Matthew Pitts from Cascade discusses the different types of environmental assessment required in water resources management plans.
Water companies in England and Wales are required to prepare water resources management plans (WRMPs) under the Water Act 2003. They form part of the periodic review (PR) system under which companies submit a business plan to Ofwat every five years. It is on the basis of this business plan that Ofwat decides the level of investment and the price increases water companies can pass to consumers.
In basic terms, the WRMP process comprises the selection of a programme of schemes to increase water supply (such as new abstractions and reservoirs), with measures to reduce demand (leakage reduction and meter installations). The selection process starts with a long, unconstrained list of schemes, which is reduced to a feasible list, from which a combination of measures is selected to meet a projected supply/demand deficit (see figure 1 below).
The WRMP must be optimised to provide the best value for money; meeting the projected deficit at the lowest cost per unit of water. However, it must also cause as little environmental impact as possible and comply with relevant environmental legislation.
Figure 1: Development of the WRMP and incorporation of strategic environmental assessments, Habitats Regulations assessments (and Water Framework Directive assessments
Environmental assessment requirements
WRMPs are developed according to the Environment Agency’s Water resources planning guideline (WRPG), which is regularly updated to incorporate regulatory and policy changes. The original WRPG (2003) featured a requirement to consider environmental effects. The WRMP process is now subject to strategic environmental assessment (SEA) according to the SEA Regulations, Habitats Regulations assessment (HRA) according to the Habitats Regulations, and Water Framework Directive (WFD) assessment to ensure the WRMP does not cause status deterioration to WFD water bodies.
The WRPG also requires environmental effects to be monetised, where feasible, for incorporation into cost-optimising models. The inclusion of so many environmental assessments has caused a number of problems in WRMPs, including the double counting of impacts; duplication of efforts; inconsistency in reporting; and a perception that some assessments are unnecessary.
Adding value through environmental assessments
These numerous strands of assessments could be regarded as a burden and constraint on the process of producing a workable WRMP; effectively nothing more than tick-box exercises to ensure legal compliance. However, with early planning and forethought, they can be structured to avoid duplication and contribute to a more robust and sustainable plan.
The SEA provides an overarching framework through which to consider and account for all effects, including those arising from the HRA and the WFD assessment. The SEA process is well established and understood by stakeholders, and the requirement to consult on the scope of SEA enables early stakeholder engagement. Earlier stakeholder communication during the periodic review for 2014 proved effective at identifying issues and establishing scope and methodologies that will ensure fewer problems later in the process when pressures are greater. Preliminary, informal discussions with stakeholders can avoid issues prior to formal consultation, leading to a less stressful process and, ultimately, a more acceptable WRMP, as well as more effective environmental protection.
The role of each form of assessment is subtly different. Once this is understood, the positioning of each form of assessment within the WRMP process becomes more straightforward. A high level consideration of ‘unalterable planning constraints’ takes place when reducing the unconstrained list to a feasible list – this falls outside the SEA umbrella, but is effective in removing those measures likely to be unacceptable due to effects on internationally designated sites.
Early stage consideration of effects through HRA and consideration of effects on WFD status allows time to iteratively amend scheme designs to reduce impacts. As designs are amended and recorded as such stakeholders are reassured that the environment will be protected should those schemes be selected. Once the lowest cost combinations of schemes have been modelled, the repository of environmental information that constitutes the SEA can be interrogated to highlight any schemes with significant environmental effects that suggest the scheme should be avoided for the next model run. Through successive iterations, the most sustainable solution is found.
Integrating catchment management and ecosystems services
Improvements were made between PR 2009 and PR 2014 to the processes through which environmental assessments are integrated into the WRMP and, ultimately, business planning processes. However, there remains room for further improvements for PR 2019, particularly in the extent and approach to incorporating environmental impacts as valued benefits and “dis-benefits”.
Introducing ecosystems services concepts to the planning process via environmental assessments, for example, will go further to ensuring water company plans are robust in the face of pressures such as habitat loss, population increase and climate change. This will be increasingly important as there will be further pressure on water companies to reduce their prices as the general cost of living increases, suggesting that in the future there will be less money to fund environmental improvements such as sustainability reductions.
