Ofwat has published its response on the River Basin Planning Guidance (Volume 2) consultation documents issued by Defra with regard to implementation of the Water Framework Directive (WFD).

Ofwat has expressed serious concerns that the proposed in-river standards are over-precautionary, have been set with a limited evidence base and no direct assessment of ecological impact. In Ofwat’s view setting the correct standards is crucial as they are the key criteria that will drive the scope and pace of the Programme of Measures.

The regulator has commented that some of the stringent standards that are being proposed are "very challenging to achieve and will need extensive work by all sectors to deliver". As an example, Ofwat cites the proposed UKTAG standard for phosphorus – currently 120 μg/l (0.12mg/l) limit for soluble reactive phosphorus in rivers as  being one of the most onerous phosphorus standards in Europe. Ofwat  views this as  overly stringent which could lead to the implementation of unnecessary remedial actions in some catchments. Ofwat is questioning  whether this is a sustainable option given the reliance on chemical dosing or energy intensive methods of treatment that the standard would entail.

Ofwat also commented that it was important to of fully understand the potential carbon dioxide equivalent emissions resulting from the additional power consumption and sludge production that the potential water industry investments could drive. Modelling work for the water industry preliminary cost effectiveness analysis (pCEA) working group and in preparation for PR09 one of the water and sewerage companies (WaSCs) had explored future carbon emissions in relation to applying all proposed WFD standards -  the results indicated that their carbon emissions would increase by around 50% (best case) due to the energy intensive nature of the technology required for reduction of organic substances.

According to Ofwat, even if the impact were to be restricted to the two key priorities of phosphorus reduction and ammonia reduction, there would still be a significant carbon dioxide impact. The regulator is concerned that potential obligations arising from the WFD could conflict with the need to reduce carbon and the impact upon climate change.

Ofwat said

“Energy intensive, and often costly, solutions should not be adopted without significant thought being paid to the disbenefits of the increased carbon emissions associated with them. With carbon emissions increasingly on the political agenda, and the introduction of the Carbon Reduction Commitment, it would be perverse if industry, including the water companies, is required to implement these energy intensive measures unless it can be proven that they are the most cost-effective and sustainable solution.”

Ofwat’s detailed response to the consultation is available from the Ofwat website.