How to assess the impact of change

How could water companies best take account of the impacts of changing discharges on downstream abstractors?

Why the contribution is important

If water companies were to take account of the impacts, we would welcome your views on ways that this might best be achieved. Any measure would of course need to be proportionate for both the water companies and downstream abstractors.

by abstractionreform on September 12, 2014 at 04:50PM

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  • Posted by psmith September 28, 2014 at 20:29

    Downstream impacts would be assessed in conjunction with EA as a responsible regulator using long-term hydrological data.
  • Posted by JLNeedle September 29, 2014 at 16:41

    Impacts of reduced discharges are likely to be least if those reductions are made at times of high river flow.
  • Posted by EnergyUK October 06, 2014 at 15:42

    We consider that it is appropriate for Government to introduce a requirement on Water Companies to assess all the consequences of proposed schemes (including changes to current operations) which could lead to changes in discharges (with respect to any and all of location, quality and timing). The assessment of the acceptability of the proposed changes should be determined in all appropriate regimes (e.g. planning, Environmental Permitting, water resource, etc.). Where stakeholders are affected by the proposed change the consequences, including economic consequences, should be assessed as part of the economic appraisal. We do not consider that current stakeholder processes of Water Resource Management Planning and the AMP process are sufficient in this regard.

    We are aware that this is not straightforward. However, we feel that the separation of water company abstraction rights and discharges, which has been convenient for society to date, needs to be put on a much firmer footing in order to better prepare society for a future which could involve substantially increased water stress. We consider that the water industry should be regarded as having sets of weakly consumptive abstraction rights (leading to strong overall discharge return flow obligations). Such is the scale of dependence of wider society on water resources under the influence of Water Companies, both via abstraction and via discharge/transfer, that these must be managed so as to have regard for the societal consequences of change. Within the power sector such potential consequences could include the reliability of power generation (i.e. duration and severity of reductions in energy output from an existing plant) and the potential implications for reduction in investment in existing or new plant).

    One contribution to this may be to expand the scope of the current water resource management planning regime to provide a means by which options, such as closure and opening of sewage treatment works, that have consequences for discharges can be identified, appraised and managed subject to stakeholder and regulatory visibility over appropriate timescales. It should be noted that the lifetime of water-dependent assets of other water users can be long (e.g. for individual power stations in the order of 30 years and for power station sites much longer). Thus, 5 or 6 year notice of material change which could arise from the Water Resource Management Planning (next round) would be inadequate. It would be inequitable and societally economically inefficient in many cases to expect others to adapt to a new expanded water resource and water management plan in those timescales. We suggest that a 20-30 year planning notification period is more appropriate and could be accommodated within the Water Resource Management Plan approach.

    We recognise the importance of retention of flexibility to innovate within the water industry to achieve more efficient delivery of its duties.

    One possibility which may provide appropriate flexibility while retaining a firm underpinning for low flows in lowland rivers would be to establish enforceable minimum STW-derived flows in all river reaches which reflect an appropriate proportion of the overall return obligations of the water industry. These would take account of the effective consumptiveness of the water use of customers and the distribution of sewage treatment works. The minimum STW-derived flow requirement could be regulated in the sense that Environment Agency would be required to ensure that the reported sewage treatment works actual discharges were consistent with the return flow obligations. Variation of these minimum STW-derived flows could be managed within the expanded scope of regional (rather than Water Company specific) water resource management plans.

    As discussed in Question 5 (should abstractors pay …), where a water company is meeting its minimum return obligations reach by reach and has additional discharge which it can choose to route to different locations, or alternatively route to storage, a commercial agreement with a third party would seem an appropriate mechanism to contribute to decision making within this ‘flexible tranche’ promoting economic efficiency.
  • Posted by PeelUtilities October 10, 2014 at 16:22

    Where a water company proposes changing a discharge point (be that via a new discharge elsewhere or diveerting to an existing discharge), it is for the EA to asses the impact of that action. Not only on the new point of discharge but also on the watercourse it is being removed from. If moving the discharge results in serious detriment to the existing waterway, (say through resulting over abstraction), then the new discharge request must surely be declined?
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