June 2026 – Southern Water have now submitted the Planning Application to the Planning Inspectorate and this page has been refreshed with additional detail.
| FIVE top concerns | This page, the one you’re reading. |
| FIFTEEN detailed concerns | This page draws out 15 bite-sized concerns, cross referencing them with further detail provided by the FAQs (see below). |
| FORTY wider concerns | This page takes a deeper look at a wider list of concerns raised by the content of the WRMP |
| Environmental Concerns | |
| Frequently Asked Questions | This page does just what it says on the tin, with an index of FAQs at the top. |
Major concern 1 – Southern Water’s plan is taking us down the wrong path
In planning a more than £1.2 billion scheme to recycle treated waste water into Havant Thicket Reservoir, along with 3 other recycling schemes, Southern Water are taking us down the wrong path. We need a plan that focuses on developing more sustainable solutions first, that work with climate change to collect the forecast increase in winter rainfall and store it in new reservoirs and confined aquifers for use in dry summers. We get plenty of free rain yet we collect less than 2% of rainfall in the UK. Collecting and storing more water in winter would also provide multiple benefits to society, helping to reduce the forecast increase in flooding, provide recreational sites for our communities, and provide biodiversity opportunities if we build more reservoirs.
Major concern 2 – Southern Water need to be far more ambitious on leakage reduction
Southern Water need to have a much more ambitious programme of action to reduce leakage. Of the water that Southern Water take from the environment, 3% is lost before it even reaches the distribution network and a further 19% of water that customers have paid to treat is currently lost to leakage in the distribution network, amounting in 2024 to more than 100 million litres of precious water lost every day. Southern Water must be required to deliver a much faster programme of renewing water mains to replace their ageing pipe network, or they will never get leakage under control. Having a mains replacement rate as they have in the recent past, of just 1 in 1000 years (0.1% per annum), when a water main is only designed to last 70 to 120 years is just unacceptable.
Major concern 3 – As Southern Water cannot be trusted to operate & maintain its current traditional infrastructure without causing pollution, what hope is there of it safely operating the complex advanced effluent recycling treatment technology without incident?
How can we trust Southern Water with the complex technology required to treat final sewage effluent, which has not been used for this purpose before in the UK?
Southern Water have a very poor track record of treatment plant and pumping station failures, many prosecutions for pollution incidents and failure to take prompt action to rectify problems. The risk of pollution to the Havant Thicket Reservoir as well as damage to Langstone Harbour and the Solent is unacceptable. Once pollution gets into the reservoir there would be no way of getting it out.
Not all of the contaminants in the final effluent from Budds Farm WWTW are removed by the planned new treatment process. Small quantities of pollutants such as pharmaceuticals, pesticides and PFAS forever chemicals will be discharged into the reservoir daily. The Environment Agency have confirmed that there is a gap in the existing regulatory regime which means they will not be able to set limits for all contaminants of concern. Contaminants such as PFAS do not degrade in the environment and can bioaccumulate within the reservoir.
Click here for more information on the lack of regulatory control
Major concern 4 – Southern Water need to do more to protect the environment, and develop a strategy that helps them honour their commitment to be carbon neutral by 2030.
Our river catchments could be protected much more quickly if they moved river abstractions closer to the tidal limit, and abstraction boreholes down the catchment, reducing the priority for abstraction reform which is driving the need for effluent recycling.
Storage options need to be developed closer to where the water is needed, so that long pipelines that damage our countryside and wildlife are not required.
Options need to be developed that do not have such a high carbon and emissions footprint. We need a strategy that prioritises low energy solutions, the energy alone for the Hampshire scheme will cost more than £3 million/year. With pumping and treatment needed 365 days a year, even though effluent recycling was selected as a drought resource.
In a time of climate emergency how can Southern Water select the schemes with the highest carbon footprint and emissions?
For example:
– The Hampshire and Littlehampton effluent recycling schemes have the highest negative environmental impact score of any of the options considered.
– The effluent recycling schemes to be developed by 2035 each have a higher carbon impact than the transfer of water from Norway by sea tankers.
The Supreme Court judgement in the case of Finch vs Surrey County Council confirmed that alternative options must be considered taking into account the whole life greenhouse gas emissions. A robust alternatives assessment has not been undertaken by Southern Water for the Hampshire or IOW effluent recycling projects.
Major concern 5 – The risks from developing the effluent recycling plant on a landfill are unacceptably high
If despite all of the concerns about whether effluent recycling is needed, the significant environmental impacts, and the enormous costs to build & operate are to be ignored, Southern Water are to go ahead with their leaky plan, they must be told to find an alternative site for the recycling plant at Havant. The risk of constructing large tunnel shafts and hundreds of piles through the 13m deep contaminated landfill waste site into the chalk aquifer below adjacent to Langstone Harbour are just too great.
We also need to press Defra to change the water industry funding mechanism to stop incentivising infrastructure heavy solutions, but instead encourage development of sustainable solutions that work with climate change.
There has been inadequate publicity and consultation about Southern Water’s plan.
– Why has there been no national or regional debate about such a fundamental change to the source of both Southern Water and Portsmouth Water customers drinking water supply?
– Why didn’t the Company write to all Southern Water & Portsmouth Customers across the region that will be impacted by this major change to their water supply to seek their views?
Less than 23% of those who responded to Southern Water’s 2024 public consultation on the HWTWRP supported the scheme. That shows that the company have no mandate from the public to proceed with this option.
Research shows that customers prefer more natural & sustainable solutions such as reservoirs and aquifer storage, but Southern Water have not listened
If you don’t support the Southern Water plan, then tell the Planning Inspector & Secretary of State for Defra to reject the scheme and require Southern Water to develop a more sustainable plan that works with climate change & which puts the environment before profit.
The Hampshire effluent recycling scheme alone will deliver a profit of more than £45 million pounds to Southern Water’s funders, this kind of profiteering paid for by customers is not acceptable. For more information on how 20% of the company’s income already gets paid to funders see this news post.
The huge cost of servicing the massive debt created by the selection of such expensive options will also have to be paid for by customers.
We recognise that the level of detail contained within the many volumes of publicly available information provided by Southern Water is hard to digest without the significant investment in time which many readers are unable to spare.
We hope that the summary lists of concerns we have provided will help you to digest what is being proposed and to consider whether there are better options for a more sustainable way forward.
Water Matters (Last updated 21/11/24)