Better understanding the risks to abstractors

What would help downstream abstractors better understand the risks they face from changes to discharges? What actions might make individual abstractors more resilient to any changing discharge patterns?


Why the contribution is important

If downstream abstractors were to better understand the risks of changing discharge patterns, we would welcome your views on how this could best be achieved. Also, in terms of abstractors becoming more resilient to future change, you may have views on some measures for doing this.

by abstractionreform on September 12, 2014 at 04:54PM

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  • Posted by psmith September 28, 2014 at 20:26

    It is not easy to divert major discharges elsewhere and implies significant investment allowed by Ofwat and permits changed by EA, who would hopefully understand the hydrological impacts and would consult downstream interests.
  • Posted by JLNeedle September 29, 2014 at 16:39

    Potential new abstractors should be advised on upstream discharges by the EA at the pre-application stage. Existing abstractors should be advised similarly, this is particularly important if there is to be any change to the status quo on this matter.
  • Posted by EnergyUK October 06, 2014 at 15:28

    The question is far more fundamental than that posed. If Water Companies were to be allowed to manipulate freely the discharge arrangements of sewage treatment works on the premise that Water Companies had the right to do so, there would need to be a comprehensive re-appraisal of many aspects of how society managed its water environment. For example,
    • The basis of target status setting within Water Framework Directive would need to be revisited to ensure that target status was consistent with secure water resource (i.e. not subject to redirection or timing by Water Companies)

    • Government agencies should present historic flows and future flow projections disaggregated to highlight the contributions to flows from the various sources so users would have better visibility of the future risks. We note that historical information in itself is of limited value since the characteristics of catchments, land, population water demand and water industry infrastructure arrangements have all been changing so the historical disaggregation may not be a good guide to the future.

    • The basis of allocation of water resource would need to be changed, probably distinguishing water company independent resource (which could be allocated by Government) and water company dependent (which could not, unless Water Companies were required to surrender discharge flows to Government for re-allocation i.e. Government acted as sole recipient of discharge flows on behalf of society/environment).

    We do not consider that Water Companies’ discharges should be regarded as ‘assets’ for Water Companies to control freely and for which they are regarded as ‘owners’ or ‘exclusive rights holders’ . Rather, Water Companies’ use of water resource should be seen more holistically as weakly consumptive (thus leading to an overall obligation to return say, for example, 80% of the abstraction, to the water environment). The proportion required to be returned may reasonably vary with region, weather, tolerable leakage position, etc. and may change over time as the nature of societal water use changes (balance and degree of consumptiveness in use). The location, quality and timing of return should be subject to regulatory control within a strategic plan (see our answers to 'how could water companies best take account of the impacts of changing discharges on downstream abstractors?') (How could Water Companies best take account of the impacts of changing discharges on downstream abstractors?).
  • Posted by YW October 08, 2014 at 15:44

    The Environment Agency do not guarantee water availability when granting licences. Changes to discharges are just one of a number of risks and reliability could reduce due to climate change, environmental legislation or changes to compensation flow. The Environment Agency should fully explain the risks to licence availability and the assumptions its uses when determining water availability (CAMS) to existing and new abstractors.

    If in the future a water company does propose a change to a discharge the Environment Agency should ensure downstream abstractors are aware of the extent of the impact and whether or not it will lead to a significant reduction in flow.
  • Posted by DCWW October 10, 2014 at 10:30

    It is important to avoid any perverse incentives or unintended consequences for wider wastewater discharges when considering these proposals. Consequently, there needs to be a clear differentiation between wastewater discharges that have been specifically moved or placed as part of a water resource scheme (planned and designed codependence) and wider (design-unrelated) wastewater discharges in the catchment.
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