Dŵr Cymru Welsh Water Revised Draft Water Resources Management Plan Statement of Response to the Consultation April 2012
TABLE OF CONTENTS
1 INTRODUCTION 1
1.1 Our Plan 1 1.2 Consultation 1
2 ISSUES 3
3 RESPONSES 4
3.1 Habitats Directive Sustainability Reductions 4 3.2 Leakage 6 3.3 Metering and Tariffs 8 3.4 Water Supply 10 3.5 Growth and Demand 12 3.6 Levels of Service 14 3.7 Supply Demand Balance 16 3.8 Climate change 17 3.9 Water Efficiency 20 3.10 Headroom 22 3.11 Strategic Environmental Assessment 23 3.12 Habitats Regulations Assessment 24 3.13 Option appraisal and selection 26
4 NEXT STEPS 29
4.1 Further Information 29
Page | i Revised Draft Water Resources Management Plan, Statement of Response to the Consultation APPENDIX 1 Revised Draft Plan comments and responses (available seperately from this document)
APPENDIX 2 Revised Draft SEA comments and responses (available seperately from this document)
APPENDIX 3 Revised Draft HRA comments and responses (available seperately from this document)
Page | ii Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 1 Introduction
1.1 Our Plan
Our Revised Draft Water Resources Management Plan (Revised Draft Plan) was published for consultation on 31 October 2011. The Revised Draft Plan details how Welsh Water will manage water resources across Wales over the next twenty-five years.
Since publishing our Draft Water Resources Management Plan for consultation in January 2009 we have received new information to inform the planning process, specifically proposals from Environment Agency Wales to modify our abstraction licences in order to comply with the Habitats Regulations 2010. As a result of this information we have produced and consulted on a Revised Draft Plan that takes the proposed changes into account.
We have also included an assessment of the likely effects of climate change on our water supply over the next 25 years using the latest climate change projections, known as the UKCP09 projections.
The Revised Draft Plan identifies deficit zones where demand is exceeding (or forecast to exceed) supply and identifies appropriate measures to either increase supply or manage demand in each water resource zone. We have looked at a range of options to meet the deficit including developing new water resources and the promotion of water efficiency measures.
1.2 Consultation
The preparation of a Plan and the need to consult is a statutory process. We published our Revised Draft Plan for consultation between the 31 October 2011 and 23 January 2012.
As part of the process we contacted more than sixty statutory consultees and published the documents on our website. The Welsh Government (WG) has sent us the 15 representations received on the Revised Draft Plan.
At the same time we also published for consultation the following supporting documents to the Revised Draft Plan; the Strategic Environmental Assessment (SEA) and the Habitats Regulations Assessment (HRA). In total we received 2 representations on each.
Page | 1 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation We are required1 to send the Statement of Response to WG to show:
1. that we have considered the representations
2. any changes to the Revised Draft Plan, as a result of considering the representations
3. where changes have not been made to the Revised Draft Plan, as a result of considering the representations, why not
Although not a statutory requirement, Welsh Water have also chosen to use this Statement of Response to summarise the comments we received on the SEA and HRA to the Revised Draft Plan.
A copy of the Statement of Response has been forwarded to each of the respondents listed in Table 1 and is published on our website at www.dwrcymru.com. In addition we have written individually to every respondent with a more detailed response to their individual queries.
Name Sector Brecon Beacons National Park Authority Planning British Waterways Statutory/Charitable Trust Cardiff Council Planning Consumer Council for Water Wales Committee NGO Conwy County Council Planning Countryside Council for Wales Statutory Denbighshire County Council Planning English Heritage Statutory Environment Agency Wales Statutory Gloucestershire County Council Planning Neath Port Talbot Council Planning Pembrokeshire Coast National Park Authority Planning Royal Society for the Protection of Birds Charitable Trust Swansea City County Council Planning Wye and Usk Foundation Charitable Trust
Table 1 List of respondents to either the revised Draft Plan, SEA and HRA
1 Section 4, Water Resources Management Plan Regulations 2007
Page | 2 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 2 Issues
The representations received on all three documents (Revised Draft Plan, SEA, HRA) have been evaluated and arranged under the following headings for our responses (see below). In Section 4, we have set out a summary of the comments received – colour coded – followed by our response. In the list we have included comments requiring responses but have not included comments which are supportive of the Plan. All the comments received are shown in Appendix 1 (Draft Plan), Appendix 2 (SEA) and Appendix 3 (HRA), verbatim, along with the associated responses.
1. Habitats Directive Sustainability Reductions 2. Leakage 3. Metering and Tariffs 4. Water Supply 5. Growth and demand 6. Levels of Service 7. Supply Demand Balance 8. Climate change 9. Water efficiency 10. Headroom 11. Strategic Environmental Assessment 12. Habitats Regulations Assessment 13. Option appraisal and selection
Page | 3 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3 Responses
3.1 Habitats Directive Sustainability Reductions
Background
The EEC Directive 92/43/EEC on the conservation of natural habitats, wild fauna and flora was incorporated into the UK regulatory system under the Conservation (Natural Habitats, &c.) Regulations 1994. The regulations provide for the designation of ‘European sites’ (Natura 2000 sites), the protection of ‘European protected species’ the adaptation of planning and other controls for the protection of such sites and impose a statutory requirement to deliver the improvement schemes.
As the designated ‘competent authority’ for England and Wales the Environment Agency (EA) is required to ensure that its permissions and operations cause no adverse effect on the ‘integrity’ of the Special Areas of Conservation (SAC) and Special Protection Areas (SPA) included in the Natura 2000 sites identified in the EU Habitats Directive. As a competent authority ourselves Welsh Water are required to have due regard for the environment in which we operate and to undertake our responsibilities as set out by the Habitat’s Directive.
The Review of Consents (RoC) process, or Habitats Directive sustainability reductions, is the EA mechanism for undertaking their review of all existing and proposed permissions that may impact upon EU designated sites.
Consultee Response
We received a number of comments in relation to the Habitats Directive RoC process and the associated changes to our abstraction licences. The focus of the comments was mainly around the quality of the data and information that the current proposed licence changes are based on and the need for further studies and ecological data. The other issue raised was in relation to the implementation date of 2020 for the licence changes.
British Waterways, Consumer Council for Water Wales, Pembrokeshire National Park Authority, Wye and Usk Foundation and Countryside Council for Wales (CCW) were all supportive of the need for additional research to be carried out, although CCW stated that they are happy that the current findings are robust and comply with the legal Habitats Directive Requirements.
EAW raised concern over the licence changes being shown to be implemented in 2020 in the Revised Draft Plan, when the Water Framework Directive (WFD) deadline is 2015. Pembrokeshire National Park Authority and Consumer Council for Water Wales also made comments on possible implications of proposed implementation of the licence changes in 2020.
Page | 4 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation Welsh Water Response
As stated in the Revised Draft WRMP, the Habitats Directive does not require it to be demonstrated that abstractions are actually having a detrimental impact on a Habitats Directive site for a permission to be curtailed or modified. Rather it requires a demonstration that there is no impact for the permission to remain unchanged. Therefore, if ‘no impact’ cannot be proven, the precautionary principle applies and the permissions may be modified. In addition, the RoC process focuses on a hypothetical scenario where all abstractions are being operated at their maximum licensed volume (using a modelled assessment of the potential impact), a position which has never been implemented in practice.
The RoC process has not identified that any of our abstractions have an actual detrimental impact on the environment, only a modelled, (potential), impact, assuming that our abstractions are operating to their full licensed volumes.
Welsh Water is currently in discussion with the EAW, CCW and British Waterways regarding further environmental investigations on the River Usk to provide defined ecological data to underpin the RoC process going forward. These discussions would inform any further studies Welsh Water may implement on either the Rivers Usk or Wye. Any further investigations undertaken cannot impede or prevent the preparation and submission of the 2013 Draft WRMP, the timeframe for which is defined to us by EAW and WG.
The Revised Draft Plan assumes that the licence amendments under the RoC would be implemented in 2020. This was based on initial discussions with the EAW during the preparation of the Plan and the lead in time of key intervention options. However, following publication of the Revised Draft Plan, we are currently in discussion with the Environment Agency regarding the licence amendment date. The 2013 Draft WRMP will reflect this and the consequent required intervention options will be implemented in a timely manner to meet any supply demand deficits identified.
Page | 5 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3.2 Leakage
Background
Our current baseline leakage policy complies with industry best practice. It follows the approach to leakage optimisation outlined by Defra, Ofwat and the Environment Agency in 20022, supplemented by various reports published by Ofwat as part of detailed reviews of certain aspects of the optimisation methodology as well as its work on sustainable economic level of leakage.
We recognise the importance of maintaining low leakage levels in demonstrating our commitment to the efficient use of water.
Consultee Response
Leakage is a key topic for all those involved in the water industry. The main response on this topic was received from the EAW regarding the rising level of leakage in water resource zones where a supply demand balance deficit is forecast. The EAW also suggested that we should evaluate alternative active leakage control policies against current leakage policy as part of the Short Run Economic Level of Leakage (SRELL) assessment to ensure effective management of the network, and consistently evaluate sustainable leakage levels across the whole planning period, not just for the first five years.
Consumer Council for Water stated that they would like to know that the best option of economic leakage control has been selected to help address the significant deficits likely to arise if full effects of climate change and environmental restrictions are taken into consideration.
Welsh Water Response
As reported in the Revised Draft WRMP the leakage rate in SEWCUS post 2015 is constrained at the 2015 level in terms of litres per property per day, as SEWCUS has been identified as a deficit zone. The EAW is correct in stating that the rising leakage levels in this zone post 2015 are due to the expansion of the customer base in zone, despite holding the leakage level static in terms of litres per property per day. We understand the Environment Agency’s concerns in this regard and will review the situation for the 2013 Draft WRMP. We do not consider that it is feasible or within the best interests of the planning process to be undertaking considerable work for the 2012 Final Plan, when our focus should be on preparing the best 2013 Draft WRMP we can. We have discussed this with the EA directly.
For the 2013 draft plan, the efficiency of the current policy, alternatives to this and the benefits of current proven technology will be assessed. The potential yields from alternative approaches and the influence these may have upon the SR-SELL will be considered. Any potential impact on the current SR-SELL at a Zonal level will be forecasted over the relevant
2 “Best Practice Principles in the Economic Level of Leakage Calculation”: report commissioned by the Tripartite Group consisting of Defra, the Environment Agency and Ofwat.
Page | 6 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation planning horizon in terms of what is practicable for delivery, at which point the Long Run Sustainable ELL will be realised.
As requested by the EAW we will present the leakage values in the 2012 Final Plan document in line with the leakage values presented in WRP1-BL.
In response to the Consumer Council for Water’s comment, our option appraisal approach follows national best practice and is consistent with the requirements of the EA water resources planning guideline. The selection of options to meet supply and demand deficits is done on a least cost basis in parallel with an environmental assessment of the options (the SEA and HRA). Should a leakage control option be selected on these grounds then it would be promoted as a preferred option. However, it is not appropriate or correct to promote an option that is not selected on these grounds.
Page | 7 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3.3 Metering and Tariffs
Background
At present around 31% of our households are metered. Our demand forecasts assume that this proportion will continue to rise in line with current trends, which would increase meter penetration to 70% by 2035. During our current investment programme (2010-15) we will be spending around £30 million on metering. We have considered the policy option of ‘metering upon change of occupancy’ as a potential means to address supply demand deficits but this is not demonstrated to be cost-effective when compared against other options.
Consultee Response
We only received one response relating to metering. The Consumer Council for Water suggested that the 2013 Draft WRMP should place more emphasis on cost effective sustainable demand management solutions, including metering. It also requested more detail on how metering has been considered and rejected against other demand management options, and how we plan to protect vulnerable customers who may struggle to pay their water bills as meter penetration increases in the future.
Welsh Water Response
Table WRP6 of the Revised Draft Plan (for all water resource zones) provides a clear breakdown of our metering assumptions by water resources zone (‘meter optants’ and ‘new properties’). We have included metering in line with the current trends which raises company-wide metering to a level of 70% under current forecasts by 2035. However, as stated in the Revised Draft Plan, this is a significant continued uptake and we will monitor this closely though annual reviews and our water resource planning process.
The Welsh Government does not currently promote universal metering, therefore with regard to both this policy and the fact that we estimate that meter penetration will naturally rise to approximately 70% by the end of the planning period, we have not included metering as an intervention option in the Revised Draft Plan. Should Welsh Government policy in this regard be amended in a timely manner for our 2013 Draft WRMP preparation, then we would obviously reassess the situation.
Regarding the protection of vulnerable customers in the face of increased meter penetration, affordability and the protection of vulnerable customers will always be a top priority for Welsh Water. In line with our beliefs regarding the affordability of water charging which is also aligned with the Welsh Government and the EA, we currently offer three support tariffs which are designed to help low income and disadvantaged customers (up to a 40% decrease in charge):
Water Direct – an annual discount is applied to each customer paying their charges to us by direct deductions from qualifying Department of Work and Pensions (DWP) benefits.
Page | 8 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation This discount of £25 will be applied for each year the customer continues to pay by this method.
Water Collect – an annual discount is applied to each customer paying charges via a registered social landlord or Local Authority participating in the scheme. The discount of £10 will be applied for each year the customer continues to pay by this method.
Welsh Water Assist – caps bills for eligible customers. The tariff is based around the vulnerable groups regulations made by Defra, but extends to unmeasured customers and is set at a lower level (below the average charge for a household customer). If the customer is metered and the charge calculated from the actual use is less than the ‘Welsh Water Assist’ tariff, then the bill will be based on the actual reading. If not, the bill will be capped at the Welsh Water Assist level.
We also have a ‘Customer assistance fund’ aimed at helping customers who have a high level of arrears get back into a regular habit of paying their current water charges. Arrangements with selected local authorities and housing associations provide further assistance to customers who are having difficulties in paying their bills.
We will, of course, be reviewing our full range of tariffs going forward to ensure that they remain in our customers best interests. These will be updated accordingly in the 2013 Draft WRMP.
Page | 9 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3.4 Water Supply
Background
We set out in the Revised Draft Plan how we calculate the amount of water we can supply in each water resource zone. This is a function of the ‘Deployable Output’ of our water resource assets together with the allowances and adjustments that are made for the operational losses that are inherent in the treatment of water, outages and transfers. The detailed work done to support the assessment of water supply is documented in a number of key supporting reports that were not published in the public domain due to the need to comply with the Security and Emergency Measures Directive on publishing information on our assets and operations. However, throughout the preparation of the Revised Draft Plan, we have been in regular contact with, and provided all documents to the Environment Agency Wales. The reports were available to all consultees on request.
Consultee Response
Comments were received on this topic from British Waterways, Countryside Council for Wales, and the Environment Agency Wales. The comments covered the areas of outage, water transfers and water resource zone integrity.
British Waterways noted that the Revised Draft Plan does not currently make any allowances for the supply of water to the Monmouthshire & Brecon Canal, even though this is under discussion with DCWW, EAW, CCW and WG as a possible solution to the outcome of the Review of Consents process. British Waterways acknowledge in their response that this has not been included because DCWW have not been directed by WG to consider it; however, they believe that it is vital to include this option in the Revised Draft Plan.
The CCW expressed the view that the Revised Draft Plan could have made greater links with the developing Natural Environment Framework for Wales and Natural Resource Management planning, in particular the links between pollution and eutrophication of raw drinking water sources and the level of outage experienced because of these issues. CCW believe that the Revised Draft Plan still gives the impression that supply of water is largely as a result of infrastructure decisions and capital interventions, and does not account for what happens to water before the point of abstraction by us. CCW would like to see this issue addressed further in the next iteration of the Plan.
The EAW recommended that we should consider whether options to reduce outage in deficit water resource zones over the life of the plan, should be included in the options appraisal for the Final Plan.
The EAW acknowledged our plans to carry out further detailed work on the way that our SEWCUS resource zone is operated and to confirm whether the zone is fully integrated. The EAW stated that they expect us to follow the new guidance from the EA on resource zone integrity and to complete this work as soon as possible.
Page | 10 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation Welsh Water Response
The WRMP is Welsh Water’s plan detailing how we will ensure security of supply to all of our customers over the defined 25 year planning period. As a statutory water and sewerage undertaker our priority is to provide a reliable supply of water to our customers reflecting the levels of service they expect from us. Therefore at this present time, until the Review of Consents process has been finalised and we are certain of the options that we require to maintain reliable supplies of water to our customer, we are not in a position to allocate resources to other users of water, including supplying the Monmouthshire & Brecon Canal with water to mitigate against the impacts of the RoC on British Waterways. We are currently in discussion with British Waterways, the EAW and CCW regarding further environmental investigations on the River Usk to provide defined ecological data to underpin the RoC process going forward. We will consider these discussions, in light of both the Rivers Usk and Wye, through continued discussions with all relevant parties.
Although not explicitly clear in the Revised Draft Plan, it does inherently take account of the issues raised by CCW regarding source pollution and eutrophication. We work closely with other teams in Welsh Water such as our Catchment Management Team to account for such issues and this work directly impacts the estimates of water available for use (WAFU) in each zone. We will endeavour to report this work with greater clarity for the 2013 Draft WRMP.
Outage options have not been considered as intervention options in the Revised Draft WRMP due to the marginal quantities of water potentially saved by the options. More importantly, outage options would not deliver the required water to meet water resource zone deficits due to the very short temporal nature of ‘outage’. We have a comprehensive and continual outage data collection process, through which we monitor outages at all our water treatment works across Wales. As part of this work we continually strive to understand and reduce outage across all of our works.
We are currently undertaking water resource zone integrity assessments for all 24 of our water resource zones, including SEWCUS. This work is using the new guidance from the Environment Agency on water resource zone integrity. We will report the results of this work as part of the 2013 Draft WRMP submission.
Page | 11 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3.5 Growth and Demand
Background
Forecasting future demand for water as accurately as possible is a major component of the WRMP. It is something we continually work on to ensure we are not developing unnecessary resources or under-forecasting the required supply and leaving our customers vulnerable to a shortfall. Demand forecasts for the Revised Draft Plan were prepared in accordance with the Environment Agency’s Water Resources Planning Guideline.
Consultee Response
Cardiff Council, the City and County of Swansea, Denbighshire County Council and the Countryside Council for Wales all made comments regarding the property forecast and growth figures used in the Revised Draft Plan. Clarity was sought on the figures that had been used in our forecasts.
The EAW also highlighted that we should liaise with the Local Planning Authorities (LPA’s) to ensure that the scale and phasing of new development is consistent with our proposals for new supply and demand options in the Plan. The EAW highlighted that this is particularly important for those LPA’s supplied by water resource zones that are in deficit and recommended that we provide a table in the Final Plan showing the proportion of each LPA population in each resource zone, to help LPA’s understand which water resource zones supply their area.
The EAW also recommended that implications for future industrial water supply in Anglesey and Milford Haven need to be considered and addressed in the Plan once adequate information on water requirements is available. The Consumer Council for Water also recommended that for accuracy of supply and demand predictions, the 2013 Draft WRMP should consider future economic development better, particularly regarding expected industrial demand, as this could put water resources under pressure in the future.
Welsh Water Response
Our demand forecasts utilise published data from the Welsh Government, the Office of National Statistics, Local Authority data, our Customer Accounting System, customer surveys and our metered data. Naturally we liaised very closely with the various Local Authorities regarding their Local Development Plans (LDP’s) throughout the preparation of the Revised Draft Plan and we are commencing liaison again with all Authorities in preparation for the 2013 Draft Plan. However, our demand forecasts follow the methodologies as defined by the Environment Agency guideline (utilising WG data specifically). We utilise the other many sources of data to consider sensitivity around these forecasts which allow us to understand potential ranges of growth across Wales.
Welsh Water are a statutory consultee in relation to LDP’s and we work closely with the Local Authorities on the spatial allocation for future development, so that Welsh Water can best meet their requirements.
Page | 12 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation
We will include in the 2012 Final Plan a table showing the proportion of each Local Planning Authority area included in each of our water resource zones.
We are currently preparing the 2013 Draft WRMP, which will be submitted to the Welsh Government in March 2013. The demand forecasts will be updated as part of the 2013 Draft WRMP, to include the latest available data. Throughout this process we would welcome the opportunity to liaise closely with all the Council’s within our supply area to verify that the property forecasts and growth figures we use to ensure our demand forecasts are aligned with those being used in Local Development Plans.
Page | 13 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3.6 Levels of Service
Background
In preparing our Revised Draft Plan we used consistent Levels of Service (LoS) with our Drought Plan. These are: Introduction of hosepipe restrictions - not more than 1 in 20 years on average, Implementation of Drought Orders/Permits – not more than 1 in 40 years on average, Rota cuts/standpipes – not acceptable. We define LoS to meet regulatory requirements and to assess the yields of our water sources and resources. We consider that the current LoS represents a balance between acceptable services to customers and having due regard to the environment.
Consultee Response
The Consumer Council for Water requested more information on how the company is planning to test its levels of service with its customers before the next price review, particularly in relation to hosepipe bans. It was also suggested that levels of service in the 2013 WRMP should be developed in line with the climate change scenarios indicated as appropriate by the Environment Agency Wales, and the Welsh Government.
The Countryside Council for Wales questioned whether it is wise or feasible to guarantee a level of service given the uncertainty around the impacts of climate change and the apparent significant potential impacts on supply in some zones. Another source of uncertainty is the response of water customers to climate change. It suggested that changing patterns of water consumption, coupled with reduced water availability, could well render target levels of service defunct or inaccurate. CCW suggested that this element of water resource planning appeared to require a fundamental rethink and it looks forward to this being addressed in the 2013 Draft WRMP.
The Environment Agency Wales made several points relating to LoS. It suggested that we should review our drought control lines for the SEWCUS resource zone as part of the review of how this resource zone is operated. EAW suggested that we should determine whether using one set of control lines to calculate the actual LoS for this resource zone is still appropriate.
The EAW also recommended that we review the impact of the new temporary water use restrictions brought in by the Water Industry Act (1991) as amended by the Flood and Water Management Act (2010) on its drought control lines for our next drought plan. It highlighted that such a review may affect our company’s LoS and/or lead to changes in deployable output figures for the 2013 Draft WRMP.
The EAW requested that we provide the evidence to support the actual LoS calculations for the resource zones with revised deployable outputs (SEWCUS, Pembrokeshire and North
Page | 14 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation Eryri Ynys Mon) in our 2012 Final Plan. It also requested that we provide the supporting evidence for our assessment of the effects of changing Levels of Service on deployable output for the deficit resource zones.
Welsh Water Response
We will be undertaking a series of customer surveys over the next 12 months, which will assist us in preparing the 2013 Draft Plan. Those surveys will include issues such as LoS and security of supply. The technical work underpinning our LoS is reviewed and updated almost on a continual basis, particularly when critical information (e.g. the latest climate change impacts) may drive fundamental change. Therefore, as part of the work to prepare the 2013 Draft WRMP, the current LoS will be confirmed.
We will review the impact of the new temporary water use restrictions brought in by the Water Industry Act (1991) as amended by the Flood and Water Management Act (2010) once directed to do so by the WG with respect to our Drought Plan. As our models that underpin the Drought Plan and the WRMP are one and the same, we will also be assessing the impact on the zonal and company LoS and deployable outputs as part of this process.
As requested by the Environment Agency Wales, we will provide evidence in the 2012 Final Plan for the SEWCUS, Pembrokeshire, and North Eyri Ynys Mon water resource zones on the derivation of the respective LoS. We will also provide further evidence in support of the 2012 Final Plan to support the deployable output versus LoS values in the form of reservoir drawdown plots against the drought control lines. However, as is evident from Table 9.16 in the Revised Draft Plan, increasing the zonal deployable output for SEWCUS, by lowering the actual zonal LoS significantly compromises the emergency storage allowance in this zone. In Pembrokeshire lowering the actual zonal LoS to the company LoS value yields only marginal gains in the deployable output (at most 0.27 Ml/d).
Page | 15 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3.7 Supply Demand Balance
Background
We undertake detailed analysis of our water supply systems to determine how much water is available for supply. Within our Revised Draft Plan we presented 3 water resource zones as having a supply deficit during the planning period to 2034-35.
Consultee Response
The Environment Agency Wales recommended that for the 2012 Final Plan we clearly state the supply demand position for the critical period for all the resource zones identified as being in deficit in the critical period in our main report. In our Revised Draft Plan we set out the supply demand position for the dry year annual average scenario for the deficit water resource zones.
Welsh Water Response
The critical period planning scenario deficits for Brecon Portis and Pembrokeshire water resource zones are shown in the Revised Draft Plan (Appendix A – Zonal Summaries). For the 2012 Final Plan these zonal critical period planning deficits will also be contained within the appropriate sections of the main report. Only the annual average planning scenario has been produced for SEWCUS because this resource zone is not forecast to be in deficit under critical period until 2028/29.
Page | 16 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3.8 Climate change
Background
Within our Revised Draft Plan the impacts of climate change are considered on both the supply and the demand components of the supply demand balance. Our Revised Draft Plan incorporated the latest climate scenarios, UK Climate Projections 2009 (UKCP09). For the purposes of preparing the Revised Draft Plan we have used the ‘medium’ climate change scenarios rather than either the upper or the lower scenarios.
In the Revised Draft Plan we treated the uncertainty around climate change as follows;
we reflected the UKCP09 50 percentile impacts in our projections of deployable output; and
we quantified the additional effect of the full range of UKCP09 climate impacts in our evaluation of target headroom, but did not use these sensitivities for the purposes of the main supply demand assessment and option appraisal process. However, we did present the outcomes of including the full range of UKCP09 scenarios the plan.
It should be noted that at the time we undertook this assessment no industry guidance was available on which to base this assessment. Climate change was one of the main areas of our Revised Draft Plan that consultees responded on.
Consultee Response
Ofwat accepted our justification for basing our proposed investment on the assessment of the supply demand balance that takes account of the impacts of climate change, but which excludes an allowance for the uncertainty of the impact of climate change on supply. Ofwat agreed that we will be in a better position to make a more definitive assessment of the impacts of climate change in our next Draft Plan in 2013, and stated that they expect us to follow the updated water resource planning guideline due to be issued by the Environment Agency and Ofwat in May, when completing the 2013 Draft Plan.
Similarly, the Wye & Usk Foundation agreed with our treatment of climate change and that it may not be appropriate at present to be proposing new sources to deal with the full range of potential impacts of climate change. However, they highlighted that the Review of Consents process excludes the consideration of climate change and recommend that this inconsistency is addressed for strategic long-term planning purposes.
The Brecon Beacon National Park Authority, Cardiff Council and the Consumer Council for Water all understood our rationale for not including the effects of climate change in our headroom uncertainty assessment, however, they all recommended that we carry out further work on this area of our plan and ensure that our 2013 Draft Plan follows the latest Environment Agency water resources planning guideline in terms of climate change assessment.
Page | 17 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation The Countryside Council for Wales raised several concerns about how we had accounted for climate change in our Revised Draft Plan:
CCW does not fully agree with the treatment of climate change uncertainty in our Revised Draft Plan, stating that the options selected take virtually no account of the potential significant impacts of climate change on the supply of water.
CCW recommended that the Revised Draft Plan needs to manage climate change uncertainty in a more coherent way than it presently does, and conduct an explicit analysis to identify how the worst case deficits could be addressed, what lead time such a project would require, when investment decisions would need to be initiated and how the project management would incorporate new climate information as and when it became available. By implementing this analysis CCW state that the worst case scenario would be explicitly considered and the decision to proceed without further action would be more clearly justified.
CCW highlight that whilst UKCP09 is a huge improvement on the 2002 projections, it is an incomplete estimate of climate uncertainty, and therefore the reference in our Revised Draft Plan to the UKCP09 95th percentile being “95% sure” is inappropriate.
CCW believes there is an ambiguity in the Revised Draft Plan with regard to how it handles climate change uncertainty because it acknowledges the potentially massive effects of climate change on water availability, but expresses an unsubstantiated confidence in having sufficient lead time and capacity to make good any deficits resulting from the effects of climate change.
CCW recommend that the knowledge gap recognised by us in our Revised Draft Plan, regarding the response of water demand to climate change, is addressed as a matter of priority.
CCW recommend that climate change impacts should be more fully analysed and planned for within our Revised Draft Plan, and certainly within the 2013 Draft Plan and highlight that it may be the case that investment decisions taken now would need to change either in type or scale as a result of further climate change analysis. CCW recommend that we ensure that options to maintain the supply demand balance chosen now, do not undermine any approach that might be considered as essential when taking climate change impacts into account.
The Environment Agency Wales also made a number of recommendations regarding the assessment of climate change:
We should revise our assessment of the impacts of climate change on supply, in particular for the water resource zones in deficit, in line with the new climate change guidance.
Page | 18 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation We should carry out further investigations in the geographical areas that are most vulnerable to the impacts of climate change, including understanding what is causing the significant impacts and considering how these can be reduced.
We should incorporate the Environment Agency’s assessment of the impacts of climate change on the River Dee Regulation Scheme into our water resource management plan.
The EAW recommend that the best approach is for us to address these recommendations in our 2013 Draft Plan, but stated that they would like to see a commitment from us in our 2012 Final Plan to do this.
Welsh Water Response
We are currently preparing to commence climate change assessment work for our 2013 Draft Plan. The work will embrace the recommendations of the forthcoming revision of the Environment Agency Water Resources Planning Guideline (WRPG). We have played an active part in steering the numerous water industry research projects on applying climate change in water resources planning which have influenced the development of the WRPG. We are therefore fully aware of the Guidance recommendations. The revised WRPG will better reflect the appropriate use of the UKCP09 climate change projections (and other data such as Future Flows) using the research that has been carried out by the water industry since our work was completed for the Revised Draft Plan. Our 2013 Draft Plan will report on the work we are about to commence to assess the effects of climate change on water resources within Welsh Water.
We note the Wye & Usk Foundation’s concerns regarding the absence of the potential impacts of climate change in the Review of Consents process. This is one of the technical areas that we have challenged the Environment Agency on and we would welcome the EA addressing this issue.
In response to the Countryside Council for Wales’ concerns about the potential selection of options that are not ‘climate change proof’, the preferred options presented within the Revised Draft Plan have all been modelled and assessed within the influence of climate change (the UKCP09 Median, 50 percentile, scenario), therefore we consider that the preferred options are as ‘climate change proof’ as practicably possible.
We note the EAW comments regarding the requirements for further work to understand the potential impacts of climate change in the SEWCUS water resource zone. We are aware of the vulnerability of this zone, not least from climate change and sustainability reductions, and we will be undertaking further work on the issues the EAW has raised.
We agree that the EAW’s assessment of the potential impacts of climate change on the River Dee system should be accounted for in the 2013 Draft Plan. We will liaise closely with the EAW on this work.
Page | 19 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3.9 Water Efficiency
Background
Welsh Water is firmly committed to water efficiency and we undertake a significant number of activities that are a combination of education and practical advice. We launched our Water Efficiency Strategy in May 2007, building on an established water efficiency programme and ensuring alignment with the Welsh Government’s Environment Strategy (Environmental Outcome number 14).
Consultee Response
Cardiff Council recommended that the plan should fully assess the potential rainwater harvesting in new developments can have on reducing overall water supply demand. It highlighted that given the scale of development likely to be identified in the Cardiff Local Development Plan, this could represent a significant ‘new’ source of water, with the added benefit of reducing surface water flooding risks.
The Consumer Council for Water recommended that the 2013 Draft Plan should place more emphasis on cost effective and sustainable demand management solutions for business and household customers and should examine a full range of options, including metering and the best options for leakage control. This should translate to a revised water efficiency strategy for Welsh Water.
The Countryside Council for Wales expressed their concern about excluding demand management measures such as domestic and non-domestic water efficiency measures on the basis of cost-benefit analysis alone. It asked whether there are improved ways of delivering efficiency measures that could be explored which would make the cost-benefit ratio compare more favourably with the preferred resource development options.
The Environment Agency Wales commented that our preferred set of options did not include demand management measures under our chosen planning scenarios. The EAW recommended that we explore more innovative and cost effective water efficiency measures, working in partnership with other organisations and that we build up our evidence base for demand management options to improve our assessment of the volumes of water saved and the costs and benefits associated with this type of options for our Plan. The EAW recommended that we should present these types of options as being flexible and incremental and not just calculate the maximum water saving from each option.
The EAW also recommended that for our 2012 Final Plan we should show how Ofwat’s water efficiency targets have been incorporated in our demand forecasts. It also recommended that we should set out what measures or activity is required from the Environment Agency, Ofwat and the Welsh Government to help reduce water consumption further.
Page | 20 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation Welsh Water Response
In the Revised Draft Plan we have included in the optioneering process six customer-side management options (5 water efficiency options and 1 tariff option) and three advanced distribution management (leakage) options for each deficit resource zone, in addition to the numerous resource side options. The water efficiency options do not include an option for rainwater harvesting for new developments because it was concluded early in the optioneering process that such an option was currently not feasible, and would not save sufficient quantities of water to warrant being included as an intervention option. However, for the 2013 Draft Plan, we will be reviewing the options across all the option categories and we will again review the applicability and use of rainwater harvesting.
Water efficiency options were not selected as our preferred options in the options appraisal process. Our options appraisal approach follows national best practice and is consistent with the requirements of the Environment Agency Water Resource Planning Guideline. The selection of options to meet supply demand deficits is done on a least cost basis in parallel with an environmental assessment of the options (the SEA and HRA).
We have since been working on specific areas of water efficiency across various sectors collecting robust evidence to inform future plans. We are currently revising our Water Efficiency Strategy which will be published in the second quarter of 2012. The principles and findings of this Strategy will be fully embedded in the 2013 Draft WRMP.
We note the Environment Agency Wales’ comments regarding utilising demand management activities, specifically in partnership with other organisations with the aim of reducing costs. We have discussed this with the EAW extensively over the past few months, and confirm that for the 2013 Draft Plan we will be reviewing the whole range of demand management and leakage reduction options in accordance with our revised Water Efficiency Strategy and leakage policies. Through this work we will review such items as embedding greater flexibility in our water efficiency options.
As stated in section 4.7 of the Revised Draft Plan, we have implicitly included within the Plan Ofwat’s water efficiency targets, as part of deriving our baseline demand forecasts. We will include, within the 2012 Final Plan, details of how these targets have been incorporated and we will liaise with the Environment Agency Wales to ensure that we meet its requirements on this issue.
Page | 21 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3.10 Headroom
Background
Target Headroom is the planning margin or buffer that a water company should allow between supply and demand to cater for specified uncertainties in the overall supply- demand balance. The calculation of an appropriate uncertainty allowance is important and often determines whether a water resource zone is in a supply deficit or surplus.
Consultee Response
The Environment Agency Wales made the only direct comments received on our headroom assessment. These are summarised below;
It was noted that we had excluded the uncertainties in our estimation of the impacts of climate change on supply from the headroom uncertainty assessment, and the EAW believe this undermines our objectives to ensure secure water supplies. The EAW expect us to include this component of uncertainty in target headroom.
It was recommended that we accept a higher level of risk in future years when setting our risk profiles for target headroom to recognise that some uncertainties can either be reduced or dealt with through time.
We should state clearly the greatest sources of uncertainty in the target headroom calculation for all resource zones in the main report of the 2012 Final Plan.
The EAW requested that we include a commitment in our 2012 Final Plan to address the first two recommendations in the 2013 Draft Plan.
Other comments received on this area were implicitly included in the feedback we received on our approach to climate change assessment. These have therefore been addressed in section 3.8.
Welsh Water Response
As stated in Section 3.8, we are preparing to commence the climate change work for our 2013 Draft Plan. We note the EAW concerns regarding the treatment of climate change uncertainty and the chosen risk profile in the Revised Draft Plan. We have discussed this with the EAW over the past few months, and confirm that both of these items will be reviewed for the 2013 Draft Plan.
The greatest sources of target headroom uncertainty for all 24 water resource zones will be provided in the 2012 Final Plan. This is likely to take the form of a tabular or graphical representation and may be best provided in an annex to avoid disrupting the continuity of the main Plan.
Page | 22 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3.11 Strategic Environmental Assessment
Background
A Strategic Environmental Assessment (SEA) is a statutory requirement for plans or programmes which could have significant environmental implications. It helps to identify where there may be potential environmental impacts through the implementation of the Draft Plan and how negative effects might be mitigated.
Consultee Response
We received three responses on the SEA consultation. These were from Gloucestershire County Council, the Countryside Council for Wales and the Environment Agency Wales. Gloucestershire County Councils comments on the SEA merely recognised the influence the SEA has on the Revised Draft Plan so that adverse environmental impacts are constrained and that some positive impacts may accrue through the selection of the preferred options.
The Countryside Council for Wales provided extensive comments that were both useful and constructive. A large number of the comments were requesting further clarification on detailed items and changes since the SEA on the Draft Plan. Other comments included recommendations regarding referencing other plans, documents and regulations, identification of areas where additional information is required to support the SEA, and concern regarding the approach used for scoring of environmental effects.
The Environment Agency Wales provided detailed constructive comments. The comments included recommendations regarding plans, projects and programmes that should be considered and/or referenced in the SEA; identification of areas where additional data and information may be required; recommendations relating to the scoring systems and thresholds used for the feasible options assessment; and the need for additional explanation as to why supply side options are preferred over demand side options.
Welsh Water Response
Detailed responses to all the individual queries raised in each response on the SEA are provided in Appendix 2.
We welcome all the comments received on the SEA and will take them into account as indicated in Appendix 2 for future iterations of the SEA.
Page | 23 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3.12 Habitats Regulations Assessment
Background
The process by which the impacts of a plan or programme are assessed against the conservation objectives of a European site is known as Habitats Regulations Assessment (HRA). Whilst Schedule 1 of the Conservation (Natural Habitats, &c) Regulations 1994 (as amended) (the ‘Habitats Regulations’) requires that competent authorities assess the potential impacts of land use plans on the Natura 2000 network of European protected sites, the requirement for this in respect of water resources management plans is not clear. However, due to the sensitive nature of our sites, we chose to undertake a HRA for the Revised Draft Plan.
Consultee Response
We received four responses on the HRA consultation. These were from Gloucestershire County Council, Neath Port Talbot Borough Council, the Countryside Council for Wales and the Environment Agency Wales. The response from Neath Port Talbot Borough Council merely acknowledged that they agreed with our assessment that none of the options considered in the HRA have potential to have a likely significant effect on European Sites within Neath Port Talbot.
Gloucestershire County Councils comments highlighted that we had omitted to mention that we have customers in parts of Gloucestershire. It also requested clarity on which Local Authority Unitary Plans have been considered for in-combination affects with the WRMP, and whether our assessment included consideration of the Forest of Dean Local Development Framework, Gloucestershire Waste Development Framework and Gloucestershire Minerals Waste Development Framework, in terms of whether there are any in-combination effects with these plans.
The Countryside Council for Wales provided detailed constructive comments. It recommended that we need to consider the possible ‘in-combination’ effects with other plans and programmes on implementation of the WRMP, and that we should provide further clarity on our intentions for monitoring the implementation of the Plan. CCW requested clarification regarding changes that have occurred to the water resource zones supply demand status since the Draft Plan, including changes to water resource option requirements and whether some options are still being taken forward. CCW largely agreed with our conclusions in the HRA subject to proposed schemes undergoing a project level assessment and suitable mitigation being carried out. It requested that we clearly state that if adverse effects were identified for an option through detailed project level assessment, which could not be mitigated, the project would not continue.
The Environment Agency Wales provided detailed comments on the HRA. It highlighted the need for us to implement detailed individual assessments of options as they are taken forward, to identify the detailed potential impacts of the options. As part of these site specific assessments the ESW recommended that a full assessment of the in-combination effects of a project, with other consents and local plans and projects should be carried out.
Page | 24 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation The EAW requested that where alternative options become the preferred option, then a full screening and test of the options likely significance should be undertaken. It was also recommended that we make further reference to our liaison with the EAW over recent years regarding work on the sustainability reductions.
Welsh Water Response
We always have high regard for the area in which we operate and so we chose to undertake an HRA to ensure we are not adversely affecting any European designated site though the proposals in our Revised Draft Plan.
Detailed responses to all the individual queries raised in each response on the HRA are provided in Appendix 3.
We welcome all the comments received on the HRA and will take them into account as indicated in Appendix 3 for future iterations of the HRA.
Page | 25 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 3.13 Option appraisal and selection
Background
The Revised Draft Plan detailed the option selection process we used to define our ‘final planning solution’ using our least-cost water resource planning model. A total of 19 resource and production management options across the three deficit resource zones were assessed as ‘feasible’ and carried forward for more detailed analysis.
Consultee Response
Some of the comments received on options appraisal have already been addressed in other sections of this document. The Consumer Council for Water, the Countryside Council for Wales and the Environment Agency Wales raised questions relating to the selection of leakage options; this has already been addressed in section 4.2. The Countryside Council for Wales and the Environment Agency Wales also raised a point regarding the selection of supply side options in favour of demand side options; this has been addressed in section 4.10.
The Brecon Beacons National Park Authority welcomed the option to reinstate Grwyne Fawr Reservoir, but raised concerns about the proposal for a new treatment works as part of this option. It suggested that any water quality issues could be solved through improved catchment management in the area and may prove to be a more cost effective and environmentally effective solution than investing in a new water treatment works.
The Countryside Council for Wales said that it was not clear in the Revised Draft Plan that the benefits associated with delivering ecosystem services have been factored into the options appraisal. It also questioned whether the wider environmental and sustainability consequences of our carbon emissions and the effects of removing more resources from the ecosystem have been fully taken into account in the cost-benefit analysis. It would like to see progress on this issue before our 2013 Draft Plan is produced.
The Countryside Council for Wales also highlighted that other water companies have previously discussed options including sourcing further water supplies from Wales, with consequent implications for the supply demand scenarios in the affected parts of Wales. CCW suggest that it could be worthwhile including some commentary on how such draft proposals may or may not affect the future supply options for Welsh Water.
The Environment Agency Wales made several recommendations regarding our options appraisal;
We should assess the monetary benefits of demand management and leakage control options as part of the environmental and social costings so that we can base our appraisal of supply demand options on a full understanding of the costs and benefits of options.
Page | 26 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation We should take a more strategic and risk based approach to our options appraisal in our 2013 Draft Plan. This should consider what is driving the deficits in resource zones, the robustness and flexibility of the options to the risks and uncertainties identified, and the wider benefits that certain options can bring.
We should improve our sensitivity analysis on our plan and make sure that it is robust and flexible. We should test the robustness of our preferred set of options to changes in assumptions or to the supply-demand balance.
We should provide further evidence to support the environmental and social costs and benefits assessment of all types of options for the deficit water resource zones in the 2012 Final Plan.
We should consider whether options to reduce outage in deficit zones over the life of the plan should be included in our options appraisal for the 2012 Final Plan
The Wye & Usk Foundation suggested that more research should be carried out on the rivers Wye and Usk, and a process of adaptive management of the gradual introduction and trialling of changes to licences and operating rules should be implemented. The Foundation stated that its analysis showed that the same benefits can be achieved with zero impact on water supplies and zero cost, and that the licence changes proposed for the Wye are likely to waste Welsh Water’s customers’ money.
Welsh Water Response.
In response to the Brecon Beacon National Park Authorities comments regarding catchment management, we agree with its concerns that catchment management should play an integral part on how Welsh Water operates, and our Catchment Management Team are working very closely with the Brecon Beacon NPA to reach sustainable solutions to difficult issues. However, the option in the Revised Draft Plan to reinstate Grwyne Fawr reservoir for operational use would still require the construction of a new water treatment works to treat the water abstracted from the reservoir, regardless of current discolouration issues. Raw water is required to be treated to the appropriate potable standards before it is delivered into supply. The proposed treatment works at Grwyne Fawr reservoir would be constructed within the boundaries of the existing Welsh Water owned land, and so allocation of ‘green land’ for the purpose would not be required. Any potential environmental impact of the option has been assessed at a high level by our SEA and HRA that were included in the Revised Draft Plan consultation. Should the Grwyne Fawr option be taken forward at some date in the future, specific environmental impacts would be assessed and mitigated through detailed Environmental Impact Assessments at the project delivery stage.
In response to the Countryside Council for Wales’ query on the inclusion of carbon emissions and the impact on raw resources in construction and operation of the options, both these elements are fully taken account of and included in the environmental and social costing of the options as summarised in Chapter 9 of the Revised Draft Plan and supporting technical documents (specifically Appendix D). Regarding the inclusion of other water companies’ options to abstract water from Wales within our Plan, whilst we understand
Page | 27 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation CCW’s concern on such issues, we can only include confirmed options within the Plan that impact upon Welsh Water. The WRMP is Welsh Water’s plan detailing how we will ensure security of supply to all of our customers over the defined 25 year planning period. The purpose of the Plan is not to define how Welsh Water may be influenced by other potential users of water. However, elements of the forthcoming updated Environment Agency water resources planning guideline may recommend that such issues are reflected in future WRMP’s. We will be reviewing this issue in our 2013 Draft Plan.
In response to the EAW comments;
Our options appraisal approach follows national best practice and is consistent with the requirements of the Environment Agency Water Resources Planning Guideline. The selection of options to meet supply and demand deficits is done on a least cost basis in parallel with an environmental assessment of the options (the SEA and HRA). We note the EAW’s concerns regarding adaptability and flexibility of option selection and we will be reviewing all of our option base, and the optioneering process, for the 2013 Draft Plan.
We also note the EAW concerns regarding the exclusion of ‘benefits’ from the advanced leakage reduction options in the Revised Draft Plan. We await and welcome clear guidance from the Environment Agency, via the revised Benefits Assessment Guidance, on this issue. We will embrace this approach for the 2013 Draft Plan.
We agree with the EAW that the end point of any sensitivity analysis is to provide certainty on the selected outcomes. We note their concerns on expanding our current sensitivity analysis for the 2013 Draft Plan. It is envisaged that the sensitivity analysis for the 2013 Draft Plan will be considerable and will also embrace many of the principles outlined in the current UKWIR project ‘Water Resources Planning Tools’ (WR27).
We will liaise with the EAW regarding what information it would like to see within the main report (or annexes) of the 2012 Final Plan to provide evidence on the derivation of the environmental and social costs and benefits for all option types for the deficit zones.
Regarding options to reduce outage in deficit zones; the zonal outage for the SEWCUS water resource zone is different for the Review of Consents (RoC) scenario compared to the baseline scenario due to the different ways in which the system is modelled and optimised (and hence the utilisation of water treatment works) to accommodate the RoC licence amendments. Through our comprehensive and continual outage data collection process we are monitoring outages at all our water treatment works across Wales. As part of this work we continually strive to understand and reduce outage at all of our water treatment works.
In response to the Wye & Usk Foundation’s suggestions, the Revised Draft Plan shows the required intervention options that would be needed as a result of the Review of Consents (RoC) licence amendments. The Plan simply states the outcome of the RoC process and accounts for the likely effect of the proposed changes on the supply demand balance for the affected water resource zones. Should the Wye & Usk Foundation wish to challenge the technical basis of the RoC process, then it will need to discuss these issues with the EAW and not Welsh Water.
Page | 28 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation 4 Next Steps
We genuinely appreciate the time taken by our consultees in responding to our Revised Draft Plan. All the comments and representations received will be taken into consideration in the preparation and publication of our 2012 Final Plan. The next steps we will take as part of the completion of our 2012 Final Plan can be summarised as follows: Publication of this Statement of Response; April 2012; Review of Statement of Response by Welsh Ministers; April 2012; Direction from Welsh Government: date to be determined by Welsh Government; Publication of our 2012 Final Plan: date to be determined by Welsh Government; and Ongoing work on our 2013 Draft Plan.
4.1 Further Information Electronic copies of this Statement of Response are available from our website at: www.dwrcymru.com/ If you require any further information please contact: Tony Harrington Director of Environment Dŵr Cymru Welsh Water Pentwyn Road Nelson, Teharris Mid Glamorgan CF46 6LY [email protected]
Page | 29 Revised Draft Water Resources Management Plan, Statement of Response to the Consultation