SWIP response to South West Water draft Water Resources Management Plan 2024

South West Water (SWW), like all water companies, has to prepare and consult on a Water Resources Management Plan (WRMP) every five years.

SWW’s draft WRMP sets out how the company will make sure there continues to be a secure supply of water to customers in the future, while also protecting and enhancing the environment. It sets out how SWW plans to manage water resources, consider changes in customer demand, and support the region’s economic growth and the wellbeing of those that work and live here.

As part of a recent public consultation on SWW’s draft WRMP, SWIP has issued a response focused on the proposals for infrastructure development within the region, i.e., the high-level supply aspects rather than the more customer-focused demand side.

However, SWIP accepts and fully supports both supply and demand side measures are needed to ensure resilient supplies for current and future population and businesses whilst reducing carbon and reducing our impact on the natural environment.

SWIP response to SWW

In general, we support the methodology adopted and the current recommendations set out in the company’s ‘Best Value Plan’, in particular the commitment to providing resilient infrastructure and water resources to meet all the needs for homes, businesses and the environment and support the long-term economic health of the region whilst meeting the challenges of climate change and reducing the carbon impact of the company’s operations and investments.

Supply-side comments

We note that you considered 157 potential schemes, rejecting 57 and pausing progression on 19 in the South West Water WRZs and rejecting 16 and pausing 6 in the Bournemouth WRZ. We look forward to understanding more about the 25 paused schemes in your revised WRMPs.

In the meantime, we would make one point concerning the supply of water to Fawley refinery. You state that consideration of a desalination plant has been rejected as previously dismissed by regulators, presumably the Environment Agency, when a similar proposal was submitted by Southern Water.

This would seem premature to us, since different circumstances and benefits will have applied in the Southern Water case and environmental and economic considerations, including the requirement to meet net zero (for the water sector voluntarily by 2030) will mean regulators should now take a different view.

This proposal for Fawley would release in excess of 10Ml/d to support the supply side. It is one of two schemes rejected in the Bournemouth WRZ that could deliver that volume, though of a further five that could, three have ‘significant uncertainty for acceptability from environmental reasons’ and another one for complexity and cost.

We note your commitment to develop a diversified mix of water resource solutions including effluent reuse and desalination. We would therefore promote further consideration of a Fawley desalination scheme rather than rejection based on previous criteria that may no longer be appropriate.

Finally, we note that you will be considering desalination options for the Colliford WRZ, specifically at a number of locations along the Cornish coast, to deliver 10Ml/d. However, you will not be able to provide further details until your Statement of Response. Clearly desalination in the UK is a controversial solution, but changing constraints around conventional water resources requires forward looking and innovative approaches. We presume the company will be proposing renewable energy sources for any future desalination plant.

Demand-side comments

We note and support the investment proposed- £184M totex – for leakage management, to meet the 50% reduction target by 2050, saving 34Ml/d in the next 25 years, together with the £57M for metering during AMP8. These investments combined are significantly in excess of the proposed investment for supply-side options. The company, and regulator, therefore, need to be have confidence that both leakage management and the meter installation programmes will deliver the expected savings.

Promoting and delivering water efficiency clearly requires the ability to measure consumption before and after any intervention. Moving customers from unmeasured to metered charging and the proactive replacement of existing meters with smart meters is therefore a positive move. However, we note that the company’s draft plan focuses only on household customers. Non-household customers, nationally, account for around 30% of consumption. And the largest 165,000 account for nearly three quarters of that 30%. It makes sense therefore to prioritise smart metering for those high use business customers, not just for household customers.

We support your proposal to champion recycling and reuse, focusing on supporting households to utilise rainwater harvesting and greywater systems thus reducing potable use as a means of meeting the Government’s 110 litres per person per day target.

We suggest there is also an opportunity, working with retailers, to support businesses with RWH and grey water recycling. Large retail units or distribution depots with extensive roofs and impermeable parking areas are a prime candidate for RWH that could reduce potable water consumption whilst have the added benefit of delaying high rainfall impacts on the sewer network, potentially reducing CSO discharges.

Download SWIP’s response as a PDF