Consultation outcome

Review of the water industry national environment programme (WINEP): summary of consultation responses

Updated 11 May 2022

In 2020, the Department for Environment, Food and Rural Affairs (Defra), the Environment Agency and Ofwat came together to lead a review of the water industry national environment programme (WINEP) ahead of the next price review (PR24). The review’s aim was to make sure the next round of WINEP actions give greater environmental benefits for every pound water companies invest by using a more outcomes-based approach.

A dedicated WINEP taskforce undertook the review and co-developed a series of proposed solutions for redesigning the WINEP. The Review of the water industry national environment programme consultation document (Environment Agency, Defra, Ofwat (July 2021)), set out in 3 parts, asked for comments on the proposed solutions.

Part 1 opened the discussion, set out the background and context, and outlined the challenges.

Part 2 explained the proposals for redesigning the WINEP and asked a series of questions about these proposals. A draft Water Industry National Environment Programme methodology (the ‘WINEP methodology’) – a separate document attached to the consultation – described how the proposed WINEP development process would work for the next WINEP cycle. The consultation responses received to the questions in Part 2 have informed the development of the WINEP methodology. The consultation document also set out:

• a longer-term roadmap for developing the WINEP, including actions for the next price review in 2024
• actions to be considered for future price reviews (2029 and beyond)

The roadmap for long-term WINEP improvement has been informed by the consultation responses.

Part 3 set out wider considerations for government, regulators and water companies to achieve the ambitions of this WINEP review. It outlined what needed to be done to take forward the proposals for change. This included increased collaboration, more data sharing and organisational culture change.

How we ran the consultation

A dedicated taskforce reviewed the WINEP. It was made up of representatives from Defra, the Environment Agency, Ofwat, Natural England, the Drinking Water Inspectorate, CCW, water companies, and environmental non-governmental organisations (eNGOs). The taskforce co-developed a series of proposed solutions for redesigning the WINEP.

A wide range of views were considered throughout the review, including those of a specialist advisory group and a wider stakeholder group. The WINEP taskforce also held stakeholder engagement workshops and targeted surveys. Recommendations from stakeholders were used to inform the WINEP options development process before the consultation.

The consultation ran for 12 weeks from 22 July 2021 to 16 September 2021 on Citizen Space.

A press briefing was issued to local and trade media on the day of the consultation launch. The consultation was promoted on our social media channels and through our partners including the eNGO community through Blueprint for Water.

We received 40 responses of which:

• 15 were from water companies
• 8 from environmental charities and organisations
• 7 from members of the public
• 2 from councils

One response was received from each of the following categories:

• trade union
• trade body
• national park authority
• professional institution
• consumer body
• academic institution
• public body

Option	Total	Percent
Responding as an individual	7	17.50%
Responding on behalf of an organisation or group	33	82.50%
Other	0	0.00%
Not answered	0	0.00%

Summary of main findings

Water industry national environment programme methodology (the WINEP methodology)

Proposal 1: To introduce a tiered approach for including schemes in the water industry national environment programme

The WINEP methodology introduces a 3-tiered outcomes approach to improve the line of sight. It adds transparency to the process and provides a better understanding of WINEP outcomes for the environment, customers, and communities.

There is widespread support for the ambition to innovate and develop solutions to give higher-level outcomes, especially the focus on outcomes and goals.

A number of responses promoted:

• the involvement of partners and customers in making decisions on outcomes and goals
• linking the outcomes and goals to other strategic planning frameworks and Ofwat’s Outcome Delivery Incentives

There were differing views on whether outcomes should be water sector specific or across other sectors. Many respondents mentioned the need for a broader environment programme that goes beyond the water industry.

A number of concerns were raised including that:

• 2 tiers would be sufficient and that a 3-tiered approach added unnecessary complexity
• companies may revert to tier 3 outputs either by default or because of potential barriers (time, regulation, funding, or partnership working)
• the focus on outcomes may hamper the delivery of urgent actions
• the approach could be challenging to implement, it will require good evidence and data and careful monitoring
• care is needed to make sure the approach is not process driven and evidence heavy putting unnecessary burden on water companies

Some respondents said that if the Environment Agency is not confident in the ability of a water company to deliver an outcomes-based approach and is therefore not eligible to take an outcomes-based approach, this would limit the potential benefits.

Views varied on:

• how the different tiers should be linked
• if there should be anything other than outcomes
• how it links to future Environmental Performance Assessment reporting

On balance, taking into consideration the points raised, the 3-tiered outcome approach remains an important part of the WINEP methodology.

The 3-tiered outcomes approach clearly describes the water company’s contribution to an outcome and a link to the expectations set out in the Environment Agency and Natural England’s water industry strategic environmental requirements (WISER) guidance.

Proposal 2: To better incorporate long-term planning in the development of the water industry national environment programme

The overall response to extend the planning horizon to 10 years and beyond was generally positive and supported. Many eNGOs believe the longer planning horizon will benefit the environment and allow for more innovation and nature-based solutions.

In extending the planning horizon there was acknowledgement that focus should not be lost on meeting short-term requirements.

Many responses sought clarification on how the approach will be managed and achieved.

Many responses suggested 10 years is not long-term for some drivers and highlight that the Drainage and Wastewater Management Plans (DWMPs) and Water Resources Management Plans (WRMPs) both adopt at least a 25-year view.

In view of these responses and to ensure the programme of environmental action that water companies propose considers the long term, the planning timeframe for the WINEP will be extended to 25 years. The WINEP will include:

• 5 years of ‘clear’ actions that align with the next price review period (financial years 2025 to 2030)
• a set of ‘indicative’ actions for the following 5 years (financial years 2030 to 2035)
• actions working towards the environmental outcomes identified within longer term plans up to 25 years where there is sufficient evidence to support them

This allows options with a longer lead time, such as catchment and nature-based solutions, to be planned into the programme of work more effectively.

Proposal 3: To clearly establish dependencies between the water industry national environment programme and other statutory planning frameworks

The responses reflected the complexity of aligning strategic plans including recognition of the different timescales, geographical scales, objectives and priorities of the various strategic plans.

Overall, the comments reflected the need for strong links between the WINEP, WRMP, DWMP and river basin management plan (RBMP). It was suggested further guidance representing the links between these plans would be a positive addition to the WINEP methodology, and that the plans need to reference each other to ensure appropriate feedback ‘loops’ between the plans.

A number of responses set out a need for a long-term catchment (or other place-based scale) vision. Generally, responses recognised this needed to reflect the government’s 25 Year Environment Plan and Environment Bill (now passed into UK law through the Environment Act 2021) targets. However, there was recognition that the RBMP objectives should be used for monitoring and reporting performance. Having common long-term objectives was suggested as a way of enabling alignment between plans with differing timescales and delivery organisations.

There were suggestions the role of the WINEP needed to be extended to cover air and land based actions, particularly those relating to sludge management.

The WINEP methodology sets out the role of the WINEP in delivering outcomes from other statutory planning frameworks.

Water companies will include actions arising from other planning frameworks in the WINEP, where appropriate, ensuring they align with PR24’s long-term strategies and adaptive planning approach.

Proposal 4: To increase the use of catchment and nature-based solutions

Generally, there was widespread support for encouraging greater uptake of catchment and nature-based solutions. However, some respondents felt the methodology did not go far enough and that they should be the default solution. Others commented that pursuing catchment and nature-based solutions should not mean abandoning permanent solutions at wastewater treatment works.

Barriers to using catchment and nature-based solutions was a common theme with requests to consider further how to remove these. Water company qualifying performance criteria, and the potential need for fall-back solutions, were a barrier for some companies. Incentives and enablers were suggested to encourage greater uptake.

Respondents noted concerns that there is a degree of uncertainty about the effectiveness of catchment and nature-based solutions, timing and other technical issues.

Many responses discussed the catchment and nature-based solutions principles set out in the consultation document. Some felt they were too prescriptive and set up barriers and others suggested more or alternative principles.

Concerns were expressed about the burden of risk on water companies when delivering catchment and nature-based solutions for regulatory drivers in partnership with others.

The WINEP methodology sets out that there should be a clear commitment to pursue catchment and nature-based solutions wherever they can achieve all or part of the required environmental outcome.

Proposed catchment and nature-based solutions should have a plausible mechanism for achieving the requirements and should maximise biodiversity gains and improvements to ecosystem integrity.

Water companies should consider catchment and nature-based solutions as part of their WINEP options development. Advice on developing well-designed catchment and nature-based solutions is provided in the WINEP options development guidance.

Proposal 5: To take account of wider environmental outcomes when deciding on solutions in the water industry national environment programme

The collective ambition of the WINEP methodology is to achieve multiple environmental outcomes. Water companies will need to take action that meets statutory obligations and non-statutory requirements, whilst maximising wider environmental benefits.

The 4 wider environmental outcomes are:

• natural environment outcomes
• net zero outcomes
• catchment resilience outcomes
• access, amenity and engagement outcomes

Water companies are expected to take account of, and where possible quantify, the contribution the WINEP options make to wider environmental outcomes.

There was broad support for the 4 wider environmental outcomes but only limited support for the proposed approach to prioritising them. Overall, all 4 wider environmental outcomes were considered equally valid.

There was a common theme that supporting climate change mitigation and adaptation, including a focus on catchment resilience, should be at the centre of the new approach.

In the WINEP methodology all 4 wider environmental outcomes will be considered equally. However, access, amenity and engagement should not be a significant driver of costs in proposed options nor a significant driver of the benefits when assessing which options to implement.

Proposal 6: To increase water company involvement in the water industry national environment programme development process

There was broad support for the WINEP methodology and its aim to increase water company involvement in the development process.

Responses highlighted the role water companies can play contributing their own ideas, defining the outcomes, engaging with customers and stakeholders and enhancing actions.

However, concerns were raised that it will be a significant challenge to co-develop WINEP solutions for PR24 in the timescales required. It may also be a challenge to align with potential partner organisations, including agreeing co-funding and delivery on a widespread basis.

The WINEP methodology sets out how water companies should work collaboratively to review the evidence and data and characterise pressures on the water environment within the catchments they operate in. They should work with:

• the Environment Agency
• Natural England
• other stakeholders, for example local authorities, risk management authorities, community groups, eNGOs, Catchment Based Approach organisations and other businesses

Working with stakeholders allows problems to be better defined with clearer evidence, to develop optimal solutions and implementation.

Proposal 7: To increase involvement of other organisations and external funding in the water industry national environment programme development process

There was support for a much greater role for co-funding environmental improvements in the WINEP and a general view that this may act as a spur for action. However, views were mixed on whether setting a target for co-funding would help meet this ambition.

Some responses considered an arbitrary target would be unhelpful and would not consider the place-based and catchment specific factors important to successful partnership working. Other stakeholders supported the idea of a target that was stretching but achievable, and supported by the market, though none suggested what a suitable target should be. Others considered that providing incentives through the price review, or support and creation of demand for ecosystem services, would achieve the objective more effectively.

A number of consultation responses raised concerns about introducing a 20% co-funding target for non-statutory actions. Some considered it arbitrary and others that it may inhibit companies from taking actions their customers would support and fund if co-funding could not be identified.

Several consultation responses submitted by water companies identified the need for the regulated approach to co-funding to be flexible, in particular as it may be difficult to secure co-funding with certainty ahead of submission of business plans to Ofwat.

The WINEP methodology sets out that water companies should consider WINEP options that are co-designed, co-delivered and co-funded. They should work towards an aspirational target of at least 20% co-funding of non-statutory actions and seek further co-funding beyond this level at their discretion. The Environment Agency will measure progress against this ambition for PR24.

Consultation responses to proposals 1 to 7

Here is a summary of responses to each consultation question.

Proposal 1: To introduce a tiered approach for including schemes in the water industry national environment programme

Question 1a: Do you think the proposed 3-tiered outcomes (3TO) approach will achieve a greater focus on outcomes?

Question 1b: How else can we support an ambitious move towards a greater focus on outcomes? For example: enabling water companies to propose a tier 1 measure in their business plans.

There were 39 responses to question 1a and question 1b about the introduction of a tiered approach for including schemes in the WINEP.

There was widespread support from water companies and environmental groups for the ambition to innovate and develop solutions to achieve higher-level outcomes. A focus on outcomes and goals, as proposed by tiers 1 and 2, was welcomed. For example, Bristol Water said, “We welcome the proposal to move to a programme that is outcome rather than output focused. We therefore agree with the statements made regarding proposal 1 and overall we agree with the new ‘3-tiered outcomes approach (3TO)’.”

A number of responses promoted the involvement of partners and customers in decisions on outcomes and goals. For example, Wessex Rivers Trust said, “The process must outline where partners provide input. Locally sourced evidence and information from on the ground stakeholders are key to inform the most beneficial Tier 2 goals and Tier 3 outputs for the local environment. The local knowledge and expertise within Catchment Partnerships can help water companies and the EA during this process.”

A number of responses suggested that outcomes and goals need to link to other strategic planning frameworks as well as Ofwat’s Outcome Delivery Incentives. There were differing views on whether outcomes should be sector specific or cross sector.

A number of concerns were raised including:

• that 2 tiers would be sufficient and that a 3 tiered approach added unnecessary complexity
• companies may revert to tier 3 outputs either by default or because of potential barriers (time, regulation, funding or partnership working)
• the focus on outcomes may hamper urgent actions
• the approach could be challenging to implement, will require good evidence and data and careful monitoring
• care is needed to ensure the approach is not process driven and evidence heavy

Some respondents considered that if the Environment Agency is not confident in the ability of a water company to deliver an outcomes-based approach and are therefore not eligible to take an outcomes-based approach, this would limit the potential benefits.

A number of questions were raised in the consultation responses:

• could companies move to tier 1 and 2 later in the price review process?
• can companies propose their own outcomes?

There were differing views on how the different tiers should be linked, whether there should be anything other than outcomes and how this will link to future Environmental Performance Assessment reporting, that is, will outcome or outputs be measured?

Proposal 2: To better incorporate long-term planning in the development of the water industry national environment programme

Question 2a: Do you agree that introducing a 10+ year planning horizon will help to address the issues identified above?

There were 37 responses to question 2a concerning introducing a 10+ year planning horizon. The overall response to the proposal to extend the planning horizon to 10 years and beyond was generally positive and supportive.

Most water companies welcomed the opportunity to extend the planning timeline. South East Water said, “We welcome a longer-term view of the WINEP programme and alignment with DEFRA’s 25-year plan.” Dwr Cymru noted, “This is an extremely positive step forward and in parallel with proposal two offer an extended planning horizon function within the WINEP…”

Many of the eNGOs believe the proposed longer planning horizon will benefit the environment and allow for more innovation and implementation of nature-based solutions. The Chiltern Conservation Board said, “We welcome a longer-term view of the WINEP programme and alignment with DEFRA’s 25-year plan and wider strategic plans.”

Several responses highlighted issues with the existing process to emphasise the need for change including that the current 5-year planning period is too short to address wider environmental issues – it restricts and prevents ambitious, innovative projects.

Question 2b: What are the main considerations in implementing a 10+ year planning horizon?

There were 35 responses to question 2b about the main considerations in implementing a 10+ year planning horizon.

There were no outright objections to extending the planning horizon. However, there were several occurring themes within the responses.

In extending the planning horizon there is recognition that focus should not be lost on delivering short term requirements. For example, Blueprint for Water raised concern over “deferring the ambition needed to meet urgent targets” and the South East Rivers Trust noted, “a long-term (10 year +) planning cycle might allow delays in delivery of urgent environmental outcomes.”

Although supportive of the proposal, many responses sought clarification on how the approach will be managed and delivered. SES Water noted, “a need for detailed processes of how the decisions will be made, over what timescales and identification of who has responsibility for sign-off of each stage.” Several responses asked for more detail on how longer-term planning will fit with the existing 5-year review and funding cycles. For example, Blueprint for Water asked, “How will this longer planning horizon be accommodated into the existing price review timescales?”

Frequently, the responses suggested how the process should work. For example, Northumbrian Water suggested, “an approach in place to jointly agree which investments have priority for the five-year programme.” Blueprint for Water suggested, “Regular, robust and transparent environmental monitoring will be crucial in order to make sure that a longer planning process does not lead to delays in issues being discovered and mitigated.”

Question 2c: What else could be done to better incorporate long-term planning?

There were 35 responses to question 2c asking what could be done to better incorporate long-term planning.

A number of responses suggested the methodology does not go far enough. For example, Jacobs said, “Water industry focused on the long term requires a fundamental redesign of the way the industry is regulated and incentivised.” Anglian Water noted, “Long-term planning will need to be better integrated across water company functions and across sectors and WINEP and Price Review will need to develop better approaches to managing uncertain obligations and therefore uncertain costs.”

A longer planning horizon and better integration with other plans was advocated, for example:

• Jacobs said, “… concerned this lacks a sufficient forward focus (why not 25 years for some drivers in line with WRMPs and DWMPs) and the regulatory mechanisms to ensure a longer-term approach is actually adopted (in the proposal, decisions continue to be made on a 5-year basis)”
• United Utilities commented, “[to] unlock the full benefits of incorporating the WINEP into long term planning we need to see long term planning for integrated water management beyond the just the water industry”
• Anglian Water noted, “Long-term planning for the environment should be done alongside long-term planning for water resources and water recycling and alongside long-term environmental planning in other sectors”
• South East Water said, “It is imperative that we as a company are clear on what our role is in the delivery of the Government’s 25 year plan”
• Jacobs said, “10 years is not long-term for some drivers. Plans such as the 25 Year Environment Plan, DWMPs and WRMPs all adopt at least a 25-year view and this should be adopted where possible”

There were several responses to the proposal about commissioning a separate project to investigate the impact of making legislative changes beyond PR24 to align the 5-year WINEP with the RBMPs and flood risk management plans (FRMPs) planning cycles. And to consider the needs of other stakeholders outside of the water sector as well as the benefits to water companies, and the optimum planning horizons for each environmental plan. Respondents asked when this will happen, what it will cover and noted an imperative need for it to happen.

Proposal 3: To clearly establish dependencies between the water industry national environment programme and other statutory planning frameworks

Question 3: What are your views of aligning the cycles of the strategic planning frameworks?

There were 38 responses to question 3 on aligning the cycles of the strategic planning frameworks.

The responses, which considered the relationships with other strategic plans, reflected the complexity of aligning strategic plans, recognising the different timescales, planning scales, objectives and priorities amongst other things.

Jacobs noted, “The environment is managed through a number of strategic plans and a variety of delivery mechanisms. There must be alignment and line of sight between these plans and funding mechanisms.”

Overall, the responses reflected the need for strong links between the WINEP, WRMP, DWMP and RBMP. For example, Severn Trent Water noted, “From a water company perspective, we have to bring the outputs of WINEP, WRMP, DWMP and FRMP together in our submission to Ofwat to ensure that we have an internally consistent business plan. Better alignment would be very beneficial from this perspective.”

It was suggested that further guidance representing the links between these plans would be a positive addition to the WINEP methodology. Additionally, it was suggested that the plans need to reference each other to ensure there will be appropriate feedback ‘loops’ between the plans.

Particular reference was made in a number of responses about needing to incorporate Local Nature Recovery Strategies into the WINEP and for a clearer relationship with local plans. A member of the public said, “much greater alignment is needed of WINEP with Local land use Planning especially preparation of Local Plans.”

A number of responses set out a need for a long-term catchment (or other place-based scale) vision. Generally, responses recognised this needed to reflect the government’s 25 Year Environment Plan and Environment Bill targets, though there was recognition that the RBMP objectives should be used for monitoring and reporting performance. Having common long-term objectives was suggested as a way of enabling alignment between plans with differing timescales and outcomes.

There were suggestions the role of the WINEP needed to be extended to cover air and land based actions, particularly those relating to sludge management.

Proposal 4: To increase the use of catchment and nature-based solutions

Question 4a: How well does the proposed draft WINEP methodology appropriately encourage consideration of catchment and nature-based solutions?

There were 37 responses to question 4a and 34 responses to question 4b.

There was widespread support for the move towards encouraging greater uptake of catchment and nature-based solutions. Some respondents felt that the methodology did not go far enough in this respect and that they should be the default solution. Others commented that pursuing catchment and nature-based solutions should not mean permanent solutions at wastewater treatment works should be abandoned.

There was significant interest in the barriers to using catchment and nature-based solutions and requests to consider how to remove these barriers. For example, the water company qualifying performance criteria and the need for fall-back solutions were perceived to be barriers for some companies.

There were comments about incentives and enablers that could be used to encourage greater uptake of catchment and nature-based solutions and suggestions about what these might be. Several respondents (Cambridge Institute for Sustainability Leadership and Wessex Water) consider that incentives, possibly financial, need to be provided to encourage investment in nature-based solutions to overcome barriers to taking risks.

As catchment and nature-based solutions is a developing area of work there is uncertainty about the effectiveness of catchment and nature-based solutions, including timing and other technical issues – this concerned some respondents. For example, Severn Trent Water said, “… there will always be some inherent uncertainty around the effectiveness of approaches such as catchment nutrient balancing, we remain concerned that regulatory sign-off of a WINEP obligation could be withheld if such a solution fails to deliver the anticipated nutrient reduction.” There was some confusion about catchment and nature-based solutions rules for statutory and non-statutory solutions.

Many responses discussed the catchment and nature-based solutions principles set out in the consultation document. Some respondents felt they were too prescriptive and set up barriers. Other respondents suggested additional or alternative principles.

There were concerns about the burden of risk on water companies when delivering catchment and nature-based solutions in partnership with others.

Proposal 5: To take account of wider environmental outcomes when deciding on solutions in the water industry national environment programme

There were 38 responses to question 5.

The approach seeking wider environmental outcomes through the WINEP methodology was supported by those responding to the consultation.

For example, South East Rivers Trust said, “setting additional, clearly defined wider outcomes is sensible and will support the delivery of multiple benefits” and CIWEM’s view was “[it] seems to direct companies to prioritise the right kinds of outcomes when deciding on the solutions to take forward…” South East Water noted, “[it will help] align with the wider targets and obligations set out in DEFRA’s 25 Year Environment Plan … ensure a holistic approach to environmental management and resilience is [achieved], with clear trade-offs understood before project implementation.”

The value of catchment planning was noted in several responses. For example, Salmon and Trout Conservation believes “strong catchment-based approaches to river management and conservation will deliver much wider environmental benefits, including for net zero, carbon storage and climate change adaption.” Wessex Water said, “it is critical that water quality does not take ‘primacy’ over other outcomes in assessing options. Water quality, carbon, and biodiversity should be considered holistically to deliver the best value overall solutions at a catchment level.”

Delivering wider environmental outcomes will encourage inclusion in developing options with better outcomes for the environment and society. A number of responses noted existing catchment stakeholders already have knowledge and experience of implementing wider outcomes. Water companies should build on this rather than duplicate efforts.

Overall, the relative priorities of the wider environmental outcomes had limited support. South East Water said, “catchment resilience should be higher in the priority order.” They suggested merging ‘natural environment’ and ‘catchment resilience’ as any catchment resilience option should consider the ecological needs and be designed in a sensitive way to both habitat and species requirements. They also noted, in relation to climate change, “the resilience of our catchments (surface and groundwater) to recover from extreme events is key to ensuring that current and future water quantity and quality is protected and where possible improved. This in turn supporting carbon reduction and biodiversity.”

United Utilities noted “The proposed priority of natural environment and net zero outcomes over catchment resilience may be somewhat short-sighted, because, in some cases, prioritising catchment resilience will also deliver above and beyond for other outcomes.” They suggested that precedence was prioritised based on local risks and issues. Jacobs noted “…all four outcomes are equally valid, and their relative importance will vary from catchment to catchment based on the evidence available. Pre-determining this importance gives the wrong message and risks a time-pressed company ignoring the priority 3 and 4 outcomes.”

The consultation responses raised a number of other areas of concern in relation to achieving wider environmental outcomes, including:

• achieving wider environmental outcomes goes beyond the statutory obligations of water companies
• the success and ability to achieve them will rely on factors over which water companies have limited control
• clarity is needed on how wider environmental outcomes will be considered and embedded in the methodology and wider guidance and frameworks to ensure long-term sustainable solutions

A number of responses said that climate change mitigation and adaptation, including a focus on catchment resilience, should be at the centre of the new approach.

Proposal 6: To increase water company involvement in the water industry national environment programme development process

Question 6a: What further steps need to be put in place to enable water companies to contribute more to the development of the WINEP for PR24?

There were 33 responses to question 6a.

Opinion was divided on the proposal to increase water company involvement in the WINEP development process.

A number of responses were supportive of the proposal. The South Downs National Park Authority, “welcomed the step especially as water companies can contribute ideas of their own to the programme, which may enhance actions.”

CCW supported, “giving companies more ownership of the WINEP, by defining their own outcomes through engagement with their customers and stakeholders on both the required outcomes and the actions needed to achieve them.”

However, Blueprint for Water said, “[the] current proposal does not read very differently from how the process has been run in previous cycles” and United Utilities said, “[the proposal] currently offers limited new opportunities for United Utilities that we didn’t take up at the last price review.”

Several responses raised concerns over the time available to implement the proposal. Salmon & Trout Conservation stated “PR24 is too short a timescale for adopting a radically new catchment approach to river management in which water companies play an important role” whilst Anglian Water said, “it will be a significant challenge to co-develop WINEP solutions for PR24 in the timescales required.” United Utilities agreed: “the time window is too short for companies to align potential partner organisations, co-design, sign up co-funders, and agree delivery routes on a widespread basis.”

Northumbrian Water believe “there will always be a requirement for a strong Environment Agency contribution to WINEP development, and that a partnership or joint approach is preferable.”

The following further steps were suggested to enable water companies to contribute more to the development of the WINEP for PR24:

• distribute effort which focuses mostly on those catchments where there is a significant possibility of delivering better outcomes through the use of catchment systems
• financially supporting local catchment partnerships to access the local expertise and knowledge required to inform the WINEP development
• plans should be put in place as to how water companies should work with Ofwat, the Environment Agency, other catchment stakeholders the 3rd sector and NGOs – this will enable effective catchment and nature-based solutions to be incorporated into catchment plans
• having clear guidance as to which drivers are appropriate for catchment and nature-based solutions
• creation of task and finish groups so that best practice and potential hurdles can be discussed across the industry
• guidance needs to be clear so that Environment Agency or water company staff can successfully identify risks and issues without extensive dialogue
• data sharing through a shared data repository to ensure the same information is used and to avoid data sharing by email

Question 6b: Do you think the ambition to have a WINEP developed by water companies by PR29 is achievable?

There were 36 responses to this question.

Although broadly supportive of the move towards the ambition that the WINEP is developed by water companies for PR29, opinion was divided as to whether it was achievable.

On balance consultees were ‘unsure’. Many stated that an understanding of the success of the deployment of the WINEP methodology changes at PR24 will be an important factor in determining whether the ambition can be achieved.

There were suggestions about ways to achieve these ambitions. They included:

• the need for systemic changes to water companies, the Environment Agency, Natural England and Ofwat
• that water companies would have to do more which would need a significant increase in resources
• that water companies should work in partnership with the communities they serve
• involving regulators and third sector or partnership organisations early to build collaborative proposals
• integrating with Local Nature Recovery Strategies and Environmental Land Management
• changing regulations and permitting policies

Proposal 7: To increase the involvement of other organisations and external funding in the water industry national environment programme development process

Question 7a: Will the proposed approach set out in the draft WINEP methodology, including the proposed timetable, be effective in increasing the involvement of other organisations in the WINEP for PR24?

There were 35 responses to this question.

These responses can be summarised as follows:

• the Environment Agency and Ofwat will need to work together to ensure that companies are appropriately funded to implement their statutory obligations
• companies can be held to account to achieve the environmental improvements the WINEP is intended to give

A number of responses commented that the revised WINEP methodology will require greater resources from regulators and companies to implement. For example, South West Water said, “while we support the principle of the proposal and are willing to step up to deliver the programme, we are mindful that by asking water companies to develop WINEP programmes this proposal is further increasing the planning activity between the EA/NE and water companies.”

Stakeholders recognised the importance of the link between the WINEP and decisions on funding.

Question 7b: Do you agree with setting a target for co-funding non-statutory actions?

Question 7c: If you agree with setting a target, what level should a target be set at? Please explain why you have suggested this target.

There were 34 responses to question 7b and 27 responses to question 7c.

There was support for a much greater role for co-funding environmental improvements in the WINEP and a general view that this may act as a spur for action. However, views were mixed on whether setting a target for co-funding would help deliver this ambition.

Some responses considered an arbitrary target would be unhelpful and would not consider the place-based and catchment specific factors important to successful partnership working. For example, the Cambridge Institute for Sustainability Leadership said, “co-funding opportunities are very place-based and catchment specific to needs on the ground.” They also said, “There are no set mechanisms that facilitate partnership working for water companies. Partnerships are often locally driven, opportunistic and pilot in scale. They require significant effort to build relationships and trust to broker deals to achieve desired outcomes for all parties. Therefore, setting out an arbitrary 20% external funding for non-statutory actions is not the best way forward.”

Other stakeholders supported the idea of a target that was stretching but achievable, and supported by the market, though none suggested what a suitable target should be.

Others considered that providing incentives through the price review, or support and creation of demand for ecosystem services, would achieve the objective more effectively. For example, United Utilities said, “Ultimately increasingly the level of co-funding will require work by Defra and the Environment Agency to drive more buyers of ecosystem services to natural capital markets so they become fully functioning markets.”

A number of consultation responses raised concerns about introducing a 20% co-funding target for non-statutory actions. Some considered it arbitrary; others that it may inhibit companies from taking actions their customers would support and fund if co-funding could not be identified. Hertfordshire and Middlesex Wildlife Trust noted the impact of social factors such as social deprivation on co-funding.

CIWEM considered the target would only be appropriate on statutory actions. Blueprint for Water consider “setting WINEP targets for collaborative working, outcome-based approaches (including more catchment and nature-based solutions) or delivery of wider environmental outcomes, may be a better way to also drive co-funding where these opportunities are available.” They suggested introducing a 20% biodiversity net gain target would be more beneficial than introducing a co-funding target.

Anglian Water said, “the costs of delivering the statutory elements of WINEP are likely to mean that affordability will remain a significant barrier to delivering non-statutory ambitions.”

Several consultation responses submitted by water companies identified the need for the regulated approach to co-funding to be flexible as it may be difficult to secure co-funding ahead of submission of business plans to Ofwat.

Next steps

Responses from this consultation have informed the:

• development of the WINEP methodology
• longer-term roadmap for developing the WINEP

The revised WINEP methodology will be published on GOV.UK.

If you want to follow up your responses or discuss any of the points made in this document, please email us at [email protected].

List of respondents

• Members of public (7 responses)
• South Downs National Park Authority
• Wessex Rivers Trust
• Angling Trust Eastern Region
• South East Water
• Severn Trent Water
• Jacobs
• Chartered Institution of Water and Environmental Management
• Can Valley Forum
• Affinity Water
• South East Rivers Trust
• Yorkshire Water
• Dwr Cymru – Welsh Water
• Salmon and Trout Conservation
• Anglian Water
• Southern Water
• United Utilities
• Hertfordshire and Middlesex Wildlife Trust
• Partnership for South Hampshire
• UNISON
• Portsmouth Water
• Chilterns Conservation Board
• SES Water
• Bristol Water
• Wessex Water
• Thames Water
• Hampshire County Council
• Blueprint for Water
• Colne Catchment Action Network
• Northumbrian Water
• Catchment Leadership Network (CLN) Advisory Group convened by the Cambridge Institute for Sustainability Leadership
• South West Water
• CCW
• Water UK

References

Review of the water industry national environment programme – consultation document (Environment Agency, Defra, Ofwat, July 2021)

Draft water industry national environment programme methodology (Environment Agency, Defra, Ofwat, July 2021)

Acknowledgements

The Environment Agency carried out this consultation on behalf of the WINEP taskforce.