The Blueprint for Water coalition is calling for water companies’ 2019 Price Review investment plans to deliver a ‘water neutral’ PR19 and for the firms to ensure that no overall increase in the amount of water is abstracted from rivers and groundwater - despite increases in population and climate change.

The group of 18 environment NGOs also want the companies to prepare strategic long-term wastewater plans to support their investment decisions along similar lines of Water Resources Management Plans.

“We look to Government to deliver reform of our archaic abstraction regime and to ensure that companies develop strategic, long-term plans for our wastewater systems, as they do for water resources.”

The proposals form part of a package of measures in a paper published by Blueprint for Water setting out environmental priorities for PR19 investment plans.

Introducing Blueprint for PR19 - Environmental Priorities For Water Companies, the NGOs said:

“As the water companies in England and Wales sit down to draft their future investment plans for 2020-2025 (PR19) they are doing so at a time of unprecedented change and uncertainty. We must make sure that the environment does not become a casualty of confusion and that the plans will deliver for people and nature.”

The Blueprint wants to see the water companies take action on a range of issues, including demand reduction, resilience, Natural Capital Accounting, catchment management, green infrastructure and sustainable drainage solutions.

Water companies must be exemplars on demand management

The NGOs say that water companies must be exemplars on demand management before they look to take more water from the environment. This can be achieved through delivering class leading leakage levels, implementing full metering, installing water efficiency measures in new and existing homes at significantly scaled-up levels, and creating effective behavioural campaigns and incentives.

Supply side water resource options, such as bulk water transfers, water reuse and new reservoirs, should only be developed where it can be demonstrated that all reasonable efforts to reduce demand have been implemented.

Abstraction – water companies need to make faster improvements

The NGOs are calling for all abstractions to be within sustainable limits and controls in place to prevent deterioration – 14% of rivers in England are classified as over abstracted, and a further 9% would be if all water licensed for abstraction was taken.

The paper says that while some good progress is being made (as part of the Restoring Sustainable Abstraction programme in PR14), companies need to make faster improvements, especially for those water bodies already failing to meet WFD standards due to over abstraction.

“ Unfortunately, while companies investigate the impact of their abstractions and develop alternative solutions, the environment bears all the risk. This is at odds with the precautionary principle, and companies should do more to mitigate this risk in the interim.”

PR19 investment plans should set out how water companies will increase resilience

Far more attention should also placed on improving the resilience of the natural environment that companies rely on to operate, alongside investment in pipes, power and processes. Water companies should consider how ecosystem resilience could be enhanced at their vulnerable sites and catchments, setting out what they will do to increase resilience within their investment plans.

The paper says that enhanced and extended catchment initiatives are needed and that with over 300 catchment initiatives currently underway, the sector needs to ensure that it is sharing best practice and valuing the wider benefits of these schemes. The NGOs want to see companies scale up catchment management in PR19, using the approach to deliver solutions for water wastewater and long-term resilience.

Natural Capital Accounting should help shape investment decisions

The Blueprint also wants the Natural Capital approach to be assessed and grown to help shape investment decisions. The companies should commit to assessing the Natural Capital they depend on, with the intent to grow it and to integrate it into decision-making.

“We can see the potential for companies to have developed Natural Capital Accounts by the start of the investment period (2020 – 2025), and would like to see a commitment to grow this capital through the five-year investment window.”  the paper says.

The Blueprints wants water resource options appraisals to materially consider the value of water left in the environment.  The companies should also set out how they will deliver and report on long-term resilience - and the resilience of the ecosystems they rely on to operate - in their investment planning.

“Companies should not be rewarded through the Outcomes Framework for causing pollution incidents”

The NGOs also want the water companies to do for more to restore rivers to good ecological status and address pollution, which it says continues to be the biggest problem facing the freshwater environment.

In addition to pollution pressures from agriculture, around one quarter of rivers are not in good ecological health due to sewage pollution from water companies and private sources, the paper says.

In 2015 only 20% of rivers in England and Wales were at ‘good’ or ‘excellent’ status, with a third of the reasons for not achieving good status due to water company abstractions and discharges and a similar proportion due to poor land management.

The Blueprint wants to see the companies aim for targeting zero pollution incidents, 100% monitoring of sewer overflows and 100% self-reporting, commenting:

“Progress has been made by the sector to reduce the number of serious (category one and two) pollution incidents, but the picture is not so good if category three incidents are included. Companies should not be rewarded through the Outcomes Framework for causing pollution incidents, as they are at the moment.”

Dealing with pollution from sewer overflows should be a top priority

On dealing with emerging pollutants, the paper says monitoring by the water industry, through the Chemicals Investigation Programme, is finding a number of potentially harmful chemicals are present in the water system including pesticides, flameretardants, pharmaceuticals and micro-plastics.

Rather than default to end of pipe solutions, which can be ineffective and expensive, the Blueprint says  better source control around usage and disposal needs to be consider  via promoting less harmful alternatives supplemented by investment into innovative natural treatment solutions, such as wetlands.

Green infrastructure and SuDS should be prioritised and promoted

The Blueprint also wants to see green infrastructure and Sustainable Drainage Solutions (SuDS) prioritised and promoted, with both new and retrofit SuDS encouraged within a company’s own drainage schemes, and those of third parties looking to connect to the sewerage network.

The automatic right to connect should also be removed and instead, SuDS should be used to reduce peak flows in the sewerage system, addressing flood risk, avoiding the need to invest in larger underground pipes.

More action needed to encourage behaviour change

The Blueprint also wants to see the water companies to take more action on encouraging behaviour change to ensure everyone uses water wisely, including the rollout of smart meters allied to incentive schemes to encourage this. Citing companies such as Thames and Southern who are starting to pilot schemes, the paper says in PR19 these should be delivered at scale. For example, community rewards linked to reduced water use during drought periods could be developed and trialled.

Water companies in England and Wales are major players in the environment

The coalition says it has been talking to the water companies, regulators and with the Government over the last year to share its ideas and inform thinking on the environmental priorities for PR19.

“We passionately believe that a healthy natural environment is at the heart of a resilient and successful water industry - an industry that can meet the needs of current and future customers and deal with the challenges we face, such as climate change and population growth.”

“In the context of uncertainty around Brexit, we look to the water sector to develop business plans based upon the principles and obligations enshrined in the Water Framework Directive (WFD) and Nature Directives. We want water companies to work with Blueprint to ensure that the Government maintains overall levels of environmental protection, with any future amendments to have full parliamentary scrutiny and public consultation.”

“The Blueprint for Water coalition and our 6 million plus members believe the 2019 Price Review (PR19) and 2020 Business Plans are crucial to deliver for customers and the environment.”

Blueprint for Water is urging the water companies to adopt the Blueprint for PR19 environmental manifesto, saying it is confident that customers will support the programme, based on effective company research to date.

Click here to download Blueprint for Water PR19