Cambridge Water Company Updated Draft Drought Plan – Schedule of Representations and Responses
March 2012
Ref.
Representation
Environment Agency
CW Response
EA.1.1
We have re-evaluated this option, and have concluded that it is no
longer necessary, in the light of other operational changes that are
being implemented. We have removed the option from our
updated draft plan, and have explained the justification for doing so
below.
The environmental impacts drought option S2 (duplication of the
Brettenham delivery main) have not been sufficiently assessed. Impacts
from its construction and operation should be assessed and details of its
environmental impacts should be included in the final plan. CW should
provide a project plan of the option, showing how any missing information
and permissions would be obtained in time to implement the option when
needed.
The supply-side option to duplicate the delivery main from
Brettenham Pumping Station was a legacy from a previous drought
plan, which also contained an option to upgrade the Brettenham
pump – an action that was taken during 2007, following the
previous drought. The upgraded pump was sized to deliver the full
licensed output of the site, but at a relatively high cost, since high
friction losses would be generated in the existing delivery main at
those high flows. Brettenham remained a key site for its ability to
deliver low-nitrate water to blend with the higher-nitrate water
pumped from a neighbouring source at Euston, which added to the
justification for retaining the option in the original draft plan.
However, the agreement to proceed with the installation of a nitrate
removal plant at Euston, due to commence later in 2012, together
with the decision to recommission Horseheath, means that the
Brettenham option is no longer cost-effective. It has also been
highlighted, by consultees, as likely to impact on nearby
environmental sites. For these reasons, it has been decided to
omit this option from our updated draft plan.
Table 2.4 of our drought plan has been updated to demonstrate
our continued ability to maintain security of supply for our
customers, in the light of the above decision.
EA.1.2
CW should review what alternative supply-side options to the Brettenham
main duplication may be more available to deliver similar volumes of water
in a drought.
We are confident that, with the supply-side option we are already
planning to implement (the recommissioning of Horseheath
Pumping Station) we can continue to supply our customers in
times of drought, without the need for further supply-side options.
Our updated draft plan explains how we have arrived at this
conclusion.
EA.1.3
A Habitats Regulation Assessment (HRA) or a Strategic Environmental
The omission of option S2 from our updated draft plan has
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Cambridge Water Company Updated Draft Drought Plan – Schedule of Representations and Responses
March 2012
Assessment (SEA) has not been carried out on the draft drought plan.
We recommend that CW carries out a screening exercise to determine
whether a HRA and/or SEA should be carried out on the draft plan. Once
the environmental impacts of option S2 are understood, CW should
assess the monitoring and mitigation measures that may be required to
protect the interesting features at the Breckland Farm SSSI.
removed the need to carry out a HRA or SEA. Thus, sections
4.1.1.1 and 4.1.1.2 of our draft plan remain unchanged.
EA.2.1
CW has not presented sufficient information to detail its proposed
approach to temporary restrictions. The draft plan does not demonstrate
appropriate consideration of the phasing or order of implementation of
temporary water use restrictions or what exemptions and concessions to
these restrictions the company might implement. Without this information
customers and stakeholders cannot determine how they would be
impacted during a drought. This may also result in increased consultation
requirements during a drought, potentially affecting lead times for option
implementation.
We have reviewed our approach and included additional
information in the plan on the implementation of temporary water
use restrictions which expands on the phasing/timing of restrictions
and exemptions that we would consider implementing. We have
updated the draft plan to reflect this.
EA.2.2
CW has not presented information on how its proposed approach to the
implementation of temporary restrictions would operate successfully with
those of neighbouring companies.
We have updated our draft plan to include a section outlining the
steps we would take to ensure the most beneficial approach with
regional companies.
EA.3.1
By not assessing the environmental impacts covered in EA.1.1 above, CW
has failed to comply with Direction 4(e) in the Drought Plan Direction
2011.
With the removal of option S2 from our updated draft plan, this is
no longer an issue.
EA.3.2
As the plan sets out no mitigation measures, any permits and approvals
needed to implement those measures have also not been considered.
Thus, CW has failed to comply with Direction 4(f) of the Drought Plan
Direction 2011.
With the removal of option S2 from our updated draft plan, this is
no longer an issue.
EA.4.1
It is not clear in the plan how and when CW would apply for a drought
order to restrict demand as part of its actions to manage demand during a
drought. CW’s plan should differentiate between drought actions it may
use within the range of conditions it plans for, and those it would only
need under an extreme drought or unprecedented drought conditions.
Section 3.0 of our updated draft plan makes clear to our customers
that drought orders are expected to be needed only under
unprecedented drought conditions.
EA.5.1
We consider that CW has provided satisfactory opportunities for
customers and stakeholders to make representations on its draft plan.
We are pleased that the Agency has recognised our efforts to
consult widely on our draft plan.
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Cambridge Water Company Updated Draft Drought Plan – Schedule of Representations and Responses
March 2012
Natural England
NE.1
We have concerns over supply side option S2, to duplicate the
Brettenham delivery main, whose route would be through Breckland
Farmland SSSI (which is part of the Breckland SPA). We would expect
CW’s drought plan to contain a more detailed environmental assessment
and a project plan outlining possible environmental impacts and
permissions required. CW should not wait until the relevant drought
trigger is breached before carrying out these assessments.
This is covered in our response to EA.1.1 above.
NE.2
CW has provided NE with a Habitats Regulation Assessment (HRA) for
the operations side of its drought plan, and NE accepted there would be
no significant effect on East Wretham Heath SSSI (part of Breckland
SAC).
No further comment.
NE.3
In the light of the further information it provides for option S2 (see NE.1
above) CW will need to amend the determination of whether its drought
plan falls within the scope of the Strategic Environmental Assessment
(SEA) Directive.
This is covered in our response to EA.1.3 above.
NE.4
NE welcomes every opportunity to work with CW on drought planning and
management, ensuring that the requirements for protecting and enhancing
the environment needs are met and there is adequate opportunity for
developing the most sustainable solutions. In particular, NE is pleased
that CW’s drought plan outlines how it will liaise with NE and ensure its
early involvement in discussions on potential drought permits, to allow
enough time to consider the environmental implications.
We are encouraged that NE recognises the efforts we have made
in our plan to protect the environment, and we are committed to
continuing to work together to develop sustainable drought
solutions.
Consumer Council for Water – Central and Eastern Committee
CCW.1
There is insufficient detail on how CW will implement its temporary
customer water use restrictions in a drought.
This is covered in our response to EA.2.1 above.
CCW.2
The draft plan does not demonstrate appropriate consideration of the
phasing or order of implementation of temporary water use restrictions or
what exemptions and concessions to those restrictions CW might
implement.
This is covered by our response to EA.2.1 above.
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Cambridge Water Company Updated Draft Drought Plan – Schedule of Representations and Responses
March 2012
CCW.3
CW’s approach allows one week for representations to be made and
considered. Without the detailed information in the draft plan relating to
phasing, exemptions and concessions, one week may not be sufficient to
satisfactorily alert customers during a drought and deal with their
responses.
This has been addressed in our updated draft plan through the
additional information provided in response to EA.2.1.
CCW.4
Did CW consult with its customers during the pre-consultation period? We
were expecting to see some customer research, and also some examples
of customer leaflets/messages (but perhaps these details are not
necessary to include in the plan).
We did not consult directly with customers at the pre-draft stage,
but were guided by the response received from CCWater, which
highlighted the need for the plan to be customer-friendly; for the
consultation process to be as wide as possible – particularly with
regard to our new powers under the Flood and Water Management
Act; for an explanation of the reasoning behind our selection of
supply- and demand-side drought options; and for a
comprehensive communications plan. We believe that our
updated draft plan addresses all these issues.
River Mel Restoration Group
RMRG.1
The RMRG was formed in 2005 with the aim of improving the River Mel
and its habitat diversity. The group works closely with local environmental
bodies, and has received an award from CW for its conservation work.
The Mel is a rare spring-fed chalk stream which supports a diversity of
wildlife. It is one of CW’s 6 drought indicator rivers, 3 of which, according
to CW’s drought plan, have to be under severe stress, if not completely
dry, before CW takes any emergency measures to reduce public
consumption of water.
Our drought indicator sites are located at six of our sourceworks
boreholes, selected to be representative of groundwater conditions
across the aquifer as a whole. The drought action trigger levels,
which are different for each indicator site, have been determined
by reference to the sites’ behaviour during historic drought
sequences.
RMRG.2
Historically, in times of low flow and drought, the EA has provided pumped
support, but this support failed at the end of November 2011, and the
upper reaches of the Mel have been dry since that time. The group
understands that the EA is questioning the future sustainability of
maintaining pumped support to the river: this is an extremely worrying
change to the current policy, which will impact upon the river, and it should
be reflected in the proposed plan.
This query refers to the River Rhee Support Scheme, operated by
the Environment Agency. The scheme is not designed to mitigate
the effects of a severe or prolonged drought. There have also
been mechanical problems with the pump, and it is understood that
the Agency has been in regular communication with the Group
about this issue. We consider that this is a matter for the
Environment Agency and is outside the scope of our drought plan.
RMRG.3
CW’s current drought plan has not saved the River Mel. In the group’s
opinion the draft drought plan is inflexible, and does not respond quickly
enough to the early indicators of drought. The present drought has
severely damaged 6 years work on the river which has accounted for
The purpose of our drought plan is to set out how we can continue
to supply our customers in the event of drought, whilst ensuring
that the environmental impacts of our management actions are
minimised. Droughts are naturally occurring events, the
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There is no reference to “indicator rivers” in our drought plan.
Cambridge Water Company Updated Draft Drought Plan – Schedule of Representations and Responses
4500 volunteer man hours.
March 2012
environmental impacts of which are normally reversible when
normal conditions return. Our drought indicators are intended to
provide a robust indication of when our resources are impacted by
drought so that we are able to respond in an appropriate and timely
way. We work closely with the Environment Agency to ensure that
our water abstraction activities are not detrimental to the aquatic
environment, and have undertaken extensive investigations at
sensitive sites to assess and mitigate the environmental impacts of
our abstractions.
Cam Valley Forum
CVF.1
The CVF is a small group of local people who aim to conserve the river
environment in the face of pressures from urban development, intensive
farming and climate change. The forum works with other groups to
discuss catchment issues and deliver practical improvements to the river
(Cam) and its tributaries. CVF is happy that CW has updated its previous
plan and appreciates the opportunity to respond, in the hope that the
consultation process is genuine, that respondents’ views are taken
seriously and, where relevant, incorporated into the final plan.
We are determined to make the consultation process meaningful,
by adhering to the published guidance. The processes set out in
the guidance are designed to ensure that water companies take full
account of representations received, when preparing their final
drought plans.
CVF.2
CVF has serious doubts about the lack of holistic thinking in the
production of the draft plan. The forum would like to have seen evidence
of a clearer appreciation of the mechanisms that deliver water to the chalk
aquifer, and how the adverse effects of drought can be met in a more
sustainable and effective way. CVF observes that the plan treats water as
a commodity with no sense that it supports life, and the group has
concerns about the social and environmental gaps.
Our statutory obligation, within our drought plan, is to demonstrate
that we can continue to discharge our duty to supply adequate
quantities of wholesome water during a period of drought, with as
little recourse as reasonably possible to drought orders or drought
permits. We believe that our draft pan fulfils that obligation,
through a balance of demand-side and supply-side management
options. None of the actions set out in our drought plan requires
us to exceed the terms of our abstraction licences.
CVF.3
CVF would like to see a deeper understanding of the adverse effects of
drought on the natural environment. The forum believes that the plan
should lay more emphasis on the whole water system and not just the
mathematics of water supply and demand.
This is covered in our response to CVF.2 above.
CVF.4
There have been changes to the countryside which have affected local
stream flows, including: the quantities extracted for domestic and
agricultural purposes; and changes in land use. CVF believes that, as a
result, the countryside is less robust to face extreme conditions such as
No further comment.
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Cambridge Water Company Updated Draft Drought Plan – Schedule of Representations and Responses
March 2012
drought. Water catchment plans encouraged under the Water Framework
Directive (WFD) should help to alleviate this.
CVF.5
CW’s plan mentions difficulties at several environmental sites. The 1976
drought caused Nine Wells to lose its SSSI status due to a loss of aquatic
invertebrates. How is this loss measured, compared with the value of
water extracted?
We are unable to answer this specific question. However, we have
worked closely with the Environment Agency and Natural England
over the last 10 years, under the National Environmental
Programme (NEP), to examine the impacts of our abstractions at a
number of environmentally-sensitive sites. Where our operations
have been shown to have a detrimental impact, we have put in
place appropriate mitigation measures.
CVF.6
In re-commissioning Horseheath Pumping Station, does CW have the
capacity to treat the Cryptosporidium problem which led to the original
decommissioning of the site? What are the implications for the cost of
treatment and the equipment required?
As part of our feasibility studies we reassessed the potential risks
at Horseheath, in line with current water quality guidance, and
concluded that the risk from Cryptosporidium had reduced, mainly
as a result of a change in farming practice at a nearby location.
However, we cannot classify the risk as low, due to the potential
from rapid recharge. Our proposed treatment therefore includes
for inactivation of Cryptosporidium.
Since the site was originally decommissioned the Regulations have
changed, and they now allow for the use of ultraviolet (UV) as a
suitable treatment option to inactivate Cryptosporidium. Thus the
treatment proposed will be UV followed by marginal chlorination:
this process is similar to that employed at another of our production
sites, and the operating costs are similar to those of our other
sourceworks.
CVF.7
Although the plan is rightly concerned with droughts, it does not reflect
any great degree of concern or a change of behaviour to address the
problem (i.e. general river health) which exists now. CVF thinks CW is
complacent in its view that there is a healthy surplus of deployable output
against demand, and that this is forecast to continue in the foreseeable
future, given the degree of housing development which is planned to take
place in the next 15 years. Climate change is an additional threat. Are
new water storage reservoirs planned, to enable winter extraction in order
to ensure summer supply? There is little realisation that we are already
experiencing low water flows and the resulting damaging impacts on the
environment and the whole water system. We have a situation which
demands serious changes soon and certainly not complacency.
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The purpose of our drought plan is to demonstrate our
preparedness to deal with the consequences of a short-term
drought, by putting in place a succession of management actions
which balance the needs of the environment, our customers, and
other stakeholders. Our drought plan complements our Water
Resources Management Plan (WRMP), which looks at water
availability in the longer-term, and the influences of environmental
pressures (including climate change), new housing developments,
and changes in customer behaviour. We believe that the concerns
raised here by CVF are best addressed under the WRMP process.
Cambridge Water Company Updated Draft Drought Plan – Schedule of Representations and Responses
March 2012
Horticultural Trades Association
HTA.1
The HTA has been working closely with Waterwise to promote a proposed
Code of Practice (CoP) for phased water restrictions in the garden at
times of water shortage. This would provide a pre-emptive phase of
communication to customers before hosepipe bans are introduced. The
HTA has done this for a number of reasons:
Water Efficiency: this is the common objective of the HTA, Defra, EA and
water companies. The proposed CoP would provide an effective and
equitable way to manage water shortages, and is a model widely used in
other countries.
Communication/Consumer Engagement: phased restrictions would
receive the support of the garden retail industry. The HTA could mobilise
its garden centres to communicate water efficiency measures to the
nation’s gardeners: this would generate increased compliance and
achieve greater water savings whilst maintaining all the benefits of
gardening.
Corporate Reputation: the HTA’s proposed phased approach would help
water companies engage more constructively with one third of their
customer base, by helping them to continue gardening for as long as
possible, and deflecting critic on leakage, etc.
GDP Protection: The HTA’s proposals would help to mitigate the losses
suffered by garden centres in the south-east when hosepipe bans were
last introduced in 2006, and would thereby help to protect jobs at a time
when the UK economy is extremely fragile.
The HTA was pleased to see its proposals included in Appendix 5 of the
recently revised UKWIR Code of Practice and Guidance on Water Use
Restrictions (11/WR/33/3), and strongly urges CW to adopt the approach
in its final drought plan.
Margaret Lynch
Page 7 of 9
Our plan follows closely the principles set out in the UKWIR Code
of Practice. We have considered the merits and demerits of
phasing of restrictions and have concluded that, with our small
geographical size and single water resource zone, such an
approach would cause customer confusion and be difficult to
enforce and administer. We have therefore decided not to adopt a
phased approach, and our updated draft plan makes this clear.
The need for effective and timely communication with our
customers and other stakeholders is recognised, and our
commitment to working closely with the HTA, in order to mitigate
the effects of restrictions, has been reinforced in our updated draft
plan.
Cambridge Water Company Updated Draft Drought Plan – Schedule of Representations and Responses
March 2012
ML.1
The River Mel forms part of the boundary to our property, as does the
th
remains of a 13 century moat. The moat dried up in July 2011, and
remained dry until mid-December: this is unprecedented, in our 30-year
experience. Water flow in the River Mel has also been exceptionally low.
The River Mel is a chalk stream, whose summer flow is supported by
aquifer levels. The EA used to support river flows by pumping from
Newsells, but have stopped because levels (at Newsells) are now too low.
A local sewage works also relies on the Mel’s water flow for its proper
operation. We are concerned that recent environmental improvements
will be compromised if flow levels in the river continue to be reduced.
This is covered in our response to RMRG.2 above.
ML.2
Why are the Rest Water Level triggers for Melbourn and Fowlmere set so
much lower than any of the other 6 areas?
The Rest Water Level triggers at individual sites are based on their
individual characteristics and long-term behaviour. They are based
on the statistical probability of the boreholes reaching a particular
level, and there is no link between the trigger levels at individual
sites.
ML.3
Initiation of drought actions, by reference to conditions at 3 out of 6
indicator sites, seems to be too optimistic. This should be lowered to 1.
Our drought indicator sites have been selected to provide a
balanced view of conditions across the aquifer as a whole, as we
were criticised in our previous plan for basing our drought triggers
on data from a single site. We believe this is the right approach.
We closely monitor conditions at all our sourceworks during a
drought, and will take action to modify our abstractions where there
is danger that they would otherwise become unsustainable.
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Cambridge Water Company Updated Draft Drought Plan – Schedule of Representations and Responses
ML.4
In summary, we are concerned that CW’s drought level indicators are too
optimistic, especially for the Melbourn area. This results in depletion of
the aquifer in drought years. It is too easy to abstract water from
boreholes, and deplete rivers, to make up a deficit. Tackling leakage and
more proactive use of restrictions would be a safer route to conserving
this vital resource in dry years.
March 2012
During the past 10 years we have undertaken a series of
investigations into the effects of our abstractions, under extreme
conditions, at a range of environmentally-sensitive sites identified
by the Environment Agency under its National Environment
Programme (NEP). Where those effects have been found to be
detrimental, we have implemented mitigation measures, including
reducing sourceworks output in some cases. Our NEP studies
have been carried out in close co-operation with the Environment
Agency and Natural England, who have expressed their
satisfaction with the outcomes. We continue to fulfil our NEP
obligations during the current 5-year planning period, which ends in
March 2015.
We operate all our sourceworks within licensed limits, which are
set and reviewed by the Environment Agency.
Demand management plays a key role in both our Water
Resources Management Plan (WRMP) and our drought plan. We
have made substantial investment in metering, water efficiency and
leakage reduction programmes, which has seen distribution input
remain stable over the past 15 years, despite a marked increase in
customer numbers over the same period.
London Fire Brigade (a generic response to all water companies)
LFB.1
We would make a request for early consultation through normal
engagement channels in relation to any drought response measures that
that may affect the provision of water for operational fire fighting.
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We are happy to comply with this request.