Campaigners and politicians fought hard to include clauses on storm overflows to cut sewage pollution including through wider use of nature-based solutions (NBS) in the UK Environment Act. But have water companies’ investment plans responded to the timescales and targets the act sets them by putting engineered solutions before green ones?
Supporters said the legislation would push the water industry to clean up its act and unleash the benefits – resilience, nature, amenity and wellbeing – of NBS deployed on a large scale. But that sea-change is notably absent from the water industry’s latest plans.
Instead, water companies have responded to the act – and to outrage about sewage pollution from public and the regulator – by preparing a massive programme of new concrete pouring. The next five-year investment round from 2024, PR24, is putting grey solutions before green ones.
That approach pushes some companies counter to their net-zero targets, raising both their embodied and operational carbon emissions. That surely runs counter to what campaign groups hoped toughening up the act would achieve.
Campaign groups, MPs and supporters in the House of Lords fought passionately to strengthen the storm-overflows clauses as the legislation passed through the UK parliament. Government made several concessions, including progressive improvements in spill reductions, frequent reporting and continuous monitoring of outfalls.
That created the Storm Overflows Discharge Reduction Plan (SODRP) to set the timescale to reduce overflow spills to 2050. Campaigners felt the three-decade plan was unambitious and too slow. The water industry felt the opposite. Many shuddered at having to deliver such huge improvements so soon.
That included increasing sewage-treatment works’ capacity and cutting the surface water their combined sewers discharge. Doing that increases capacity for foul sewage, so that combined sewers discharge less frequently into rivers, bar heavy rainstorms.
There are several ways to do this. You can build hard-engineered tanks underground to store surface water while it rains. You can disconnect surface-water drainage from combined networks using sustainable drainage systems (SuDS), and plant these to benefit nature and place-making. Or you can optimise flows within the system – where capacity allows it – to hold back stormwater to minimise spills.
The pragmatic and effective solution is probably to combine all these. SuDS and NBS are not panaceas but we should, ideally, use them far more widely.
SuDS advocates argued for the Environment Act to harness the huge investment it will take to tackle sewage pollution to deliver as many benefits as possible.
How? By prioritising surface-water removal in combined-sewer catchments that must also manage surface-water flood risk. Or by using green SuDS to manage surface water at the surface, not in a buried pipe, enhancing public areas’ biodiversity and air quality and providing shade in summer to beautify the streetscape.
That resonated with select committees and government. It shaped SODRP and a raft of guidance to water companies, directing various plans that feed into the coming price review in 2024 (PR24), the Strategic Priorities Statement (SPS) from Defra to Ofwat, the Water Industry National Environment Programme (WINEP) methodology, guiding principles for Drainage and Wastewater Management Plans (DWMPs) and more.
The latest WINEP guidance tells companies to increase the use of catchment- and nature-based solutions, “wherever they are feasible and appropriate”.
The DWMP guiding principles “expect companies to consider green infrastructure, nature-based and low-carbon solutions”.
The SPS urges companies to “significantly increase” use of nature- and catchment-based solutions. Government expects “companies and regulators to work towards delivering these solutions as a matter of preference”, it says.
The guidance is also pushing for more partnership working and funding – an essential component of delivering NBS, especially at scale.
For the current, 2019 investment period WINEP is driving spend of some £4.8 billion on environmental improvement for England and Wales.
PR24 – with SODRP projecting a £56 billion sewage clean-up programme to 2050 – looks set to transform the scale of investment. The 2023 WINEP will dwarf spending seen in previous rounds. Some companies plan to spend more on their own environmental-improvement programmes than the current WINEP spent nationwide.
Investment to 2035 will target the most harmful overflows. The law requires companies to deliver against the SODRP targets and timescales. That means huge bills and no margin for error on performance. Companies are sticking to what gives greatest certainty on cost and on regulatory compliance: traditional engineering.
That trend became apparent last summer when the draft DWMPs were published. Many plan traditional near-term solutions, pushing nature-based approaches towards the 25-year planning horizon.
That prompted the Environment Agency (EA) and Ofwat to write to companies in October to express their concerns about the draft plans. Many DWMPs lacked evidence to explain their chosen solutions.
Ofwat and the EA had “expected companies to provide appropriate evidence in their plans for prioritising traditional grey solutions… over more sustainable, green solutions”.
The companies had failed to give satisfactory evidence to support timescales and delivery-centric justifications for choosing grey solutions, they said.
Timescales are challenging for various reasons. The SODRP has demanded pace. But time was also tight, between when the regulator issued its guidance to companies and the final deadline for their plans.
The WINEP guideline gave companies nine months to compile their plans. Initially the DWMP guiding principles, published in August, gave companies five months, expecting the final plans in January. The deadline is extended to May for companies that need more time.
Nature-based solutions need time and collaboration to work well. But to cut sewage pollution quickly and to promote NBS, campaigners and regulators pushed through a regulatory package that asks a lot of water companies.
The water companies – who fear failure and expect no wriggle-room – have responded by going with what they know.
Has this driven the most sustainable outcomes for people and the environment long-term? No. Will it rebuild trust in water companies while helping them to deliver widespread environmental recovery? Absolutely not, certainly in the short-term. Is it what campaigners behind the Environment Act wanted to see? Surely not.
As the proverb goes; if you want to go fast, go alone. If you want to go far, go together. It would put us on a much more sustainable trajectory to focus less on speed of delivery, and more on delivering the best outcomes through strong partnership working.
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