Consultation outcome

Water resource planning guideline: consultation response summary

Updated 18 December 2020

1. Background

The water resource planning guideline sets out our expectations for water companies in producing their statutory water resource management plans (WRMPs) and regional plans. The guideline is jointly produced by the Environment Agency, Natural Resources Wales and Ofwat.

WRMPs set out how water companies will provide a secure, sustainable supply of water to their customers and businesses over at least the next 25 years.

We produce supplementary guidance to the main water resource planning guideline to provide further detail covering specific topics and subjects. These supplementary guidance notes have been out for consultation through the autumn and we will produce final versions in Spring 2021. See Section 4 for more details. They are available on request from:

• [email protected] (for England)
• [email protected] (for Wales)

The last version of the water resource planning guideline was in 2017 for use in WRMP2019. We have significantly revised the guideline for use in WRMP2024. The most significant changes are that water companies:

• should take account of regional plans in England (and Wales as applicable)
• (in England) are expected to be resilient to any drought of a return period of once in 500 years
• should plan to provide a long-term destination for the environment by reducing abstraction where it is causing the most environmental damage
• should use natural capital in decision-making and provide environmental net gain through their WRMPs

We consulted on the revised water resource planning guideline from July 2020, for 10 weeks. This document provides a summary of the responses we received and explains how we will change the guideline as a result of those comments. Natural Resources Wales considered any responses specific to Wales and these are incorporated into this response.

We expect to publish the final guideline in January 2021.

2. How we ran the consultation

The draft water resource planning guideline was available for public consultation on GOV.UK for 10 weeks from 27 July to 2 October 2020. The consultation was accompanied by a consultation response form which is included in Appendix B.

We promoted the consultation through:

• emails to water companies, interested third parties, academics and non-governmental organisations that had expressed interest in this subject
• emails to previous respondents to the most recent guideline consultation We received responses through the provided consultation form, but also in the form of technical annexes, emails and reports.

We received 27 responses in total. The responses were from the following:

• 14 from water companies, retailers and regional water groups
• 6 from public or nationally representative organisations
• 3 from environmental and interest groups and charities
• 1 from an individual
• 1 from a parish council

Many respondents provided detailed technical comments. We received approximately 300 individual comments.

In addition to the consultation questions we asked, we had a number of comments on the following technical topics:

• population
• coronavirus (COVID-19)
• biodiversity net gain
• carbon
• regional planning
• chalk streams
• comments relating to retailers
• sustainability reductions and the long-term destination
• demand management and leakage ambition
• private water supplies
• timescales

3. Summary of main findings and actions we will take

We have reviewed the comments we received from the consultation. As a result we propose to make changes to the draft water resource planning guideline and relevant supplementary guidance.

This summarises the responses we received to our consultation questions and the action we will take as a result of these responses. The second section summarises the comments we received and the action we will take on other topics raised. We have covered questions 6 onwards as question 1 to 5 were information gathering questions (such as ‘please tell us if you are responding as an individual or on behalf of an organisation or group’). You can view these in Appendix B.

Consultation question summary

Q6. Do you have any concerns, suggested improvements or comments regarding the guideline that you would like to highlight?

(Note - there are specific questions below on resilience, natural capital, the climate emergency and the environment).

Most respondents answered ‘yes’ to this question, although many used this to highlight concerns they later highlighted in subsequent questions. We have addressed these concerns in section 3 and therefore we have not outlined changes detailed for this question. However we have included an overview of the comments for completeness.

Respondents covered a range of topics; these included:

• alignment of different plans as a concern (particularly the alignment of WRMP, price review 24 and river basin management plans), with some of these plans not being available in time for draft WRMP
• welcoming the opportunity to comment and praised the increased involvement and collaboration for the last round of planning
• barriers to full participation by third parties
• customer engagement and what meaningful engagement should look like
• that the guideline encouraged water companies to be too cautious with their planning
• proportionality of analysis suggested as too onerous for smaller water only companies
• that the suggested approach was not suitable for a specific geography and instead proposed a holistic integrated approach to combine waste and clean services
• the length of the guideline was highlighted and streamlining was suggested
• highlighted other sectors and the ability of regional plans to reflect other sectors
• it would be helpful to provide an additional guiding note on how to deal with specific growth corridors which impact multiple plans

Q7. Do you believe that the guideline allows water companies to produce plans with secure and resilient water supplies?

Most respondents felt that the guideline allows water companies to produce plans to help deliver secure and resilient water supplies. There was general support for the requirement to be resilient to ‘1 in 500’ drought for England.

Several respondents answered ‘no’ or ‘did not know’. The reasons given for this included:

• not giving enough weight to protecting valuable chalk stream habitats
• feeling that the non-household customer base was not adequately represented

We have responded to these concerns in the relevant technical sections within this overall section.

Several water company respondents were unclear as to how to avoid final planning deficits before they reached the ‘1 in 500’ drought level of resilience for England. The guideline states that water companies should consider either drought options and, or (or both) selecting a reduced level of service as an option in the interim.

Some respondents felt that further clarity was required within the guideline as to whether there would be minimum levels of service for Wales. The guideline will:

• provide clarity on levels of service for water companies wholly or mainly in Wales
• clarify the position in respect to new transfers (trading options) from Wales to England

Q8. (England only) The 25 Year Environment plan states that it is the Government’s ambition to leave our environment in a better state than we found it. Do you think the guideline sufficiently contributes to this aim?

We have also included comments relating to sustainability reductions in this section. Most respondents felt that the guideline sufficiently contributed to the aim. There was support for the integration of natural capital and biodiversity net gain into decision making processes.

Several respondents expressed views that the expectation on companies was too onerous and beyond the remit of water companies.

A couple of respondents did not feel that the guideline contributed to the aim, for example because it did not place enough emphasis on nationally important chalk streams habitats.

One respondent stated that the guideline should ask companies to provide the location, proposed amount, timing and the reasons for each sustainability reduction. They also requested that companies should assess whether a sustainability reduction could cause a benefit for any downstream water company abstractions.

Another respondent was concerned that some schemes might be more environmentally damaging than the environmental problem they were trying to address.

As a result of the comments we received, we will make the following changes to the guideline:

• update the terminology used around the ‘long-term destination’ to be consistent with the guidance provided to regional groups
• clarify that plans should provide positive environmental benefit, that is the solutions should have less impact on the environment than any problems that are being solved
• request companies to provide information on location, proposed amount, timing and the reasons for each sustainability reduction
• request companies to assess whether there will be any downstream benefits to water company abstractors as a result of a sustainability reduction
• revise the text around biodiversity net gain (see separate section for further details)

Q9. The guideline incorporates a natural capital approach into decision-making. Do you agree with the approach set out in the guideline and supplementary guidance which combines the natural capital approach, biodiversity net gain and the Strategic Environmental Assessment into decision-making?

An error on the consultation form meant there was no text box available for free text responses. However, many consultees presented their views elsewhere in the document.

Overall there was support for combining the 3 approaches into decision making, and the flexibility of the approach was praised. Several consultees cautioned that monetisation should not be the sole approach in considering the environment. Our guidance reflects this position as monetisation is only one part of the methodology proposed.

There was support in principle for this, however it was noted that this is largely an untested approach. We recognise that this round of planning will be the first time we have provided detailed guidance on natural capital, and also the first time many companies will have undertaken a natural capital assessment. We therefore accept that this is a new process and both regulators, water companies and practitioners will learn from it. We will use this learning to inform any future guidance.

There was concern that the approach did not value highly enough the provisioning services of the natural environment to other abstractors. We have addressed this issue in the supplementary guidance. The guidance asks that an assessment is made of the value to other actual and potential future abstractors.

In respect to Wales, respondents welcomed the guidance from Natural Resources Wales specific to Welsh legislation that ensures the principles of ‘Sustainable management of natural resources’ are incorporated into decision making to:

• enhance the resilience of ecosystems
• contribute to the ‘well-being goals’

The respondents also welcomed guidance provided for Water Framework Directive, Strategic Environmental Assessment and Habitat Regulation Assessment in respect to any plans affecting Wales.

Q10. We are facing a climate emergency. Do you think our guideline adequately addresses this challenge?

We have also included comments relating to carbon in this section.

A number of respondents wanted greater clarity on what emissions scenario should be used by water companies. The products available from the Met Office, and the uncertainty around climate change means we believe our guidance to consider a range of emission scenarios is pragmatic.

One respondent asked why our guidance allowed companies to use UKCP09 when UKCP18 was available. Our guidance allows water companies to pick which dataset is most appropriate and asks them to demonstrate why the dataset they have selected is appropriate. We expect the vast majority of companies to use UKCP18. However for some companies networks are much less constrained by impacts of climate change on water availability. It therefore might not be proportionate to update the climate change assessments if they are not facing a particular risk from climate change.

Several comments were positive expressing support for the pragmatism of the guidance and the utilisation of most recent data. Several comments were concerned at the broadness of the guidance. We believe our guidance is risk-based to allow companies to undertake an assessment which is proportionate the risk they face.

One consultee stated that climate change was likely to lead to increased winter rainfall and that this could increase deployable output for some sources of abstraction. We have reviewed this comment, and accept that it is possible and might offset some of the summer losses in overall water resource availability. However we do not believe these changes will be significant in the context of the variability in rainfall, temperature changes and potential impacts upon groundwater recharge at the extreme end of drought, which is what companies will be basing their planning on. We believe our current approach remains appropriate and proportionate.

One respondent highlighted the ‘Updated projections of future water availability for the third UK climate change risk assessment’, and its findings for water companies.

A number of consultees commented on carbon. These comments included how water companies should account for carbon, how to consider decarbonisation and whether carbon off-setting was appropriate mitigation. Several respondents stated that water companies should provide their carbon emissions from future options in tonnes, as well as being monetised.

In the guideline we will:

• ask water companies to report their carbon in tonnes alongside the monetised cost
• include additional guidance around carbon mitigation and the possibility of carbon offsetting
• ask water companies to consider the results of ‘Updated projections of future water availability for the third UK climate change risk assessment’
• ensure that water companies met government expectations for carbon (and accounting for greenhouse emissions) within their plans

Q11. (England only) Our guidance asks companies to plan on the basis that the:

• water available is what they would have in a severe drought (with a probability of 0.2% occurrence each year or known as 1 in 500 drought)
• demand is a hot dry year before temporary use bans are in place, (known as dry year annual average)

This is considered to be a worst case scenario. Do you think this approach is appropriate? Or should water companies plan for a demand for water under the same severe drought scenario as their water supply assumptions?

The comments received from water companies indicated that the majority were satisfied with the current approach. However, a minority considered using a demand that they might expect during a ‘1 in 500 year’ drought more realistic. Water companies listed lack of data, expertise and the significant uncertainty understanding ‘1 in 500’ demand as reasons for remaining with the current approach.

Other respondents were generally more in favour of using the same scenario for both supply and demand as this was seen as a more realistic scenario.

After assessing the responses we have received, we believe our current approach remains appropriate. We feel this is the most resilient approach given the data and understanding we currently have. However this is an area we would like to develop and our approach may change for the next round of planning as we move towards a more system simulation approach.

Q12. – Do you think it is clear what companies wholly or mainly in Wales need to do? (Separate from the English companies)

A number of consultees commented that it was clear what companies wholly or mainly in Wales need to do, particularly where they differ from the English companies. For example, level of service (resilience) and specific Welsh legislation. Some respondents questioned why there needed to be different approaches across England and Wales.

Other respondents were unsure when guidelines for Wales were for an English company or regional group to consider within their plans.

In the guideline we will provide clarity:

• that Welsh Government policy is specific to water companies wholly or mainly Wales (which includes some parts of England)
• that any options within or affecting Wales are subject to Natural Resources Wales guidance, such as for ‘Environment and society decision making (Wales)’
• that wider expectations for environmental destination is linked to the boundary of the relevant regulator
• where the guideline is applicable to both England and Wales

Technical areas

Through the consultation a number of technical queries and questions were asked that were not part of the consultation questions. This section covers the responses from the consultation.

Population (England only)

We received a considerable number of comments concerning differences in population forecasts. Ofwat guidance and recent Competition and Markets Authority decisions have put some weight on using Office for National Statistics (ONS) population projections, whereas the water resource planning guideline asks water companies to use Local Plan data.

In developing this response we consulted the Ministry of Housing, Communities and Local Government who set policy around growth and population. Our position is clear that WRMPs should not constrain growth and should continue to be based on Local Plan projections. ONS population projections provide an indication of the future size and age structure of the population based on mid-year population estimates and a set of assumptions of future fertility, mortality and migration. However, it is worth noting, that these projection have limitations as they are based on recent trends in data that can be influenced by recent economic, political and natural situations. As a result they should not be taken in isolation. We believe it is appropriate to test the impact of alternative population growth scenarios, and to manage any significant differences, particularly where it affects investment decisions.

We will make the following changes to the guideline:

• reference the ONS forecasts
• advise that companies consider testing the impact of alternative population growth scenarios in the WRMP
• advise that water companies could consider an adaptive plan where there is significant difference in projections which might affect investment in the short to medium part of their plans

Best value

Generally, consultees expressed support for the development of best value plans and the emphasis that the guideline placed upon this. Given the importance of best value in water company plans, we will combine the ‘Supplementary guidance – best value’ into the main guideline.

Several respondents queried whether UKWIR’s ‘deriving a best value water resource management plan’ should be referenced in the guideline.

This will be referenced in the guidance as a resource that companies may find helpful in developing their best value planning. However, companies do not have to use it and we expect companies to follow the regulatory guidance on best value planning in full.

One respondent highlighted a possible tension between what a best value plan might be at national, regional and local scales. We acknowledge this potential issue in the supplementary guidance on best value. The guidance states that where possible water companies should reconcile their WRMPs and regional plans to achieve alignment, and that a company should reflect the regional plan unless there is clear justification for not doing so. However there may be legitimate reasons for differences between a best value company WRMP and regional plan. Also it is possible a hybrid programme that provides best value at both a company and regional level could be appropriate. It is also recognised that regional plans are likely to be strategic and therefore some minor deviation at a company level might be justified where this does not affect the regional solution.

We will make the following changes to the guideline:

• reference UKWIR’s ‘Deriving a best value water resource management plan’
• incorporate the best value supplementary guidance text into the guideline

Coronavirus (COVID-19)

A number of water companies noted that coronavirus (COVID-19) was affecting demand for water and asked for further guidance as to how to manage it. Several respondents queried why the guidance was asking water companies to consider coronavirus as part of a critical period scenario when the longer-term impacts were likely to affect the annual average demand profile. Respondents noted that impacts might include changes in geographical demand due to more people working at home and housing growth falling due to the economic impacts of coronavirus.

As a result of the comments we have received, we will make the following changes to the guideline:

• acknowledge the change in demand distribution and the uncertainty of whether this will change future demand patterns
• request that companies include an estimate of any changes in water use behaviour and distribution of demand as a result of the coronavirus in their baseline
• clarify how companies should consider their base year in the context of the coronavirus impacts

Biodiversity net gain

A number of water company consultees queried whether there were conditions under which they might not be expected to achieve biodiversity net gain, such as when the site was in good condition, or customers were not in support.

Biodiversity gain is likely to be a requirement in the forthcoming Environment Bill for schemes requiring planning permission. Companies will therefore have to meet their statutory obligations when the Bill comes into force. We have reflected our understanding of the Bill in the guidance. We expect that if a site is in good condition, a company will need to provide biodiversity net gain off-site.

We will also update the text of the guidance to better reflect the duty of public bodies to enhance biodiversity.

We will make the following changes to the guideline:

• emphasise that it is our expectation that all options which require planning permission and are selected in the preferred plan, will need to provide biodiversity net gain
• describe our expectations around the Environment Bill’s requirement that public bodies ‘should look to contribute to, and enhance, the natural environment by providing opportunities for biodiversity gain and enhancement’

We will also update the supplementary guidance with these points and provide further detail where needed.

Environmental destination (Wales only)

One respondent raised that it was unclear what the environmental destination requirements were for Wales and expectations for the water company to help support this (given it’s within regulator remit to deliver sustainable management of natural resources).

We will provide supplementary guidance to cover this and reference it within the guideline itself.

Regional planning

Some consultees expressed support for the reference to regional planning in the guideline. There were some queries about the extent of divergence allowed between regional plans and water resource management plans. Companies should justify why there is any deviation from their plan compared to the regional plan.

We will make the following changes in the guideline:

• clarify where deviation from a regional plan might be acceptable

Chalk streams

One consultee highlighted the importance of chalk habitats and that the guideline did not adequately underline their rarity and global significance. They stated that chalk streams have been significantly damaged by many decades of over-abstraction. Many local wetlands and distinctive wetland species have been lost as a result of this over-abstraction in chalk streams and their catchments.

We recognise the importance of chalk streams and the desire to ensure sustainable abstraction. The water resource planning guideline does not cover the policies but outlines how companies should assess challenges such as population growth, climate change and improving our environment (that will cover chalk streams). Assessment of chalk stream protection is covered in:

• water resources national framework that sets the challenges to improving the environment to the new 5 regional groups to include in the first regional water resources plans
• the chalk stream action plan that Defra and the Environment Agency will continue to develop - this will inform water companies and regional groups before the next round of water resource management plans
• Environment Agency long-term water resources environmental destination guidance for regional groups and water companies

Overall we expect the regional groups and water companies to include how they can protect valuable habitats, including chalk streams in the short, medium and long term within the next set of water resources plans.

Retailers

We received comments from consultees representing retailers surrounding their expertise in providing information regarding wholesale usage from commercial users. They also expressed their wish to be included in demand forecasting as appropriate. Suggestions were also made surrounding the process of information requests to avoid numerous demands from different companies and to ensure no duplication of effort or information. There was also emphasis upon early consultation and the insights that retailers may be able to provide into their customers early plans and likely future demand profile.

One consultee was pleased that they had been included in the consultation and they praised the reference to the action plan within the guideline. They made corrections to some wording surrounding their actions regarding the joint action plan. They also outlined their plans to fast track the following actions:

• setting up a national ‘Wholesaler: Retailer WRMP24’ working group which will encourage collaboration in the development of multi-sector regional water resource management plans
• working with partners to develop the non-household data requirements to inform the water resource management planning process at a variety of scales

One consultee noted that in Wales, retailers can only supply non-household customers that are eligible under restricted retail authorisation. They noted that the guideline should make it clear that in most cases, the incumbent water company will be responsible for discussing demand management with non-household customers directly. This only applies to Wales.

We will make the following changes in the guideline:

• update the wording in Section 6.5.1 to ensure water companies work collaboratively with the national retailers and wholesalers WRMP24 working group when developing their WRMPs
• emphasise the need to prioritise retailers with the greatest customer demand
• update the wording regarding the action plan submission by the Retailers and Wholesalers Group to emphasise that this is a joint action plan between wholesalers and retailers rather than an individual company action plan
• emphasise the requirement to ensure early engagement with retailers and wholesalers when developing plans
• provide clarity with position relating to retailers in Wales

Third parties

Several respondents queried the level of detail that third parties were expected to provide given they might not have access to the resources or expertise of water companies. It is acknowledged that third parties may not be able to develop options to the same level of technical detail as water companies.

We will make the following changes in the guideline:

• clarify that companies should support third parties in their provision of information and analysis as part of the development of third party options

Multisector (Wales)

One respondent asked for further clarity on the position for accounting for multi-sector demands within their plans, particularly in respect to private water supplies. The concern raised was that private water supplies that are not connected to the water supply network, are not within water companies remit.

The guideline will clarify

• what multi-sector demands should be accounted for within the forecasts
• when to provide a position on company policy with respect to those not directly included in forecasts

Options (Wales)

One respondent queried whether drought supply measures and drought permit or order can be considered as options. The guideline will clarify the position on this for Wales.

Demand management and leakage ambition

A number of respondents asked that government targets for demand management and leakage were included in the guideline. Some respondents asked for clarity regarding how national targets should be interpreted at a company level. We expect Defra and Welsh Government to publish policy in these areas in 2021. These documents should include government policy expectations regarding demand management. The guideline is a technical, rather than a policy document.

Some respondents noted that Water UK’s commitment to 50% reduction in leakage was at an industry wide level, rather than the company level implied in the guideline.

Some respondents queried the new approach to baseline demand management assumptions. The guideline asks that companies assume that leakage remains static from the first year of the plan and that water companies should assume no further water efficiency or metering activity from this point. Some companies also asked for clarification as to what was meant by the ‘start year’. We believe that our approach to baseline demand management allows a nationally consistent approach and provides the clearest base on which to select options in the WRMP.

One respondent noted that the companies with the biggest need for sources have the least ambitious plans for metering and per capita consumption. We support the twin-track approach, and therefore will encourage those proposing significant resource development to also have an ambitious demand management programme. We expect English and Welsh government to set out their policy on demand management in 2021.

One respondent noted that the guideline implied universal metering is an option for all companies and not just those in a water stressed area.

One respondent queried whether water companies should be using UKWIR’s Consistency of reporting performance measures.

We had assumed that all companies would be using this methodology, but will clarify this is in the guideline.

We will make the following changes in the guideline:

• clarify that Water UK’s commitment to 50% leakage is at an industry level
• clarify that the start of the plan is 2025 to 2026 for baseline demand management assumptions
• set out that companies should be using use the UKWIR’s Consistency of reporting performance measures and Ofwat’s Reporting guidance – Leakage
• clarify our wording around our expectations on universal metering

Drainage and wastewater management plans

Several respondents stated that it will be difficult for drainage and wastewater management plans and WRMPs to align as the timetables are staggered. We acknowledge that there are differences in timetables, however think that it is important that the two plans inform each other through the cyclical process of review. Both planning processes also include an annual review to allow changes to be accommodated.

We will make the following change to the guideline as a result of the comments received:

• include the word ‘where feasible’ regarding the alignment of WRMPs and drainage and wastewater management plans

Timescales

One respondent suggested that 50 years was a more appropriate timescale for WRMPs. The guideline reflects the legislation, which is that WRMPs should cover a minimum of 25 years. However the guidance encourages companies to go beyond this where there are challenges and risks in the relevant regional plan. It is likely a number of companies will exceed the minimum planning period of 25 years. However we do not believe this will be necessary for all companies and so we believe our guidance is appropriate and flexible.

Uncertainty

One respondent stated that the guidance allowed water companies to plan for an excess of uncertainty. This meant companies were planning to a standard well beyond ‘1 in 500’ year’ system response resilience (although this does not apply to Wales). They listed a number of ways in which uncertainty is included in water company plans:

• headroom
• outage
• population growth assumptions
• cautious allowances for demand management
• climate change assumptions
• not assessing whether sustainability reductions might lead to benefit for other water company abstractors
• emergency storage in reservoirs
• drought plan assumptions

We have reviewed these and we believe that the guidance we have set out allows legitimate uncertainty to be captured and planned for as the guideline outlines the need to consider the appropriate level of risk for the WRMP planning period. We acknowledge that if uncertainty is too large it may drive unnecessary expenditure. However if it is too small companies may not be able to meet their planned level of service and need to use drought measures more frequently. It is acknowledged that the scale of target headroom allowances should be dependent on the forecasts (and inherent uncertainty) for the components of the supply-demand balance.

We will make the following changes as a result of this comment:

• companies should consider whether sustainability reductions might have benefits to downstream water company abstractors
• consider whether companies should include ‘More before 4’ options in their WRMPs^{[footnote 1]}

We are planning to develop a new approach for the next round of planning for WRMP 2029. This should mean we are able to make improvements in how we capture uncertainty in the planning process.

Usable water

Several respondents queried what was meant by water being ‘usable throughout the zone’ For example water quality in a zone can differ, but still be compliant to Drinking Water Inspectorate standards. We are aware that some companies have had issues with supplying their customers when they have had to make changes to their sources of supply within a water resource zone. We therefore included this new wording to address this risk. We will clarify in the guideline that ‘usable’ is in terms of customers and network.

4. Supplementary guidance

We have consulted on 9 supplementary guidance documents over the autumn of 2020. These guidance notes were jointly produced between the Environment Agency, Natural Resources Wales and Ofwat. These consist of:

• ‘1 in 500’ year drought resilience
• climate change
• adaptive planning
• leakage
• outage
• resource zone integrity
• stochastics
• best value planning
• environment and society in decision making (this includes natural capital)

These supplementary notes were available on request from the Environment Agency.

We consulted on the first 7 of these notes from 2 September 2020 for 6 weeks, ending on 14 October 2020. We consulted on ‘Best value planning and environment’ and ‘Society in decision making’ on 28 September 2020 and the consultation ran for just under 8 weeks, ending on 18 November 2020.

We will review the comments we have received on these documents and update the supplementary guidance accordingly.

We intend to publish the updated supplementary guidance notes by the end of February 2021.

We also intend to publish supplementary guidance for ‘New appointments and variations’. This is to provide proportionate guidance to these companies which are supplied by bulk agreements from an incumbent water company, rather than having their own sources.

5. Next steps

We will publish the updated water resource planning guideline in January 2021.

The supplementary guidance will be available on request. We expect these will be available from the end of February 2021.

Email us at: [email protected] if you wish to:

• follow up on your responses
• ask for more detail on any points made in this document
• request the supplementary guidance

Appendix A - respondents

Affinity Water

Anglian Water

Arup

Bristol Water

Business Stream

Cam Valley Forum

Canal and Rivers Trust

CCW

Committee on Climate Change

Dwr Cymru

East Hendred Parish Council

Energy UK

Everflow Water

GARD

Northumbrian Water

RWG Water Efficiency Group

South East Water

South Staffordshire Water

South West Water

Southern Water

Thames Water

United Utilities

Wardrop Minerals Management

Waterwise

Water Resources South East

Yorkshire Water

Appendix B - consultation questions

Q1. Please tell us if you are responding as an individual or on behalf of an organisation or group.

Please select one answer only from the following options:

• responding as an individual

• responding on behalf of an organisation or group

• other

Q2. Keeping up to date

The Environment Agency would like to keep you informed about this consultation. If you would like to receive email updates about this consultation, please give us your email address below to provide consent.

We will keep your details until the consultation response document has been published or until you withdraw your consent.

You can withdraw your consent to receive these emails at any time by contacting us at [email protected].

We will not share your details with any other third party without your explicit consent unless required to by law.

The Environment Agency is the data controller for the personal data you provide.

For further information on how we deal with your personal data please see our Personal Information Charter on GOV.UK (search ‘Environment Agency personal information charter’) or contact our Data Protection team.

Address: Data Protection team, Environment Agency, Horizon House, Deanery Road, Bristol, BS1 5AH

Email: [email protected]

Please tell us if you would like to (tick all that apply)

• Receive an email acknowledging your response

• Receive an email to let you know that the summary of responses has been published

If you have ticked any of the boxes above, please provide us with your email address:

Email:

Q3. Can we publish your response? We will not publish any personal information or parts of your response that will reveal your identity.

• yes
• no

If you do not want us to publish your response, you need to tell us why.

Q4. Please tell us how you found out about this consultation?

• from the Environment Agency
• from another organisation
• through an organisation/group/club you’re a member of
• press article
• social media such as Facebook, Twitter
• through a meeting you attended
• other (please specify)

Section 2: Your views

We welcome your views on the water resource planning guideline.

Please complete the questions and where there is a free text field, give as much information as possible to support your answer. To help us understand your response, please can you indicate the page, section and paragraph number your comments refer to.

Q6. Do you have any concerns, suggested improvements or comments regarding the guideline that you would like to highlight?

(Note - there are specific questions below on resilience, natural capital, the climate emergency and the environment).

Please tick relevant box:

• yes
• no
• I don’t know

Please explain your concerns, improvements or comments. Please provide evidence for your views where you can.

Q7. Do you believe that the guideline allows water companies to produce plans with secure and resilient water supplies?

Please tick relevant box:

• yes
• no
• I don’t know

Please explain your answer. If you ticked no, how could it address your concerns?

Q8. The 25 Year Environment plan states that it is the Government’s ambition to leave our environment in a better state that we found it. Do you think the guideline sufficiently contributes to this aim?

Please tick relevant box:

• yes
• no
• I don’t know

Please explain your answer. If you ticked no, how could it be improved?

Q9. The guideline incorporates a natural capital approach into decision-making. Do you agree with the approach set out in the guideline and supplementary guidance which combines the natural capital approach, biodiversity net gain and the Strategic Environmental Assessment into decision-making?

Please tick relevant box:

• yes
• no
• I don’t know

Q10. We are facing a climate emergency. Do you think our guideline adequately addresses this challenge?

(Please refer to the guideline and the supplementary guidance for this topic)

Please tick relevant box:

• yes
• no
• I don’t know

Please explain your answer. If you ticked no, how could it be improved?

Q11. (England only) Our guidance asks companies to plan on the basis that the:

• water available is that they would have in a severe drought (with a probability of 0.2% occurrence each year or known as 1 in 500 drought)

• demand is a hot dry year before temporary use bans are in place, (known as dry year annual average)

This is considered to be a worst case scenario. Do you think this approach is appropriate? Or should water companies plan for a demand for water under the same severe drought scenario as their water supply assumptions?

(Please refer to the guideline and the supplementary guidance for this topic)

Please tick relevant box:

• use dry year annual average
• use a ‘1 in 500 drought event’ demand
• I don’t know

Please explain your answer.

Q12. – Do you think it is clear what companies wholly or mainly in Wales need to do? (Separate from the English companies)

Please tick relevant box:

• yes
• no
• I don’t know

Please explain your answer. If you ticked no, how could it be improved?

1. ‘More before 4’ options are those options which companies consider as a last resort before implementing emergency drought orders. The drought plan guideline sets out more information about these options. ↩