk supplies with drought event. For this Drought Plan, we have much neighbouring companies better provision and insight into the other company's - Clearly states why there is a risk to agreed bulk operations and planning accordingly. supplies and associated need for override triggers, and include scenarios of appropriate severity and duration to We have amended the wording around our override test how the reduction or loss of a bulk supply would trigger in the Drought Plan in section 2.6 of our revised affect its triggering of other drought actions (linked to draft Drought Plan, and provided additional commentary recommendation 1) throughout section 8 to allow an appreciation of the - Ensures these arrangements are consistent with other circumstances under which our override trigger might relevant water companies’ drought plans and ensure be used and the potential consequences in terms of our communications with these companies are co-ordinated drought scenarios. during a drought event We have made reference to section 6.2.5 as well. EA(g)EnvImpacts South East Water has not presented sufficient evidence We fully understand the comments regarding drought No change to draft drought in its draft plan to demonstrate compliance with the permit/order readiness and the gaps in environmental plan following Drought Plan (England) Direction 2016: knowledge for the groundwater sources, although the (e) the measures that may be needed to mitigate any mitigation and monitoring detailed in the plan for adverse effect on the environment resulting from the surface water abstractions has been successfully implementation of a drought management measure. implemented a number of times during permit/order operation. This point is linked to the EA's Recommendation 3, which requests that South East Water completes Due to changes in the way that our water resources are Environmental Assessment Reports and appropriate being managed as set out in the dWRMP19, it is monitoring plans, which will ensure that the company is considered that the groundwater drought permit/order 'drought permit ready' and help ensure security of supply schemes would not be operated until a third dry winter. during a drought whilst minimising the impact on the This gives us a sufficient period of time to plan and environment. pump test the sources and establish any impacts on
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of representation Our Response Proposed change to draft drought plan (Note - some of the below points are an extract, and some have been summarised) important habitats and/or species and how we would We also recommend that South East Water ensures its mitigate for those before they were put into operation. environmental monitoring plan is appropriately designed to adequately assess the environmental impact of all its Because of the cost of such works it would not be drought permits. It is the water company’s responsibility practical to prepare groundwater sources in advance to undertake this monitoring. when they may not be used for a number of years, if at all. Because of the variety of ways in which a drought can develop it is considered that a flexible approach based on careful monitoring of trigger points would be the best option. This would allow us to carry out environmental monitoring as the need for a particular source developed, and to design adequate mitigation.
As a result we have not yet completed the environmental assessments for the groundwater drought permit/order sites.
We understand the concerns regarding any overreliance on Environment Agency monitoring stations. For the Ouse abstractions, we have undertaken significant baseline monitoring during 2017 at the survey locations set out in Section 4.4.1 of the plan. This has allowed us to update the previous baseline and set out the monitoring and mitigation for the Ouse should a permit be implemented.
In the case of the Cuckmere permits, Environment Agency engagement during the early stages of Drought Plan development agreed that the current baseline information gathered would be sufficient for drought permit/order application. Table 4.8 in the plan details current Environment Agency monitoring sites for fish, water quality, macroinvertebrates and flow; if these were to be discontinued we would hope to discuss sites at which South East Water could continue to collect
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of representation Our Response Proposed change to draft drought plan (Note - some of the below points are an extract, and some have been summarised) data to ensure that potential environmental impacts of drought permit/order implementation could be monitored. EA(h)Actions Improvement 1: We suggest South East Water provides We are not proposing to implement emergency drought Minor change to draft details of the likelihood of emergency drought orders (for orders under anything but the most extreme drought Drought Plan rota cuts, standpipes and tankering) in its final drought events, for example during a one in 500 year drought plan as it needs to align with the WRMP. This will give event (0.2 per cent probability of occurring each year). clarity to customers and regulators when, or if, this is Even then, it is only a risk (not a certainty) that they likely to happen. might be needed. This is because we are looking to plan to one in 200 year level of resilience (0.5 per cent probability of occurring each year) in our draft WRMP19 without the need for restrictions or drought permits/orders. This is clarified in each of the scenarios set out in section 8, with the links to the dWRMP19 explained in section 8.4. EA(i)Mon&Trig Improvement 2: South East Water’s draft plan does not During a meeting with the Environment Agency Minor change to draft include an indicative drought trigger for the resource following the draft Drought Plan consultation period, an Drought Plan situation in the Medway Gravels aquifer. Environmental approach has been agreed where we will work with the assessments have established a link between low flows local Environment Agency team to locate and install a and ecological impact in the River Medway, thus not new observation borehole (OBH) over the next 12 having an indicative drought trigger could cause an months of publishing of final drought plan. We propose impact on the environment. Developing a drought trigger to fund and manage construction of this new OBH, and based on river flow conditions may be more appropriate will also monitor and manage it going forward. than bespoke groundwater level conditions. We suggest it would be useful for South East Water to include an indicative trigger within its drought plan for the resource situation in the Medway Gravels aquifer that relates to the River Medway flow condition. EA(j)Mon&Trig Improvement 3: South East Water’s reservoir drought We have updated the reservoir drought triggers for our Minor change to draft triggers outlined in its draft plan are likely to trigger revised draft drought plan, in accordance with work Drought Plan moderate and severe drought status during ‘normal done for our dWRMP19. The scenario testing chapter years’. We suggest South East Water reviews its drought has also been updated to reflect these revised triggers. triggers and control curves for its reservoirs to ensure the company is not escalating drought status and
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of representation Our Response Proposed change to draft drought plan (Note - some of the below points are an extract, and some have been summarised) implementing associated actions unnecessarily. Through WRMP pre-consultation we are aware that the company has done this work and therefore should include the results in its final plan.
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Draft Drought Plan 2017 Statement of Response December 2017
2.2 Natural England
Natural England’s representation is shown in the table below. The colours reference Figure 1.2.
SoR Ref. Summary of Representation South East Water Response Proposed change to draft Drought Plan (Note - some of the below points are an extract, and some have been summarised) NE(a)AppGen It is unfortunate that the online version of this document These appendices were not published on our website, but No change to draft drought lacks several appendices pertinent to the review of instead made available on request. They have now been plan impacts on protected sites, habitats and species and, received and looked through by Natural England who are despite requesting this information from South East satisfied with the data presented. Water, Natural England has not received these documents prior to submission of this response. NE(b)AppP We note the inclusion of a Habitats Regulation These appendices were not published on our website, but No change to draft drought Assessment screening in Appendix P. Natural England instead made available on request. They have now been plan concur with the overall assessment of the HRA screen received and looked through by Natural England who are however we are concerned that the updated satisfied with the data presented. environmental assessments and ecological reports undertaken by Johns Associates as referred to in the draft plan have not been presented in support of the HRA screening conclusions. NE(c)AppP Where sites have been further screened for potential The plan has been thoroughly checked with regards Minor change to draft impacts, for example as presented in Table P.1 on page referencing as part of preparing a revised draft drought drought plan 284 for the Oaklands and Southlands drought permits, plan. reference should be made to the supporting baseline evidence, reports or any other relevant documentation The point made regarding HRA for Southlands and used for this summary assessment. It would also add Oaklands and Halling No. 8 is valid. This can be clarity to the assessment to address the question posed addressed in greater detail once these schemes have on page 283 as to whether the Oakland and Southland been developed further and additional assessment on drought permit has the potential to affect the interest potential impacts, for example draw down, have been features of the European sites. This also applies to the undertaken. HRA screening assessment for Halling No 8 borehole. NE(d)EnvImpacts The draft Drought Plan states that SSSIs have been Appendices have been sent to Natural England although No change to draft drought considered throughout the environmental assessment they would also be interested to see the original SSSI plan process for all drought permit sites and concludes that assessments which were undertaken by John there are no likely significant adverse effects on SSSI’s Curson/Entec. These are to be provided in response to
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of Representation South East Water Response Proposed change to draft Drought Plan (Note - some of the below points are an extract, and some have been summarised) (Section 4, p88). It is important that such conclusions are Natural England's request and will be available on clearly evidenced and justified. It would be helpful in this request to any other party who may be interested. respect to demonstrate a consistent approach to screening and assessing impacts to those SSSIs which fall within your drought plan area. Although this is not evident in the plan as it currently stands it is anticipated that the updated environmental reports for each drought option will provide clarity on this. NE(e)EnvImpacts In addition, under section 40 of the Natural Environment This was discussed at a meeting between South East No change to draft drought and Rural communities Act 2006, every public authority, Water, Natural England and Matt Johns Associates (on plan including water companies, must in exercising its 8th November). functions have regard, so far as it is consistent with the proper exercise of those functions, to the purpose of As discussed at the meeting, rather than looking at conserving biodiversity. Conserving biodiversity in this individual sections of priority habitat we have undertaken context includes restoring or enhancing a population or a holistic approach in terms of potential impacts to habitat. It is unclear if the location of susceptible priority sensitive habitats and species. habitats and priority species has been identified in this draft document. Of particular importance in the context of Natural England were supportive of the approach so we this drought plan are priority headwaters and priority are not proposing to change the methodology used in the stretches of river. These have been mapped since the last revised draft drought plan. drought plan revision and should be included in the environmental baseline and assessment where it is determined there is a pathway for impacts to these receptors. The Upper Ouse for example has two stretches of priority river habitat just south east of Lindfield in the vicinity of monitoring stations 6, 7 and 10. NE(f)EnvImpacts We welcome the inclusion of the summary tables (p95) This is detailed within appendices which have now been No change to draft drought detailing the potential generic effect and likely significance received by Natural England. plan and assessment of permanent impacts. It would be helpful to understand how the conclusions of significance and long-term impact have been assessed. NE(g)Gen There are numerous editing inconsistencies throughout The document has been checked for editing Minor change to draft the document which would benefit from a thorough review inconsistencies prior to publication of the revised draft drought plan particularly where referencing across to other sections of drought plan.
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of Representation South East Water Response Proposed change to draft Drought Plan (Note - some of the below points are an extract, and some have been summarised) the plan. References have been made wherever possible to Inclusion of references to relevant ecological reports and ecological reports and evidence used to support evidence used to support statements and conclusions statements and conclusions within the plan. within the plan would add authority and clarity to the document. We considered altering the presentation of some tables and maps in landscape format for ease of viewing, but Some of the tables and maps would be improved if feel that retaining the entire document in A4 format is presented in landscape format and enlarged to make it most appropriate, but this does not preclude the easier to read (especially as hard copy). enlargement of certain pages for printing if desired.
It would perhaps have been clearer to provide the HRA We note Natural England's comment regarding the HRA screening assessment as a separate document which screening assessment being included as a separate included the supporting evidence rather than cross document, but we feel that including all appendices referencing to multiple sections in the plan. together aids the feeling of continuity across the plan, so propose to retain the structure as per the draft drought plan NE(h)Mon&Trig Natural England generally support the approach adopted As set out in section 3 (Table 3.7) we would only apply for No change to draft drought by South East Water for this draft Drought Plan. To avoid and implement (if granted) drought permits/orders in plan adverse impacts to designated sites and/or priority moderate or severe drought events, and after we have habitats and species, drought permits should only be considered and implemented (where feasible based on implemented where there is a considerable risk to water the timing of the drought) all demand management supply from significant and infrequent drought events. options. NE(i)Testing Testing the plan against historic drought data from 2003 - Lessons learned from our previous drought situations are No change to draft drought 2006 and 1995 -1997 gives weight and certainty to the integrated into our proposed drought management plan plan. It might be helpful to include a summary of any actions as set out in section 3 of our plan. We note this lessons learned from previous drought situations. We are point but feel that providing additional summarising of pleased to note that South East Water will be reviewing lessons learnt would repeat information already in the the Water Resources Management Plan in light of the plan, adding to what is already a very complex and modelling undertaken for this drought plan to see if long detailed document. term investment is needed to improve resilience and plan for longer and more severe droughts. NE(j)Actions We are pleased to note that SEW have included a plan to No change to draft drought promote voluntary measures to restrict water use in pre- plan
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of Representation South East Water Response Proposed change to draft Drought Plan (Note - some of the below points are an extract, and some have been summarised) drought conditions. NE(k)EnvImpacts Habitats Regulation Assessment Screening Following a discussion with Natural England on the 6th Minor change to draft We advise that the HRA Screening Assessment December a number of minor changes to this section of drought plan (Appendix P) is completed so that the questions posed the revised draft drought plan have been agreed to within this section are fully answered with a brief improve the clarity of conclusions made regarding justification of the conclusions made (as well as potential impacts. referencing to other parts of the plan and supporting documents). For example, the Southlands to Oaklands Drought Permit screening assessment needs to state that there is no hydrological connectivity to Woolmer Forest SAC, Shortheath Common SAC, East Hampshire Hangers SAC and Wealden Heaths Phase II SPA in order to screen this option from further assessment. NE(l)EnvImpacts Evidence should be presented to support this statement We have collected evidence to support the conclusions of Provision of further and to demonstrate SEW has undertaken a robust no impact drawn in the HRA for Southlands and Oaklands information screening assessment process drawing on the available and the Halling drought permit/order sites. This is ecological and hydrological survey data. Reference to the summarised and referenced in Appendix P. HRA undertaken for the original abstraction permit application and pump test monitoring could also be used to support this assessment. Should there be any doubt regarding the hydrological connectivity or potential impacts, for any of the internationally important sites identified in the study area, a Habitats Regulations Assessment should be undertaken. NE(m)EnvImpacts Section 4 Environmental Impacts A summary table to provide the reasons that all SSSI Provision of further sites were screened out of the assessment and information Natural England are still of the view that it would add information regarding previous consultation with Natural clarity to the plan if this section included a summary of the England regarding these is included in the revised draft assessment of impacts on SSSI sites to support the drought plan. conclusion stated on page 88 of no likely significant adverse effects on SSSIs. Although the plan states that none of the SSSI sites within the Cuckmere and Ouse catchments are in hydrological connectivity with the river it is unclear which SSSIs have been assessed as they
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of Representation South East Water Response Proposed change to draft Drought Plan (Note - some of the below points are an extract, and some have been summarised) have not been listed.
We acknowledge that some of this information has been provided in the appendices listed above but it remains unclear in the Draft Drought Plan how all SSSI sites within the study area have been screened for impacts. The 2016 River Ouse Environmental Baseline for example, provides details of all 12 SSSI sites located in the catchment and it is evident from this document that some sites are not in hydrological connectivity with the River Ouse or do not have water dependent features. For example Freshfield Lane, Philpots and Hook Quarries, Scaynes Hill, Southern Works Pit and Southerham Grey Pit SSSIs are all geological sites. Lewes Brooks and Offham Marshes have limited connectivity to the river due to embankments. However, it is unclear how or why some of the other SSSIs sites identified within the 5km plan area have been screened from further assessment, either in the plan itself, in the supporting environmental baseline or in the associated drought permits templates. If this information has been provided elsewhere then it would be helpful to make reference to it in this section.
A summary table which pulls together the evidence and information from the various detailed environmental reports and hydrological surveys would help to clearly demonstrate how these nationally important sites have been considered and scoped out from further assessment. NE(n)EnvImpacts For implementation of the five ground water permits Following consultation with the Environment Agency we Minor change to draft during extreme drought condition Natural England are of agreed that drought permits/orders for groundwater sites drought plan the view that further work is needed for permit readiness. would likely only be applied in anticipation of a three dry At our meeting on 8th November 2017 SEW clarified that winter scenario, so after two dry winters we would have pump testing would be needed to support the baseline time to plan and complete the pumping assessment evidence for the Halling and Balcombe sites in the lead before third dry winter occurred. This would also mean
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of Representation South East Water Response Proposed change to draft Drought Plan (Note - some of the below points are an extract, and some have been summarised) up to a severe drought. We would expect a clear that data would be more representative than if pumping timetable (linked to drought triggers) for the gathering and test was undertaken now. implementing of evidence for the 5 groundwater permit applications should they be needed.
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Draft Drought Plan 2017 Statement of Response December 2017
3.0 REPRESENTATIONS FROM OTHER ORGANISATIONS
During the consultation we received 45 representations from other organisations. The points raised in these responses have been colour coded according to the section of the draft Drought Plan to which they relate and grouped by organisation in the below table. Our response to each representation is provided as well as what changes have been made to the draft drought plan. The colours reference Figure 1.2.
SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) Affinity Water AW(a)Actions Section 3.2.3 Shared Resources and Bulk Transfer We thank Affinity Water for their response to our No change to draft drought Agreements recognises the existence of bulk supply consultation, confirming discussions between our two plan agreements shared between us and South East Water. companies during preparation of our respective As stated by South East Water within their plan, we are dWRMP19s. currently engaged in discussions regarding these transfer volumes as part of ongoing work on our respective 2019 Water Resource Management Plans (WRMP19). This work will provide the opportunity for us to refine our existing in-principle agreements, in order to ensure they remain resilient and effective in the future. We accept these discussions may not be able to feed back into our respective 2017 Drought Management Plans due to the differing timescales of both the WRMPs and the DMPs. Our draft WRMP19 will be submitted to DEFRA this December and the public consultation period will run early next year. Ash Parish Council APC(a)Gen The Committee are concerned that the thousands of Given that we have now submitted our draft Water Minor change to draft new houses planned within our local area will put Resources Management Plan 2019 (dWRMP19) to Defra drought plan extensive strain on the water supply in the area. (1 December 2017), we have provided some supplementary information in section 8.4 regarding the ways in which we propose to improve the resilience of our water resources for the longer term, which feeds back into our drought resilience as applicable to our revised draft drought plan.
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) Bracknell Forest Council BFC(a)Gen Bracknell Forest Council endorse the actions that are We thank Bracknell Forest Council for their No change to draft drought recommended in the South East Water Draft Drought representation and look forward to continuing to work with plan Plan September 2017 for customers being prepared in them during preparation of their Comprehensive Local the event of a drought occurring in this part of the Plan Infrastructure Delivery Plan. country. We will continue to liaise with South East Water in the production of the Bracknell Forest Council’s emerging Comprehensive Local Plan Infrastructure Delivery Plan, which will make reference to the South East Water Draft Drought Plan and its contents when adopted. Hampshire County Council HCC(a)Gen As the plan states The South East of England is one of Given that we have now submitted our draft Water Minor change to draft the driest regions in the country and is classified by the Resources Management Plan 2019 (dWRMP19) to Defra Drought Plan Environment Agency as an area of ‘serious water (1 December 2017), we have provided some stress.’ Indeed, the agency’s Water Stressed areas - supplementary information in section 8.4 regarding the final classification (2013) indicates that South East ways in which we propose to improve the resilience of our Water’s area is under water stress for both current and water resources for the longer term, which feeds back all future water usage and climate change scenarios into our drought resilience as applicable to our revised that were considered. Climate change and population draft drought plan. growth, much of which is predicted to occur in areas where water is already scarce, are putting increasing pressure on the water sector. By the 2050’s, it is likely that summer temperatures will increase whilst rainfall decreases, leading to increased risks of short duration droughts (Defra: Creating a great place for living - Enabling resilience in the water sector). At that time many catchments will need to manage water deficits and competing demands for water, for public supply, industry, agriculture and the environment (The UK climate change Risk Assessment 2017 Evidence Report).
Having regard to the above it is noted that the plan
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) acknowledges that for drought planning there is currently a high reliance on drought permits and drought orders, more so than might be acceptable and that reducing the reliance on them will result in a more robust plan. Therefore, as part of its WRMP19 (Water Resources Management Plan) process the company plans to identify whether potential investment is needed to enhance resilience. This approach is welcomed and supported, recognising as it does the wider water resources issue and the environmental impact on water systems of increasing abstraction during periods of drought. HCC(b)PostDrought Finally, in relation to post drought actions, the intention No change to draft drought to undertake a review of the company’s management of plan any drought occurrence to ensure that any lessons learnt are incorporated into future drought and water resource planning, is again welcomed. Historic England (South East) HE(a)EnvImpacts We are pleased to see that heritage designations near We are aware that these are statutory environmental No change to draft drought to Drought Permit locations are shown on plans in designations, however for clarity they were included in plan Appendix C.3, although we would emphasise that the heritage designations maps. scheduled monuments are “statutory environmental designations”. HE(b)EnvImpacts Listed buildings are also statutory environmental Our GIS team has updated all heritage maps included in Minor change to draft designations and we would have liked to see these the revised draft drought plan to include listed buildings. drought plan identified on the maps in Appendix C3 – the Cuckmere Drought Permit Location is shown on Figure C.15 as being in close proximity to the Grade II listed Stapley’s Farmhouse and the Halling Drought Permit Location is shown on Figure C close to the Grade II listed buildings. HE(c)EnvImpacts However, the only potential impact on the historic Until pump testing is done, it would be difficult to assess No change to draft drought environment from the proposed drought measures the potential impact of our groundwater drought plan appears to be from potential increased abstraction from permits/orders on the water table in the vicinity of any
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) the five groundwater locations identified in Table 3.4. local archaeological deposits. They will, however, be Any consequent lowering of the water table could affect looked at in detail if/when we need to undertake pump any archaeological deposits in the locality, as may be testing in preparation for a potential groundwater drought identified on the relevant County Council’s Heritage permit/order. Regarding sites for Kent, we do have a list Environment Record. Accordingly, when considering and have considered potential impacts on these as far as abstraction, the effects of dewatering on known or possible, but again pump testing will be needed to better potential archaeological deposits should be considered. assess potential impacts on the water table of groundwater drought permits/orders. Kent County Council KCC(a)Gen Overall, we found the main technical document We acknowledge Kent County Council's comments No change to draft drought unnecessarily lengthy and complex, confusing in some regarding the length and complexity of the main Drought plan of the terminology usage and therefore a little Plan document. In this document, we have to inaccessible. The non-technical summary is very clear demonstrate what we'd do in different drought situations and concise but does not provide all the information we and assess the potential impacts of these actions. It is an need. operational plan so we must retain a level of complexity within it. We sought clarification from KCC, who confirmed that this representation was not critical of the non-technical summary document, rather KCC clarified it will need to see detailed information that, by its nature, it would not expect to see in a non-technical summary. We are confident the detailed information required by KCC during a drought event will be provided to it through enacting our communications plan and working closely with KCC. KCC(b)Mon&Trig The drought triggers are very well explained and, given No change to draft drought SEW's large dependency on bulk transfers and shared plan resources with other companies, we support the idea of having an ‘override trigger’ relating to transfers. The flexible approach also seems sensible and makes it suitable for dealing with a range of different drought conditions. KCC(c)Actions The drought management actions are comprehensive We are clear that under the current non-household No change to drought plan and are set out very clearly. However, the relationship market code, we the wholesaler have a specific duty on with the non-domestic retail providers gives some us to contact retailers in good time when we foresee the
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) cause for concern as the obligations (if any) of the retail possibility of needing to implement restrictions that may companies to respond to SEW’s water use restrictions affect non-household retail customers. for businesses are not made clear. KCC is aware that the financial operating margins are very tight for these In that regard, we consider that the steps in our plan are retail companies, and that other services (such as water robust, in terms of when and how we propose to use efficiency activities) are expected of them. As such, communicate with retailers, and ensure our plan will be it is not clear to what extent they will invest in systems successfully implemented. to help them readily pass on SEW’s drought communications to the end customer especially when That said, we recognise improvements could be made to these may also reduce their revenue from water sales. the existing non-household market codes to better reflect This appears to be a weakness in the plan, although we how retailers will engage and work with wholesalers understand that it is largely beyond SEW’s control. during a drought. KCC(d)Actions One of the problems that we have seen during past No change to draft drought droughts is confusion amongst domestic customers as plan to what restrictions are in place for their area. This can arise because of differing water use restrictions across the five companies that serve Kent and is compounded by having two companies with similar names providing the same customer - SEW providing water supply and Southern Water providing wastewater services. KCC is therefore very pleased to read that there is collaboration between companies to ensure consistency in the application of Temporary Use Bans as far as possible across the SE England. KCC(e)Gen Unfortunately, each of the water companies that serves We cannot comment for the Environment Agency, but No change to draft drought Kent is publishing its draft DMP at a different time, and acknowledge that while companies are obligated to the plan SEW is the second to do so. This makes it difficult for same statutory deadlines for their WRMPs, drought plan KCC to comment on the important issue of imports from are currently updated to differing time frames. neighbouring companies that would be available in a drought situation as these cannot be checked against the draft DMPs of those companies. We therefore will expect that the Environment Agency (EA) will provide the strategic oversight to address such interdependencies between the companies’ draft DMPs.
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) KCC(f)Testing It is this part of the plan that we find unnecessarily We have provided clarifications to the meanings of Minor change to draft complex and a little confusing. certain terms in section 8 of our revised draft drought drought plan plan, and have reviewed how they have been used in this In KCC’s view Sections 8.2, 8.3 and 8.4 could be made and other sections of the plan. much clearer by reconsidering the terminology used to describe the various drought parameters. In particular the terms ‘severity’, ‘impact’, 'intensity' and ‘risk’ appear to be used incorrectly or inconsistently. For example in Table 8.15 the term ‘Drought Severity' is used to describe the probability of occurrence and the terms 'worst historic’, ’severe’ and ‘extreme’ are referred to as ‘Drought descriptions’ whereas in the text (Section 8.3, paragraph 3) the term ‘extreme’ is described as an ‘impact severity category’.
Clarity here is very important because it should provide the logic to underpin the drought strategy so it would be helpful if all water companies are careful and consistent in the terminology used and explain the meaning given to each term KCC(g)Testing Overall, we note that the plan has been successfully We are pleased that KCC supports the level of drought No change to draft drought tested against a drought having a return period of 1:200 risk which we are proposing to plan for. plan years and against the ‘third dry winter' scenario and we believe this strikes the right balance between resilience and cost. Polegate Town Council PTC(a)Actions In answer to our specific consultation question no. 7: In our capacity as a wholesaler we will inform and consult No change to draft drought Do you feel our approach to implementing restrictions with non-household retailers to comply fully with the plan for certain customers (e.g. small businesses) is requirements of Process E6 of the Operational Terms of reasonable?, Polegate Town Council answered: the Market Codes, as stated in section 3.1.4 of the revised draft drought plan. We would propose to inform YES, supply to business is being prioritised but are retailers of imminent demand restrictions as soon as there any issues with speed of communication of possible through our drought management action plan, problems to the businesses? but it would be the responsibility of the retailer to
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) communicate this onwards to non-household customers in a timely way. PTC(b)Actions In answer to our specific consultation question no. 8: Our dWRMP19, due to be published for public No change to draft drought We feel that the introduction of emergency demand consultation in early 2018, considers leakage reduction plan measures such as standpipes and rota cuts is only alongside other demand management and supply side considered in the event of an unprecedented drought options to secure the long-term resilience of our water event (i.e. a drought that is significantly worse than supply system. We would only expect to ever need to anything recorded in the past). Do you think it is ever implement emergency demand restrictions during the acceptable to introduce them?, Polegate Town Council most extreme drought events, for example a one in 500 responded as follows: year drought event. We will be consulting with our customers and other stakeholders on our draft WRMP19 We would not expect the need for that in this country to ascertain the level of support for our proposed and expect the water company to fix leaks in old approach, which is to plan to be more resilient to a one in networks of pipes and take other measures to reduce 200 year drought event. water loss. 9/10 customers were happy with restrictions but companies must also do their bit to reduce unnecessary water loss. PTC(c)Testing In answer to our specific consultation question no. 9: Our drought plan sits as an operational plan alongside No change to draft drought The analysis for this draft Plan shows that our plan our dWRMP19, which enables us to plan for longer-term plan would not be resilient to an extreme drought (1:500 changes to population and property numbers, as well as years on average) and that planning to meet such a many other factors including, for example, the potential rare event would have implications for investment of a impacts of climate change. Through our dWRMP19, we scale that is disproportionate to the likelihood of such a will be proposing to improve our supply system resilience drought occurring and therefore inappropriate for our to withstand a one in 200 year drought event (0.5 per customers. Do you agree?, Polegate Town Council cent probability of occurring each year), even with responded as follows: expected growth in population and properties. Our drought plan will then sit alongside this WRMP, setting No, extreme drought is a rare event. Plans have been out the operational detail of how we would deal with made but not for one lasting 1 ½ years? The water drought events, whether they fall within or beyond our authority must consider any future housing and planned planned levels of resilience. developments and ensure that these demands are met. There are no details for how long the longest drought recorded in this area. The concerns are that this area is experiencing an unprecedented increase in building at the moment.
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) PTC(d)Actions In answer to our specific consultation question no. 10: We can assure Polegate Town Council that we have No change to draft drought Does our draft Drought Plan strike an appropriate consulted extensively with both the Environment Agency plan balance between customer measures (Temporary Use and Natural England around the environmental issues Bans on water use etc.) and actions that might affect raised in our draft drought plan. the environment (e.g. reducing environmental flows in rivers)? How might the order of implementation these be changed?, Polegate Town Council responded as follows:
The council did not consider itself qualified to make a comment but suggested that the water authority liaise with the water board in the area. PTC(e)Gen In answer to our specific consultation question no. 11: We acknowledge the representation made by Polegate Minor change to draft Do feel we have addressed all potential measures?, Town Council, and agree that town and local councils drought plan Polegate Town Council responded as follows: have a valuable role to play in the communication around drought events. To reflect this, we have included specific This is an outline plan, there also needs to follow a reference to local councils throughout section 6.2.7 in the detailed practical plan. The council feels that on many Community section of the tables which describe our occasions in the plan it refers to other authorities but it drought communications strategy. Appendix R.6 includes should also include local town councils also. P141 (add reference to communication with councils under the town councils) reservoir for example. P182 add local 'Community' section. town councils and councillors. P184 add local councils as well. P318/9 add community, town councils and local councillors. The council would like to see a consistent approach across the region, whilst reflecting the overall flexibility of the plan. Southern Water SWS(a)Mon&Trig Weir Wood reservoir bulk supply We acknowledge and thank Southern Water for their No change to draft drought We currently provide a bulk supply from Weir Wood representation on our draft drought plan, confirming plan reservoir to SEW of 5.4 Ml/d. This contract expires in recent and proposed ongoing discussions between our 2020 but we are assuming a continuation of this two companies around the bulk supplies. arrangement, and this will be included in our draft 2019 Water Resources Management Plan (dWRMP19). Both companies recognise that the existing Weir Wood bulk
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) supply contract is not specific enough to be effective under drought conditions, especially with regard to the pain share approach. As such we are working with South East Water on updating the contract document in readiness for renewal, aiming to make it fit for the future term.
It has been agreed between the companies that there will be a number of stages at which decisions with regard to the provision of supplies will be made and we have also agreed that the trigger levels used for the management of Weir Wood reservoir are those used by Southern Water Services (SWS). We will continue to work together to gain a better understanding of this bulk supply contract and its management under drought conditions. SWS(b)Mon&Trig River Medway (Bewl and Burham water supply We acknowledge and thank Southern Water for their No change to draft drought works) bulk supply representation on our draft drought plan, confirming plan The dDP makes reference to the shared resource recent and proposed ongoing discussions between our arrangement on the River Medway. Under the terms of two companies around the bulk supplies. the River Medway Scheme (RMS) agreement, SEW receives 25 percent and SWS has the remaining 75 percent of the yield of the scheme.
We support the statement that as a drought situation develops we will hold regular discussions with SEW to agree any restrictions or concessions for bulk supplies as triggers are met. The nature of the bulk supply will depend on how both companies are affected by any given drought. SWS(c)Mon&Trig Darwell reservoir bulk supply We acknowledge and thank Southern Water for their No change to draft drought As stated in the dDP, South East Water is permitted to representation on our draft drought plan, confirming plan abstract up to 8 Ml/d from Darwell reservoir (under non- recent and proposed ongoing discussions between our drought conditions) and, up to 12 Ml/d for short periods. two companies around the bulk supplies. In accordance with the Ofwat determination, the yield
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) arising from the enhanced Bewl-Darwell transfer scheme is shared between SEW and SWS in the respective proportions of 8/17 and 9/17 in case of drought (or restriction caused by other events).
We acknowledge reference to the pain sharing clause in this contract which shares the volume of additional water available for transfer from Bewl Water to Darwell reservoir determined through a section 40 agreement.
We agree with the description of control curves and triggers that determine when transfers are made from Bewl Water to Darwell reservoir and when action will be needed to reduce supply in line with the pain share agreement. We confirm that discussions were held around the reliability of the bulk supply in a 1 in 500 drought and agreed a best estimate reduction in the bulk supply from 8 M/d to 4 Ml/d. This will be reflected in our own Drought Plan accordingly. During a drought which would typically be triggered by one dry year, we also agree that both companies would meet and discuss the requirements from the reservoir during the course of the year.
This supply has been provided to South East Water and paid for by them since 2005 but it is of concern that the contract remains unsigned. The process of finalising it to sign-off between the two companies stalled completely between 2008 and 2015. We have worked with South East Water over the last eighteen months to re-invigorate the contract document for sign-off. SWS(d)Mon&Trig Belmont Scheme bulk supply We acknowledge and thank Southern Water for their No change to draft drought We agree with the description of the Belmont Scheme representation on our draft drought plan, confirming plan agreement and the statement that there is not a formal recent and proposed ongoing discussions between our drought pain share agreement for the bulk supply. We two companies around the bulk supplies.
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) are also assuming that the bulk supply arrangements will remain in place in our dWRMP19. SWS(e)Mon&Trig We have commenced discussion with South East Water We acknowledge and thank Southern Water for their No change to draft drought about updating all these supply contracts to make their representation on our draft drought plan, confirming plan documentation and terms fit for the future. recent and proposed ongoing discussions between our two companies around the bulk supplies. Sussex Wildlife Trust and Kent Wildlife Trust SWT&KWT(a)Gen The Trusts strongly support South East Water’s (SEW) Given that we have now submitted our draft Water Minor change to draft plan to link this Drought Plan (DP) to the emerging Resources Management Plan 2019 (dWRMP19) to Defra drought plan WRMP and their acknowledgement that they must (1 December 2017), we have provided some assess all of the assumptions within the plan. Water supplementary information in section 8.4 regarding the resource management planning and drought planning ways in which we propose to improve the resilience of our must be integrated to ensure that measures to prevent water resources for the longer term, which feeds back or alleviate drought do not worsen the risk or impact of into our drought resilience as applicable to our revised flooding and vice versa. However we believe that draft drought plan. WRMP19, and in particular the resilience review, should have much stronger prominence in the DP. SWT&KWT(b)Gen The Trusts also support the commitment to demand We have made reference in section 3.1 of our revised Minor change to draft management programmes. We would like to see draft drought plan to the potential synergies between drought plan recognition of the intention to, and value of, working demand management activities as detailed in our with key stakeholders to educate customers on water dWRMP19, and those planned as drought management conservation and efficiency. This should be the first actions in our revised draft drought plan. priority in terms of changing behaviour that will ultimately reduce demand. We acknowledge that this element of demand management will feature in the WRMP19, but it should also be included in the DP to ensure consistency and commitment. SWT&KWT(c)Mon&T Given that SEW monitor and manage river flows as part We have not included a river flow trigger in our revised No change to draft drought rig of their general operations, it is not clear to the Trusts draft drought plan because there is not a direct link plan why river flows are not being proposed as an additional between river flows and our sources. The way in which trigger (section 2.3). The review of river flow data our reservoir abstraction licences are constructed, should enable relatively quick identification of rivers particularly the way they require us to operate under low receding in response to low rainfall for example, and flow conditions, means that abstractions during droughts the onset of potential drought conditions. would not be permitted, therefore protection of the
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) environment in this way is already taken account of. In this way, we have already been conservative in that the deployable outputs of our reservoirs (based on likely refill during drought events) already take account of these low flow conditions. With regards the River Ouse: releases from Ardingly Reservoir support the level of abstraction proposed.
When considering river flow triggers, we consider there to be no appropriate trigger site. The River Stour is subject to a flashy flow regime, with a high base flow component, but is also influenced by surface water factors. This high level of variability wouldn't provide an effective drought trigger with which to manage resources.
Furthermore, we consider that river flow triggers would signal environmental droughts, but these don't always impact on water resources. For example, a winter drought doesn't always lead to environmental stress, but it does lead to water resource stress.
In summary, from a resource perspective we consider we have already been conservative about the amount of water we can take out of the environment, and we consider that we are using the most representative trigger sites for our mix of sources. SWT&KWT(d)EnvIm We are also unclear as to why no sites for Emergency We have revised the text in Table 4.1 and section 3.2.6 to Minor change to draft pacts Drought Orders have been identified in the DP (Table distinguish more clearly between supply-side 'potentially drought plan 4.1). Leaving the environmental assessment until the damaging environmental drought orders' and demand- area is already in severe drought status is not side emergency drought orders which would comprise acceptable, we would expect SEW to better plan for standpipes and rota cuts. Furthermore, we have clarified emergency situations. The Trusts recommend that the that there are currently no sites where we would consider environmental value of sites where abstraction could be a 'potentially damaging environmental drought order'. increased above licenced quantities is assessed ahead of time. This would allow any necessary mitigation and
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) resilience measures to be identified and implemented in advance to minimise impacts. The Trusts appreciate that the need for an Emergency Drought Order is considered unlikely, however if needed it is likely to require a quick decision. Given the environmental risk is high, robust evidence must be available beforehand. SWT&KWT(e)EnvIm We note that the summaries of the Drought Permit In the case of the Ouse and Cuckmere drought No change to draft drought pacts effects for the Surface Water sites listed in Section 4.3 permits/orders the monitoring and mitigation plan that has plan state that effects are not expected to persist in the been drawn up as part of the drought permit/order will medium and long term, however this analysis is ensure that even if a second drought permit/order is generic. 6-24 month recovery is very wide ranging and implemented during the recovery phase, any negative does not account for the specific conditions at the site impacts on the river system can be identified and or connected areas. The severity of the impact of a mitigated against. We have operated permits on both Drought Permit will be dependent on the length of time rivers on a number of occasions in the past; on these over which it is used. This can vary, as can the ‘ability occasions they have only been in place for a couple of of established ecosystems to recover from climatic days. events’. Additionally this seems to assume a one off Drought Permit, there is no consideration of a second Drought Permit being required during the recovery period. The Trusts also note that the residual effect summaries for the Surface Water sites do not consider the heating of river water systems as a potential outcome of abstraction. These issues should be rectified. SWT&KWT(f)EnvImp The DP does not give enough consideration of locally We have undertaken surveys and assessment of a wide No change to draft drought acts important, but non-statutory designated sites and variety of valued receptors including habitats and plan habitats such as Local Wildlife Sites. For example, protected species at both groundwater and surface water designated sites may not be hydrologically connected abstraction sites. We have also undertaken to the main channel of the River Ouse (section 4.3.1), macroinvertebrate sampling at the water bodies but other important ecological features are, such as associated with the proposed Halling and Balcombe sites chalk and greensand streams (priority habitats). and have undertaken a detailed ecological survey of the Together with statutory designated sites, Local Wildlife freshwater marsh at Halling in order to gain a good Sites contain the most important habitats and species in understanding of potential impacts which could occur as each county and form the core of our biodiversity a result of operation under a drought permit/order. resource. These features and sites need to be Macroinvertebrate surveys also form part of our
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) recognised as part of the environmental context for the assessment of potential impacts to the Ouse. plan, along with a commitment to protect them. SWT&KWT(g)EnvIm The summaries for four of the five Groundwater With regards pump tests to understand impacts on local No change to draft drought pacts Drought Permit sites conclude ‘no significant negative hydrology, these have not yet been undertaken, as based plan environmental effects’. However the assessments do on current modelling it is considered unlikely that any of not seem to consider impacts on local springs, the groundwater sources would be operated until a third particularly the associated habitats and water dry winter. However, pump testing would certainly form temperature. Abstracting groundwater will have an the basis of any drought permit/order application at these effect somewhere. SEW must fill any gaps in the sites in the future. understanding of the hydrology of these areas in order to adequately assess impacts and specifically the likely In the case of the groundwater schemes pump testing location of impacts. would need to be carried out prior to a mitigation plan being drawn up, this would be designed to ensure that monitoring to inform appropriate mitigation is being undertaken at any time when a drought permit/order is in operation. SWT&KWT(h)EnvIm The Trusts are concerned that there seems to be no We have undertaken surveys and assessment of a wide No change to draft drought pacts assessment of the potential impacts of using water variety of valued receptors including habitats and plan abstracted from Balcombe to supplement the refill of protected species at both groundwater and surface water Ardingly Reservoir and augment the flows of the Ouse. abstraction sites. We have also undertaken This needs to be rectified, particularly in terms of water macroinvertebrate sampling at the water bodies quality. It is also not clear how confident SEW are that associated with the proposed Halling and Balcombe sites none of the Local Wildlife Sites are in hydrological and have undertaken a detailed ecological survey of the continuity with the abstraction source, this needs to be freshwater marsh at Halling in order to gain a good clarified. understanding of potential impacts which could occur as a result of operation under a drought permit/order. Macroinvertebrate surveys also form part of our assessment of potential impacts to the Ouse.
Due to the very small amount of water which would be pumped to Ardingly reservoir as a result of operating the drought permit/order at Balcombe, and the blending of water with the existing resources at Ardingly, it is not considered that there would be an impact in terms of water quality as a result of the drought permit/order
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SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) implementation SWT&KWT(i)EnvImp The environmental baseline for the Halling No. 8 The main body of the plan has been updated to Minor change to draft acts Drought Permit (section 4.3.7) is out of date. In incorporate the changes to nomenclature. The baseline drought plan particular, sites of nature conservation interest are now environmental assessments provided for this scheme by called Local Wildlife Sites as per national guidance. Matt Johns Associates already carry the correct names. Additionally this list should be updated as follows: - Holborough Marshes SNCI – does not exist, Holborough Marshes is part of the Holborough to Burham Marshes SSSI - River Medway and Marshes SNCI – actually called Local Wildlife Site TM03 River Medway and Marshes, Wouldham - Arable Field, Lad’s Farm SNCI – actually called Local Wildlife Site TM35 Arable Field, Lad’s Farm, Upper Halling - Bores Hole SNCI – site by this name does not exist, presumed to be Local Wildlife Site TM30 Leybourne Lakes etc., Snodland - South Hill and Houlder Quarries SNCI – actually called Local Wildlife Site ME10 South Hill and Houlder Quarries SWT&KWT(j)EnvImp Again the DP considers that the above sites are not in With regards pump tests to understand impacts on local No change to draft drought acts direct hydrological continuity with the source. It is not hydrology, these have not yet been undertaken, as based plan clear to the Trusts whether this is an assumption or on current modelling it is considered unlikely that any of whether evidence to validate this has been collected. It the groundwater sources would be operated until a third is vital that decisions are based on robust data. If there dry winter. However, pump testing would certainly form are gaps in the understanding of the hydrology of this or the basis of any drought permit/order application at these any other proposed permit site then they need to be sites in the future, and the results used to inform filled urgently. mitigation and monitoring requirements for any future permit application SWT&KWT(k)EnvIm It is also not clear what the impact of water being We have undertaken surveys and assessment of a wide No change to draft drought pacts repurposed and put back into the distribution network, variety of valued receptors including habitats and plan rather than discharged onto the marsh, would be. The protected species at both groundwater and surface water Trusts support the suggestion that a macroinvertebrate abstraction sites. We have also undertaken
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) survey is being carried out to establish a baseline and macroinvertebrate sampling at the water bodies assess potential environmental impacts, however other associated with the proposed Halling and Balcombe sites impacts on the LWS and the habitats and species it and have undertaken detailed ecological survey of the supports need to be considered. We recommend that freshwater marsh at Halling in order to gain a good SEW use the associated citations as a guide for understanding of potential impacts which could occur as assessing possible effects on LWSs. a result of operation under a drought permit/order. Macroinvertebrate surveys also form part of our assessment of potential impacts to the Ouse. SWT&KWT(l)AppGe It is also unhelpful that the appendices were not We note your comment regarding the availability of No change to draft drought n available with the document or through the SEW certain appendices. There are legitimate reasons why plan website. It is not convenient to have to request a these appendices are only available on request, in part separate folder from SEW. due to the nature of site specific data and information contained within them. These can be shared with the SWT and the KWT on receiving a request. SWT&KWT(m)EnvIm We notice that the survey metrics in section 4.4.1 refer We thank the SWT and KWT for this clarification and will Minor change to draft pacts to River Habitat Surveys. Any future surveys should update the terminology in the revised draft drought plan. drought plan instead be Modular River Physical (MoRPh) surveys. SWT&KWT(n)EnvIm The Trusts are concerned that the mitigation suggested The mitigation we propose in section 4.5 demonstrates Minor change to draft pacts in section 4.5 is very short term and immediate. There our immediate response, which necessarily ramps up drought plan needs to be more focus on long term future drought quickly. But then monitoring continues during the proofing of water resources through better catchment drought. management, natural flood management and wetland restoration. We are also concerned that the testing in Given that we have now submitted our draft Water Section 8 does not seem to consider separate droughts Resources Management Plan 2019 (dWRMP19), we coming in quick succession. More frequent and more have provided some supplementary information in section severe droughts are predicted, it would therefore be 8.4 regarding the ways in which we propose to improve prudent to consider droughts occurring during the the resilience of our water resources for the longer term, recovery period of a previous drought. which feeds back into our drought resilience as applicable to our revised draft Drought Plan.
The stochastics work and selection of droughts upon which we have tested our plan in section 8 link back to the UK Long Term Planning Framework and industry- leading stochastics work. We note your point about
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) modelling successive droughts but feel that, given the recovery periods of our sources are most often limited to one recharge season, they would be able to withstand another drought event in the year after anyway. Furthermore, the third dry winter scenario we have examined in section 8.3 demonstrates our continued ability to cope with what is essentially multiple drought events occurring in quick succession, before full recovery each year has taken place. SWT&KWT(o)Testing The DP highlights the heavy reliance on drought We broadly support this conclusion, which is why we've Minor change to draft permits and orders and the uncertainty associated with taken the work from here and have incorporated it into drought plan obtaining them. Additionally, table 8.15 demonstrates our dWRMP19 in terms of identifying improvements to that the DP cannot meet the stated level of service our resilience. We have provided additional commentary without drought actions for the three generated drought on this in section 8.4 of our revised draft drought plan. conditions. Even with drought actions, the level cannot be met in the extreme scenario. SWT&KWT(p)Gen Therefore there is a clear need for investment to We don't necessarily agree that drought-proofing should Minor change to draft enhance resilience. We do acknowledge that there is a feature more in the drought plan as it is often linked to drought plan commitment to assessing this through WRMP19, significant investment which requires a mechanism such however there does not seem to be any mechanism for as the WRMP through which to secure funding, but we this to feed back into the DP or for a reduction on have emphasised the link between the dWRMP19 and reliance on permits/orders to be incorporated into our revised draft drought plan in section 8.4. drought procedures. The Trusts believe that drought- proofing should feature much more prominently throughout the plan. Uckfield Town Council UTC(a)Actions With reference to Phase 1 application of demand The expectation is that during the early stages of a No change to draft drought restrictions, where South East Water would apply a drought, during which the concessions to Phase 1 of our plan traditional hosepipe ban but allow for concessions i.e. proposed temporary use restrictions would be permitted, the elderly and blue badge holders would still be we would not feel it necessary or appropriate to set an allowed to use their hosepipes during a drought period: age limit to define 'elderly'. However, as the drought members wondered whether it would be more helpful to worsens, we would reflect on the specific situation likely specify an age at which you consider use to be remove these concessions, but always allowing for a two- necessary in the case of concessions. Within your week consultation on any proposed restrictions, giving us
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) report, there appeared to be no definition of elderly. time to reflect on any representations received. We have not undertaken an Equality Impact Assessment, but we Members also questioned that if one member of a have undertaken an assessment of the impacts on the household was a blue badge holder, but the remainder community of our drought management actions: the of the household were not, how would this be applied? scoring system shown in Table 5.1 has been used to assess potential impacts to the human environment. It was suggested that more clarity was required on the Specific consideration has been given to impacts to use of concessions and wondered if an Equality Impact customer health and wellbeing, and impacts to other Assessment had been undertaken to consider the business, non-household water supply retailers or impact on each of the protected characteristics. recreational related users. UTC(b)Gen Members felt it was a valid document but did not help to Given that we have now submitted our draft Water Minor change to draft address the long-term problem of water leakage from Resources Management Plan 2019 (dWRMP19) to Defra drought plan non-maintained water mains. There was a need for the (1 December 2017), we have provided some water companies to look at their water storage capacity, supplementary information in section 8.4 regarding the and for local planning authorities to stress more heavily ways in which we propose to improve the resilience of our in planning applications, the need to impose conditions water resources for the longer term, which feeds back around water management. into our drought resilience as applicable to our revised draft drought plan. UTC(c)Mgmt&Comm Members also wondered if there was any role for parish We acknowledge and thank Uckfield Town Council for No change to draft drought s or town councils during a period of drought: whether the their consideration of the potential role of parish and town plan Town Council would become a hub or important point of councils during a period of drought. We agree that the contact in times of drought to assist with the supply of councils play and important communication role during water. The Town Clerk would check with South East drought and our plan reflects this and we hope by Water. sending information to the councils during a drought they can help us keep people informed. We will consider this idea of the town council becoming a hub and to assist with the supply of water in future iterations of our drought plan, this may be more appropriate during emergency drought situations, which form part of our emergency plan measures. We will discuss this idea through our resilience forum network to see if other councils agree with this approach.
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Draft Drought Plan 2017 Statement of Response December 2017
SoR Ref. Summary of Representation(s) South East Water Response Proposed change to draft Drought Plan (Representations from other organisations have been grouped by organisation and summarised) Wooburn and Bourne End Parish Council WBEPC(a)Gen Wooburn and Bourne End Parish Council would like to We thank Wooburn and Bourne End Parish Council for No change to draft drought register its approval of your drought plan. From their response to our consultation. plan laymen's perspectives it seems to cover every eventuality.
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Draft Drought Plan 2017 Statement of Response December 2017
5.0 NEXT STEPS
5.1 Publication of the statement of response
We have published this statement of response on our website and a copy has been sent to all individuals and organisations who responded during our consultation period.
A revised draft drought plan has also been prepared which highlights the changes we have made as a result of the consultation. This has replaced the draft drought plan and is also available on our website.
5.2 Producing a final drought plan
The statement of response document provides a response to representations received on the draft drought plan. It also sets out how we have updated the Drought Plan to form a revised draft drought plan for submission to the Secretary of State alongside this statement of response. This document has taken account of the following legislations, which provides the legal framework for producing the statutory drought plans:
Drought Plan Regulations 2005 Flood and Water Management Act 2010 Water Use (Temporary Bans) Order, 2010 Drought Permits and Drought Orders, 2011 Drought Direction 2011 The Drought Plan (England) Direction 2016 Process E6 of the Operational Terms of the Market Codes
The following steps will now be taken to complete our final Drought Plan: Publication of our statement of response and revised draft drought plan Secretary of State to review statement of response and revised draft drought plan Direction from Secretary of State that our statement of response and revised draft drought plan have been accepted Preparation of final drought plan Environment Agency review of final drought plan for compliance with Secretary of State directions Publication of final drought plan
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