While we agree that there is a need to transform the way we look at water resources, we completely disagree with the approach being put forward by Southern Water.
We object to the proposal by Southern Water to prioritise effluent recycling schemes, including the one in Hampshire.
The current funding mechanism is driving completely the wrong behaviour in meeting the challenges we face. Under the proposed scenario water companies will continue to take as much water as they can from rivers and aquifers, which provide the cheapest source of water. If we genuinely want to protect our river catchments then we need a completely new approach to water resource development, but not one that is led by the water company’s drive for profit, selecting infrastructure heavy solutions (effluent recycling) that require huge amounts of energy and carbon (operating 365 days a year even though they are selected as drought resources), have a relatively short life expectancy, leave no legacy, and which work against climate change. Southern Water’s selected solution does not provide best value for customers or the environment.
Instead, we need to step back and look at the problem in a different way. A large part of the demand deficit in Hampshire is driven by sustainability reductions required to protect the environment, especially our chalk streams.
We need to rethink where, when and how we take water from the environment. We believe that there is a different and more sustainable way that we can protect the environment while still meeting our water supply needs, which is likely to be cheaper for customers (to build and operate) and have less adverse impact on the environment.
Solutions that should be developed in advance of effluent recycling
These include:
- Making it a priority to move abstractions from the upper catchment of rivers to the tidal limit to provide an immediate and certain environmental improvement to the whole of the freshwater catchment, which is not then reliant on the Company making the right operational choices for the environment, protecting the river flow and ecology all year round and in a drought. This can be done in line with the United Kingdom Technical Advisory Group Report on Environmental Standards and Conditions (2008), which would allow up to 50% of the 95 percentile flow to be taken from the tidal limit. It cannot be sensible to allow large volumes of river water to flow out to sea in a drought, but instead construct large energy/ carbon hungry desalination or effluent recycling plants as a solution. Moving abstractions downstream as proposed would allow a substantial quantity of river water to be captured before it flows out to sea, in all likelihood without any significant adverse impact on the downstream tidal estuary (minimum flow levels can be set to ensure this), removing, or substantially reducing the pressure for abstraction reductions. This simple change to where we take water from the environment would be a ‘game changer’ for water resource planning and would cost very little for customers as it requires minimal new infrastructure. It would drastically reduce, or remove the need for drought permits.
- Where there is no abstraction on rivers consider whether it is practical/ appropriate to install new abstractions at the tidal limit to help meet demand, especially in a drought. Most of our population centres are on the south coast, taking the water from closer to where the water is needed reduces transfer & pumping costs. Large volumes of freshwater are flowing out to sea, even in a drought, we need to understand if we can take some of that water without there being a significant adverse environmental impact. Why are the water companies and regulators not funding investigation of these type of solutions now?
- Prioritise the investigation and delivery of new reservoir schemes and aquifer storage solutions which store surplus water in winter, a solution that works with climate change forecasts for wetter winters. This also has the added benefit to society of reducing flood risk. Proposing to build one new reservoir in West Sussex by 2045/46 and one aquifer storage scheme on the Test by 2035/36 does not respond to the urgent need for more storage to protect the environment in a drought.
- Prioritise the investigation and movement of existing abstraction boreholes to suitable locations down catchment where they will have less environmental impact so that there is then less pressure for abstraction reduction. In the meantime, bring forward more quickly borehole improvement schemes at existing sites, including Romsey and King’s Somborne.
- Developing a more flexible approach to abstraction licensing that allows more water to be taken in winter to encourage storage solutions, in association with time limits on the licence to enable volumes abstracted to be regularly reviewed and amended based on evidence of harm.
The industry will not take action unless pushed to do so by the Regulators as there is much less profit in a more sustainable approach. We believe that if the industry is properly incentivised, they can identify and develop more sustainable solutions which would also be cheaper to implement and operate for customers. For example, you could build three new reservoirs the size of Havant Thicket for the same price as the Hampshire effluent recycling scheme.
To deliver the wholesale change in approach for the benefit of customers and the environment
We need:
- Ofwat to urgently change the funding mechanism to drive sustainable solutions such as moving exiting abstraction infrastructure and promoting winter storage solutions.
- The environmental regulators to support and encourage a more sustainable approach to public water supply abstraction by changing the licensing regime to help facilitate and drive these changes as quickly as possible.
Most of the studies that will determine the need for abstraction reform have not even been completed, meaning the extent of license reform is very uncertain. As are the worst case forecasts used by Southern Water for population growth and climate change. As a result, there is no strong evidence base to drive the need for such costly, unsustainable and environmentally unfriendly effluent recycling solutions in the short term. We need to step back and take a different approach to urgently fund the investigation and movement of existing abstraction locations to protect the environment, while also funding the urgent investigation and development of more sustainable storage solutions that work with climate change forecasts, not against them. In five years Ofwat would then be in a much better position to determine if effluent recycling is actually needed, and it could still be delivered by 2040 when changes to national guidance require companies to be more resilient to a 1 in 500 year drought.
We already know that research across the water industry has shown that customers support more natural solutions such as catchment management, reservoirs and aquifer storage solutions, rather than effluent recycling and desalination. Companies and regulators should be listening and taking action to respond to this feedback. Other areas of the country are building new reservoirs in the plan period, and Southern Water should be identifying new sites in Hampshire for winter storage.
We do need a huge investment package to change the way we take water from the environment, but not the package of measures put forward by Southern Water based on construction of effluent recycling plants. A solution that due to the lack of trust in Southern Water risks driving people away from drinking tap water and creating a plastic bottle mountain.
Southern Water have a very poor track record on forward planning. They rejected including the sustainably spring fed Havant Thicket Reservoir in their plan for more than ten years, claiming that it could not be delivered. They have already wasted five years pursuing desalination at Fawley which is now rejected on environmental grounds, when it should have been clear from the off-set that this was not an environmentally acceptable solution. Multiple stakeholders certainly pointed this out to Southern Water before they selected the desalination scheme at Fawley. Now they are proposing effluent recycling which utilises a similar reverse osmosis technology to desalination, so it still uses huge amounts of energy; carbon and chemical. As for desalination, it still produces an enriched brine waste stream that must be pumped out to sea. Their main argument for selecting effluent recycling is that given the time they have wasted on the non-viable desalination scheme, no other solution can now be delivered in time to meet the need!
[Last updated, 20-10-2024]
Havant Matters 