Taking account of downstream abstractors

To what extent should water company decisions about changes to discharges take account of the impact a change could have on downstream abstractors?

Why the contribution is important

Currently, water companies are not required to consider the impacts of changes to discharges on downstream abstractors. As we have explained, in the future some water companies may consider changing where they discharge, for example to improve the water quality in a river or to make more efficient use of water. This may impact on the water available for abstractions downstream, particularly at low flows.

by abstractionreform on September 05, 2014 at 11:05AM

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  • Posted by psmith September 28, 2014 at 20:19

    Changing a major discharge usually entails a new or modified discharge consent elsewhere. Would the regulator be liable to pay compensation for allowing loss or damage to businesses with existing abstraction licences?
  • Posted by JLNeedle September 29, 2014 at 16:48

    A decrease to an established and significant discharge should not be allowed without serious consideration of downstream abstractors.
  • Posted by EnergyUK October 06, 2014 at 15:49

    We recognise that the question of how to regard Water Companies in the context of water resource management planning, objective setting in Water Framework Directive and general water industry infrastructure planning is a difficult one. However, it is of such potential importance to society as a whole that we welcome DEFRA’s intention to get a better appreciation of the issue.

    We consider that Water Companies should be required to obtain an appropriate permission to modify a discharge from the appropriate regulator prior to carrying out any deliberate modification. This is already required should a water company wish to vary the water quality outside their existing permit limits or increase the flow from a discharge. Permission would be granted subject to assessment of the acceptability of the proposed change. We contend that a proposal to change the location of a discharge or reduce its volume should be subject to an appropriate control regime in order that societal interests should be considered and suitably protected. Societal interest here includes all of downstream abstractors, downstream discharges, in-stream users, those who take value from non-use and the environment.

    We present a possible framework within which to structure such a decision-making process in our response to Question 3 (How could Water Companies best take account of the impacts of changing discharges on downstream abstractors?).
    For many non-Water Company direct users of water with abstractions and discharges there is typically a close coupling between a specific abstraction (currently controlled via an abstraction licence) and a specific discharge (currently controlled by an Environmental Permit). Determination of the abstraction licence takes into account the extent of the depleted reach that would result. Moreover, where the abstraction and discharge are associated with a single installation, the overall impact of abstraction and discharge combined is considered fully in a coupled way via the planning regime.

    This is not the case for Water Companies as a Water Company deliberately, and validly, makes use of a number of water sources including surface and groundwater abstractions, reservoirs, transfers, etc along with flexible infrastructure linking it with users in order to provide a reliable supply to users. User waste water is collected with infrastructure, treated and a high proportion of the source water is returned to the environment via treatment works.

    Policy makers and regulators have long accepted that the return to the environment of this water is not brought about in such a way as to minimise the effects of flow reduction from the water resources from which it predominantly originated. Instead, policy makers and regulators have preferred the return to the environment in locations principally determined by the location of the treatment works. In effect, any societal advantage to be gained by returning water nearer to the source of supply has been waived in favour of avoiding the need for additional pipework infrastructure, pumping, and possible water quality issues.

    In years gone by this could be managed holistically because of the institutional arrangements of the time (eg Regional Water Authorities of the 1970s ). However, privatisation of the water industry and separation from the environmental regulator has created new institutions with different drivers leading to the risk which underlies the question. Recent further reform of the water industry accentuates pressures for Water Companies to consider acting very differently in future than historically.

    Whilst the possibility of Water Companies choosing to move or withhold discharges is not new in the sense that it could happen in the current regulatory landscape, the abstraction reform process has highlighted both the potential and the consequences associated with it. It also offers an opportunity to address it. Given the dependence of society and the environment on the flow of lowland rivers it is important to address it to ensure an equitable basis of transition to the future management of water resources and to avoid unintended adverse societal consequences of the package of reforms affecting water resource and the water industry. An example of a direct unintended adverse consequence from within the power sector would be the increase in severity and duration of water related constraint of operation (i.e. reduction in energy generated) at a power plant. Related to this over the longer term might be reduced new investment in an existing power plant or loss of investment in a new water-dependent plant as a result in the anticipated increased constraint related to water availability.
  • Posted by YW October 08, 2014 at 15:06

    Water companies have a duty to deliver an economic and efficient service to customers and to minimise impacts on the environment. These duties must take priority in any decision making. It is feasible for water companies to consider the impacts on downstream abstractors when investigating changing a discharge. However, alternative schemes that do not impact on downstream abstractors could only be implemented if they did not impact on the water company’s statutory duties or incur inappropriate costs.
  • Posted by YW October 08, 2014 at 15:37

    Water companies’ have a duty to deliver an economic and efficient service to customers and to minimise impacts on the environment. These duties must take priority in any decision making. It is feasible for water companies to consider the impacts on downstream abstractors when investigating changing a discharge. However, alternative schemes that do not impact on downstream abstractors could only be implemented if they did not impact on the water company’s statutory duties or incur inappropriate costs.
  • Posted by CCWater October 09, 2014 at 14:27

    This issue will become more important with the opening of competition in the water industry – there might be water companies (and customers) who depend on the discharges of other water company (ies) upstream. For example, company A returns a large volume of water to a river where another water company (company B) abstracts from. But due to reductions in the volume company A is allowed to abstract, it decides to develop a water re-use scheme, transferring treated wastewater to a nearby water treatment works or to an industrial customer who does not require potable water. As a result, the original discharge to the river is reduced. This change in company A’s discharges could place potential strain on the water resources available to company B and other abstractors downstream.

    The dependency on water is an issue for household and non-household customers. Our SME research (http://www.ccwater.org.uk/w[…]-sewerage-services-2014.pdf) shows that dependency on water and sewerage services is high (72%). Although water is mostly used for ‘domestic’ purposes (i.e. drinking, waste water and toilets), 24% of SMEs use water as part of the services they offer (i.e. café, hair dresser, laundrette, car wash).

    As a result, any decisions that might affect changes to water company discharges need to be considered carefully, as they can have a detrimental impact on other water company’s ability to fulfil their duties of providing a reliable water supply.

    Finally, reducing water company discharges could also have an impact on the environment and on achieving water quality objectives. Whilst we support a more integrated approach to water management we would expect companies and regulators to consider the wider impacts of proposed changes to water company discharges.
  • Posted by DCWW October 10, 2014 at 10:32

    Wastewater discharge permits are permissions to discharge, they are not a requirement to discharge. Wastewater flows can vary or cease beyond the control of the discharger (changes in population, ceased industrial discharges etc). Wastewater discharges may also be rationalized, moved and combined to bring about efficiency and/or as the only way to meet water quality needs within a waterbody.
  • Posted by SouthStaffsWater October 10, 2014 at 19:14

    An additional demand for water downstream from any discharge is the environment itself. Many major rivers in the UK are almost entirely supported by treated water effluent from water company sewage treatment works during dry summers. A number of major water resource schemes have been put in place that were planned on the basis of, and continue to rely on, treated water discharges. Whilst the majority of these rely on direct abstraction of effluent discharged upstream, others rely on abstraction of groundwater and depend on effluent to maintain flows in the rivers passing by. These schemes constitute a sensible system of catchment water resources management but have no statutory footing at present.

    There are a number of reasons for changes to water company discharges. Some of these are unavoidable due to changes in customer numbers or behaviours such as the impact of greater water efficiency in the home reducing the volume and quality of foul sewage entering works. Others are driven by a wish to reduce costs through centralisation of capacity or cost-effective implementation of higher effluent quality standards. Centralisation does not always mean better quality releases as witnessed by the use of long sea outfalls to avoid treatment to inshore freshwater quality standards. The choice of engineering solutions to the meet the internal or external drivers for change are usually subject to some degree of cost benefit test including statutory drivers. It seems sensible that the wider demands of catchment water resources management and other downstream abstractors are included in a more transparent process going forward.
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