Severn Trent Water Ltd

Transcription

1 Severn Trent Water Ltd Drought Plan 2009 Prepared by the Strategic Water Resources Planning Team Water Services Severn Trent Water Limited September /10.116

2 Foreword The Water Act (2003) made it a statutory requirement for water companies to produce and maintain a Drought Plan, and update it every three years. In accordance with this we prepared our draft Drought Plan in June 2006 and published it for consultation. The consultation period extended into mid-september 2006, during which time 110 stakeholders were contacted and 11 responded. Our statement of response to these comments is included in Appendix D of this document. Where we have made changes to the content of this Plan as a result of stakeholder comments a cross reference to these changes is given as a supplement to the Statement of Response. Based on the comments of our stakeholders and our response to them, DEFRA and Welsh Assembly Government issued a conditional Drought Plan Direction, cited as the Severn Trent Water Limited Drought Plan Direction (2008), on 7th April This sets out the modifications that are required to finalise our Drought Plan. A copy of the Direction is given in Appendix E. This document, therefore, is our Final Drought Plan for September 2009, and it incorporates these directions and other points of clarity raised by DEFRA and the Environment Agency. It should be noted that the finalisation of this Plan has been done over the period from publication of the draft Plan to September It therefore also incorporates any operational or regulatory updates that have occurred over this period. Please note: The requirements of AN/11 ed2 The Control of Sensitive Water Company Information states that we have been obliged by the Secretary of State to remove from this document, any information that is site specific that can be used to identify any sensitive or key company assets. This includes Appendix F of our original draft Drought Plan which gave detailed descriptions of our operational sites in relation to the environmental impact assessments; reports that were undertaken to support any drought permit applications we may make. 2

3 Executive summary This document is the Severn Trent Water Ltd Drought Plan (DP) for It is an update of our DP for 2003 and it reflects our recent activity and initiatives to build on our ability to manage our water resources and to maintain our service to our customers in droughts. The Plan also embraces the recent Government legislation relating to drought management and has been prepared in line with the updated Drought Plan Guideline which was issued by the Environment Agency in September This Plan has been subject to submission to the Secretary of State and National Assembly for Wales prior to public consultation. In the process of producing this Plan, we have liaised closely with the Environment Agency and our neighbouring water undertakers with which we have bulk supply agreements. We recognise the need to maintain these links to ensure that the optimum use is made of water resources in Wales and the Midlands during a drought, and in a way that minimises impact on the environment. To ensure impacts are minimised, we have commissioned Environmental Impact Assessments to provide important baseline information should we need Drought Permits to help us manage our water resources in future droughts. As in the previous Plan, our operational area is divided into nine drought management zones. For each zone, the supply and demand management options available during a drought are discussed, together with an assessment of the risks associated with these options. The triggers that initiate actions are also discussed together with the make up of our Drought Action Team that will be responsible for decision making as drought develops, and for standing down actions in its aftermath. A key requirement of drought management is the monitoring of a developing situation and the timeliness of action, and good co-operation and communication with the EA is an essential part of drought management. We continually monitor reservoir storage and groundwater abstraction rates, thereby giving sufficient lead time to deploy the actions described in this Plan. Where these actions involve demand savings, an indication of these savings is given, but these figures should be treated with caution as they are difficult to assess with any accuracy. A further key requirement of drought management that is covered in the Plan is the management of leakage and customer awareness of the water supply situation. The Plan therefore covers details of our recent efforts in leakage management, and our programme of media publicity aimed at customer awareness of the need for the sensible usage of water. This is particularly relevant due to the challenges faced by water undertakers in our changeable climate e.g. the South East of the UK in 2006 where abnormally low rainfall caused depleted reservoir and aquifer levels. 3

4 With regard to levels of service, our policy is to meet our customers needs at all times. Indeed, the control graphs given in Appendix B of the Plan have been developed to ensure that the risk of supply failure of any of the major resource systems is less than 1% in any year. Nevertheless, we recognise that certain droughts may occur when resources are so depleted that summer drought permit powers will be required to extend the availability of the resources in a particular zone. In these circumstances we accept that a hosepipe ban will be necessary. Our stated level of service is that a regional hosepipe ban will be applied no more often than 3 times per century. The recent legislation recognised the potential commercial sensitivity of some of the information that we would have to discuss in the Plan. For this reason we were allowed the opportunity to retain from the public version of the document, any information that we considered was commercially sensitive. However, after due consideration, we did not identify any such details. In addition to this, we have been directed by the Secretary of State to omit certain details of our assets that could potentially identify their location, and hence compromise National security. We have complied with this direction. A summary of the changes made to this Plan since the Drought Plan of 2003 are listed in Appendix A. 4

5 CRYNODEB GWEITHREDOL Dyma Gynllun Sychder Severn Trent Water Ltd ar gyfer 2009, sef diweddariad ar ein Cynllun Sychder ar gyfer Mae n adlewyrchu ein gweithgareddau diweddar a n mentrau i wella ein gallu i reoli ein hadnoddau dŵr a chynnal ein gwasanaeth i n cwsmeriaid mewn cyfnodau o sychder. Mae r cynllun hefyd yn mabwysiadu deddfwriaeth ddiweddar y Llywodraeth sy n ymwneud â rheoli sychder ac fe i paratowyd yn unol â r Canllawiau ar gyfer Cynlluniau Sychder a ddiweddarwyd ac a gyhoeddwyd gan Asiantaeth yr Amgylchedd ym Medi Cyflwynwyd y Cynllun hwn i r Ysgrifennydd Gwladol ac i Gynulliad Cenedlaethol Cymru cyn yr ymgynghoriad cyhoeddus.. Yn y broses o gynhyrchu r Cynllun hwn, rydym wedi cydweithio n agos ag Asiantaeth yr Amgylchedd a r darparwyr dŵr cyfagos y mae gennym gytundebau cyflenwi swmp â nhw. Rydym yn cydnabod yr angen i gynnal y cysylltiadau hyn i sicrhau y gwneir y defnydd gorau o r adnoddau dŵr yng Nghymru a Chanolbarth Lloegr yn ystod sychder, a hynny mewn ffordd sy n andwyo r amgylchedd cyn lleied ag y bo modd. I sicrhau r effaith leiaf posibl, rydym wedi comisiynu Asesiadau o'r Effaith Amgylcheddol er mwyn darparu gwybodaeth sylfaenol bwysig petai arnom angen Trwyddedau Sychder i n helpu i reoli ein hadnoddau dŵr mewn sychder yn y dyfodol. Fel yn y Cynllun Sychder, mae ein hardal weithredu wedi i rhannu yn naw parth rheoli sychder. Ar gyfer pob parth, trafodir yr opsiynau sydd ar gael ar gyfer rheoli r cyflenwad a r galw yn ystod sychder, ynghyd ag asesiad o r risg sy n gysylltiedig â r opsiynau hyn. Trafodir hefyd y pethau sy n sbarduno gweithrediadau ynghyd â phwy fydd yn ein Tîm Gweithredu Sychder a fydd yn gyfrifol am wneud penderfyniadau wrth i sychder ddatblygu ac am y gweithrediadau i ddychwelyd i r sefyllfa arferol ar ôl y sychder. Un o ofynion allweddol rheoli sychder yw monitro sefyllfa sy n datblygu a gweithredu n brydlon ac mae cydweithredu a chyfathrebu n dda ag Asiantaeth yr Amgylchedd yn rhan hanfodol o reoli sychder. Rydym yn monitro trwy r amser y cronfeydd dŵr a r cyfraddau tynnu dŵr daear, sy n rhoi digon o amser i ni gyflawni r gweithrediadau a ddisgrifir yn y Cynllun hwn. Os yw r gweithrediadau hyn yn cynnwys arbedion o safbwynt y galw, mae maint yr arbedion hyn yn cael ei nodi, ond dylid trin y ffigurau hyn yn ofalus gan ei bod yn anodd eu hasesu n fanwl. Un arall o ofynion allweddol rheoli sychder a gynhwysir yn y Cynllun yw rheoli gollwng dŵr ac ymwybyddiaeth gan gwsmeriaid o r sefyllfa o ran y cyflenwad dŵr. Mae r Cynllun felly yn cynnwys manylion am ein hymdrechion diweddar i reoli gollwng dŵr a n rhaglen gyhoeddusrwydd yn y cyfryngau sy n ceisio gwneud cwsmeriaid yn ymwybodol o r angen i ddefnyddio dŵr yn synhwyrol. Mae hyn yn arbennig o berthnasol oherwydd yr her a wynebir gan ddarparwyr dŵr yn ein hinsawdd gyfnewidiol, e.e. yn Ne-ddwyrain y DU yn 2006 achosodd glawiad anarferol o isel i lefelau cronfeydd dŵr a dyfr-haenau gael eu darwagio. O ran lefel gwasanaeth, ein polisi yw diwallu anghenion ein cwsmeriaid trwy r amser. Yn wir, datblygwyd y graffiau rheoli yn Atodiad B yn y Cynllun i sicrhau bod y risg o dorri r cyflenwad o unrhyw un o r systemau adnoddau mawr yn llai nag 1% mewn 5

6 unrhyw flwyddyn. Serch hynny, rydym yn cydnabod y gallai sychder ddigwydd pan fydd adnoddau wedi u darwagio i r graddau fel bod angen pwerau i gyflwyno trwydded sychder yr haf i sicrhau bod mwy o r adnoddau ar gael mewn parth arbennig. Yn yr amgylchiadau hyn rydym yn cydnabod y bydd angen gwahardd defnyddio piben ddyfrhau. Y lefel gwasanaeth a nodwyd gennym yw na fyddwn yn cyhoeddi gwaharddiad rhanbarthol ar ddefnyddio piben ddyfrhau yn amlach na dwywaith neu dair gwaith y ganrif. Roedd y ddeddfwriaeth ddiweddar yn cydnabod y gallai rhywfaint o r wybodaeth y byddai angen i ni ei thrafod yn y Cynllun fod yn sensitif yn fasnachol. Oherwydd hyn rhoddwyd cyfle i ni adael allan o fersiwn cyhoeddus y ddogfen unrhyw wybodaeth yr oeddem yn ei hystyried yn sensitif yn fasnachol. Fodd bynnag, ar ôl ystyriaeth ddyledus, ni wnaethom adnabod unrhyw fanylion o r fath. At hynny, mae r Ysgrifennydd Gwladol wedi ein cyfarwyddo i adael allan rai manylion o n hasedau a allai ddatgelu lle y maent, a thrwy hynny beryglu diogelwch gwladol. Rydym wedi cydymffurfio â r cyfarwyddyd hwn. Mae crynodeb o r newidiadau a wnaed i r Cynllun hwn ers Cynllun Sychder 2003 i w weld yn Atodiad A. 6

7 Severn Trent Water Ltd Drought Plan Foreword Executive summary...3 Welsh executive summary Introduction Background Objectives Meeting regulatory expectations Business as usual - planning for drought in the context of company business The drought zones Our water resources network and its flexibility of supply Our management of demand and leakage Levels of service, and ensuring they can be met despite a drought Alignment between the DP and the company s hot weather plans Alignment with the 2004 water resources plan The use of drought permits The use of drought orders The relationship to the strategic environmental assessment directive Liaison with other water companies and organisations Summary of bulk supply agreements and their use in droughts Liaison with Yorkshire water services Liaison with Anglian water Liaison with Thames water Liaison with Bristol water Liaison with Dwr Cymru Welsh water

8 Liaison with United Utilities Liaison with South Staffordshire water Liaison with other licensed water undertakers Inset agreements Co-operation on planning development river severn modelling. association Liaison with other organisations The company s drought management structure and communication and liaison...plan Communications within the company Communication with the agency and dat activity Alignment with the agency s river severn DP Other regulators - Defra, Ofwat and DWI Other external bodies The news media Appeals for conservation to the public 42 4 The drought management process Recognising a drought situation - triggers for action and incremental measures Drought scenarios - base positions for demands, source outputs and raw water... storage Supply/demand balance Drought management options Supply side options Demand side options Drought zones background and drought management

9 5.3.1 The Stoke drought zone The Ladderedge drought zone The East Midlands drought zone The Severn drought zone The Birmingham drought zone The Forest and Stroud drought zone The Oswestry drought zone The Vale of Powys drought zone The Staffordshire and East Shropshire drought zone Licensed source review Package treatment plants Temporary pipelines and pumps Tankering Short term licence variations and emergency licences Action at the end of a drought Application for drought permits and drought orders Assessing environmental impacts Applying for drought permits Derwent valley reservoirs River derwent at Ambergate Tittesworth reservoir and the River Churnet River Wye at Wyelands River Severn at Trimpley River Leam at Eathorpe and river Avon at Stareton Applying for drought orders Data exchanges with the agency

10 6.5 Post drought monitoring Continued base-line monitoring Post drought review Update of this drought plan Assessing the frequency of drought actions Derwent valley reservoirs Carsington and Ogston River Dove reservoirs Elan Valley Tittesworth reservoir Draycote Appendices...86 Appendix A list of changes from DP Appendix B drought plan summary tables and figures..87 Appendix C relevance to strategic environmental assessment directive.120 Appendix D statement of response 122 Appendix E the Defra direction

11 1 Introduction 1.1 Background The development of a formal Drought Plan (DP) for Severn Trent Water Ltd began in 1999 with the compilation and issue in that year of our first Plan. This was followed in 2003 by the second updated DP, but whilst both of these documents had been developed in conjunction with the Environment Agency, (the Agency) there had been no statutory requirement for us to produce such documents. However, the Water Act of 2003 made it a requirement for us (and indeed, every other water utility), to develop and maintain a statutory DP. This document is therefore our first statutory Plan, and its development has followed the guidance issued by DEFRA, and has been compiled after detailed consultations with the Agency. 1.2 Objectives The key objective of this plan is to develop appropriate measures in advance of a drought so that water supply to our customers is made as secure as possible within the levels of service declared in our 2004 Water Resources Plan, and with minimal impact on the environment. The Plan covers the actions we will take related to demand management that might extend to Drought Orders that restrict the nonessential use of water. It does not, however, aim to cover the provision of essential water supply at all times including a civil emergency or any event that threatens national security. A significant addition to this new plan is a formal assessment of the impact of all the Drought Permits it proposes. Whilst all Drought Permits are intended to minimise any impact on the environment, the introduction of legislation related to the Water Framework Directive has meant that this new Plan must contain details of an assessment of the likely impact that the Drought Permits proposed in the Plan will have on the local environment. In addition, it is a requirement of the legislation that we undertake routine environmental monitoring both during and after a drought, so that the true impact of the actions can be evaluated. These are two significant additions to the 2003 DP. A summary of these impact assessments and the monitoring program is given in Appendix F of this document. The second objective of this Plan is to make it a more public and a more accessible document. The guidance released by DEFRA gave details of the formal statutory consultees that we have provided copies of the Plan to during the formal consultation period. However, we recognise our role as a custodian of the environment, and as such we made available the details of this Plan to a wider stakeholder group. To this end, we provided details of this plan on our website, and alerted all designated stakeholders to the Plan s existence on this medium. We also recognise the need to keep this DP a live document. The plan will therefore be improved as and when changes to any aspect of drought management occur. 11

12 1.3 Meeting regulatory expectations To help the water companies develop their DP to meet the expectations of the regulators, the Agency published a guide in 2005 that prescribes a step by step approach to the compilation of the Plan. This has proved very useful to us and the Check List that is given in the guide to help ensure all necessary aspects of drought planning and management are covered, is reproduced below. It also serves to direct the reader to the relevant section of this Plan for greater detail. DP check list Item Reference in Plan 1 Contents consistent with 2004 Water Resources Section 2.6 Plan (LoS, DO) 2 Map of Company Area showing Resources Section 2.1 Zones, Drought Management Zones, ecological sites affected by Plan 3 Justification for Drought management Zones Section 2.1, Section 5.3 where different from Water Resources Zones 4 Details of outcome of consultation with other Section 2.10 organisations 5 Summary of consultation with any licensed Section water suppliers 6 Details and justification of drought scenarios Section 4 used 7 Details of triggers and associated drought Section 4, Table 4.1, Appendix B actions 8 Reservoir control curves Appendix B 9 Completed Appendix B for all management Appendix B options 10 Additional options if available Appendix B if any options are available 11 List of sites for Drought Permits Section Details of Environmental assessments and Summaries are in Appendix F Studies at Drought Permit sites 13 Details of Environmental monitoring plan Section 6.5 and Appendix F 14 Potential mitigation measures Appendix F 15 Company Communications Plan Section 3 16 Company management structure Section Arrangements for data exchange with Agency Section Post Drought Review and reporting arrangements Section

13 2 Business as usual Planning for drought in the context of our business This section describes in general terms, the background and basis to drought planning in our Company, how this is organised and how it links in to daily operations, strategic planning, and contingency planning. Drought Planning is not seen as something that is only undertaken when water resources begin to deplete after a period of below average rainfall. On the contrary, our approach to business as usual encompasses drought preparedness, and this extends beyond the day by day operational objectives to external communications, media and customer awareness, and strategic water resource planning. This section therefore describes these processes and how they link into our drought planning activities. 2.1 The drought zones In many respects our approach to drought management is on a regional basis, particularly in our external communications campaign and demand management activities. These will have common threads in which ever part of our area they are deployed, these are discussed in greater detail in Appendix B. However, the operation of the sources needs to be managed on a more local basis, and for this purpose, our area has been divided into nine drought zones. The geographic delineation of each zone has been done in such a way as to allow an early indication of likely drought problems to be recognised as they develop, and hence instigate the drought management process. In terms of numbers of zones this is the same as in the Drought Plan of 2003, but in this Plan we have adopted a new zone based on the Ladderedge system in North Staffordshire, and merged the Bishops Castle zone back into the Severn zone. The zones used in the 2003 Plan are shown on Map 1 below. 13

14 The new zones for this Plan are shown on Map 2. The reasons for the changes to the zone configuration are discussed in section 5.3. To alert us to the onset of a potential drought situation, we have adopted strategic raw water reservoir storage as the direct indicator and trigger. This is our main indicator of the onset of a drought. Based on this, triggers have been identified for each zone that is linked to the major strategic storage reservoirs and certain resource rivers. This is discussed in more detail in Section 4.1 Recognising a Drought. As each trigger is met and crossed a predefined set of management actions are instigated. The details of these are discussed in greater detail in the body of this Plan. These actions and triggers are not necessarily exclusive to a particular zone, and indeed the smaller zones that have no discrete storage reservoir within their boundary share triggers with the larger adjacent zones that contains such a reservoir. This gives us the flexibility to manage a drought in a consistent and realistic manner across our whole area. Nevertheless, the actions we can deploy during a drought may vary with each zone depending on the zones topography, customer base and geographic extent. As a particular zone is served by a discrete group of sources and/or bulk supplies, the frequency that mitigation actions will be required is also peculiar to that zone. In some cases, there may be the opportunity for transfers between one drought zone and another and therefore some commonality of actions and the frequency of application will exist. Furthermore, we may consider that we can restrict demand management actions (particularly hose 14

15 pipe bans) to one specific drought supply zone. Indeed we will strive to minimise the impact of these measures on our customer base. On the other hand, it may be necessary or indeed sensible to extend such restrictions to a wider area to make our drought management actions more effective. We believe that we must reserve our right of choice in where we apply supply restrictions if we are to minimise the risk of widespread supply failure due to drought. It is worth discussing here why we have a different configuration of Drought Management Zones to Strategic Water Resource Planning Zones. In the 2009 Water Resources Management Plan, our area is divided into six Strategic Water Resource Planning Zones, which compares to nine Drought Management Zones in this Plan. Whilst strategic water resource planning and drought management have the same ultimate objective of providing adequate water supplies to our customers, the timescales involved and spacial extent of the planning processes that are used in either activity are significantly different. Long term strategic resource planning is concerned with maintaining adequate headroom between the water available for supply, and customer demand for a specific demand scenario (usually the dry season demand). This is not necessarily drought period demand, when abnormal variations in demand patterns can occur for a range of reasons, Furthermore, the yields of the sources in the zones that make up the sustainable water available for use in strategic planning terms is not equivalent to the yield available during drought periods. Additionally, droughts tend to impact on more localised systems, and the resolution of drought supply problems tends to be more locally based. The combination of all these factors can produce differences in how droughts are managed and how long term water resources need to be planned, and these differences can be significant. Nevertheless, strategic water resources management is concerned with asset development that sustains or increases the water available for use into supply, in such a way that satisfactory headroom is established between demand and supply. This automatically supports drought management through the provision of adequate water resources and supply deployment capability. Hence, there is some commonality between our Strategic Water Resource Planning Zones and our Drought Management Zones and in our planning we have used drought management zones that are embedded within our water resource management zones to reflect the more localised requirements of drought management. The full list of zones in this DP is:- Stoke Ladderedge East Midlands Severn Birmingham Forest and Stroud Oswestry Vale of Powys Staffordshire and East Shropshire 15

16 These zones are shown above on Map 2. A detailed description of each zone and its susceptibility to different types of drought is given for each zone in section 5.3 Two further generic points should be noted at this stage. The first is that whilst the trigger lines for a zone give the indication of when a hosepipe ban should be issued in support of a relevant drought permit, we would apply the hosepipe ban only to those areas in the zone that are directly supplied by the controlling source, i.e. zonalwide hosepipe bans will not necessarily be applied. The second generic point is that when a Drought Permit is implemented, we will continue to regularly assess the likelihood of the drought continuing to deepen to the extent that supply system failure looks increasingly likely. This is the situation when all actions to reduce demand by use of a hosepipe ban, media appeals and leakage management efforts have been exhausted, that raw water storage is approaching the emergency level and the risk of complete failure of a resource system is becoming increasingly likely, or in a zone where there is no controlling raw water reservoir, continued abstraction of groundwater to meet excessively high levels of demand would not only breach the conditions of our abstraction licences, but also incur a high risk of environmental damage. In these circumstances we would consider imposing a Restrictive Uses Drought Order to prohibit the use of all non-essential demand for water. Clearly, this is not an action we would implement lightly, but we would regard this as a necessary operational contingency. It should be noted that we are reviewing the constituency of both the water resource zones and drought zones that we use to manage our resources as part of the 2009 Water Resources Management Plan that was published in the spring of Any changes to the make up of the zones will be reflected in subsequent Drought Plans. 2.2 Our water resources network and its flexibility of supply We have a complex supply system and in water resources and drought planning terminology this is known as the supply side. This is based on upland reservoirs, direct river abstraction and ground water sources. Of the other areas that are not connected to the Grid, some opportunity exists to operate surface and ground water sources conjunctively. These areas are very prone to problems during droughts and solutions have been proposed in the latest Water Resources Management Plan. Ground water sources have been established largely on the Triassic Sandstone. These are the most significant units for ground water although other groups of sources are located on the Permo- Carboniferous aquifers. The main Triassic aquifers generally have good storage characteristics that do not in general show a marked or immediate reaction to a deficit of rainfall. These sources tend to remain very robust during droughts. 16

17 Despite the existence of large surface water impounding reservoirs, significant ground water developments and well-established transmission networks, a sustained and severe drought would be a major challenge to our ability to maintain supply. 2.3 Our management of demand and leakage We also operate a complex distribution system that delivers the water sourced from the strategic grid and groundwater areas to our customers. This is known as the demand side. The management of this system is based on 130 Control Groups that are centred on large treated water service reservoirs, which feed on into the Distribution Management Areas (or DMAs). The topography and hydraulic characteristics of each Control Group have a big influence on the nature of demand side options available to us to manage demand during a drought. We meet a variable demand for water over our area and this demand varies considerably with hot and dry weather. In recent years it has peaked at over 2300 ml/d during peak demand weeks. This includes estimated leakage, and therefore we see the management of this leakage as a vital part of drought planning and preparation. We therefore take very seriously, the development and implementation of best practices in leakage management. Leakage management is regarded as an everyday business as usual activity for us and not an activity that is merely introduced when water resources are stretched as in droughts. Nevertheless, when a drought threatens and it is clear that reservoir storages will reduce to extreme low levels, we will review our leakage management activity and focus those efforts in the Zones that will be most impacted by the drought. Whilst, as a matter of our routine business, we strive to meet our agreed economic level of leakage, we will concentrate our efforts within the resources we have available to us to exceed this level in the critical zones, and if possible make savings in leakage that equate to the increased supplies that a drought permit in that zone would provide us with. The following section discusses our achievements in leakage management over the last AMP period. An overview of our AMP4 leakage management success This section illustrates our efforts at reducing leakage over the current AMP period. We recognise that the optimum management of leakage is crucial to maintaining our supplies to customers in a drought and we believe our efforts as described below reflect this. This section is a brief extract from our PR09 Business Plan. For more detail and discussion, please refer to that document. 17

18 Leakage targets The table below shows the target leakage levels that we were set by OFWAT in 2005 (by Water Resources Zone) AMP4 leakage targets by Water Resource Zone (post-mle) Resource Zone AMP4 target (Ml/d) East Midlands 181 Birmingham 76 Forest and Stroud 12 Oswestry 9 Severn 162 Staffs and East 56 Shropshire Company total 496 These leakage reductions were to be achieved through a combination of: sustained levels of detection and repair activity, significant increase in the rate of mains replacements, further investment in pressure management and pressure optimisation, targeting leakage from trunk mains and service reservoirs, fixing leaks on customer supply pipes. Our AMP4 leakage performance The figure below shows leakage changes within each Water Resource Zone since the start of AMP4 (2005). DMA leakage trends since April DMA leakage Company by Resource & WRZ Leakage Zone Performance (AMP4 to date) Apr 05 to Mar 07 Ml/d Leakage rise cold winter spell in Detection & repair resources increased Leakage rise following hot summer in Detection & repair resources increased 0.00 Apr-05 Jun-05 Aug-05 Oct-05 Dec-05 Feb-06 Apr-06 Jun-06 Aug-06 Oct-06 Dec-06 Feb-07 East Midlands Elan Forest & Stroud Oswestry Severn Staffs & Telford 18

19 We have worked hard to improve the quality of our data on leakage. For example, we have increased our ability to observe and respond to short-term increases in leakage, and in summer of 2006 we recruited more leakage detection technicians and repair teams to deal with the increased in the numbers of leaks detected. We also established a Regional Leakage Action Team that meets weekly to review trends in leakage and burst volumes in order to ensure staffing levels are optimised and efforts focused in the most important areas. As a result we are now much more responsive to trends of increasing leakage. We have also adopted the use of acoustic noise logging technology in areas with access problems (e.g. city centre areas, traffic sensitive streets), and we have made improvements to our free supply pipe repair process. Hours employed in leakage detection by month Hours booked to leakag detection Apr May Jun Leakage Detection Hours Jul Aug Sep Oct Nov Dec Jan Feb Mar Month The graph above shows the increase in the numbers of staff employed in detecting leaks following the leakage increase in the summer of

20 Leak repairs undertaken Leak Repairs Leaks Repaired Apr-06 Jun-06 Aug-06 Oct-06 Dec-06 Feb-07 Apr-07 Jun-07 Aug-07 Oct-07 Dec-07 Month Company Private The graph above shows the increase in the numbers of leaks repaired since The increased numbers of repairs has been sustained at this high level. Leak repairs undertaken reported leaks Detected & Reported Leaks 3000 Leaks Repaired Apr-06 Jun-06 Aug-06 Oct-06 Dec-06 Feb-07 Apr-07 Jun-07 Aug-07 Oct-07 Dec-07 Month Detected Reported The graph above shows the trends in the numbers of repairs of detected and customer-reported leaks. The overall proportion of leaks repaired has increased since leak detection resources were increased in This is a major factor in our achievement of our JR08 leakage target. 20

21 Our Leakage management policy & practice This section outlines the core elements of our current leakage management policy. These are:- Section 19 Undertaking and the leakage action plan Since 2006 we have been committed to a legally binding Section 19 undertaking with OFWAT in which we agreed to achieve our leakage targets for the remainder of the AMP4 period. Active leakage control We monitor trends in demand over our 2844 DMAs allowing the selection of DMAs for proactive targeting of leakage, particularly areas with historically high levels of leakage. Non-DMA policy In AMP4 we have been moving towards the concept of Accountability Zones, which enable improved leakage reporting and targeting. We have also started a number of initiatives that target leakage reduction from our large diameter mains and aqueducts including; trunk main walking, to find obvious and visible leaks, flow-balancing along lengths of trunk main and service reservoirs to identify lost water and/or meter errors, aerial surveys using thermal imaging, use of the WRc SAHARA system use of Ground Penetrating Radar on service reservoirs and associated pipe-work. Service reservoir leakage monitoring continues as part of our ongoing reservoir maintenance programme. Pressure management - critical point remote logging Reducing system pressures is one of the quickest methods of reducing leakage across a wide area, and possibly decreasing burst frequency. We are currently installing continuous pressure monitors at over 4000 critical pressure points within our network. A study is in progress to use this data to identify further pressure management opportunities, in particular where cost-effective pressure reduction opportunities are identified at a sub-dma level. Remotely read pressure data have the benefit of identifying areas subject to high, low and significant swings in pressure and enable these pressures to be more proactively managed. Mains replacement Our AMP4 mains replacement programme was driven by the need to reduce burst frequency as well as to address the increasing rate of deterioration of the network. This asset renewal will reduce the future cost of detecting and repairing leaks to help achieve leakage targets. 21

22 Targeting those DMAs with a high burst frequency ensures that mains are replaced which will deliver maximum long-term leakage benefits, thus ensuring optimum return on investment. Reductions in burst frequency following mains replacement Weighted average repair rate (Number/km/year) Mains Mains ancillaries Communication pipes Stop taps / Boundary Boxes Repair Category 2 Years Pre 1 Year Pre 1 Year Post Supply pipes This graph shows reductions in burst frequency on all asset types, pre- and postmains renewals. This indicates that long-term there will be a significant and ongoing leakage saving, through reductions in actual bursts. Supply pipe leakage - repair & replacement process We have offered a subsidised or free supply pipe repair to customers since Nearly 9000 supply pipe repair and replacements were carried out since 2005 as a result of enhanced leak detection activity and working closely with customers. We believe this is now close to the number of repairs and replacements required to be undertaken every year, in order to maintain supply pipe leakage at a stable level. Numbers of supply pipe repairs and relays No. of supply pipe repairs and relays District metering and zonal investigations Our ongoing DMA improvement programme involves restructuring of DMAs to improve leakage targeting and reporting. All district meters are fitted with Cello data loggers transmit data every 24 hours allowing for increases in night-flows to be observed and leak detection staff quickly deployed. We are constantly reviewing the structure of our DMA network to ensure the optimum response to perceived changes in leakage 22

23 Large meters and accountability zones We define large meters as abstraction meters, distribution input meters, and bulk transfer meters. These measure significant volumes of water at water resource zone level, all of which contributes to our efficient operation. Our AMP4 strategy has focused on: checking these meters for accuracy, reactively replacing failed meters, implementing 47 Accountability Zones that sit between DMAs and Water Resource Zones (RZ). These Accountability Zones will be used for sub-rz water balance analysis, including trunk mains leakage. Leakage data and consumption monitors During AMP4 we have significantly increased our understanding of customer consumption (and hence leakage) by supplementing our long-standing unmeasured domestic consumption monitor (DCM) with further data collection programs including:- A household consumption monitor made up of 1000 representative properties, a domestic night-usage monitor in 70 DMAs, a supply pipe leakage monitor in 50 cul-de-sac areas. In addition, a monitor to estimate commercial night usage is being established. NETBASE NETBASE is our new water production and distribution database, and our use of it will deliver the following enhancements to our leakage management processes:- visual representation of the network hierarchy, monitoring and reporting on leakage levels across our area, support for targeting leakage, visibility of anomalous leakage in DMAs, improved understanding of the pressure-leakage relationship. To conclude With all these advances in technology and leakage management processes we believe that we have much better control of our leakage management activity. 23

24 2.4 Levels of service, and ensuring they can be met despite a drought Our declared objective is to meet all its customers needs at all times. Nevertheless, the nature of droughts as natural phenomena means that the duration and depth of a period of rainfall deficit creates the possibility that there will be occasional droughts when supplies will be so restricted that it will be necessary to impose a hosepipe ban to reduce demand. To be able to state this, we have developed a resource planning tool that allows the simulation of over 86 years of historic river flow in all its major resource rivers, and runoff to its major reservoirs. By using this it is possible to determine in how many years per century a particular level of service can be met, or how often hosepipe bans will be required. Hence, by using this statistical analytical approach, we can say with some confidence that the resource system will meet current levels of demand in all years with the exception of around 2 or 3 summers per century. During those summers, when we cannot meet demand, a hose-pipe ban will be necessary, and this is our declared level of service in its 2009 Water Resources Management Plan. It must be noted however, that the effects of climate change is not built in to this analysis. We will follow any guidance that the Agency may give, on how to accommodate the impact of climate change into the development of future Drought Plans. A key factor when planning operations to achieve this level of service is to operate in such a manner as to start to control the risks of a resource shortfall long before actual drought conditions occur. To do this we have developed a series of control curves at all our major reservoirs, which progressively reduces output from the reservoir as storage reduces, whilst increasing output from an alternative source such as a river abstraction that can still operate within its statutory abstraction licence. The timing of any action defined by this approach has been built into the simulation process so that in reality there is time for us to deploy an action and assess its impact. This is possible as the simulation model works using one day time steps. For example, it has been assumed in the simulation that a hosepipe ban will be applied after seven days notice to the customers, and a drought permit will take 28 days to process by the Agency. A typical control rule graph is shown below and contains up to five lines that define a change of action as each line is crossed as storage reduces. 24

25 Derwent Valley Reservoirs Drought Control Lines Flood drawdown Simulated % full Flood drawdown Lift restrictions Storage Alert Line Drought Warning Trigger Consider HB & Apply for summer DP Implement Summer and Winter DP Apply for winter DP Emergency level Dead water level Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec When storage is above the storage alert line, the normal output from the reservoir is possible. As storage crosses the storage alert line, the first actions start to take place. All Senior Managers involved in water supply and distribution, leakage management and customer and media relations, will be alerted to the increasing likelihood of the onset of a drought. We will also appraise the Agency of the situation. As storage reduces further the next line to be crossed is the Drought Warning Trigger. At this point the pre-determined drought actions are instigated. These are listed in the individual sections for each reservoir system. It is at this point that the Drought Action Team would be first convened and increased drought liaison with the Agency would commence. As storage reduces further the next control line to be crossed would be to impose the hosepipe ban and apply for Drought Permit Line. In deriving this line on each control rule graph it was assumed that a hosepipe ban would be applied after seven days notice, and that a Drought Permit would be applicable after 28 days. By simulating the operation of each reservoir using our 86 year database, the configuration of each control rule graph can be optimised to ensure that the frequency of crossing the Impose Hosepipe Ban line is on average three times per century. At this stage we would also seek a Drought Permit from the Agency to vary either our licensed abstraction or compensation release requirements. Part of the new features in this DP is therefore a list of sites where we will seek Drought Permits if necessary. We have identified six such sites around our area and the details are given in the individual sections below. These actions relate to the supply side. On the demand side, we understand quite clearly that to obtain such powers from the Agency to manage the supply side, it will have had to have taken action on the demand side such as the imposition of a hose 25

26 pipe ban in the relevant supply area, and hence delivered the associated demand savings such a ban creates. Additional demand side measures that we could introduce would be to reduce leakage during a drought by pressure management. Clearly this would have to be carefully managed to avoid DG2 service level problems and close monitoring of the distribution system would play a significant part in this. Nevertheless, we are committed to maintain a high level of customer service whatever the weather conditions. 2.5 Alignment between the DP and the our Hot Weather Plans Hot weather and the increased demand it brings can happen in any year whether a drought year or not. We have prepared Hot Weather Plans to ensure local peak demands can be met. However, it is important that this Drought Plan is complemented by these Hot Weather Plans so that when peak weeks occur in droughts, they are managed appropriately. The Distribution Department of our Water Services Directorate has Hot Weather Plans for the nine county areas. These plans were updated in April 2006, and were originally devised to ensure consistent and effective management of water supply and distribution throughout our area at times of high demand during hot weather. For each area, expert teams will carry out specific tasks during a sustained and developing hot weather situation when the distribution system becomes more stressed than normal. These activities will include:- monitoring of demands and taking particular note of trends, maintaining up to date records of plant availability, e.g. booster pumps, identifying distribution hot spots, logging customer problems - loss of supply or poor pressure, recording outstanding bursts, liaison with rehabilitation contractors, reviewing mains pressures against DG2 triggers, reviewing levels of unaccounted for water, monitoring of service reservoir storage, and hydraulic model analysis to aid optimisation. Additional activities may include: increasing leakage detection, enhanced speed of response to leakage repairs, adjustment of system pressures, adjustment of booster pumping regimes, increase of pressure control by fitting additional devices, suspension of flushing and mains rehabilitation activities, tankering support, 26

27 appeals to customers for conservation by leafleting or media statements, requests to local authorities to conserve water, e.g. street cleaning, parks watering. There is commonality between the problems arising during a long term resources drought and shorter period peak demands. The Drought Action Team will ensure a co-ordinated response during peak periods that occur in designated droughts. The demand savings accrued from this activity are not large and much care is necessary in making the adjustments to maintain adequate pressures for customers. 2.6 Alignment with the 2009 Water Resources Plan In Spring 2009 we submitted our Water Resources Management Plan to OFWAT in preparation for the 2010 Periodic Review. Whilst that Plan deals with the planning of our long term strategic water resources requirements, it is important that there is consistency between it and the DP particularly in terms of our production capacity, deployability and levels of customer service. There is however, one basic difference between the 2009 Water Resources Management Plan and this DP, and that is the number of management zones. The 2009 Water Resources Management Plan deals with our area in 6 zones as shown on Map 3. In simple terms, the Water Resources Plan (WRP) gives details about how we will meet the projected demand for water over the planning horizon to 2035, with adequate headroom or spare production capacity to allow for such contingencies as 27

28 lost capacity through outage and uncertainty in the demand forecasting process. In the WRP our area is divided into six water resources zones and the deployable output for each of these zones is evaluated using the same simulation process as was used to define the operating curves for the major reservoirs that is described in section 2.4 above. In terms of deployable output the same values for all sources and major zones applies to both the Water Resources Plan and this DP. In terms of levels of service the WRP assumes dry weather demands similar to those experienced in drought, and that the frequency of hosepipe bans will be no more than 3 times per century. As the WRP is put into action over the next 25 years, and the proposed resource development schemes materialise, the changes these make to our resilience to drought will be reflected in subsequent DP updates. 2.7 The use of drought permits Section 79a of the Water Resources Act 1991, later amended by the 1995 Environment Act, introduced an alternative drought management tool in the form of a Drought Permit. This is a legal process by which the Agency can grant a water company a temporary abstraction permit, a variation to an existing abstraction licence or a variation to a compensation requirement, to enable us to continue providing water for public consumption. A drought permit will normally be in force for a maximum period of six months, but those six months can start at any time of the year. However, it is an understanding between the Agency and all water companies that a drought permit, starting in early summer, must be accompanied by a reduction in customer demand through demand management measures that include a hosepipe ban. We also accept that we must demonstrate that our leakage management efforts have achieved the targets set by our regulators and that we are prepared to sustain and, in fact, increase these efforts during the period of the hosepipe ban. This point was specifically made by DEFRA in its Drought Direction to us, and we intend to comply with this requirement. The alternative is a winter drought permit, and these are in some ways preferable as they are potentially less detrimental to the environment. Additionally, winter drought permits, whilst still requiring to be supported by all demand management options available to us; do not necessarily require a hosepipe ban. This is because such a measure during winter is unlikely to deliver any significant extra demand savings. Nevertheless, we recognise that there may be circumstances when it may be relevant to impose a hosepipe ban during a winter period to support a winter drought permit, and we will give this due consideration in the context of the prevailing situation. We would stress though, that we do not presume the implementation of a hosepipe ban during either summer or winter will guarantee a drought permit is granted. Therefore in preparing this DP, it has been our overriding objective to limit Drought Permit applications where possible to those that enable winter refill. In this way the 28

29 impact on the environment will be minimised, and levels of customer service will not be compromised. Nevertheless, where a summer drought permit cannot be avoided, we will introduce a hosepipe ban in the area supplied by the source or sources affected by the Drought Permit. Greater detail of how the hosepipe bans and other efficiency measures will be deployed, are given in the following sections. A prerequisite of obtaining drought permits is to identify in this plan the locations where such powers will be sought should a drought arise. We have identified six locations where Drought Permits will be requested. The Derwent Valley Reservoirs where a cut in compensation will be requested. The River Derwent at Ambergate where a variation to the prescribed flow at Derby will be requested to allow greater winter refill of Carsington Reservoir. The Tittesworth Reservoir and River Churnet conjunctive use area, where a variation to the compensation requirements from Tittesworth Reservoir and Deep Haye Valley will be requested, along with a variation to the Leek Groundwater Unit abstraction licences. This will assist the refill of Tittesworth Reservoir. The River Wye at Wyelands where a variation to the abstraction restrictions is requested. This will allow greater support from the River Wye to the Lower Severn and Forest of Dean supply areas. The River Severn at Trimpley where a variation to the abstraction restrictions during maximum regulation of the River Severn is requested. This will allow greater conjunctive use of the River Severn and River Wye systems especially when storage in the Elan Valley Reservoirs is low. The River Leam at Leamington and the River Avon at Stareton, where a variation to the prescribed flows will be requested to assist the refill of Draycote Reservoir. Having identified these sites, it is a prerequisite condition that the likely impact of these temporary variations will have on the environment must be assessed. The Agency has greatly assisted us by making available a considerable amount of ecological and water quality data for the rivers where these variations will be sought. We have in turn, appointed environmental consultants to undertake desk study assessments of the likely impact of the changed conditions. The Consultants reports will be available with the Final DP when it is published. An additional requirement is that we will undertake routine background monitoring of these rivers both before and during a drought. This will allow the actual impact to be determined during real drought conditions. Part of the Consultants brief is to identify an adequate back ground monitoring program, and this will be agreed with the Agency. 29

30 2.8 The use of drought orders The Water Act of 2003 also introduced a variation on the existing Drought Order. A Drought Order is now intended to give water utilities wider powers during extreme droughts that will include imposing restrictions on water use by anyone in its area including its customers, over and above a hosepipe ban. These actions can include rota cuts of mains supplies. Whilst a Drought Permit can be granted by the Agency, a Drought Order is granted by the Secretary of State or National Assembly for Wales. As we have declared in our WRP that we see such restrictions and reductions in service as unacceptable, we have not identified the specific need for Drought Orders. Nevertheless we accept that in reality, there is always the likelihood of a drought occurring that is severe enough to cause storage to fall to the emergency levels in our reservoirs. It is estimated that a drought of this severity has a return period of greater than once in 200 years or a likelihood of less than 0.05% in any one year. During such a drought, if storage continued to fall despite all the demand reduction measures introduced by us, and increased resources made available by the designated drought permits, then we would consider introducing a restrictive uses Drought Order on our customers. It should be pointed out that this would not be an Emergency Drought Order. In our interpretation, emergency drought orders cover situations where the economic and social well being of our customers is threatened by an exceptional and severe shortage of rainfall. In these circumstances we would take all necessary steps within the powers we have to preserve supplies to our customers. Obviously, this would be done with the full knowledge and co-operation of all stakeholders, especially the EA. Definitive trigger lines that would instigate this procedure are not shown on the control graphs given below because in these extreme circumstances we believe that predetermined and prescriptive actions cannot be set out. A drought of this severity would have to be managed in a way that would reflect the current situation of rainfall deficit, and the demand and public awareness, if the impact of the Drought Order was to have the greatest effect. In this situation we would be monitoring the situation daily and making regular projections of future reservoir storage given likely runoff and demand. Regular and detailed liaison would be ongoing with the Agency. 2.9 The relationship to the Strategic Environmental Assessment Directive The Strategic Environmental Assessment (SEA) Directive of 2001 is intended to apply to all strategic plans that have been prepared by any Planning Authority or Utility so that the impact of the plan on the environment can be assessed before the plan is developed. The question therefore remains as to whether this DP should be subject to a SEA. The guidance issued by the Agency (dated September 2005) on the preparation of the whole DP states that the UK Government, does not consider that all water company drought plans automatically come under the SEA Directive. However, the guide recommends that, a water company is advised to assure itself that its drought plan is not subject to this Directive. 30

31 Additional and more detailed advice is given in the document Draft Practical Guide to the SEA Directive issued by the ODPM in Notwithstanding this guidance, we have undertaken its own assessment of applicability of this plan to the SEA Directive and the Habitats Directive, as was advised by the Agency. Appendix C provides a discussion on this. Based on this, it is our belief that this DP does not fall within the SEA Directive; hence, there is no need to do a formal strategic environmental assessment. However, we have commissioned the impact assessments of the Drought Permits as described in Section 2.7 above, hence any relevant information will be available for future consideration Liaison with other Water Companies and organisations We have common boundaries with seven other water companies, and Bulk Supply Agreements with five of these organisations. Detailed discussions have been held with each of these organisations on our respective Drought Plans. A brief summary is given below of the Bulk Supply Agreements we hold, with particular reference to how we will use these in a drought, followed by details of the discussions we have had with our neighbouring water companies A summary of our bulk supply agreements and their use in a drought We have Bulk Supply Agreements with our five of our neighbours detailed in the table below. Neighbouring Company Yorkshire Water Services Anglian Water Drought Zone / location East Midlands at Derwent Valley East Midlands into East Leicestershire (Market Harborough and Rutland) Basic details Yorkshire Water Services take up to 60 Ml/d of untreated water. The quantity reduces as storage in the Derwent Valley Reservoirs reduces Up to 18 Ml/d from Anglian s Wing WTW. Dwr Cymru Welsh Water United Utilities 1. Forest and Stroud from our Mitcheldean WTW 2. Birmingham Oswestry at Oswestry (Llanforda) 1. We provide DCWW with up to 9 Ml/d of treated water. This volume is supported by regulation releases from the Elan Valley. This is not usually variable in a drought 2. DCWW provide up to 356 Ml/d of untreated water to us. Up to 12 Ml/d. This agreement will terminate on 31 st March

32 South Staffordshire Severn from Hampton Loade WTW into our Wolverhampton area Average of 40.7 Ml/d (peak day of Ml/d) Liaison with Yorkshire Water Services In 1989 we entered into an agreement with Yorkshire Water Services to supply untreated water from the Derwent Valley Reservoir system to the Rivelin Reservoirs near Sheffield. The agreement provides a maximum of 21,550 Ml per year (59Ml/d) until March The amount that can be taken by both Yorkshire Water and ourselves is set in operating guidelines based on the principal that Yorkshire Water is entitled to 24.1% of the available water. The normal minimum supply rate to Yorkshire Water as set in the agreement is 35 Ml/d. However, there is provision in the agreement to modify this, and this was carried out in 1995/96 and in In the event of serious drought in our area, Yorkshire Water could assist by taking a reduced supply from the Derwent Valley Reservoirs. In operating the Derwent Valley Reservoirs, we use 5 control lines to manage the export to Yorkshire Water, taking different amounts from the reservoirs depending on the time of year and the reservoir storage. We operate the reservoirs in a similar way using control lines, and the amount we take depends on where reservoir stocks lie in relation to the storage alert line. The control lines can be seen in figure below, and they show the maximum that will be taken by either ourselves or Yorkshire Water at any time, including in a drought situation. We have agreed with Yorkshire Water that they will endeavour to reduce their minimum transfer to 15Ml/d in the lowest band (below State 5) should the nature of the drought require it. Reservoir Stocks percent full Derwent Valley Control Lines and Yields Severn Trent Storage Alert line State 1: YWS can bank surplus water States 2 and 3: YWS can use up to 5Ml/d of banked water 0.0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Shaded areas show YWS yields Line shows Severn Trent yields YWS Yields State 1, 68 Ml/d State 2, 50 Ml/d State 3, 45 Ml/d State 4, 40 Ml/d State 5, 35 Ml/d 15 Ml/d* Severn Trent Yields 185 Ml/d above 80 Ml/d below * YWS will endeavour to reduce transfer to 15Ml/d below state 5 32

33 However, Yorkshire Water would not impose demand restrictions on its customers even if we chose to enforce such restrictions in our supply area. The decision to implement restrictions in Yorkshire is triggered by Yorkshire Water s own resources. The scale, timing and duration of any reduction in supply would depend on the scale and extent of drought impacts in Severn Trent and Yorkshire. We hold routine liaison meetings with Yorkshire Water on the operation of the Derwent sources, and likely changes to the supply rules will be agreed prior to any change being made Liaison with Anglian Water We had two Bulk Supply Agreements with Anglian Water, both of which are based on the Wing WTW supply system. We have terminated what was known as the Wing 2 agreement which supplied our Whatborough Service Reservoir, with up to 30 Ml/d. However, this was not guaranteed in a drought and indeed, in a severe dry period, the supply could be withdrawn by Anglian Water. This link has in fact been severed. Nevertheless, we have agreed with Anglian Water that contact will be maintained as appropriate to consider what mutually beneficial contingency options might be available in extreme drought, and that these contingencies could include reinstatement of the link if adequate resources were available in the Wing / Rutland Water system. The other agreement we have with Anglian Water is known as Wing 1, and provides up to 18 Ml/d into the rural areas of the former county of Rutland. These do not vary with any drought management measures, and the Agreement does not stipulate that we will reflect any drought management measures that Anglian Water have to impose on its customers that are fed from their Wing WTW system. Nevertheless, in such circumstances, we will liaise closely with Anglian Water to minimise the impact on our customers whilst supporting Anglian Water s efforts to maintain supplies from the Wing WTW system Liaison with Thames Water (TW) The cross border supplies between us and TW are minor in terms of drought planning. No formal liaison has taken place with TW Liaison with Bristol Water (BW) The cross border supplies between us and Bristol Water (BW) are minor and only emergency connections. No formal drought planning liaison has taken place with BW Liaison with Dwr Cymru Welsh Water (DCWW) We met with DCWW in December 2005 to discuss how the bulk supply from our treatment works at Mitcheldean in the Forest of Dean, and the bulk supply to us from the DCWW reservoirs in the Elan Valley would be managed in a drought. DCWW 33

34 were satisfied with the proposed use of a drought permit on the Lower Wye to increase the reliability of the Mitcheldean system, and also with the proposed conjunctive use of Rivers Wye and Severn through increased drought abstraction at Trimpley. In the case of drought powers at the Elan Valley Reservoirs, it will be DCWW that will consider promoting a drought permit if such is seen as necessary. However, as the bulk of the water resource from this system is deployed in to our Birmingham Drought Zone, we would support such an application with demand management actions in this Zone Liaison with United Utilities (UU) Our bulk supply agreement with UU for a supply into Oswestry is secure until 31 st March 2010 when it terminates. On that date we will have a new source at Nescliffe near Shrewsbury to make up this loss. The variable use of Vyrnwy Reservoir that provides a bulk supply to UU has been discussed in relation to the regulation support this reservoir gives the River Severn, particularly in times of drought. This area of investigation is being considered in conjunction with the Environment Agency and, in this context, UU and ourselves have agreed to use a common database for simulation of the reservoir s operation Liaison with South Staffordshire Water We have discussed with South Staffordshire Water the use of the numerous emergency connections between ourselves. However, we place no reliance on such emergency supplies to be available for a protracted period during a drought. The way we apportion our respective shares of the joint Hampton Loade Trimpley abstraction licence would also be reviewed with SSW and the Agency. This licence allows for the transfer of the overall quantity between SSW and ourselves, and the intention would be to review our respective positions with regard to the other resources SSW have at their disposal, and our resource availability in the Severn and Birmingham Zones, and allocate the balance between Hampton Loade and Trimpley accordingly. This agreed arrangement has existed for over 15 years and has worked satisfactorily throughout this time. SSW is aware that we would seek a Drought Permit at Trimpley should the drought situation dictate such action. Nevertheless, before any Permit was sought, we would seek to maximise the water available at Trimpley WTW and the neighbouring SSW works at Hampton Loade, whilst minimising the impact on the river Liaison with other licensed water undertakings There are no other licensed water undertakings in our area. However, there are a number of privately owned supply systems e.g. Welbeck Estates in Nottinghamshire, which do not receive water supplies from us. We do not envisage that any drought actions as described in this plan will impact in any way on these private arrangements. Therefore, no contact has been made with these operators. 34

35 Inset agreements There are no inset agreements in our area Co-operation on planning development - the River Severn Modeling Association The River Severn impacts directly on the water resources available to three water companies, namely ourselves, South Staffordshire and Bristol Water, and indirectly to Dwr Cymru Welsh Water through the conjunctive use of the Wye and Severn. As all these companies have a requirement to undertake simulation modeling of their respective resource systems for both drought planning and strategic resource planning, the River Severn Modeling Association was formed. All these companies are members in conjunction with the Agency, and the objective is to use common values for deployable outputs and drought yields for all aspects of use of the river. Therefore, through this informal arrangement all member companies are aware of the intentions of the others in drought planning terms Liaison with other organisations Other than the statutory consultees (that is the Agency, OFWAT, DEFRA and National Assembly for Wales) no other organisation has been approached during the preparation of this Plan. However, during the consultation period, we contacted the stakeholders listed in Annexure 1 of the 2004 DEFRA Guidance on the Water Company Drought Plan Regulations. This list included Natural England and the Countryside Council for Wales. 35

36 3 Our drought management structure and communication and liaison plan The way we manage a drought and the way we communicate with all stakeholders is seen as being of great importance to the success of the process. This section aims to describe how this is organised and the preparations that have been made should a drought occur. 3.1 Communications within our company In the event of a drought developing, a clear management chain and line of communication is essential. Clear management is necessary so that informed decisions can be made quickly and effectively, and actions agreed and implemented. It is therefore essential that overall control of our response to a drought is managed by the Drought Action Team, and that this team forms once a drought warning trigger is crossed. The Drought Action Team is made up of Senior Managers from within the company who have expertise in water resources, water treatment, water quality and communications. These managers are supported by extensive technical expertise from within their departments. Whilst the requirement for a sound operational base is perhaps obvious, it is nonetheless vital that a clear communications route is available with our customers so that the correct messages are disseminated. Experience in past droughts has shown that a badly worded or badly timed communication can have a detrimental impact on the public s response to water undertaker s appeals for restraint in water use. We therefore have a predefined Drought Action Team. The Drought Action Team will be headed by the Director of Water Services. The structure of the Drought Action Team is shown in Table 3.1 below. Table 3.1 Drought Action Team membership DAT Member Role Chairman Director of Water Overall responsibility for managing the response to a Services drought Deputy Chairman Director of Deputise as necessary for Chairman Customer Relations Water Strategy Manager Responsible for monitoring development of drought Water Production Service Delivery Manager Distribution Service Delivery Manager Quality and Environment Manager Public Affairs Manager Distribution Asset Delivery Manager Customer Operations Service Centre Manager Responsible for operating water resources supply and treatment Responsible for network management Responsible for quality and environmental issues Responsible for managing external communications with the media and customers Responsible for the development and management of the water services asset base Responsible for all external customer communications 36

37 The Drought Action Team will decide on the progression of actions and measures to be made in line with this Drought Plan, and the setting of responsibility and frequency for extensive data monitoring and reporting, inline with the consultants reports on the impact assessments. Clear briefings will be prepared for all customer service staff to ensure appropriate messages and advice is communicated to customers. The Drought Action Team will decide on the content and method of such communication, by leafleting or mailed letters or radio and/or television and/or press publicity and/or by updating the Company s web page. Close liaison will be needed with operational managers and operators to ensure the plans are appropriately implemented, licence use is optimised and monitored, and any production shortfalls are immediately reported. 3.2 Communication with the Agency and Drought Action Team (DAT) activity If a storage alert line is crossed, our operations managers will be informed and kept appraised. If a Drought Warning line is crossed, then the DAT will be convened. One of the first actions of this group will be to contact the Agency to inform them of the situation. The DAT will instigate and oversee a number of special activities within our company, all of which are aimed at managing the ensuing drought. A primary activity will be a greater level of monitoring and reporting of the situation, followed by regular (fortnightly) likelihood analyses to attempt to quantify the severity of the developing drought. This will include scenario testing using simulation modelling to define the likelihood of storage reducing further to the Drought Action line. The DAT will use this iterative process to decide the actions they wish to pursue from the lists on the demand and supply side option tables. Regular contact will be maintained with the Agency, by telephone, or formal meeting for the duration of the drought, so that both parties are aware of the measures that each is taking. The exception to this procedure is in the Severn zone where the Agency has the primary responsibility for management of the river. When a drought cessation line is crossed the DAT will decide whether the situation can revert to normal operations. The Agency will be fully appraised of this situation Alignment with the Agency s River Severn DP We have been in close liaison with the Agency whilst it has developed its own control rules for the River Severn. As we said in our 2003 DP, there is no benefit in developing a parallel set of control rules for our sources which abstract from the River Severn. We accept the principles outlined in the Agency s Draft River Severn DP. However, as stated above, we have identified Trimpley as a site where a Drought Permit will be requested, therefore close liaison with the Agency will be required to avoid any conflicts that this might create. We will also liaise closely with South Staffordshire Water to ensure the full and optimal use is made of the resources available at Hampton Loade. 37

38 3.3 Other regulators - DEFRA, OFWAT and DWI Once the Drought Action line is crossed and a hosepipe ban imposed, there will be a need to send regular briefing statements to DEFRA and OFWAT. The DWI will also be contacted if drinking water standards are likely to be compromised. All such communications will be approved by the DAT. 3.4 Other external bodies The situation will be reported regularly to WaterUK particularly if the rest of the UK Water Utilities are suffering similar drought problems. It is important that any reporting of the National situation is co-ordinated by WaterUK and presented in a consistent manner in the national news media. Similarly, there will be the need to involve other external bodies if supplies are under extreme risk. For example, if tankering to outlying areas becomes necessary, the police and county highways departments may be asked to advise. Contact will also be made with the Regional Civil Contingency Groups to ensure full public awareness of the situation We have prepared and maintain comprehensive lists of direct contact points with responsible bodies such as the Regulators, MAFF, Health Authorities, the Drinking Water Inspectorate, the Police (via RAYNET), Local Authorities and adjoining water companies. 3.5 The news media Good communications in a drought are essential to successful drought management. Communication with the news media will be managed by the Public Affairs Manager under the guidance of the DAT. Media messages before and during a drought need to achieve the following: assure customers that their contribution to water efficiency is worthwhile; explain to customers how they can easily save water; and assure customers that we are managing water resources wisely. The media plan for any drought should be clear, but not over-prescriptive, so that any media messages can be tailored to meet the situation at the time. It is essential that all media messages should be timely and relevant if any impact is to be achieved. An outline framework is given below but this will be varied at the discretion of our DAT. 38

39 Level 1 Level 2 Level 3 Definition and likely activity level Ongoing and current water efficiency promotional activity on ad hoc basis, building on the water efficiency plan as agreed with OFWAT in the last Periodic Review. Includes standard marketing of Save-a-flushes Water butts and other products (e.g. shower heads, timers) Guide to saving water (print and web) Education activity Opportunistic media and PR More specific focus on promoting water efficiency through regional media, exploiting existing relationships, and creation of newsworthy opportunities. It is envisaged that this level will start if the fortnightly projection shows a high likelihood of a continued fall in storage. Creating specific media opportunities to raise awareness of the issue and saving water. Sell-in water resource stories Advertise leakline via van, web and PR Demonstrate our own work on finding and fixing leaks Frost awareness PR and web soft water efficiency stories enlist help of Waterwise and WaterUK communications team to broaden message This will be factual and use supporting media stories about water efficiency. Specific water efficiency campaign which could include paid for elements. This includes promotions, features and possible reference to previous campaigns. It is envisaged that this level will be reached in the one or two weeks prior to the likely imposition of a hosepipe ban. Increased activity e.g. save-a-flush or product giveaways via local press and radio Increased media activity e.g. water butts and gardening advice Higher visible profile of water saving on the web site Press features on water resources activity, summarising how we plan for dry spells and how customers can help Water efficiency adverts in newspapers Formal media appeals to conserve water Possible sponsorship of weather section in print media Participate in any joint national media campaigns on water efficiency One to one media briefings Trigger None DAT sitting DAT decision 39

40 Level 4 This will be factual with an increased focus on issues such as visible leakage and any emerging environmental concerns. More formal daily or weekly updates on the supply situation. It is likely that at this point there would be national coverage of the issue, relating to a countrywide problem as level three but also: probably a higher reactive content as issues require a national focus, regular weekly or daily updates on resources position, drought updates regular Company-led media briefings, broadcast advertising with appeals for water saving, withdrawal from some softer approaches to avoid potential criticism, ensure possible critics such as the EA, Consumer Council for Water and Natural England operate no surprises policy in relation to their media statements. This will be more critical with leakage, a high profile issue. The environmental consequences of restrictions will feature more strongly. Restrictions imminent or in place The Water Efficiency Plan Following the completion of two large scale water efficiency trials in 2008 we reviewed and updated our water efficiency strategy. We identified a number of improvements and additional activities and have restructured our work programme to facilitate delivery of the increased levels of activity identified. There are two methods by which we can deliver water efficiency savings, the first is influencing customers behaviour, and the second is through installation of equipment that delivers savings without a requirement for behavioural change. The resulting reward may be financial for measured customers (or customers reducing water heating and pumping costs) or non financial for unmeasured customers (environmental consciousness). Our strategy is based upon three work streams: 1. General promotion and awareness (including product promotion) 2. Proactive Consultancy and Advice a. Domestic (Social Housing) b. Non Domestic 0 to 20 Ml/year c. Non Domestic >20Ml/year 3. Property Developers and product manufacturers This strategy builds on current initiatives and is focused on those areas where we have the greatest need to deliver reduction and where efficiencies are likely to be most easily achieved. Streams 2c and 3 are new activities designed to fill the knowledge gap. 40

41 During periods of drought the primary focus would be on an increase in the level of activity around work stream 1, general promotion and awareness. Teaching water efficiency Our extensive education programme entered its sixteenth year in 2008 and remains as popular as ever with pupils both young and old. The objective of the education programme is to provide a focused learning environment which promotes understanding of the importance of water and the need for efficient use of water resources. There are three key elements to the education programme: Classroom based learning, the Be Smart Award Programme and Teaching resources. The Be Smart award is designed to be directly relevant to the National Curriculum, and also meets the increasing need in schools to address issues of sustainability. 18 schools in our region have been awarded the Be Smart award for planning and carrying out action in four areas, including auditing the school s water use and promoting water conservation. To support the be smart award and other aspects of teaching water in schools, a new teaching pack has been developed in partnership with Tide (Teachers in Development Education) and DFID. Water Issues - Local and Global includes a photo pack and a teachers guide which supports the teaching of water with a very strong emphasis on the issues of sustainable development. Initial feedback is extremely positive. The Be Smart programme challenges schools to: audit the schools water use, promote water conservation, promote the positive health benefits of drinking water, and promote greater understanding of water issues locally & globally. Each school that registers to take part in the scheme is offered a Severn Trent mentor, a member of our staff who will go into the school to support the school in achieving the award. In 2005, 76 people were trained as Be Smart mentors. Through the enhancement of this project to include accurate data monitoring and research, assessment can be made of measurable benefits delivered through this scheme. We continue to distribute the Waterwise CD-ROM specially designed as a teaching aid for school teachers for children up to the age of 11. It raises awareness and increases understanding of the environmental importance of human water usage. In the home One of the key activities to promote water efficiency in the home is the distribution of save-a-flush devices. We distribute around 150,000 of these devices each year. We continue to distribute Your guide to saving water which provides a range of practical water efficiency tips for both inside, and outside the home. All customers have been offered the chance to request this via main billing promotions and our website. 41

42 Included in the guide is a water use self audit, which is also available as an on-line calculator to help people assess their water use. In 2008 we introduced additional product promotions including water efficient shower heads and shower timers to help encourage consumers to use water wisely. In the garden Our Customer Billing Booklet offers customers the opportunity to purchase a discounted water butt kit. The kit includes a water butt, stand, diverter and child proof lids. Although during prolonged dry periods it is unlikely that the water butts would be effective, they do contribute to water savings when in use and are useful method to raise awareness of the continued need for water efficiency. Our publication Your Guide to Saving Water is provided free to customers, and contains information on water efficiency measures in the home and the garden, giving advice on many aspects of gardening including plant selection and mulching. For businesses We consider encouraging efficiency within the non domestic sector to be an essential component of our activity. In 2007 and 2008 we have partnered with Envirowise to promote water efficiency best practice to businesses in our region. We are currently promoting the Rippleffect, an online programme to encourage non domestic customers to adopt water efficiency measures. For institutional premises we also undertook a trail involving the installation of efficient products. In 2008 we are now extending this programme to deliver a further 600 audits and installations by March Publicising the efficiency savings and financial savings for the institutions involved will help promote the message of water efficiency and could be used to encourage businesses to undertake additional efficiency measures during drought periods. 3.6 Appeals for water efficiency to the public When drought conditions begin to have significant widespread impact on our ability to provide continuous supplies to our customers, the DAT will initiate appeals for water efficiency by customers. The messages that we will issue will include: use showers instead of taking baths, 40 litres instead of 100 litres, challenge yourself to reduce your shower time by 1 minute maybe even take a 4 minute shower do not leave the tap running whilst cleaning your teeth, repair dripping taps and faulty cistern valves, water plants in the evening and apply compost or mulch to retain moisture, fill kettles only with the water you require, use economy settings on washing machines, select water efficient washing machines and dishwashers when buying new, look at the label, 42

43 make sure you use dishwashers and washing machines with full loads. To ensure that these messages and actions are targeted in the most effective way, we have collected local demand data at sub-daily time intervals over a number of years. From this, valuable information has become apparent, some examples are shown below. In summer 1995, peak demands in local networks tended to occur at 9 o clock in the evening, and this was assumed to be associated with use of sprinklers and hose pipes for garden watering. For small areas of mainly detached houses the ratio of peak flow rates to mean daily flow was over 7 to 1. For small areas of terraced and semi-detached properties the ratio was 3.6 to 1. For a mixed suburban area of properties, the ratio was 2.56 to 1. Nationally, customer awareness campaigns during 2006 demonstrated the benefits of media awareness campaigns in reducing total demand, despite no restrictions on use in our region. One of the most effective ways of reducing peak demands is to reduce dependence upon the public water supply by gardeners. This can be achieved through encouraging alternative practices. 43

44 4 The drought management process This section looks in detail of how we have developed a management process to recognise a developing drought situation, and then progressively deploy actions that are aimed at ensuring customer service is maintained as the resource deficit builds up. 4.1 Recognising a drought situation - triggers for action and incremental measures There are a number of indications that a drought period is developing. The first is rainfall deficit, particularly long term three month averages. These are available from the Met Office for any catchment or supply area and show when a long term trend in rainfall is below average. This linked to soil moisture deficit is a very good indication that a drought may be building up. However, short term respites from long term trends may mean that all raw water reservoirs are replenished during a wet spell in winter, and hence dry though the weather may be, we have sufficient water reserves to sustain supplies. The second indication is falling ground water levels. These tend to be long term and are influenced by more factors than simply a deficit in rainfall. As it is, our groundwater network is so designed that its production wells are generally into deep aquifers that are not immediately affected by a rainfall deficit. The third indication of a drought is river flow. This is indeed an indication of dry weather particularly later in a summer. However, our resource rivers are, with only one exception, supported by impounding or pumped fill reservoirs. It is because of this that our operations can generally survive a short sharp drought (e.g. 2003) when river flow is markedly reduced. Whilst the three indicators listed above are regarded as a source of supporting evidence of a drought, in operational terms we use reservoir storage as the basis of drought recognition. The monitoring and management of our reservoir storage is a fundamental necessity to us in providing continuous supplies of water to our customers. Hence, its careful management is essential if we are to meet these commitments. We therefore regard the variation in reservoir storage as the fundamental measure of any drought situation. For each zone there are a number of triggers that are linked to the storage in key reservoirs, and they are intended to alert us to the increasing likelihood of a storage deficit or drought. From these, the drought management actions that are described in the particular section for each zone in Appendix B are instigated. The triggers have been designed to allow sufficient time to phase in a series of measures that seek to make additional resources available or manage demand through customer involvement in increased water efficiency drives to reduce any unnecessary use of water. In establishing this process, it is important to recognise that setting trigger points at too low or too conservative points such that they are crossed every other year, will lose the public s support. As we say in the section on the media campaign, 44

45 a carefully developed and managed relationship with customers and public is essential. As is shown on Table 4.1, all the Drought Zones have primary triggers that are linked to key surface storage reservoirs. These reservoirs are usually within the particular zone, but two of the Zones (i.e. Oswestry and Vale of Powys); do not have such a reservoir within their boundaries to provide the triggers for actions. In these cases, the triggers are linked to storage reservoirs in adjacent zones. This is to enable us to have the option to manage our media campaign and any supply restrictions in a consistent way across our wider area. These may include a Company-wide hose pipe ban if such is seen as necessary, even though a particular zone is not under immediate threat of drought. Some sources, such as the Elan Reservoirs and the River Dove, have controls built into the abstraction licence. Here, the warning lines can shadow the licence controls to give an early warning of when the changes to operations must be applied. For other sources, the new lines have been created and tested using the simulation program Aquator to determine the likely frequency that they would be crossed. A list of the triggers are shown on Table 4.1 and listed for reach zone in Appendix B. Table 4.1 Drought triggers by zone Drought Zone Primary Trigger(s) Secondary Trigger Ladderedge Tittesworth Reservoir Storage East Midlands Derwent Valley and Carsington- Ogston Reservoirs storage Dove reservoirs storage Severn Clywedog Reservoir storage and / or Draycote Reservoir storage Birmingham Elan Reservoir storage Forest and Stroud Elan Reservoir storage and flow in River Wye at Redbrook Oswestry Clywedog Reservoir storage Vale of Powys Clywedog Reservoir storage Stoke Tittesworth Reservoir Storage Stafford and Telford Clywedog Reservoir storage The crossing of any storage alert trigger is one indication that a dry period may be building up and this hence heralds the need for more frequent reviews of the developing situation and wider general awareness within our Company of the possibility of a drought. However, once a drought alert trigger on any reservoir control curve is crossed, the convening of the Drought Action Team is instigated. This is made up of senior managers and key staff. The Team will assess the risk, and the options available to mitigate this risk, and liaise with the Agency and other water companies as required. The team will then manage the progressive implementation of actions from the list of measures for each zone which are included in Appendix B. Any further actions which present themselves that may not have been identified at this stage will also be considered by the team. 45

46 The phasing and the timing for the introduction of these measures will depend on the severity of the drought and the relative success or otherwise of prior actions. We believe it is difficult and largely unnecessary to develop rules to mechanistically control the timing of every individual action. Our intention is to carry out regular liaison and situation appraisal such that timely and relevant actions can be instigated. In this way, the Agency and other key stakeholders can be reassured that the situation is being dealt with seriously and appropriately. We believe that even in the most severe drought that we have time to recognise and act on a developing situation. An analysis of the time between the crossing of the drought alert lines and seek drought permit lines for our key reservoirs during the significant droughts on record was undertaken. To do this, Aquator model simulations were undertaken for the period from 1920 to 1996 for the Elan Valley, Clywedog, Derwent Valley and Draycote Reservoirs. These simulations tested the time between crossing the control curves that prompt consideration of applying a hosepipe ban and the actual implementation of the ban. For Tittesworth Reservoir the time lags were taken from actual recent droughts as these are considered to be more realistic than simulated events The results are shown below in column 4 in terms of the number of days between both crossings both control lines Reservoir Crosses consider Hosepipe ban curve Crosses apply Hosepipe ban curve Lag in days Elan Valley 29/06/ /09/ /05/ /08/ /07/ /08/ /07/ /08/ Clywedog 23/07/ /08/ Derwent Valley 04/09/ /11/ Lag in days (dry change scenario) 31/08/ /09/ /02/ /02/ /09/ /09/ /10/ /11/ /10/ /11/ Draycote 05/01/ /02/ /10/ /10/ /01/ /02/ Tittesworth 19/10/ /11/ Not assessed 21/03/ /04/ Not assessed Whilst there is some variation in the period between instigation and application of the hosepipe ban process, this analysis shows that in general we have between at 46

47 minimum of 15 to 20 days to act. In some of these examples we would have between 5 and 12 weeks. Based on this and on previous experiences in droughts we believe we can mobilise ourselves to take all necessary action needed to manage a drought. A note on climate change It may be relevant at this stage to include a short look at the impact that climate change might have on this assessment of the time we have available to respond. Whilst current research suggests that the impact of climate change will take a number of decades to become apparent, we are infact planning for climate change in our Water Resources Management Plan that looks 25 years ahead. In doing this we have followed a prescribed method that in its simplest form adjusts the 86 years of flow data that we do our resource simulations with, by factors that create a revised dataset for two change scenarios. The first is a wet scenario, which may occur if we move into a milder and damper climate. The second scenario suggests that the climate will become warmer and drier. We have repeated the assessment of how much time there will be between the significant drought action lines for the dry climate change scenario. This was done for all the reservoirs except Tittesworth (the Tittesworth entry on the table is actual data, not simulated). The results are shown in column 5 on the table above. There is clearly some variation in the results and not all droughts are apparent in both normal climate and dry climate scenarios. Nevertheless, where comparison between the two scenarios is possible, the results show a significantly reduced lag time, which is to be expected. This enforces the need to be able to respond quickly and effectively to droughts especially when actions involve the agreement and co-operation with our regulators and other stakeholders. Other impacts of climate change and more severe droughts There are other significant influences on drought management that will occur with climate change, the principal one being customer s use of water (i.e. the behavioural aspects). This could easily have a highly significant influence on our ability to manage droughts in future years, but we have not so far undertaken any research into this. We realise and accept that customer restrictions will be necessary in droughts that have a likelihood of occurrence that is less than the declared level of service of three hosepipe bans per century. It is envisaged that in these droughts the storage in the key reservoirs will approach the emergency levels, and there is an increasing possibility of system failure. In these circumstances we will take appropriate actions which may include the banning of non-essential uses of water. 4.2 Drought scenarios - base positions for demands, source outputs and raw water storage The water resources that we have at our disposal are divided almost equally between surface water impounding reservoirs, run of river intakes, and groundwater. As the majority of the groundwater is abstracted from substantial Sherwood 47

48 sandstone aquifers, the resilience of this component of the overall resource to drought is relatively high. Whilst low rainfall periods may result in short-term reductions in groundwater levels, we do not experience the groundwater droughts that are experienced in, for example, the South East of the UK where the Chalk aquifer forms the basis of the local water resources. In effect therefore it is only surface water droughts that threaten our ability to meet our customers demand for water. Hence, only surface water droughts were analysed in the compilation of this plan. The drought management controls and actions described in this Plan were originally developed and tested using the computer model RESSIM, and more recently Aquator. Both these simulate the operation of our supply system on 86 years of river and reservoir flows in all the major resource rivers and reservoirs in the area. This process is identical to that used to evaluate the deployable output of each zone for our Water Resources Plans. Within the 86 years of the database, a number of droughts are represented, ranging from major two season events where reservoir storage fails to reach capacity during the intervening winter, to short intense single season occurrences which were followed by a wet winter that recharges the system to capacity. The management control lines given for each reservoir were thereby optimised to ensure that our declared level of service was met throughout the whole simulation period. The use of this length of record also ensures that we can manage our resources in a wide range and durations of droughts. Whilst this range of droughts have been tested using this simulation process, e.g. single season droughts of 1959 and 2003, and double season droughts of , and , it should be noted that only the most severe drought for each zone is shown on the control charts in Appendix B. For example, in the Severn Zone this is , whilst in the East Midlands and Ladderedge, this is The frequency with which the particular control lines are crossed and hence actions are deployed is shown and discussed in Section 7. The simulation of all these droughts therefore tests the robustness of the triggers and related actions, and ensures that the declared level of service in terms of number of hosepipe bans per century is maintained. 4.3 Supply/demand balance The Drought Zones delineated in this DP are not completely isolated, and some significant movements of water are possible between certain zones. However, no specific triggers are identified for controlling these bulk supplies. Furthermore, we wish to reserve the right to move water from one zone to another at our discretion, and to base any decision to do this on the operational conditions at the time and the relative position of resources in each zone. In making such decisions, the relative success of any other measures that we have already deployed or could deploy, will be taken in to consideration. It is neither feasible nor desirable to design a single control rule to cover every eventuality that might be possible in this situation. We will however, fully discuss our operational plan with the Agency and other key stakeholders at all appropriate times through the agreed liaison process. 48

49 The water supply grid that we have developed is the greatest tool we have to allow us to cope with drought conditions. Its flexibility must be retained throughout the duration of a drought. In simple terms the grid is capable of transferring water between the East Midlands Zone, parts of the Severn Zone, parts of the Forest and Stroud Zone and the Birmingham Zone. The bulk transfers available to each zone are identified in the discussion of drought management in each zone. Hence, by using the grid to its full potential, we are confident that this will reduce to a minimum the need for either customer restrictions or drought permits that will potentially be damaging to the environment. 49

50 5 The drought management options The approach we will take as a drought develops and progresses is depicted on the Drought Progression Chart below. This is a generic representation and is intended to show the managed way a drought is observed and monitored, and actions are deployed. Greater detail of these actions is given for each Zone in Appendix B, Sections 1 to 9. However, overall, our goal is to provide a continuous and reliable supply of water to our customers in all droughts within our stated level of service. By simulating the operation of our supply system using the 86 years of resources data in our supply system model Aquator, we have satisfactorily tested a number of scenarios in our supply system, and we believe we can deliver this objective. The sections below give more details about how we believe this can be achieved. 5.1 Supply side options The Supply Side Option tables in Appendix B provided for each zone outline a wide range of options that reflect the different kinds of resources supplying each zone. However, some options are common to several zones and a brief description of these is given here. Normal operations take place within a framework that seeks to control the risk of having a resource shortfall later in the year. The safe output from the major surface reservoir systems has already been determined, but at monthly intervals, use of our water resource simulation model Aquator provides estimates of the likelihood of entering a drought sequence. Our cost optimsation model Waterman is then used to ascribe output from each source to ensure that demand is met in the most cost optimal way. The simulation of our supply system is done using these models with projections of likely rainfall, (provided by the Met Office), and likely demand for the coming period. This demand is estimated using recorded demands from our production and demand archive. If the likelihood of a marked reduction in storage is considered to be high, or if storage alert lines are crossed at any reservoir, alternative sources may be used to meet demand Increasing the use of unsupported river abstractions will then be used even in spring and early summer to reduce the rate of drawdown at surface water storage reservoirs if the likelihood of this seems to be high. A review of the schedule of maintenance works at our key sites will be carried out if a storage target line is crossed. This would seek to ensure that any reduction in capacity at a treatment works or in the distribution system caused by a capital scheme would be minimised. Imports from other zones or neighbouring water companies will be considered in order to protect resources under stress. The scope for this will depend on the relative resource position of each area. Exports from the Zone will be minimised where possible to protect resources under stress. The scope for this will depend on the relative resource position of each area. The Drought Permits identified at key locations, and listed in Section 2.7 will be considered by the Drought Action Team if any apply for drought permit lines are 50

51 crossed. If this should be during early summer, a hosepipe ban will be introduced in the supply area linked to the source if we believe realistic demand savings can be made. However, if possible, we will only apply for a drought permit to increase refilling of a reservoir during winter. We will consider not enforcing a hosepipe ban in these circumstances as such a ban would have negligible impact on demand during a winter period. Indeed, winter Drought Permits to enable refill of such as Carsington Reservoir are seen as a way of reducing the risk of needing a more damaging Drought Permit the following summer. Nevertheless, we will liaise closely with the Agency and agree whether a winter hosepipe ban is relevant to the particular situation. There are some other options specific to certain zones which are included in Appendix B. These include bulk transfers between zones where this is realistic and practical. 51

52 52

53 linked by the strategic grid, and increased imports from neighbouring water companies where this is still possible. 5.2 Demand side options The demand side options considered are generally common to every zone. These are listed here and also repeated for each Drought Zone in Section 5.3 below, and also in the DP Summary Tables and Figures in Appendix B for completeness: Demand Side Options Water efficiency campaign Distribution system pressure optimisation Increased leakage detection to achieve leakage reductions to below ELL if possible Increased metering Appeals for customer restraint and ultimately in the most severe drought conditions, hose pipe bans during periods of the year when such would have a significant impact on demand and ultimately, restrictions on non-essential use through a Drought Order. Increased leakage detection will be targeted using our leakage monitoring and management systems which are already used during periods of normal operation. 5.3 Drought zones background and drought management The following section gives a brief description of the nine drought zones that we have designated. This contains details of the sources that are particularly critical in a drought, and how these can be deployed in drought conditions through actions that we would undertake on the supply and demand side to manage a drought The Stoke drought zone Greater detail of these actions is given Appendix B, Section 1 Background The Stoke Drought Zone covers the Potteries conurbation of North Staffordshire. The drought zone is bounded to the west by the margin of the Severn catchment and to the east by the River Dove. In the Drought Plan of 2003, this zone included the Ladderedge system which serves the area around the town of Leek. However, as discussed above, the Ladderedge system is now treated as a separate drought management zone. Resources The Stoke Drought Zone is supplied predominantly by groundwater sources, supported by the Ladderedge Zone to the northeast. All of the groundwater abstractions are from the Sherwood Sandstone aquifer. These include three 53

54 sources, Tatttenhall, Tower Wood and Peckforton, which are situated outside our boundary in the River Dee catchment. Demands The Stoke Drought Zone includes the major urban demand centres of Stoke, and other small towns such as Stone in the south. Included in this zone are large parts of rural Staffordshire. Drought susceptibility The majority of the groundwater sources are unaffected by low groundwater levels caused by drought conditions. However, the output from the sources in the Spot groundwater unit is constrained by low groundwater levels Triggers The primary trigger for the drought zone is based on storage in Tittesworth Reservoir. Whilst this is a source in the Ladderedge Zone. If a Drought Permit is considered necessary to sustain the Tittesworth Reservoir output, the requirement for a hosepipe ban would almost certainly extend to the Stoke Zone. Drought management options The demand side options include:- a water efficiency campaign, targeted increased leakage reduction, increased metering, appeals for constraint in the more severe droughts, hosepipe bans in the most severe droughts, restrictions on non essential use. The supply side options include:- optimising resources and licence usage increasing imports from other resource zones reducing exports to other resource zones Drought permits There are no Drought Permits identified for this Zone The Ladderedge drought zone Greater detail of these actions is given Appendix B, Section 2 Background The Ladderedge Drought Zone covers the Staffordshire Moorlands area around the towns of Leek and Cheddleton. These are the only significant urban developments in this zone and the remainder is predominantly rural. This zone is new for this Plan and was separated from the Stoke Zone in the Drought Plan of 2003 to reflect the drought susceptibility at Tittesworth Reservoir. This is considered to be significantly different to the operational problems with the groundwater sources in the Stoke Zone which are linked to rising nitrate concentrations. 54

55 Resources The resources of this zone are split almost equally between surface and groundwater. Tittesworth Reservoir and treatment works is supported by groundwater sources at three sources which are run conjunctively in such a way that reduced output from Tittesworth during dry periods can be offset by increased groundwater abstraction. Demand The Leek area provides significant support to the Stoke Drought Zone. Demand has a significant seasonal trend due to tourism. Drought susceptibility The critical period for Tittesworth is 18 months, based on the simulated operation of the reservoir for 1995/96 inflows. Nevertheless, the reservoir is prone to single season droughts. The groundwater sources have never shown any adverse affect of drought conditions over the duration of their operation. Triggers The primary trigger for this drought zone is based on storage in Tittesworth Reservoir. As this zone provides significant support to the Stoke area any drought management actions instigated by this trigger will be reflected in the Stoke Zone. If a Drought Permit is considered necessary to sustain the Tittesworth Reservoir output, the requirement for a hosepipe ban would almost certainly extend to the Stoke area. Drought management options The demand side options include:- a water efficiency campaign, targeted increased leakage reduction, increased metering, appeals for constraint in the more severe droughts, hosepipe bans in the most severe droughts, restrictions on non essential use. The supply side options include:- optimising resources and licence usage reducing the export to the Stoke Drought zone Drought permits The only Drought Permit related to this Zone is for Tittesworth Reservoir. This would request a reduction in the compensation release from the reservoir to the River Churnet and the use of Abbey Green Borehole. 55

56 5.3.3 The East Midlands drought zone Greater detail of these actions is given Appendix B, Section 3 Background The East Midlands Drought Zone covers much of Derbyshire, Nottinghamshire and Leicestershire. Resources The East Midlands Drought Zone is supplied by a complex mixture of sources including, impounding reservoirs, pumped storage reservoirs, river abstractions and groundwater sources. The major impounding reservoirs are the Derwent Valley Reservoirs, the Dove Reservoirs which are filled from the River Dove, and Ogston and Carsington Reservoirs which are filled from the River Derwent. The bankside storage at Church Wilne is filled from the River Derwent. Church Wilne Reservoir storage can also be supported by abstractions from the River Trent. These are normally only done during drought periods when flow in the River Derwent is low and abstraction from the Lower Derwent cannot be supported by upstream reservoir storage. In Leicestershire smaller impounding reservoirs exist in Charnwood Forest. Direct river abstraction is made from the River Derwent near Derby to the nearby treatment works. The major groundwater abstractions are from the Nottinghamshire Sherwood Sandstone aquifer and from the Carboniferous Limestone. Demands The East Midlands Drought Zone supplies around 40% of Severn Trent Water s customers. This includes the major urban demand centres of Nottingham, Derby and Leicester. A significant export of water is also made to Yorkshire Water Services to supply Sheffield in South Yorkshire, and significant transfers of water can be made to the Severn Drought Zone. Drought susceptibility The critical period for the East Midlands is 18 months, based on the storage in the Derwent Valley and Carsington reservoirs during 1995/6. The critical period for the River Dove is 5 months, based on flows on the Dove during In general, the groundwater sources in this drought zone are not affected by drought conditions, particularly single season droughts. Triggers The primary triggers for the drought zone is storage in the Derwent Valley, Carsington and Ogston. These are considered to be the critical resources for the zone during a drought. A secondary trigger has been established based on storage in the Dove reservoirs. 56

57 Drought management options The drought management options for this zone are as follows: The demand side options include:- a water efficiency campaign, targeted increased leakage reduction, increased metering appeals for restraint in water use hosepipe bans restrictions on non essential use. The supply side options include:- optimising resources and licence usage increasing imports from the Severn zone reducing exports to the Severn zones and Yorkshire Water Services drought permits to preserve reservoir storage and assist winter refill. Drought warning lines have been established for the critical reservoirs in order to trigger selected operating conditions. Drought permits There are two potential drought permits which could be applied in the East Midlands Drought zone. The first relates to the Derwent Valley Reservoirs and allows a reduction in compensation release from Ladybower Reservoir. The second relates to the refilling of Carsington and Ogston, and provides greater availability of water in the Derwent at Ambergate via a partial relaxation of the prescribed flow limitations at Derby The Severn drought zone Greater detail of these actions is given Appendix B, Section 4 Background The Severn Drought Zone covers the counties of Worcestershire, Warwickshire, and parts of Gloucestershire, Shropshire and Powys, and the metropolitan area of Wolverhampton. In the Drought Plan of 2003, the area around Bishops Castle in South Shropshire was designated as a separate drought zone. However, for this Plan, it is considered that the drought planning needs of this small area can be reflected in the larger Severn Zone. The Severn Drought Zone is supplied by a complex mixture of sources including, impounding and pumped storage reservoirs, river abstractions and groundwater sources. 57

58 Draycote Reservoir is a pumped storage reservoir that supplies East Warwickshire. It can also supply parts of Coventry. It relies on abstractions from the river abstractions for its source water. A further water treatment works near Leamington has a direct river abstraction but is also supported by a direct feed from another reservoir and river releases from a reservoir upstream. In the Severn Zone, the River Severn is by far the greatest source of water. There are five major river intakes along its length. One other treatment works exists in this Zone to the north east of Birmingham. This treats water abstracted from both the Rivers Blythe and Bourne and can be supported by a transfer of mains water from the distribution system in North Birmingham. The major groundwater abstractions in the Severn Drought Zone are from the Sherwood Sandstone aquifers in Worcestershire, west of Wolverhampton, South Warwickshire, Shropshire, and Gloucestershire. Other significant abstractions are taken from the Permo-Triassic aquifer around Coventry. There are also a number of small rural sources (including boreholes, wells and springs) in Shropshire, south Worcestershire and Gloucestershire. Demands This includes the urban demand centres of Shrewsbury, Wolverhampton, Redditch, Bromsgrove, Worcester, Cheltenham, Gloucester, Coventry and Rugby. Drought susceptibility The critical period for the River Severn is 4 to 5 months, based on the limited storage in Clywedog Reservoir which is used to regulate the River Severn. In contrast, the critical period for Draycote Reservoir is 3 to 4 years, reflecting the large storage capacity relative to the typical output. In general, the Sherwood Sandstone groundwater sources in this drought zone are not affected by drought conditions, particularly single season droughts. However, the yield of some of the smaller sources (particularly the springs) will reduce in a single season drought. The critical period for these spring sources may be less than 4 to 5 months. However, information is limited to historic outputs in many cases, so an accurate critical period cannot be evaluated. The spring sources are mainly in South Worcestershire and Gloucestershire and are supported by water from Mythe WTW and Mitcheldean WTW, which is in the Forest and Stroud Zone. Triggers The Midland Region of the Environment Agency is responsible for the regulation of the River Severn and has produced a River Severn Drought Plan. The triggers for action are presented in the Agency s plan, and may invoke the need for demand reductions in the Severn Trent Area supplied from this river. We are currently liaising with the Agency to agree the best way forward to manage a drought in the highly regulated river catchment. 58

59 A Secondary trigger, the drought alert line for action has been developed for Draycote Reservoir and is based on a control curve depending on the storage in the reservoir. The state of storage in this reservoir will also trigger a drought permit that will make more water available for its refill. Drought management options The primary drought management options, relating to the regulation of the River Severn have been produced by the Environment Agency and are described in the Agency s River Severn Drought Plan. The demand side options include:- a water efficiency campaign, targeted increased leakage reduction, increased metering, appeals for restraint in water use in more severe droughts, hosepipe bans in the most severe droughts, restrictions on non essential use. The supply side options include:- optimising resources and licence usage increasing imports from the East Midlands Zone, and if feasible the Forest of Dean sources reducing exports to the East Midlands Zone, and if feasible the Forest and Stroud Zone drought permits to preserve reservoir storage and assist winter refill. Drought permits There is one drought permit identified for the Severn Zone. This is to increase the water available to refill Draycote Reservoir by a partial relaxation of the prescribed flow condition for the River Leam at Princes Drive Weir in Leamington. In addition to this, a further provision of the drought permit will make extra water available at Brownsover on the River Avon by allowing a partial relaxation of the prescribed flow on the Avon at Stareton. In addition to this, we have identified a Drought Permit which has an indirect effect on this Zone. This relates to Trimpley and our ability to support the Elan system from the River Severn during periods of full river regulation The Birmingham drought zone Greater detail of these actions is given Appendix B, Section 5 Background The Birmingham Drought Zone consists of reservoirs in Wales and the City of Birmingham and surrounding areas of the West Midlands. The two are linked by aqueduct. 59

60 Resources Birmingham is supplied from the Welsh reservoirs, the River Severn, and boreholes in Worcestershire. Certain of these boreholes can also be used to provide an emergency supply for a limited period. Demands Apart from some very small local demands in Wales and some minor exports from the drought zone, the demand centre is effectively the City of Birmingham and surrounding urban areas. Drought susceptibility The critical period for the Elan Valley reservoirs is 18 months, based on the 1975/76 inflow pattern and simulated performance for the reservoirs using 1995 demands. Triggers The primary trigger for the drought zone is based on storage in the Elan Valley reservoirs. Drought management options The demand side options include:- a water efficiency campaign, targeted increased leakage reduction, increased metering, appeals for constraint in more severe droughts, hosepipe bans in the most severe droughts, restrictions on non essential use. The supply side options include:- optimising resources and licence usage increasing imports from the River Severn at Trimpley, and the Severn Zone via the Meriden Link the use of the emergency boreholes at Norton reducing exports to the Severn Zone drought permits to preserve reservoir storage and assist winter refill. Drought permits There is only one potential drought permit identified for the Birmingham Drought Zone. This relates to the use of one of our sources on the River Whilst this source is on the Severn, the benefit of the Drought Permit is to the Birmingham Drought Zone. Nevertheless, the use of this source in this way increases the conjunctive use of the Rivers Severn and Wye, and can potentially maximise the resources of both river systems. We are developing operational control rules to define how this will be achieved. The decision to apply for this permit will depend on the water resource availability at the time in the River Severn system and the Welsh Reservoirs. This permit would, however, potentially oppose the conditions of the Agency s River Severn Drought 60

61 Order to reduce River Severn abstractions below licensed limits if required at the same time. This is a clear conflict of interests. Following our detailed discussions with the Environment Agency, the following statement has been included in the Agency s River Severn Drought Management Plan:- In undertaking our statutory duties we (the Environment Agency) have to balance the competing interests of the river environment, water companies, navigation interests, industry and agriculture. During severe droughts this balance becomes increasingly more difficult to manage. We recognise that in extreme drought situations we will have to give priority to ensuring that essential public water supplies can be met, whilst working together with water companies to minimise the effects of any resulting environmental damage. We have agreed with Severn Trent Water that we will meet to discuss the potential conflicting nature of these permissions at an early stage during a drought. This will be important to ensure we manage proper use of water resources on the River Severn during a drought and both parties make appropriate, timely decisions. A meeting will be called when Severn Trent Water crosses its drought action trigger curve It should also be noted that the Welsh Reservoirs provide significant compensation and regulatory releases to the local river system. However, any Drought Permit to vary this will be promoted by Dwr Cymru Welsh Water as they manage this activity. Nevertheless, in this instance we would be expected to make all necessary supply efficiencies as the majority of the water from this system is used to provide potable supplies to the Birmingham Drought Zone. We will work closely with Dwr Cymru Welsh Water to promote any drought permit related to this system The Forest and Stroud drought zone Greater detail of these actions is given Appendix B, Section 6 Background The Forest and Stroud Drought Zone extends from the Forest of Dean in the west to the River Severn to the South of Gloucester, and to the area around Stroud. Resources The drought zone is supplied by a combination of surface and groundwater sources. The groundwater sources in the drought zone consist of springs and boreholes. Some water can be transferred from the neighbouring Severn Zone but at some risk of discolouration of supplies. Demands The demands from this drought zone are largely rural, with the exception of Stroud and smaller developments at Cinderford, Mitcheldean, Lydney and Cam. 61

62 Drought susceptibility The critical period for this drought zone is based on the River Wye. This is supported by releases from upstream reservoirs during drought periods and as a result, the critical period for the zone is 18 months. Triggers The primary trigger for the drought zone is based on storage in the upstream reservoirs and flow in the source river. Drought management options The demand side options include:- a water efficiency campaign, targeted increased leakage reduction, increased metering, appeals for restraint in water use, in the more severe drought conditions, hose pipe bans in the most severe drought conditions, restrictions on non essential use. The supply side options include:- optimising resource and licence usage increasing imports from Mythe WTW in the Severn Zone a drought permit to relax the licence conditions relating to the Mitcheldean abstraction. Drought permits There is one potential drought permit for this drought zone. The permit would be required to enable abstractions on the source river to be maintained under certain conditions. A drought permit at this site is linked to operations in the Severn and Birmingham Zones. As is discussed in Section above, the Wye system also provides water to Birmingham from the Welsh Reservoirs. However, this potentially reduces the availability of water into Worcestershire. This in turn, puts greater pressure on other treatment works to supply more into that county. At these times, additional water availability in this Zone will help this situation by releasing more River Severn sourced water to be supplied to areas further north in Worcestershire. This therefore promotes the conjunctive use of the Severn and Wye The Oswestry drought zone Greater detail of these actions is given Appendix B, Section 7 Background The Oswestry Drought Zone extends from Lake Vyrnwy in Wales, eastwards towards Wem, and from Ellesmere in the north to the River Severn in the south. 62

63 Resources The Oswestry Drought Zone is supplied by groundwater sources which abstract from the Sherwood Sandstone aquifer, and the Namurian Millstone Grit. There is also a link to the Severn Zone. This meets approximately 40% of the demand in the Oswestry Zone. There is an additional emergency link from the neighbouring Water Company. This may be used in a situation where supplies from the Severn Zone are under threat. Demands This drought zone is largely rural, with the exception of the towns of Oswestry, Ellesmere and Wem. Drought susceptibility Even during extended drought periods, groundwater levels in the Sherwood Sandstones in this area are only reduced by a few metres. As a result most of these sources are not susceptible to droughts. The relationship between output and drought water level at Mardy are less clear, but is nonetheless believed to be robust in most drought scenarios. The reliability of the import from Shelton in the Severn Zone is considered to be robust, but it is linked to the surface water resources of the River Severn, Clywedog and Vrynwy Reservoirs, and the Shropshire Groundwater Scheme. Drought management of this river is vested in the Environment Agency and the triggering of any drought alert situations is described in the Agency s River Severn Drought Management Plan. Triggers We have no direct triggers for drought management in this zone. Nevertheless, the Environment Agency s Drought Management Plan as described above, may request demand reductions in all zones supported by the River Severn. As this Zone receives a significant import from the Severn Zone, the same reference reservoir is therefore used as the control for drought management actions in this Zone.. We will support the Agency in its drought management activities on the River Severn by imposing all relevant demand management restrictions in this Zone. Drought management options The demand side options include: a water efficiency campaign, targeted increased leakage reduction, increased metering, appeals for constraint, in the more severe drought conditions, hose pipe bans in the most severe drought conditions, restrictions on non essential use. 63

64 The supply side options include:- optimising resource and licence usage increasing imports from the Severn Zone from Shelton WTW Drought permits There are no potential drought permits identified for this zone The Vale of Powys drought zone Greater detail of these actions is given Appendix B, Section 8 Background The Vale of Powys Drought Zone extends from Machynlleth and Clywedog in the west to Welshpool and Montgomery in the east. For this Plan, its identity as distinct from the larger Severn Zone, has been retained to highlight the limited supply surplus at times of peak demand in the area. Resources The Vale of Powys Drought Zone is supplied by two groundwater sources that abstract from river gravel deposits adjacent to the River Severn, (with a significant resource contribution likely to be supported by reservoir releases to the rivers), and from river gravels adjacent to the River Dovey. New boreholes are currently being commissioned at one of these sources. Demands The Vale of Powys Drought Zone is almost entirely rural, with the exception of the towns of Llanidloes, Newtown and Welshpool. Tourism in this area can cause high peak demands in summer. Drought susceptibility It is likely that the larger source in this Zone would not be affected in a drought whilst releases were being made to support flow in the River Severn. The deployable output of the source without river regulation is not known, but it is anticipated that output will not be reduced unless significantly reduced regulation releases are made. This would only occur when the supporting reservoir storage falls to emergency levels. In this circumstance, it is likely that we would be supporting the Environment Agency, which manages the resources in the Severn, by requesting significant reductions in demand by customers. Triggers There is no clear trigger for drought actions in this small zone. However, as discussed above, drought demand management will be linked closely to the situation in the supporting reservoir and the requirements of the Environment Agency in managing the overall resources of the River Severn. Any drought actions triggered by critical reservoir storage in the Severn Zone would be reflected in this Zone as necessary. 64

65 Drought management options The demand side options include: a water efficiency campaign, targeted increased leakage reduction, increased metering, appeals for constraint, in the more severe drought conditions, hose pipe bans in the most severe drought conditions, restrictions on non essential use. The supply side options include:- optimising resource and licence usage Drought permits There are no drought permits identified for this zone The Staffordshire and East Shropshire drought zone Greater detail of these actions is given Appendix B, section 9 Background The Stafford and Telford Drought Zone extends from Whitchurch and Wem eastwards to Stafford, and from Market Drayton in the north to Bridgnorth in the south. Resources This Zone is supplied exclusively by groundwater sources. The majority of these abstractions are from the Sherwood Sandstone aquifer. Demands This Drought Zone includes the urban demand centres of Stafford, Telford, Market Drayton, Newport, Whitchurch and Bridgnorth along with large parts of rural north and east Shropshire and north Staffordshire. Drought susceptibility Even during extended drought periods, groundwater levels in the Sherwood Sandstones in this area are only reduced by a few metres compared with the large total aquifer depth. As a result these sources are not particularly susceptible to droughts. It is possible however, that in a severe drought, local areas of this drought zone may experience a shortfall in resources. Local contingency plans are in place and will be instigated as necessary. Triggers There are no clear triggers for this Zone, but due to its proximity to the Stoke and Severn Zones, we may invoke drought actions in this area that are invoked by triggers in these two neighbouring zones. 65

66 Drought management options The demand side options include:- a water efficiency campaign, targeted increased leakage reduction, increased metering, appeals for constraint, in the more severe drought conditions, hose pipe bans in the most severe drought conditions, restrictions on non essential use. The supply side options include:- optimising resource and licence usage Drought permits There are no potential drought permits identified for this zone. 5.4 Licensed source review Since 2000, we have identified a number of sources where there may be the potential to increase deployable output during a drought. A review was instigated and completed in March The investigations concluded that some of our sources under review could deliver additional output. Where additional deployable output was identified and implemented, all operating procedures, and this Drought Plan, have been amended accordingly. However, some sources remain with potential limitations. The value of these sources is under continuous review as revised needs and external pressures and considerations arise. Consequently, the status of these sites as drought sources will be revised accordingly. Furthermore, as a consequence of discussions with the Environment Agency as we prepared our Draft Water Resources Management Plan 2008, two further reviews of our sources including current abandoned and mothballed sites, have been commissioned. The first is driven by the Agency s initiative for Restoring Sustainable Abstraction (RSA)) and addresses proposed abstraction licence reductions in areas where unsustainable abstraction is believed to be occurring. The second review has just been commissioned (June 2008) and will review all historic sites that we have licensed that have been out of operation for some years. These reviews will update our understanding of what emergency resources we could draw on in a drought from sources that normally are difficult or uneconomic to operate. Consequently, this part of the Plan will be updated when revised information becomes available, but as yet it is uncertain which of these sources could be used safely in a drought. Nevertheless, if the situation warranted it, we would work closely with the Agency and the Drinking Water Inspectorate to ensure that all sites the can be brought back into supply would be re-commissioned provided their use was operationally safe and compliant with all drinking water safety regulations. 66

67 5.6 Package treatment plants We have a number of sources that are licensed, but cannot be used due to a variety of problems. These include poor raw water quality or obsolete treatment processes. Small mobile treatment plants as used by the armed forces during field operations is one possible solution, and progress in the development of membrane technology for micro-filtration has been significant in recent years. However, in reality, these plants are only credible in absolute extreme circumstances, and any semi-permanent installations would require complicated and potentially dangerous connections to high pressure delivery mains. Also, effluent discharge from the treatment process would have to be dealt with adequately and would be subject to normal constraints set by the Environment Agency. 5.7 Temporary pipelines and pumps Following experiences in summer 1995, we undertook a comprehensive review of areas where deficiency of supply occurred. Considerable investment took place in enhancing the network by duplication or upsizing of mains and provision of new local booster pumps. Investment was assigned to making sources more robust in terms of treatment and deployability. In addition, much effort has been put into leakage detection and repair and some 300 Ml/d reduction in water distributed due to lower leakage has been achieved since Work continues on the network to deal with areas where distribution pressures are occasionally at risk of falling below the DG2 standard of service. The solution to this situation would involve construction of permanent infrastructure rather than use of temporary plant. More recently the Isolated Communities initiative has been established to identify particularly small developments in rural areas that are at a high risk of loss of supply during extreme events such as droughts. The intention is to reduce to a minimum the number of tanker movement that are required to maintain supplies to these customers. 5.8 Tankering Small scale tankering activity in outlying rural areas is aimed at replenishing small service reservoirs or to supply customers via bowsers, when the distribution system cannot cope with abnormally high demands. This is regarded as a temporary measure and it is our aim to minimise the need for this through its Network development process to improve service to customers. 5.9 Short term licence variations and emergency licences The usual way to vary a licence on a temporary basis is through the Agency via a drought permit. However, we have not identified any areas where this would be considered Actions at the end of a drought Once a drought has broken and the precipitation returns we will set in place a series of actions to return to normal as soon as possible. Our reservoir storage management graphs given in Appendix B show a series of curves that instigate actions as a drought builds up. However, a further line dictates when storage is filling and the likelihood of refill is high. These are called the lift restrictions curves. These have been generated by the same simulation process that gave the control lines that 67

68 put the restrictions and control actions in place. In terms of likelihood of the reservoir filling once these lines are crossed, the nature of the curves is such that in the 86 year of record the reservoir always filled once these lines were crossed. Once such a line is crossed the Drought Action Team will meet to determine the next actions. We will liaise with the Environment Agency to agree to lift all relevant actions granted by the drought permits we may have in place. However, as a drought permit is granted for 6 months we will retain its authority reserve the right to reintroduce the powers if the situation turns dry once again. However, as the reservoir storage simulations have shown, the likelihood of this is low. The lifting of powers will also include the lifting of any hosepipe bans or other more widespread demand restrictions we have imposed. We will then arrange a meeting with the Agency and other relevant stakeholders to review how the drought was managed and identify any areas for improvement or revision to this Plan. This will include the need for continued environmental monitoring in catchments where drought permit powers have been deployed. We clearly recognise that this is important so that we better understand how, these extraordinary operations have impacted on the environment, and whether such powers are acceptable in future droughts. 68

69 6 Application for drought permits and drought orders On 1 April 1996 the Environment Agency took responsibility for the regulation, management and protection of water resources. Under the 1995 Environment Act, the Agency gained new responsibilities regarding drought management. For the first time, it became possible to apply for drought permits to protect the environment. Previously these powers could only be sought to protect essential water supplies. In addition, water companies were given powers to apply to the Agency for drought permits to enhance supplies or to change conditions of abstraction or compensation release without having to apply to the Secretary of State for a drought order. The process for permit acquisition still involves advertising and may involve public hearings to hear objections. The process is speedier with decisions made by those who have a full appreciation of local issues and circumstances. 6.1 Assessing environmental impacts As a large industrial company we accept that our operations have a considerable impact on the natural environment. Whilst we are in business to provide adequate supplies of potable water to our customers we recognise that our operations, both on the clean water and waste water sides of our business, can potentially damage the environment. To this end we have set out our Biodiversity Action Plan which aims to embrace all aspects of good environmental stewardship. However, we recognise that during the extremes of drought we have to use drought powers to ensure supplies of potable water to our customers. We recognise that powers such as drought permits can allow actions that may have detrimental environmental consequences. Hence we have taken action to assess what the impacts of our drought permits may be. It is a requirement of any Water Company to assess the impact of any drought permit that it might apply for. Any impact of a drought permit on the aquatic environment must be compared with normal conditions. Baseline survey data on ecology, presence of rare and protected species, fisheries, water quality and recreation uses is available from a number of sources, in particular the Agency. Reference has to be made to eco-hydrology models such as PHABSIM and LIFE for specific areas. These can describe the baseline state of the ecology to be compared with any changes if, or when, Drought Permit conditions are applied. We have commissioned environmental consultants to undertake impact assessments at all sites where we believe that Drought Permits may be required. These reports are available with this Plan, and should be read in conjunction with it. The reports also indicate what level and range of back ground monitoring should be undertaken in non-drought years. A summary of the main findings of each report is given in Appendix F. Considerable discussion has taken place with the Agency on these reports and extensive data on river quality and river flow has been provided by its staff. This is, however, seen as an ongoing requirement and a routine monitoring plan will be drawn up and discussed with the Agency in readiness for any future Drought Permit applications. 69

70 6.2 Applying for Drought Permits An application for a Drought Permit is made to the Agency and is available following sections 6 & 7 and schedule 22 (139 & 140) of the Environment Act Schedule 22 amends sections 73 and 79 of the Water Resources Act. Schedule 8 contains the statutory procedures to follow in making an application for a permit, and we will observe these requirements. We recognise the need to consult with the Agency from the beginning of any drought management process, and that this consultation with increase in frequency and detail as a drought progresses and deepens. The Drought Permit will specify the day on which it comes into force and will normally last for up to six months. However, we will seek to extend this period should the need for the Permit still be relevant and justifiable. In considering an application for a Drought Permit the Agency will require us to have undertaken a number of demand management actions. These must be in place before any support for the Permit can be expected from the Agency. The Agency will also require monitoring of likely effects on the environment, as specified in the Impact Assessments commissioned by us. The Agency will decide on the validity of the permit based on our needs, any representations made from third parties, the needs of the environment etc. Including the preparation, it is unlikely that a Drought Permit will be granted in less than 28 days. With a public enquiry, this could extend the period to two months or more. We have indicated that we will apply for any of six Drought Permits should the need arise. The details of these are given below Derwent Valley Reservoirs This Drought Permit will: - reduce the aggregate quantity of compensation water from Ladybower Reservoir to the River Derwent system; Information to support an application 1. Introduction This will contain details of the background to our supply system showing how the Derwent Valley output links into the rest of our supply system. 2. Derwent Valley Reservoirs Information on the source, the legal requirements (which covers compensation quantities) and how the source is operated. 3. Rainfall, water resources and supplies Information from the local area rainfall, plus actual storage and output from the source. Information on the local supply area or zones. 4. Measures to meet demand. 70

71 How demand can be managed, including information on demand and leakage trends. 5. The need for a Drought Permit Lack of rainfall, low storage, chances of refill. 6. The proposed Drought Permit Why a Drought Permit will help and the effects on the river downstream. The application will also include maps, plans, tables, figures and photographs, plus a copy of the current legislation. Operational data and frequency of provision Resource storage daily rainfall monthly relevant river flow daily Supply treatment works output daily Demand County and Company daily Leakage information weekly R Derwent water quality to the Trent weekly effects on fisheries and invertebrates monthly STW effect on effluent dilution monthly Third Party effects on major downstream abstractors monthly River Derwent at Ambergate This drought Permit will: - authorise the abstraction of up to 320 Ml/d under certain river flow conditions. Information to support an application 1. Introduction Background to our supply system showing how this abstraction supports our supply system. 2. Ambergate Information on the source, the legal requirements (which covers compensation quantities) and how the source is operated. 3. Rainfall, water resources and supplies Information on catchment rainfall, plus actual storage and output from the sources, including releases from reservoirs in the area. 71

72 4. Measures to meet demand. How this can be managed. Include information on demand and leakage trends. 5. The need for a Drought Permit Lack of rainfall, low storage, likelihood of refill 6. The proposed Drought Permit Why this Drought Permit will help and the effects on the river downstream. The application should also include maps, plans, tables, figures and photographs, plus a copy of the current legislation. Operational data and frequency of provision Resource relevant storage daily catchment rainfall monthly relevant river flow daily related river releases daily Supply local works production daily Demand county and company daily leakage (nightlines, numbers of repairs) weekly R Derwent water quality to the Trent confluence weekly effects on fisheries and invertebrates monthly STW effect on sewage discharge effluent dilution monthly Third Party effects on major downstream abstractors monthly Tittesworth Reservoir and the River Churnet This Drought Permit will authorise additional abstraction from Abbey Green borehole for discharge into the River Churnet. Also, to reduce the compensation requirement from the Reservoir Information to support an application 1. Introduction Background to the local supply system. 2. Tittesworth and the Upper Churnet Information on the sources, the legal requirements (which covers compensation quantities) and how the source is operated. 3. Rainfall, water resources and supplies Information on the catchment rainfall, plus actual storage and output from the sources. Supply area and zones 4. Measures to meet demand How this has been managed including information on demand and leakage trends. 72

73 5. The need for a Drought Permit Lack of rainfall, low storage, chances of refill. 6. The proposed Drought Permit Why this Drought Permit will help and the effects on the river downstream. The application should also include maps, plans, tables, figures, photographs, plus a copy of the current legislation. Operational data and frequency of provision Resource reservoir storage daily catchment rainfall monthly related river flow data daily compensation discharges daily Supply treatment works outputs daily groundwater outputs daily Demand county and company daily leakage management weekly Groundwater water levels in local boreholes weekly water quality of discharges weekly R Churnet downstream river water weekly effects on fisheries and invertebrates monthly STW effect on sewage effluent dilution monthly Third Party effects on downstream abstractors monthly River Wye at Wyelands This Drought Permit will authorise additional abstraction from the River Wye. Information to support an application 1. Introduction Background to our supply system showing how the abstraction links into our supply system. 2. Wyelands Information on the source, the legal requirements and how the source is operated. 3. Rainfall, water resources and supplies Information on the upstream catchment and rainfall plus actual storage and output from the sources, including relevant releases to the river. 4. Measures to meet demand. How this has been managed including information on demand and leakage trends. 5. The need for a Drought Permit Lack of rainfall, low storage, chances of refill. 73

74 6. The proposed Drought Permit Why this Drought Permit will help and the effects on the river downstream. Operational data and frequency of provision Resource reservoir storage daily catchment rainfall monthly relevant river flow data daily relevant river releases daily Supply works outputs daily Demand county and company daily leakage management weekly River conditions downstream water quality weekly effects on fish and invertebrates monthly STW effect on sewage effluent dilution monthly Third Party effects on downstream abstractors monthly River Severn at Trimpley The key constraint at Trimpley during a drought is that the daily licence is reduced under maximum river regulation of the river. The proposed Drought Permit will take effect if the abstraction at Trimpley has to be reduced due to the maximum regulation condition in its licence. A reduction in abstraction at Trimpley will have the greatest impact on our operation if there is the requirement to support other supplies zones than the Severn Zone. The proposed Drought Permit will:- - suspend the daily abstraction restriction under maximum regulation; - suspend the joint licence constraints at Trimpley and Hampton Loade WTW. Information to support an application 1. Introduction The Agency will require background information on how Trimpley supplies water into our supply system. This is a key aspect of this drought permit application. Additionally, details of how Trimpley will be affected by abstraction restrictions during a drought along the River Severn. 2. The Trimpley abstraction Information on this source, the legal requirements and how this source is operated will be required. Additionally, licence information on related sources will be included. 3. Rainfall, water resources and supplies Information will be provided on the rainfall recorded over the region as well as storage trends in related reservoirs. Information on the output from this source and supporting reservoir releases will be included. 74

75 4. Measures to meet demand. How our supply system is managed, including information on demand and leakage trends. 5. The need for a Drought Permit Lack of rainfall, low storage, chances of refill. 6. The proposed Drought Permit Why this Drought Permit will help, and the effects on the river downstream. The application should also include maps, plans, tables, figures and photographs, plus a copy of the current legislation. Operational data and frequency of provision Resource relevant reservoir storages daily relevant catchment rainfall monthly relevant river flow data daily relevant river releases daily Supply relevant supply data daily Demand county and regional daily leakage management weekly R Severn downstream water quality data weekly effects on fisheries and invertebrates monthly STW effect on sewage effluent dilution monthly Third Party effects on downstream abstractors monthly In relation to related reservoirs that are owned by Dwr Cymru Welsh Water, that organisation would normally take action to apply for drought powers to protect the reservoirs in time of drought. We have a sound working relationship with Dwr Cymru and we will support them in these circumstances. However, we do not rule out applying ourselves for such drought powers if Dwr Cymru fails to do so when in our opinion such powers are required River Leam at Eathorpe and River Avon at Stareton This Drought permit will: - authorise additional abstraction from the River Leam at any time of year when the storage conditions in our related reservoirs dictate. - relax the prescribed flow in the River Leam at Princes Drive Weir in Leamington; - reduce the hands-off flow in the River Avon at Stareton to allow us to abstract additional water from the River Avon. Information to support an application 1. Introduction Background to our supply system showing how this system links into the eastern part of the wider supply system. 75

76 2. Major Intakes Information on the sources, the legal requirements and how the sources are operated. 3. Rainfall, water resources and supplies Information on the Rivers Avon and Leam catchments and rainfall in the East Midlands. Actual storage and output from related reservoirs and other local sources. 4. Measures to meet demand. How this has been managed, including information on demand and leakage trends. 5. The need for a Drought Permit Lack of rainfall, low storage, chances of refill. 6. The proposed Drought Permit Why this Drought Permit will help and the effects on the local rivers. The application should also include maps, plans, tables, figures and photographs, plus a copy of the current legislation. Operational data and frequency of provision Resource reservoir storage daily catchment rainfall monthly related river flow daily related river releases daily Supply works output daily Demand county and region daily leakage management weekly River conditions downstream water quality weekly effects on fish and invertebrates monthly STW effect on sewage effluent dilution monthly Third Party effects on downstream abstractors monthly 6.3 Applying for Drought Orders A Drought Order is obtained under the provisions of the Water Resources Act 1991 sections 73 to 81. Permission is required from the Secretary of State. Drought Orders may only be applied for if it is possible to show that there has been an exceptional shortage of rain. Drought Orders are required for proposals that involve other abstractors and their operations. We have given serious consideration to whether we would wish to impose restrictions on other abstractors through the power of a Drought Order. For the duration of the current Drought Plan we see the likelihood of using these powers as minimal and only as a last resort. However, we would seek authority to impose a Drought Order to restrict nonessential uses of water by our customers if the situation warranted it. These restrictions go considerably further than a hosepipe ban which, in the main, only affects our domestic customers. The circumstances that would force us to seek Drought Order powers are the very severe droughts when reservoir storage is 76

77 approaching emergency levels and all other forms of demand reduction have been exhausted. Whilst we take our obligation to provide a continuous and adequate supply of water to all our customers seriously, we would seek to reduce nonessential use of water in such emergency situations by the powers granted in a Drought Order. It should be noted that this would not be considered to be an Emergency Drought Order which in our interpretation is intended for use when, for what ever reason, sudden and serious asset failure causes the loss of supplies. This may not necessarily be due to drought. 6.4 Data exchanges with the Agency There is an established agreement covering data exchanges between ourselves and the Agency that works well in periods of normal operations. However, once the weather turns dry and a drought becomes more and more likely, it is important that key items of information are readily exchanged between our two organisations to ensure that an up-to-date picture of the situation is available to both parties. This will also enable the preparation of any Drought Permit applications by us using data covered in section 6.2, to be made quickly and effectively. One particular item of information that we recognises as being important to share with the Agency, is its routine projections of reservoir storage, particularly after drought warning triggers have been crossed. As reservoir storage reduces, the value of these projections increases with the likelihood of us needing to resort to Drought Order powers. At such times it is envisaged that regular and detailed liaison will be held with the Agency. 77

78 6.5 Post-drought monitoring Once the drought appears to be over, and drought cessation lines have been crossed at the key storage reservoirs, the management of the situation does not stop. There are two important tasks to undertake. These are base-line environmental monitoring to assess the impact of the drought and a post-drought review Continued base-line monitoring The environmental impact assessments that have been commissioned by us recommend a program of base-line environmental monitoring that we will undertake once normal conditions return. This program will be agreed with the Agency and will provide data to determine the impact of the drought permits that we have deployed Post-drought review It is important that we and Agency meet soon after the drought to review all aspects of how the event was managed from its start to its finish. There will inevitably be learning points however well it is felt the drought was managed, and these must be recognised and recorded. From these findings any necessary modifications can be made to the procedures that this Plan embodies. Additionally, it is very important that the environmental impact of the drought and the actions we have taken must be analysed. This will involve a review with the Agency of the sampling and monitoring program particularly where a drought permit has been deployed. 6.6 Update of this Drought Plan Following the drought review process it is important that this Plan is updated to encompass any procedural or operational improvements that can be made based on the experience of the drought. All changes to the Plan will be discussed and agreed with the Agency. 78

79 7 Assessing the frequency of droughts and actions In this document and in our Water Resources Management Plan we state that we believe we can maintain supplies to our customers without needing to supply restrictions such as hosepipe for all years except on average three per century. We believe it is relevant to explain how we can state this with some confidence. To prepare this Plan, and the Water Resources Management Plan, we have used a computer based resources and supply system model that can undertake simulations of how, our system will meet the water demands of our customers. The model is built up of demand centres based on the towns, cities and rural communities in our supply area. These represent the demand for water that each centre creates through its resident population and industry. Hence this part of the model represents the demand side requirements. To meet this demand all our production sources are represented in the model as production nodes and these supply the demand centres through linkages that are representative of the trunk mains and distribution systems that we operate. Where a source is fed from a reservoir or river, the model represents the reservoirs in our area as storages and the rivers as continuous feeds of water to be used into supply. However, to make this realistic we have a database of 86 years of flow data (based on actual records from 1920 to 2006 at our river sources and an equivalent length of record of run-off to our reservoirs. This database contains the natural flow that occurred in our rivers or into our reservoirs over this period of record. Additionally, the model contains all details of abstraction licences and operating rules that control source output. With this database and the representation of how our resources are controlled, we can simulate how our supply system will operate for any level of demand over the 86 year period. By doing this we can assess any aspect of our supply systems operation e.g. when it will fail, completely, or how often we need to reduce demand by assuming a hosepipe ban is applied (note that we assume a hosepipe ban will create 5% demand savings). Therefore, amongst other things, we can assess how often we might need to take certain actions to maintain our service to customers. By this process we have assessed that our system will meet all normal demands in all years except an average of three per century. As we know of now scientific method to forecast when a drought will occur, our only resort is to plan for the likelihood of a drought based on the statistical analysis that the model simulation performs. Based on this, the details given in section 6 above illustrate the drought management actions that we will deploy in a drought, once a particular trigger has been crossed. By analysing the reservoir simulation process that was used to define the control lines for each reservoir, it is possible to determine the approximate frequency of the key actions, e.g. closure of a treatment works, a significant reduction in a works output, dependence on a regional transfer between zones etc. From an operational aspect it is important to demonstrate that that the major change from normal operations that a drought causes can be accommodated within the production capacity and operational resources available to us. It is therefore necessary to evaluate the likelihood with which the more significant actions will occur. This will enable us to plan for any necessary contingency resources to be 79

80 made available within the timescale of a drought. The following sub-sections provide a breakdown of the statistical likelihood of key actions occurring at the Derwent Valley Reservoirs, Carsington and Ogston Reservoirs, Dove Reservoirs, Elan Valley Reservoirs, Tittesworth Reservoir and Draycote Reservoir. The operation of water supplies in the East Midlands Drought Zone during a drought is directly linked to any reduction at Bamford WTW. Therefore, the analysis of the operation of Carsington and Ogston Reservoirs (sub-section 7.2), and the Dove Reservoirs (sub-section 7.3) on the tables that follow, is linked to the output from this works. Therefore, the sensitivity of any reduction at Bamford to consequent actions is clearly illustrated. 7.1 Derwent Valley Reservoirs Once the storage alert line has been crossed the proposed action is to reduce Bamford WTW output. This will require additional output from linked sources to make up any supply shortfall and inevitably incur greater operational costs as Bamford is one of our cheapest sources to operate. The table below gives details of a sensitivity analysis of the optimum output to achieve a frequency of hosepipe bans of three per century. This table shows that a reduction to an output of 80 Ml/d once the Storage alert line is crossed achieves the target frequency of hosepipe bans. However, operationally, this means that Bamford output will reduce to 80 Ml/d in 59 of the 77 years of the simulation and have an average overall output of Ml/d. It is also of interest that this same table shows that whilst the implement hosepipe ban line will be crossed in only three years of this simulation, the storage alert line is crossed in 59 years, the Drought Warning Trigger in 29 years, and the Apply for Summer DP and consider HPB line in eight years. Only three of these eight years result in an actual hosepipe ban. Number of years in simulation period (1920 to 2006) that control lines are crossed Minimum Bamford output As bulk supply agreement Control Lines Storage alert line Drought warning trigger Apply for summer DP consider hosepipe ban Implement summer DP / HPB Apply for winter DP 12 80

81 Implement Winter DP 11 25% full Average output from Bamford (Ml/d) Carsington and Ogston As a reduction in output at Bamford to 80 Ml/d will cause other works in the East Midlands to be increased, the frequency with which additional river support from Carsington will be required can be evaluated. As Carsington and all the other treatment works in the zone are more expensive to run than Bamford, this will allow us to accommodate such a change from normal operations within our short and medium term operational plans. This will include agreeing with the Agency how Carsington can be refilled in a timely manner, be that within the current abstraction licence constraints or under the additional powers granted by a Drought Permit. This shows that, overall, with Bamford on an output of 80 Ml/d at the critical time, the storage in the Carsington and Ogston system will cross the implement hosepipe ban line during two years in the simulation period i.e. a likelihood of one summer in approximately 40. Number of years in simulation period (1920 to 2006) that control lines are crossed Minimum Bamford output As bulk supply agreement Control lines Storage alert line Drought warning trigger Apply for summer DP consider hosepipe ban Implement summer DP /

82 HPB Apply for winter DP Implement winter DP % full 7.3 River Dove Reservoirs As a reduction to 80 Ml/d at Bamford will put extra demand on and the River Dove system, the following table illustrates the frequency with which drought management actions will be deployed. Number of years in simulation period (1920 to 2006) that control lines are crossed Minimum Bamford output As bulk supply agreement Control Lines Storage Alert line Drought Warning Trigger Prescribed Flow Reduction Curve Emergency level 31% This shows that the Prescribed Flow Reduction curve, which means that the flow in the Dove can be reduced to 90 Ml/d from 159 Ml/d, will be reached in four years of the simulation period or about once in 20 years. 82

83 7.4 Elan Valley For the Elan Valley system, the key operational actions involve use of the River Severn to supplement flow from the Elan Reservoirs. The table below shows that to achieve a target of only three hosepipe bans per century, this has to occur in 17 years of the simulation period, or about once in four years. Number of years in simulation period (1920 to 2006) that control lines are crossed Control lines Storage alert line 31 Drought warning trigger 23 Trimpley control line 17 Apply for summer DP consider hosepipe ban 11 Implement summer DP / HPB 3 Apply for winter DP 15 Implement Winter DP 11 Licence rule curve 13 25% full 1 83

84 7.5 Tittesworth Reservoir At Tittesworth the frequency of crossing the implement hosepipe ban line is given as twice in the simulation period. This is achieved by reducing the works output to 15 Ml/d once the storage alert line is crossed, and a further reduction to 11 Ml/d once the Drought Warning Trigger is crossed provided that this can be offset by extra water from other sources in the Zone. Overall, the average output from the works is 21.1 Ml/d over the simulation period. Number of years in simulation period (1920 to 2006) that control lines are crossed Control lines Storage alert line 42 Drought warning trigger 15 Apply for summer DP consider hosepipe ban 4 Implement summer DP / HPB 2 Apply for winter DP 9 Implement Winter DP 6 Emergency level Average Tittesworth output in Ml/d Draycote Number of years in simulation period (1920 to 2006) that control lines are crossed Control lines Storage alert line 29 Drought warning trigger 18 Apply for summer DP consider hosepipe ban 4 Implement summer DP / HPB 3 84

85 Apply for winter DP 16 Implement Winter DP 10 River abstraction threshold Emergency level This demonstrates that the drought warning trigger is crossed 18 times over the simulation period or approximately once every four years. One action at this point will be to consider a reduction in Draycote WTW production or a complete shutdown of the works until storage recovers. Nevertheless, the standard of not more than 3 hosepipe bans per century is achieved. 85

86 Appendix A List of changes from DP 2003 This is a list of updates following issue of Drought Plan guidelines from the Environment Agency in November Identification of Drought Permit sites 2. Inclusion of impact assessments made by environmental consultants 3. Changes to Drought Management Zones 4. Changes to Drought Action Team Membership Structure of team with job titles including name of member of staff responsible for heading the Team 5. Positioning statement regarding the Strategic Environmental Assessment Directive 6. Review of sources with spare capacity over normal operating output 7. Review of Control Graphs and Drought Triggers 8. Inclusion of Drought Cessation line to indicate when Drought measures can be relaxed. 9. Inclusion of seasonal Apply for Drought Permit lines to differentiate when a winter permit (November to March) is more appropriate than a summer permit, hence negating the need for a hosepipe ban and reducing the impact on the environment 10. New style operating control graphs. The details are discussed in Appendix B 86

87 Appendix B Drought Plan summary tables and figures In this Appendix the detailed supply side actions that will be deployed across each zone as a drought develops are described. The detail includes that required by the Drought Plan guideline that was issued to water companies in September Similar detail of the demand side actions is given, but as demand side actions are seen as being regional and generally common to all zones, only one table is given i.e. table B2. The only exceptions to this is the East Midlands Zone where one demand side option relates to the export of water to Yorkshire Water Services, and the Birmingham Zone where one option relates to exports out of the zone. These are shown on tables B5 and B8 respectively. Table B. 1 Drought Triggers by Zone DP Zone Primary Trigger(s) Secondary Trigger (if any) Stoke Reservoir storage Ladderedge Reservoir storage East Midlands Reservoir storage Alternative reservoir storage Severn Reservoir storage Birmingham Reservoir Storage Forest and Stroud Reservoir storage Flow in key river Oswestry Reservoir storage Vale of Powys Reservoir storage Stafford and Reservoir storage Alternative reservoir East Shropshire storage 87

88 Table B.2 Drought Management Options Company-wide Demand Side Options These actions will be deployed in every Drought Zone as triggers are crossed Option Name Trigger Demand saving Implementation timetable Permissions required Risks Risk to environment Environmental impact Studies undertaken Monitoring Requirements Mitigation actions Other impacts Water efficiency camp Normal operation Leakage reduction to economic level Normal operation Ongoing None None None None Research started into scale of demand savings Consumption monitoring to support research Ongoing None None None None None None None None None None Free meter option Normal operation Ongoing None None None None None None None None Raise awareness in the Company, CCWales, Natural England and EA Storage alert line Ongoing None None None None None None None None Convene Drought Action Team and liaise with EA Drought Warning Trigger None None None None None None None None Staged pressure Drought Possible 88

89 reduction below normal level Action Team 0-2% 7 days None DG2 Complaints None None None None None None Enhanced leakage detection and repair Drought Action Team 0-2% 14 days None None None None None None None None Enhanced water conservation campaigns High profile promotion of meter option Media appeals for customer restraint Drought Action Team Drought Action Team Drought Action Team 0-2% 7 days None None None None None None None None 0 0.5% 7 days None None None None None None None None 0-2% 7 days None None None None None None None None Consider hosepipe ban Trigger Line 0 5% 7 days 7 day Public Notice Reduced level of service None None None None None None Consider nonessential use ban. Contact should be made with the Regional Civil Contingency Groups to ensure full public awareness of the situation Return to normal Drought Action Team Drought cessation line Possibly 15% 28 days Drought Order granted by Secretary of State Impact on customer livelihood None None None None None None None None None None None None None None 89

90 Table B.3 Stoke Drought Zone Drought Management Options Supply Side Option Name Trigger Demand saving Implementation timetable Permissions required Risks Risk to environment Environmental impact Studies undertaken Monitoring Requirements Mitigation actions Other impacts Operate system within normal operating parameters Raise awareness in Company and with EA Convene Drought Action Team and liaise with EA Normal operation Storage alert line Drought Warning Trigger Ongoing None Normal level of operational risk Ongoing None Normal level of operational risk 1 day None Normal level of operational risk None None None Within consented parameters - Within consented parameters Within consented parameters - Company Exercise testing Normal monitoring of abstraction and discharges Normal monitoring of abstraction and discharges Formal minutes taken None None None None None None Consider options for rezoning Stoke Area Review schedule of maintenance at major works Drought Warning Trigger Drought Warning Trigger Reduction of import from Laddered gzone 7 days None Discolouration of supplies 1 day None Plant failure if change is None None Within consented parameters None Within consented parameters Normal level review of works Increased monitoring of water quality in distribution Normal level of work Custo mer warnin g as neces sary Revie w alterna None None 90

91 Maximise Cresswell Group of sources (excludes Meir) Determine scope for recommissioning Meir Seek Drought Permit as required Return to normal operations Drought Action Team Drought Action Team Drought Action Team Drought Action Team Up to 10 Ml/d Up to 4 Ml/d 8 Ml/d at Titteswort h Reservoir 7 days None 14 days None 28 days DP approval from EA protracted scheduling operation tive produc tion scenar ios Low risk of discolouration of supplies Poor water quality into supply As given in #1 None None None None None None None None None None None None As given in #1 As given in #1 As given in #1 As given in #1 As given in #1-7 days None None None None None None None None As given in #1 #1 Environmental Impact Assessment Report Note that in this Zone we are accommodating the EA s National Environmental Programme initiative by assessing the potential for sustainability reductions at 4 of our sources. This will not be affected by any drought management actions. 91

92 Figure B. 1 Stoke Drought Zone Primary trigger Tittesworth Reservoir 92

93 Table B.4 Ladderedge Drought Zone Drought Management Options Supply Side Option Name Trigger Demand saving Implementation timetable Permissions required Risks Risk to environment Environmental impact Studies undertaken Monitoring requirements Mitigation Actions Other impacts Operate system within normal operating parameters Normal operation Ongoing None None None None None None None None Raise awareness in Company and with EA Storage alert line Ongoing None None None None None None None None Maximise Leek Area GWS and reduce WTW output to 15 Ml/d Convene Drought Action Team and liaise with EA Drought Warning Trigger Save 8 Ml/d output from Titteswort h 1 day 1 day None None None None None None None None None None None None None None None None Consider options for re-zoning Stoke Area and reduce export to this area. Reduce Tittesworth WTW to 11 Ml/d Review schedule of maintenance at Drought Warning Trigger Drought Warning Save 4 Ml/d from Titteswort h 1 day None None None None None None None None 7 days None Plant failure if None None None None None None 93

94 major works Trigger change is protracted Determine scope for increased use of Cooper s Green Sources Seek Drought Permit as required Return to normal operations Drought Action Team Drought Action Team Drought Cessatio n Trigger Up to 10 Ml/d 7 days None None None None None None None None 8 Ml/d off Titteswort h comps 7 days None None None None None None None None 7 days None None None None None None None None Note that drought management actions in the Zone may be affected by the outcome of the Humber Habitats Directive assessment currently being undertaken by the EA. Also, we are accommodating the EA s National Environmental Programme initiative by assessing the potential for sustainability reductions at 3 of our sources. This will not be affected by any drought management actions. 94

95 Figure B. 2 Ladderedge Drought Zone Primary Trigger Tittesworth Reservoir 95

96 Table B.5 East Midlands Zone Drought Management Options Demand Side Option Name Trigger Demand saving Implementatio n timetable Permissions required Risks Risk to environment Environmental impact Studies undertaken Monitoring requirements Mitigation Actions Other impacts Consider reducing export to Yorkshire Water Services Derwent Valley Storage Alert line Up to 40 Ml/d off demand on DV 7 days None None None None Establishe d agreement with YWS None None None 96

97 Table B.6 East Midlands Drought Zone Drought Management Options Supply Side Option Name Trigger Demand saving Implementation timetable Permissions required Risks Risk to environment Environmental impact Studies undertaken Monitoring requirements Mitigation Actions Other impacts Operate system within normal operating parameters Raise awareness in Company and with EA Reduce Bamford WTW output to 80 Ml/d Consider use of Monksdale Convene Drought Action Team and liaise with EA Consider increased use of unsupported river abstraction Consider use of Witches Oak Scheme Normal operation Any Storage Alert line DV Storage Alert Line DV Storage Alert Line Any Drought Trigger Drought Warning Trigger Carsington Drought Trigger Reduces DV output by up to 80 Ml/d Increases production by 2 Ml/d Extra 30 Ml/d into supply Ongoing None None None None None None None None Ongoing None None None None None None None None Ongoing None None None None None None None None 28 days None Plant failure None None None None None None 1 day None None None None None None None None 1 day None 14 days None Must operate within licence None None None None None None low quality water to be treated Review Drought Plant failure None None Feasibility studies Water quality in supply Extra GAC treatment 97

98 schedule of maintenance at major works Consider reopening Wing Bulk Supply to Whatborough Service Reservoir Consider increasing import from Severn Zone Consider use of Rothley Brook into Cropston WTW Seek Drought Permits as required Action Team Drought Action Team Any Drought Warning Trigger Any Drought Warning Trigger Drought Action Team Up to 17 Ml/d made available Up to 70 Ml/d possibly available Up to 7 Ml/d Reduced compens from DV, refill Carsington 7 days None Agreement 14 days with Anglian Water 1 day None 1 day None 28 days DP granted by EA if change is protracted Agreement not guaranteed Availability of water in Severn Zone not guaranteed Poor water quality in to Cropston Reservoir As Env Impact Assessment Low None None None None None None None None None None None None None None None None None Cropston Reservoir receives poor quality water As Env Impact Assessment None None None None None As Env Impact Assessment As Env Impact Assessment As Env Impact Assessment As Env Impact Assessment None Return to normal operations Drought Cessation Trigger 7 days None None None None None None None None Note that demand management actions in this zone may be affected by the outcome of the Humber Habitats Directive Assessment that is currently being undertaken by the EA. Also, we are accommodating the EA s National Environmental Programme initiative by assessing the potential for sustainability reductions at 2 of our sources. This will not be affected by any drought management actions. 98

99 Figure B. 3 East Midlands Drought Zone Primary Trigger Derwent Valley Reservoirs Derwent Valley Reservoirs Drought Control Lines Flood drawdown Simulated % full Flood drawdown Lift restrictions Storage Alert Line Drought Warning Trigger Consider HB & Apply for summer DP Implement Summer and Winter DP Apply for winter DP Emergency level Dead water level Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

100 Figure B. 4 East Midlands Drought Zone Primary Trigger - Carsington and Ogston Reservoir Carsington & Ogston Combined Storage Drought Control Lines Simulated % full Lift restrictions Storage alert line Emergency level Drought Warning Trigger Consider HB & Apply for summer DP Implement summer and winter DP Dead water level Apply for winter DP Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

101 Figure B. 5 East Midlands Drought Zone Secondary Trigger Dove Reservoirs 100 Dove Reservoirs Drought Control Lines Emergency level Simulated % full Dead water level Storage Alert Line DWT Prescribed Flow Reduction Curve Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

102 Table B.7 Severn Drought Zone Drought Management Options Supply Side Option Name Trigger Demand saving Implementatio n timetable Permissions required Risks Risk to environment Environmental impact Studies undertaken Monitoring requirements Mitigation Actions Other impacts Operate system within normal operating parameters Raise awareness in Company and with EA Convene Drought Action Team and liaise with EA Normal operation Any Storage Alert line Any Drought Trigger Ongoing None None None None None None None None Ongoing None None None None None None None None 1 day None None None None None None None None Consider increased use of unsupported river abstraction Maximise use of Campion Hills and Draycote WTWs Review schedule of maintenance at major works Consider scope for increased import from Drought Warning Trigger Drought Warning Trigger Drought Action Team Drought Action Extra 10 Ml/d into supply 1 day None 1 day None 7 days None Up to 50 Ml/d made 1 day None Must operate within licence Depends on state of Draycote Res storage Plant failure if change is protracted None None None None None None None None None Water quality in supply None None Low None None None None None Depends on water None None None None None None 102

103 East Midlands Zone Team available availability in East Consider summer abstraction at Eathorpe to Draycote If Draycote storage below Licence Rule curve River flow dependan t 1 day Complianc e with Licence Low river flow may inhibit Seek Drought Permits as required Return to normal operations Drought Action Team Drought Cessatio n Trigger Increased refill to Draycote; Support to Frankley WTW from Severn 28 days DP granted by EA None None None None None None As #2 As #2 As #2 As #2 As #2 As #2 None 7 days None None None None None None None None #2 As Environmental Impact Assessment Report Note that in this Zone we are accommodating the EA s National Environmental Programme initiative by assessing the potential for sustainability reductions at 10 of our sources. This will not be affected by any drought management actions. 103

104 Figure B.6 Severn Zone Primary trigger Draycote Reservoir Draycote Reservoir Drought Control Lines % full simulated %full Emergency level Lift restrictions Dead water level Storage Alert Line Drought Warning Trigger Consider HB & Apply for summer DP Implement summer and winter DP Leam summer abstraction threshold Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

105 Figure B. 7 Severn Zone - Primary Trigger Clywedog Reservoir provided by the Agency Ressim modelled Clywedog storage versus drought trigger curves Modelled Alert 80.0 Application Enforce 70.0 Emergency storage Dead water Clywedog % full /01/ /01/ /03/ /04/ /05/ /06/ /07/ /07/ /08/ /09/ /10/ /11/ /12/1976 Date 105

106 Table B.8 Birmingham Zone Drought Management Options Demand Side Option Name Trigger Demand saving Implementation timetable Permissions required Risks Risk to environment Environmental impact Studies undertaken Monitoring requirements Mitigation Actions Other impacts Minimise exports from Birmingham Normal operation Up to 20 Ml/d Ongoing None None provided water available elsewhere None None None None None None 106

107 Table B.9 Birmingham Drought Zone Drought Management Options Supply Side Option Name Trigger Demand saving Implementation timetable Permissions required Risks Risk to environment Environmental impact Studies undertaken Monitoring requirements Mitigation Actions Other impacts Operate system within normal operating parameters Raise awareness in Company and with EA and liaise with Welsh Water over situation Convene Drought Action Team and liaise with the EA Liaise with SSW over projected use of River Severn Consider use of Trimpley to support Normal operation Clywedog or Elan Res Storage Alert line Clywedog or Elan Res Drought Warning Trigger Trimpley Control Curve Trimpley Control Curve Ongoing None None None None None None None None Ongoing None None None None None None None None 1 day None None None None None None None None 1 day None None None None None Normal None None Up to 120 Ml/d on Elan Valley 1 day Agreemen Abstraction licence limits. Quality of See Env Impact See Env Impact See Env Impact report See Env Impact report See Env Impact report See Env Impact 107

108 Frankley to maintain storage in Elan Valley Optimise use of Trimpley and Hampton Loade (SSW) Consider import to Birmingham from Whitacre Review schedule of maintenance at major works Consider Norton and Beechtree Lane Emergency Boreholes Supply to Aqueduct Seek Drought Permits as required Return to normal operations Clywedog or Elan Res Drought Warning Trigger Drought Action Team Drought Action Team Drought Permit Trigger Drought Cessatio n Trigger system t with SSW River Severn water Extra 20 Ml/d into Birmingha m supply Up to 36 Ml/d extra to Aqueduct Increased abstraction to support to Frankley WTW from Severn 1 day None 7 days None 7 days None 28 days DP granted by EA High risk of major discolouratio n in supply to NE Birmingham Plant failure if change is protracted Limited amount available on 5 year rolling licence As Env Impact Assessment report report report None None Birm ham Security of Supply Scheme Water quality in supply Extensive mains flushing beforehand Low None None None None None None None None Env Impact Assessment As Env Impact Assess ment As Env Impact Assessment As stipulated in abstraction licence As Env Impact Assessment None As Env Impact Assessment 7 days None None None None None None None None Note that drought management actions in this zone may be affected by the outcome of the Wye Habitats Directive Assessment that is currently being undertaken by the EA. None None 108

109 Figure B. 8 Birmingham Drought Zone Primary Trigger Elan Valley Reservoirs Elan Valley Reservoirs Drought Control Lines % full simulated % full Storage Alert Line Drought Warning Trigger Trimpley Control Curve Licence Rule Curve Implement summer and winter DP Emergency Level Dead Water Level 0 Lift restrictions Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

110 Figure B. 9 Birmingham Drought Zone Primary Trigger Clywedog Reservoir supplied by the Agency Ressim modelled Clywedog storage versus drought trigger curves Modelled Alert 80.0 Application Enforce 70.0 Emergency storage Dead water Clywedog % full /01/ /01/ /03/ /04/ /05/ /06/ /07/ /07/ /08/ /09/ /10/ /11/ /12/1976 Date 110

111 Table B.10 Forest and Stroud Drought Zone Drought Management Options Supply Side Option Name Trigger Demand saving Implementation timetable Permissions required Risks Risk to environment Environmental impact Studies undertaken Monitoring requirements Mitigation Actions Other impacts Operate system within normal operating parameters Normal operation Ongoing None None None None None None None None Raise awareness in Company and with EA and liaise with Welsh Water over situation Maximise Buckshaft source within licence limits Consider using Trimpley into Elan Aqueduct to preserve storage in Elan Valley Convene Drought Action Team and liaise with the EA and Welsh Water Review schedule of maintenance at major works Storage Alert line Ongoing None None None None None None None None Storage Alert line Trimpley Control Curve Drought Warning Trigger Drought Action Team Up to 4 Ml/d Ongoing None None None None None None None None Up to 120 Ml/d into Elan Aqueduct Ongoing None None See Env Impact report See Env Impact report See Env Impact report See Env Impact report See Env Impact report 1 day None None None None None None None None 7 days None Plant failure if change is protracted See Env Impact report Low None None None None None 111

112 Liaise with Welsh Water over possible reduction of export Consider use of increased support from Severn Zone Seek Drought Permit as required Return to normal operations Drought Warning Trigger Drought Warning Trigger Drought Permit Trigger Drought Cessation Trigger 7 day None None None None None Normal None None Up to 10 Ml/d 1 day None None None None None None None None Increased abstraction at Wyelands 28 days DP granted by EA As Env Impact Assessment As Env Impact Assessment As Env Impact Assessment As Env Impact Assessment As Env Impact Assessment As Env Impact Assessment 7 days None None None None None None None None None Note that drought management actions in this Zone may be impacted by the outcome of the Wye Habitats Directive Assessment which is currently being undertaken by the EA 112

113 Figure B. 10 Forest and Stroud Drought Zone Primary Trigger Elan Valley Reservoirs Elan Valley Reservoirs Drought Control Lines % full simulated % full Storage Alert Line Emergency Level Drought Warning Trigger Trimpley Control Curve Licence Rule Curve Implement summer and winter DP Dead Water Level Lift restrictions Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

114 Table B.11 Oswestry Drought Zone Drought Management Options Supply Side Option name Trigger Demand saving Implementation timetable Permissions required Risks Risk to environment Environmental impact Studies undertaken Monitoring requirements Mitigation actions Other impacts Operate system within operating parameters Normal operation Ongoing None None None None None None None None Raise awareness in Company and with EA Consider re-use of Llanforda liaise with United Utilities Review schedule of maintenance at major works Consider use of increased support from Vale of Powys Zone Return to normal operations Storage Alert line Ongoing None None None None None None None None Drought Action Team or Director of Water Services Up to 7 Ml/d 14 days None Storage Alert line 7 days None Drought Cessatio n Trigger Change of water quality into supply Plant failure if change is protracted None None None None None None Low None None None None None Up to 10 Ml/d 1 day None None None None None None None None 7 days None None None None None None None None 114

115 Figure B.11 Oswestry Drought Zone - Primary trigger Clywedog Reservoir supplied by the Agency Ressim modelled Clywedog storage versus drought trigger curves Modelled Alert 80.0 Application Enforce 70.0 Emergency storage Dead water Clywedog % full /01/ /01/ /03/ /04/ /05/ /06/ /07/ /07/ /08/ /09/ /10/ /11/ /12/1976 Date 115

116 Table B.12 Vale of Powys Drought Management Options Supply Side Option Name Trigger Demand saving Implementation timetable Permissions required Risks Risk to environment Environmental impact Studies undertaken Monitoring requirements Mitigation actions Other impacts Operate system within normal operating parameters Normal operation Ongoing None None None None None None None None Raise awareness in Company and with EA Review schedule of works at Llandinam and Llanwrin Consider using Trimpley into Elan Aqueduct to preserve storage in Elan Valley Return to normal operations Storage Alert line Ongoing None None None None None None None None Storage Alert line Ongoing None Trimpley Control Curve Drought Cessatio n Trigger Up to 120 Ml/d into Elan Aqueduct Ongoing None None Plant failure if change is protracted None None None None None None See Env Impact report See Env Impact report See Env Impact report See Env Impact report See Env Impact report See Env Impact report 7 days None None None None None None None None 116

117 Figure B. 12 Vale of Powys Drought Zone Primary Trigger Clywedog Reservoir provided by the Agency Ressim modelled Clywedog storage versus drought trigger curves Modelled Alert 80.0 Application Enforce 70.0 Emergency storage Dead water Clywedog % full /01/ /01/ /03/ /04/ /05/ /06/ /07/ /07/ /08/ /09/ /10/ /11/ /12/1976 Date 117

118 Table B.13 Stafford and Telford Drought Zone Drought Management Options Supply Side Option Name Trigger Demand saving Implementation timetable Permissions required Risks Risk to environment Environmental impact Studies undertaken Monitoring requirements Mitigation actions Other impacts Operate system within normal operating parameters Normal operation Ongoing None None None None None None None None Raise awareness in Company and with EA Convene Drought Action Team and liaise with the EA Review schedule of maintenance at major works Return to normal operations Storage Alert line Ongoing None None None None None None None None Drought Warning Trigger Drought Warning Trigger Drought Cessatio n Trigger 7 days None Plant failure if change is protracted Low None None None None None 7 days None None None None None None None None Note that in this Zone we are accommodating the EA s National Environmental Programme initiative by assessing the potential for sustainability reductions at 11 of our sources. This will not be affected by any drought management actions. 118

119 Figure B. 13 Stafford and Telford Drought Zone Primary Trigger Tittesworth Reservoir 119

120 Appendix C Relevance to Strategic Environmental Assessment Directive This appendix contains a detailed discussion on the interpretation of the legislation relating to the Strategic Environmental Assessment Directive. For brevity it paraphrases the relevant text. The relevant references in full are 1. Statutory Instrument 2004 No Environmental Assessment of Plans and Programmes Regulations EU Directive 85/833 on the assessment of the affects of certain public projects on the environment as amended by Council Directive 97/11/EC 3. EU Habitats Directive (92/43/EEC) Part 2 sections 2(a) and (b) of Statutory Instrument 2004 No 1633 (Environmental Assessment of Plans and Programmes Regulations 2004), define which plans require environmental assessments. In this context, such plans are defined as (a) being prepared for agriculture, forestry, fisheries energy, industry, waste management, water management, and (b) which set the framework for future development consent of projects listed in Annex I of EU Directive 85/337. On this list water resource transfer schemes of more than 100 million cubic metres per year are included, but transfers of piped drinking water are excluded. It is important in this context to note that the Drought Plan is not dealing with future development. The Plan describes a series of actions we would undertake to monitor and manage its water resources in a drought and thereby preserve water supplies to its customers during such times. As such this is an emergency plan which may or may not be required. It is not a development plan. Part 2 section 3 of this SI refers to Article 6 of the EU Habitats Directive (92/43/EEC). This Article requires Member States to establish conservation measures corresponding to the ecological requirements of the natural habitats in the affected area. Action must be taken to avoid damage to and deterioration of natural habitats and disturbance of species for which areas have been designated. Part 3 of this Article requires that appropriate assessments be undertaken of the implications of the plan for the site s conservation objectives. It is important to note that in this context, we have commissioned environmental consultants to undertake environmental assessments of the impacts of the Plan. Where the Plan prescribes actions that will potentially affect natural habitats and ecosystems. Part 4 of Article 6 allows for imperative reasons of overriding public interest including those of a social and economic nature to overrule any negative assessment of a site that might place restrictions on a plan. This however, is conditional on adequate compensatory actions being taken. 120

121 This is interpreted to mean that standards of public health afforded by an adequate and safe water supply, qualify as overriding public interest. The overall interpretation of this is that Drought Plans do not fall within the scope of the SEA Directive. They are seen as short term contingency arrangements that protect the supply of potable water to support human health and well being, i.e. an essential public requirement. They are not long term development plans and are not part of our strategic development objectives. Nevertheless, whilst a formal strategic environmental assessment is not being carried out, an impact assessment of the plan on the local environments and ecosystems it will affect is being conducted. This will be supported by a routine monitoring plan that will be agreed with the Agency. 121

122 Appendix D This is our statement of response to the stakeholder comments. It was originally published on our website in September Where we have made changes to this Plan as a result of these comments, a reference is made to the specific section of the Plan where the change is discussed. Severn Trent Water - Draft Drought Plan Statement of response to consultees comments Following the publication of our draft Drought Plan on our website on June 14 th, 2006, we received from DEFRA letters with comments from 11 consultees. This is our statement of response to these comments. We also explain how we intend to address the issues raised in these comments in our final Drought Plan, which will be available by mid-summer In accordance with the DEFRA Guidance, we have replied to all consultees who commented on our Plan, and we have sent a copy of this statement to DEFRA. We sent out over 130 letters to Government and NGOs to make them aware of this consultation. The 11 organizations which commented were:- Bolsover District Council Derbyshire County Council Forest of Dean District Council Anglers Conservation Association OFWAT Environment Agency Nottinghamshire Wildlife Trust Cherwell District Council Herefordshire Council Countryside Council for Wales Consumer Council for Water Midland A further 6 letters were received but these did not offer any comments. These were received from:- Stafford Borough Council South Staffordshire Council Erewash Borough Council Borough of Telford and Wrekin Federation of Small Businesses Peak District National Park Authority 122

123 There were a number of similar comments covering common issues, and these are dealt with collectively in 15 sections lettered A to O. Where a correspondent made a comment that was specific to their interest, this is dealt with individually. The 15 sections are:- A. Quality of reproduction of the Plan on our website B. Accessibility of the Plan C. Leakage D. Water metering E. Ecological impact F. Civil contingency arrangements G. Frequency of drought occurrences H. Differentiating between Ordinary Drought Orders and Emergency Drought Orders I. Wider liaison during a developing drought J. Points raised by the Environment Agency K. Range of consultees L. Impact of climate change M. Impact on biodiversity N. Choice of Drought triggers O. Relevance to the Strategic Environmental Assessment (SEA) Directive A. Quality of the reproduction of the Plan on our website A number of correspondents pointed out that there are some minor points of clarity required, none of which detract from the substance of the Plan. Included in this is the clarity of the control lines shown at the rear of the Plan. Our response is that these issues will be addressed in the reproduction of our final plan. B Accessibility of the Plan Bolsover DC and OFWAT pointed out that not all members of the public have access to the internet and hence cannot easily access the Plan. Our response is that the DEFRA Guidance does not specify that members of the public should have access to the water company drought plans. The guidance specifies a number of representative bodies of councils and associations including the Consumer Council for Water Midlands whose remit is specifically to represent customers. We wrote to all these who operate in our area, alerting them to the existence of our plan. We believe this complied with the intent and spirit of the guidance. In this context OFWAT also pointed out that they did not receive a copy of our draft plan. Our response is that we wrote to OFWAT on 9 th November 2005 inviting comments on our proposal to revise our plan and asking for any initial views on this. Shortly 123

124 after (November 11 th ) they replied saying they had no comments. We interpreted this to mean they did not wish to receive a copy of the draft plan. We can only apologise for this misunderstanding and hope that their access to the plan via the website did not hinder their appraisal of its contents. C Leakage Bolsover DC, the Countryside Council for Wales, Herefordshire Council, the Consumer Council for Water Midlands, and the Anglers Association pointed out that our level of leakage is unacceptably high when we may ask customers to limit their use of water during rare drought summers. Our response is that leakage reduction is one of a number of key activities that are funded through the Periodic Review of prices made by OFWAT. We have agreed the target economic level of leakage with OFWAT. This ensures that the charges to our customers are balanced between being reasonable yet with an acceptable associated risk of occasional restrictions on supply. In times of drought, we give a very high priority to increasing leakage control in those areas where it is needed most. See section 2.4. D Water metering Bolsover DC, the Countryside Council for Wales and Cherwell DC all raised points about water metering. They pointed out that metering is the obvious method to regulate demand and promote water conservation. Nevertheless, any metering policy must address customers who are poverty bound and have difficulty in paying for such essential services. A tariff based system was suggested that provides a free basic quantity but yet charges for excessive use. Our response is that we are aware of potential hardships which some tariffs might introduce. The question about which tariffs are fairest is still up for debate, and there is also the wider uncertainty about how much water, if any, might be sustainably saved in future droughts with different metering policies and tariffs. We will be reviewing our domestic metering strategy before our next Business Plan due in See our Strategic Business Plan 2008 and sections 2.3 and 3 in this Plan E Ecological impact Bolsover DC, the Countryside Council for Wales (CCW), and the Anglers Association pointed out that we should assess the ecological impact of each drought provision on the ecology of the rivers and specifically the fisheries. Our response is that impact assessments are being completed to the Environment Agency s requirements for each site where we have identified the need for a drought permit. These will be available by the time the final Plan is published in mid Once these are available we will discuss the findings with the Environment Agency and refer to any specific points raised by these correspondents. 124

125 These assessment reports are available separately to this Plan copies can be obtained directly from us. They are discussed in section 6.1 of the Plan CCW also warned against assuming that a hosepipe ban would ensure the granting of a drought permit. Our response is that we do not, and will not, assume this. We will apply for the drought permits as the situation requires, whilst recognising that the decision to grant such powers rests with the Environment Agency. See sections 2.4 and 2.7 F Civil contingency arrangements Derbyshire CC pointed out that during severe and protracted drought situations there will be the need for us to engage with Regional Civil Contingencies Groups. This is to ensure full awareness of the situation exists at all appropriate levels of local and regional government. This will ensure that unnecessary water consumption is reduced and the public s response to the situation is appropriate. Our response is that this is reasonable and correct, and we are fully engaged with such groups in this respect. See table B2. G Frequency of Drought occurrences Forest of Dean DC and the Countryside Council for Wales (CCW) questioned whether our estimation of the frequency of requiring demand reductions (one year in 30) is realistic. Our response is that we have used our regional resource model to simulate the operation of our system. This draws on a rainfall and river flow database covering the 80 years since Through this we have simulated how we will manage current levels of demand over this 80 year period. This has demonstrated that, on average, we meet all demand in all summers in this period on all but 3 occasions. Hence, we have confidence that on average we will only require significant demand reductions (hosepipe bans) during three summers in this 80 years period. (Or approximately 3 summers per century). See section 7. CCW suggested that we use a predictive method to assess when future droughts would occur that would have an adverse impact on riverine ecology. This should be the base of our frequency of hosepipe bans. Our response is that we know of no scientific process that can predict when future droughts will occur. Our estimation is based on statistical likelihood estimation that draws on historic records of observed drought sequences. We will be happy to explain this process to CCW if required. H Differentiating between Ordinary Drought Orders and Emergency Drought Orders OFWAT pointed out that we do not differentiate between ordinary drought orders and emergency drought orders. 125

126 Our response is that in our plan, we have not identified the need for any form of Drought Order, other than for the banning of non-essential uses, so a differentiation was not considered necessary. However, other consultees have raised this point, and we will add this clarification to our Plan. See section 2.8. I Wider liaison during a developing drought OFWAT and the Consumer Council for Water Midland (CCWM) asked that they be appraised earlier during a developing drought period. CCWM also recommended that we should explain how we will prioritise customers and businesses with special needs or high dependency on water, once drought restrictions develop. CCWM also pointed out that we have no formal procedures that recognise the effort made by customers to reduce demand during drought periods. The Environment Agency also commented that we should ensure full liaison with English Nature (Natural England) and the Countryside Council for Wales as a drought develops. Our response is that, firstly, we shall ensure that we have procedures in place to appraise these consultees during the early stages of a drought. Secondly, we will review our communications plan to address the specific points raised by CCWM, and we have written separately to CCWM with more a more detailed response to the comments they have raised. See table B2. J Points raised by the Environment Agency 1. The Water Resources Zones used in the company s Water Resources Plan differ from the Drought Planning Zones used in this Plan. The Agency s fear is that this difference may hide risks to public water supply during droughts. Our response is that we are reviewing our Water Resources Zones in preparation for the next Water Resources Plan and this will take on board any problems with meeting supplies during drought periods. We will expand the text in the Plan to reflect this. Se section (The following point was also raised by the Nottinghamshire Wildlife Trust). The point is that the Plan, as it stands, contains little information on environmental assessment and monitoring. The final document must contain an analysis of gaps in information and what monitoring will be undertaken to close these gaps It must also identify any mitigating actions and demonstrate that the drought actions will not damage Habitats Directive sites. Our response is that we are completing impact assessments with the help of environmental consultants. These assessments cover all issues raised above, and the reports will be made available over the next 6 months. We will discuss these fully with the Agency and take further guidance from them as is necessary. As E above and Appendix F. 3. The Agency has expressed concern that our action trigger lines do not allow enough time to promote sufficient demand reduction measures between the initial crossing of a drought warning trigger and the point when we apply for 126

127 drought permit powers. Furthermore, the Agency expects our demand reduction measures to include the banning of non-essential uses of mains water, for which we will require a drought order. Our response to this is that we believe that we have modelled the operation of our system adequately and we have satisfied ourselves that we can implement hosepipe bans and other demand reduction measures in the time we have allowed between the relevant trigger and application lines on our control graphs. However, our planning has not necessarily included the application of a drought order to stop non-essential use of water. As a water utility we regard this measure as a last resort for use in the most severe droughts when even drought permits cannot provide sufficient extra resource to sustain demand. We nevertheless do not rule out these measures if the alternative is a drought permit that will cause serious environmental damage. We have agreed to talk further with the Agency on this to explore a solution that is acceptable to all that retains our flexibility to deal with any drought as it develops. See section The Agency also expressed concern that we do not have a clear plan of action to return to normal once we feel that storage in our reservoirs has recovered from the drought period. Our response is that we will ensure that once the trigger to stand-down all drought actions has been reached, then all extraordinary drought actions will be terminated immediately. We will ensure our final plan states this very clearly. See section The Agency also expressed concern that it is unclear how we will manage the process for applying for summer and winter drought permits across a combined summer and winter season. Our response is that we will review the control curves around the switch between summer and winter drought permit applications to make the transition clearer and add explanatory text to our Plan. See section 2.7 and the revised control graphs in table B. 6. The Agency also commented that four of our drought zones have triggers related to reservoirs outside the zonal boundaries. The expectation is that we must demonstrate that drought management actions can be deployed effectively in these zones. Our response is that we believe that drought actions can be deployed effectively in zones where there are no controlling reservoirs. Nevertheless, we will explain the way this will be deployed more clearly in our Plan. See section The Agency also commented that we have not discussed the issues associated with the drought options we have given. Our response is that we believe that we have given this detail in section B of our Plan. Nevertheless, we will expand the section in our Plan to better describe the sequencing of drought actions across the drought zones, and any issues that are involved in this action. See table B. 8. The Agency expressed the view that our Plan suggests that any hosepipe bans we impose would only apply to the zone in which the sources the ban was protecting were operating. Their view was that we should apply bans over a wider area if necessary. Our response is that we would do that in a drought, thereby maintaining flexibility in our drought management actions. 127

128 We will ensure that this is made more explicit in our final Plan. See section The Agency has proposed that we consider winter hosepipe bans as well as summer bans. Our response is that we believe that a winter hose pipe ban yields little or no demand saving, and our customers are likely to see this as silly unless it is part of a sensible overall programme of measures. We will, nevertheless, not rule out such a demand restriction where a significant saving can be expected. We will reflect this in the text of our Plan. See section The Agency advised that a demonstration of leakage reduction at zonal level will be required for any drought permit application. Our response is that we recognise this as a requirement that has existed for a number of years and we will provide all necessary information if the occasion arises. See section The Agency has asked for clarity on the circumstances under which we would apply for a drought permit at Trimpley. Our response is that we will review how our Plan explains these circumstances, and liaise further with the Agency to clarify the situation to their satisfaction. We have already opened discussions with Dwr Cymru Welsh Water on the interaction between the Trimpley Permit and any Drought Permit or Drought Order that they might promote at the Elan Valley. See section The Agency expressed the view that we should not rely on Dwr Cymru Welsh Water to promote any drought powers at the Elan Valley. Our response is that we will always endeavour to work with Dwr Cymru Welsh Water as we have done in previous years. However, if agreement was not reached we would, of course, take all steps we felt necessary to protect supplies to our customers. See section The Agency asks for clarity on how the Elan Valley Reservoirs control curves triggers a particular drought permit. Our response is that we will clarify this in the final plan. See section The Agency has suggested that for the Vale of Powys Zone we promote a drought permit to increase the annual licence at Llandinam. Our response is that we will discuss this with the Agency. Our view is that we need to explore all options within this zone to maximise the resources under the normal licensing arrangements before such a drought permit is considered. For example, the recent conclusion of the Merrionedd CAMS leads us to believe that our source at Llanwrin might well provide adequate supporting resources for the foreseeable future. This will be part of our discussion with the Agency. 15. The Agency suggests that we clarify our intentions for a number of abandoned or closed sources that we still own. Our response is that we believe our plan lists all sources that we would use, and we give details of why any other sources cannot be deployed. Nevertheless, we will ensure that the situation is made clear in our final plan. See section

129 16. The Agency asks for details of how we will share our licence at Hampton Loade with South Staffordshire Water Plc. Our response is, that we will follow the agreement between our two companies as is given in the licence for this source. We see no reason to change this in a drought period situation but, nevertheless, accept that a flexible approach is essential to maximise reducing resources in times of drought. See section K Range of Consultees Nottinghamshire Wildlife Trust commented that English Nature have not been consulted on this Plan. Our response is that we followed the Guidance issued by DEFRA on who to contact when we published our Plan. English Nature were contacted by letter at the time the Plan was entered on to our website. L Impact of Climate Change Nottinghamshire Wildlife Trust expressed concern that we have not allowed for climate change in our Plan. Our response is that current research in to climate change suggests that it is expected to take place slowly over several decades, whereas our Plan will be updated every three years. Therefore, any perceived changes to our water resources caused by any change to our climate will be adjusted for on a three year cycle. See section M Impact on biodiversity Nottinghamshire Wildlife Trust made the assertion that whilst our company professes a biodiversity action plan, no mention of this is made in our Drought Plan. Our response is that we are undertaking environmental impact assessments at all sites where we may ask for drought permit powers. These reports will address any impacts these actions may have at the particular sites. However, in terms of supporting our BAP, we suggest that it is our Business Plan that reflects our longer term intentions to develop our water resources with biodiversity in mind, rather than the Drought Plan. Furthermore, the Drought Plan is a contingency plan, not a development plan. As such it will only be used should drought conditions develop. (We would also like to point out that none of our potential drought permit sites lie within Nottinghamshire). See section 6.1 N Choice of Drought Triggers The Countryside Council for Wales questioned our sole choice of reservoir storage as a trigger for drought actions. Our response is that whilst we accept that there are a number of indications of drought conditions, we use only reservoir storage as it is this that forms the basis of our water resource system. As such it must be protected against failure, and this is 129

130 what the drought plan aims to achieve. We do not favour using such as rainfall deficit as an indication of drought as situations can arise when a long term rainfall deficit exists but yet reservoir storage can be normal. We would not (and could not) set drought actions in motion just because a long term rainfall deficit existed when our reservoirs were full. See section 4.1. O Relevance to the Strategic Environmental Assessment (SEA) Directive The Countryside Council for Wales warned that the Plan may come under the SEA Directive. Our response is that we considered this in some detail when the Plan was compiled, and our reasoning why we do not think the Directive applies is discussed in Appendix C of the Plan. We recognise the concern CCW shows but stand by our decision. The environmental impact assessments will be available by spring 2007 which we believe will be adequate in this respect. See Appendix C. 130

131 Appendix E The DEFRA Direction of April 2008 We received the following Direction from The Secretary of State for the Environment in April The Direction advised us to review how we will tell people about the risk of drought and, to ensure that we have assessed an adequate range of drought scenarios in putting this Plan together. We are regularly updating our media and publicity campaigns and we believe that we are proactive in doing this, especially when emergency and abnormal operating conditions develop. Nevertheless, as incidents and challenges occur we are open to comment and constructive dialog with all our stakeholders and this will be our attitude to stakeholder management in a drought. We are particularly keen to ensure that vulnerable groups within our customer base are adequately served especially if we have to impose supply restrictions in severe droughts. Our proactive and flexible approach dealing with customer service issues will ensure this is achieved. Additionally, we believe we have covered a satisfactory range or drought scenarios in our planning. This is discussed in sections 2.4 and 4.2. We have also addressed the additional matters cited in the Direction in the following sections of our Plan:- 2 a see section b see section c - see section d see section e see section