1) Why do we need effluent recycling?
If we only currently need 15Ml/day additional drinking water to meet the requirements of a once in 200 year drought, that could be met in other ways, why do we need to plan for a once in 500 year drought (allowing for a capacity of 90Ml/day) all in one scheme now, when more environmentally friendly solutions could be found and delivered in a more phased approach?
(The once in 500 year planning scenario is only coming forward in emerging policy guidance, it is not yet a legal requirement for planning at this point, so there is time to look for better more phased environmentally friendly solutions. There is a danger we end up with a white elephant like the Thames Desalination plant, which also uses Reverse Osmosis, which is too expensive to run to produce drinking water, but they have to run it every day to keep the membranes sweet using energy, carbon and chemicals when Thames Water really just want to shut it down.)
- Why are we not educating consumers to expect to have restrictions on what water they can expect to have available to use in a once in 500 year very extreme drought?
(Ask yourself, do you want your water bill increased now to pay for something that may not be needed in your lifetime, your children’s or grandchildren’s lifetime? Would you support paying for such an expensive and environmentally unfriendly solution now, or just prefer to accept the risk that for ‘X’ weeks at some point you may have to restrict your water use at home and/or work?)
2) Why are Southern Water not proposing to recycle 15ml/d of effluent from Peel Common Sewage Treatment Works which has many benefits over the Budds Farm scheme?
- Shorter pipelines, less construction cost, less carbon and energy costs during construction and operation.
- Southern Water acknowledge that there is more environmental benefit delivered by a scheme at Peel Common discharging via the long sea outfall there, rather than via the Budds Farm/Eastney long sea outfall.
- You can avoid the need for an environmental buffer lake altogether because the Peel Common STW does not have the salt problem that Budds Farm has and as a result the recycled effluent can be discharged to a river. For example, this means that it can be discharged to the lower River Itchen close to the tidal limit, allowing the Gaters Mill Water Treatment works to abstract an equivalent extra volume of water at times of drought, with no adverse impact on river flow. People would then still drink the water they are used to getting and no one has to drink the recycled water until the technology has been proven. It is the Itchen abstraction reductions which have caused the supply problems for Southern Water and this solution returns water to the River Itchen which is cleaner than that already discharged from Chickenhall STW. A win-win situation for the river. Plus Gaters Mill is close to where Southern Water need the drinking water, a pipe connection has already been made to Southampton under the motorway.
(Southern Water did have this scheme in their draft plan, but seem to have rejected it because it could not deliver 60Ml/day, but it does not need to, there just needs to be the capacity to expand to meet that need, as for the Budds Farm scheme, and there is. Instead, they plan to pump Peel Common Effluent east to Havant, treat it, then pump it back west again if option B5 is selected. That is madness!)
- Pipeline route options look potentially easier as less urban and there is no need to impact South Downs National Park.
- If the water recycling technology becomes more widely accepted for drinking water and demand does increase to require 90Ml/day, then effluent from Budds Farm STW can later be piped over from Havant to wherever the recycling plant has been located. There is more suitable land available close to Peel Common STW and north of Fareham to accommodate the footprint needed for future expansion. Avoiding the additional risks of building the Water Recycling Plant on the dilute and disperse landfill at Broadmarsh. adjacent to Langstone Harbour. By the time this additional capacity is needed there may be more environmentally friendly treatment technologies and trenchless tunnelling techniques available to reduce the environmental impacts.
(Southern Water’s Scheme Development Summary Page 38 says the best value plan gives overall benefit to the customers and wider environment, so why are Southern Water not prioritising the Peel Common option first, ahead of Budds Farm?)
3) Why are Southern Water not progressing smaller scheme solutions they have already identified, but which have been dismissed because they cannot deliver 60Ml/day, or can not be delivered by 2027?
(Noting that even their proposed Budds Farm water recycling scheme cannot be delivered until 2030, even if everything goes smoothly according to their plan. If smaller schemes including water transfers are brought forward they may never need the Budds Farm scheme upgrade to 60 or 75Ml/day they are currently allowing for in the site selection process.)
4) If Southern Water insist that effluent recycling is the only viable solution, then why not look seriously at aquifer recharge (in to confined aquifers) as this is a more established methodology used in other drought-stricken countries, instead of discharging in to the Havant Thicket Reservoir, with the uncertain risk that poses to the reservoir environment and the downstream harbour?
(You don’t need one big confined aquifer that can take all of the recycled water, you could discharge it into different aquifers across the region to be available at times of need. Or as indicated in Q2 above discharge the recycled water in to the Lower Itchen.)
5) Why haven’t Southern Water modelled the impacts on the Havant Thicket Reservoir (including the wetland) and downstream harbour environments before pushing forward with this as their preferred solution? What treatment upgrades will be needed?
(Even now the modelling has not been done, yet Southern Water have had a further twelve months since December 2021 when they published their Gate 2 reports to undertake modelling and assessments to establish the impact it will have, and get it peer reviewed, but they did not do this. Southern Water are making assumptions that there will be no significant impact on the reservoir or the harbour, but they have nothing to back this up, this could be a showstopper, then where will they be if they have all their eggs in one basket?)
6) Why don’t the consultation documents make it clear that Southern Water’s ‘recycled water’ will go to Portsmouth Water customers to drink?
(For example, the Summer 2022 consultation overview drawing shows the water going to Southern Water customers via the Otterbourne Water Treatment Works (WTW). The drawing on Page 15 of the summer 2022 consultation brochure has deliberately excluded the fact that the reservoir water will also go to the Farlington WTW and be supplied to Portsmouth Water customers across the area. In fact given the cost of pumping it is likely that Portsmouth Water customers will get more of the water, freeing up water in the west of their district to be sent to Southern Water customers instead. Is this deliberately left out so that most Portsmouth Water customers think the scheme will not affect them? )
7) Why are Southern Water not making it clear that the water will taste different when it comes out of the tap, and asking if consumers are prepared to accept it to drink?
(If consumers notice a taste difference, think about the fact that it has been recycled from Budds Farm Sewage Works and then reject the water, that makes the water unwholesome. It also has public health and economic consequences, especially for the more vulnerable in our society.)
8) Where else could Southern Water put in bankside storage or reservoir schemes to collect excess winter rainfall and reduce flood risk, giving a win-win situation?
(Constructing lots of smaller schemes around the region would avoid long pipelines, reduce pumping costs, as well as reducing operational energy and carbon costs in the long-term, more in line with the water industry and government targets. Best value is not just about absolute financial cost, it is about looking at multiple benefits and reducing environmental impacts. Sadly, the way the industry has been funded since privatisation encourages the company to look for largescale engineering infrastructure solutions that puts assets on the balance book to be maintained and funded through customer bills in the long-term, so it guarantees an income.)
9) Why has it not been made clear in the Summer 2022 consultation that the open cut route for pipeline option ‘O’ remains a viable option which people need to comment on?
(The tunnel route shown as preferred is much more expensive and is only likely to be selected if there is a big local response objecting to the cheaper open cut route with reasons given. I know Portsmouth Water rejected the route as non-viable for open cut because it is a main through route that would cause major disruption when closed, has two schools on it (including the large secondary), a community medical centre, and other local shops and facilities like the petrol station. Can you imagine the disruption to the local community if that route was selected and open cut. I checked with Southern Water (asked two different people at the Wickham drop in event) and because it does not have an asterix on the open cut part of the route that option is still very much in the running. They accepted that the key colouring on map sheet 1 & 2 is confusing as route ‘O’ is the same colour for ‘preferred’ and ‘not being progressed’ options. Let us hope the local community get mobilised to give a strong response to the consultation against the open cut route.)
10) If Southern Water are to build a tunnel from Bedhampton to the reservoir why are they not planning to put the Portsmouth Water pipeline in it as well, to minimise disruption to the community and the environmental impacts of both schemes?
(Southern Water will say that because Portsmouth Water need to start building their pipeline sooner to fill the reservoir this is not an option. However, Portsmouth Water’s timescale for the reservoir is being completely driven by Southern Water’s programme requirement, which in turn is driven by their Section 20 legal agreement with the Environment Agency for the River Itchen. Therefore, the timescale could be adjusted to enable a sensible coordinated programme to be developed in order to minimise the impact of the combined scheme.)
11) Why has the scoring system/outputs not been made available to the public for the site selection process for pipelines and other infrastructure? How can people be expected to comment on whether they agree with the decision making process when this information is not provided?
(The scoring certainly needs to be challenged. For example, they say the process takes into account ecology, ground conditions and contamination, then select the site for Water Recycling Plant as a gassing, dilute and disperse landfill, next to Langstone Harbour. They have indicated that the effluent recycling scheme to the reservoir provides benefits, but the benefits the reservoir will provide are delivered without the recycling scheme, so they cannot claim the benefit for that. The information in the consultation documents is too high level to allow any scrutiny and the detail in the Gate 2 documents was redacted. There is also reference to an ‘importance weighting’ but that is not explained.)
12) If the selection process for the Water Recycling Plant took into account ecology, ground conditions and ground contamination, then why has the dilute and disperse, gassing landfill site at Broadmarsh been selected? How can this site be developed safely without increasing the risk of gas and leachate migration to the harbour and along new pipeline/tunnel pathways proposed to be constructed into the landfill?
13) Why has the search radius for the Water Recycling Plant at Havant not been extended beyond 1500m to find a more suitable site?
(This is an arbitrary number and there is no reason that the search distance could not be increased to find a safer site to develop the WRP. Some of the statements made in relation to the site selection process and reasons for sites being dismissed are suspect for the associated High Lift Pumping Station evaluation in the Broadmarsh area.)
14) Why are Southern Water not looking more seriously at options involving Peel Common STW, especially as Ofwat did confirm funding for Option B5?
(Page 43 of the Summer 2022 Scheme Development Summary refers to B5 is not being further developed in its entirety at this stage. Yet it should be to ensure Southern Water have a viable alternative. They should be exploring discharging recycled effluent to the Lower Itchen and use of Gaters Mill WTW, as well as establishing potential locations for an alternative environmental buffer lake. This would then enable a proper and more robust assessment to be made of the costs and impacts of the different options to support a decision on what should be taken forward.)
15) If effluent recycling (B4) is such a great option then why was it not selected by Southern Water back in the 2019 appraisal process?
(Nothing has changed, except that Havant Thicket Reservoir now has planning permission, which was already being applied for. What is the ‘material change in circumstances’ which justifies its inclusion now?)
16) If the D2 pipeline from the reservoir to Otterbourne goes ahead (even without the Water Recycling scheme) where can I find information on the environment and biodiversity impacts of more regular reservoir drawdown and filling events?
17) What additional controls and monitoring will Southern Water put in place for industrial premises that discharge into the sewers that flow into the Budds Farm Sewage Treatment Works? Will you trust Southern Water to ensure that there are adequate controls in place?
(In other countries additional catchment controls are put in place to stop hazardous chemicals from industrial/ commercial premises being discharged into the sewers and to monitor the sewers, as the WRP new treatment process is reliant upon surrogate parameters to identify problems. Laboratory testing will take longer by which time any contaminated recycled effluent will have been discharged into the reservoir.)