PR19 – what’s in it for the environment?

Guest blog from David Black at Ofwat – the water sector regulator. 

Improved environmental health has been one of the great successes of the water sector in the past few decades. Since 1989, the work of water companies has led to a 137% increase in the share of UK bathing waters achieving “excellent” status, and wildlife such as otters and lamprey have returned to waters previously too polluted for anything to live in. In addition, since its high in 1994, the amount of water lost through leakage has been reduced by around a third. All of this has helped the UK shed its label as the ‘Dirty Man of Europe’.

Fast forward to the present, and environmental protection and resilience remain high on the public agenda, with decarbonisation, air quality, and pollution of our oceans all grabbing headlines in recent months. The water sector is not immune to environmental challenges, with issues caused by population growth and climate change requiring attention. It’s with these challenges in mind that we put together our 2019 price review (PR19).

Challenging companies

At PR19 our ambition for the environment is high. We will help ensure companies can deliver their statutory obligations and the environmental improvements that customers want and are willing to pay for. To make this happen, we are:

  • challenging companies to reduce leakage by 15% per annum;
  • asking companies to set ambitious targets for per capita consumption (PCC) reductions;
  • challenging companies to set stretching performance commitments on pollution incidents, sewer collapses and wastewater treatment. Companies will face financial penalties if they are not achieving stretching levels of performance;
  • requiring companies to have a performance commitment on reducing abstraction from environmentally sensitive sites;
  • ensuring companies consider the environment as an explicit part of their wider resilience.

Our PCC measure is particularly important, as it requires reductions in the amount of water households and businesses consume. To deliver this, water companies must engage with their customers on the best way to reduce their water use, putting communications at the heart of their operation and promoting a powerful tool in pursuit of environmental improvement – behaviour change.

But PR19 also puts a responsibility on companies to consider the environment in contexts that customers won’t see. A resilient environment is at the heart of a resilient water sector, and our resilience principles explicitly consider eco-system resilience. When planning for how they will deal with unexpected events, water companies will need to consider wider costs and benefits to society and the environment, including the sustainable use of natural capital.

Looking to the long term

The water sector needs to think long term, which is why we are asking water companies to provide assurance that their plans address long-term issues, and set indicative performance commitment levels for at least the next 15 years. This approach helps us to ensure that companies are on a genuinely sustainable path, rather than just responding to short-term incentives or issues. A number of emerging environmental issues – including nano-particles and antibiotics – are set to challenge the sector in the coming years, so it is right that companies expand their planning horizons.

PR19 also harnesses the power of markets in the interests of the environment. In January water companies will publish water resource market information, allowing third parties easy access to information about how they are planning to meet demand over the next 25 years. We are expecting and encouraging third parties to bid to provide services where they spot an opportunity for additional efficiencies. For example, a third party could offer innovative demand side solutions to enable a company to reduce abstraction of water from environmentally sensitive rivers and streams. We are also promoting the development of bioresource markets helping turn sludge waste into valuable energy and fertiliser.

When developing their business plans, we expect companies to actively engage customers and stakeholders to understand their requirements for environmental outcomes and investment. Our methodology indicates where we consider companies’ ambition should be on many issues. But beyond statutory and licence obligations, it is for customers to decide what level of environmental ambition they want and are willing to pay for. Our PR19 framework will ensure that companies will be held to account for delivering more of what matters to customers.

David Black
Senior Director, Water 2020, Ofwat

Read the full PR19 methodology. 

Welcome New Farming Rules for Water

Earlier this month the Government published a set of farming rules for water, establishing a mandatory baseline of good practice that land managers across England must follow. These focus on planning farm operations to reduce the risk of water pollution, conserve soils and promote the most efficient use of nutrients. The rules make sense and are a welcome step that has been some time coming.

Tackling nutrient pollution and soil loss is one of the biggest challenges we face in improving the state of the environment in the UK. Across England and Wales, 2.9 million tonnes of soil are lost from fields every year. Nutrient pollution kills fish and other aquatic animals and can drive a change from plant communities dominated by flowering plants to ones dominated by algae. Ultimately this can lead to toxic algal blooms and pose a risk to the health of humans and animals that come into contact with polluted water. Other sectors, especially waste water treatment, contribute to the problem but across the UK agriculture is responsible for 50% of total nitrogen losses, 25% of phosphorus and 75% of sediment. For predominantly rural catchments, these proportions are much greater.

There is no doubt that there is an urgent need for action, but if the new rules are to play their part in reducing pollution from farming, we need clarity on three things:

  1. what guidance will be available? Farmers must have confidence that their practice is complying and know where they can go for advice
  2. how will these rules help? People need to know what contribution these rules are expected to make to the recovery of waters and, where compliance with these will not be enough, what other combination of regulation and incentive will be applied
  3. how will compliance be ensured? The Environment Agency does not have the resources to monitor and enforce these rules at present

The majority of farmers will already be meeting the requirements set out in the new rules and will not need to make any changes to their operation, as the rules do not raise the bar above what is already required by Cross Compliance under the Common Agricultural Policy (CAP).

They aim to set a fair baseline of practice for everyone so that nobody can seek to gain an advantage by taking risks and imposing some or all of the cost of that risk on others. These rules are also helpful in setting out the expectations of minimum performance for the sector; an essential prerequisite to thinking about what a future system of payments for public goods might look like post-Brexit.

It is not clear how the Environment Agency intends to ensure compliance. This will require clear guidance from Government to ensure that farmers are provided with support and guidance, especially in relation to those rules that expect farmers to take ‘reasonable precautions’ without setting out explicitly what they are. Support for initiatives such as Catchment Sensitive Farming and the Catchment Based Approach will also be essential in providing trusted advice and support.

It is critical that the rules are properly enforced but far from clear that the Environment Agency has the resources to do it. The risk of soil erosion is greatest in the autumn and winter, when soils are most likely to be exposed and rainfall is highest, so inspections designed to identify problems must target that period. Many respondents to the previous consultation raised understandable concerns about privacy if monitoring was done remotely without landowner consent, but there must be a role for technology in identifying problem areas and targeting effort. Detail about how the Environment Agency will achieve adequate compliance monitoring is urgently needed.

These rules will not be enough on their own to drive the recovery of our water environment. The accompanying policy paper states that they ‘fulfil obligations under the Water Framework Directive (WFD)’ but this is a bit misleading. The WFD requires Member States to have controls in place to limit diffuse pollution and there were no such controls in place in England outside Nitrate Vulnerable Zones. However, the overriding obligation arising from the WFD is to enable water bodies to achieve good ecological status and we will still be a long way from achieving that. For example, to meet the targets of the last round of River Basin Management Plans, it was calculated that phosphorus losses due to agriculture needed to be reduced by 28-43%. By contrast, when these new rules were consulted on in 2015, they suggested only a 2.4% reduction in phosphorus. While the published rules might be better than those consulted on, there is still a significant gap. Setting out a road map for closing that gap will be a key challenge for the Government’s 25 Year Plan for the Environment.

The new rules are a welcome first step but there is much still to do if we are to see the recovery we need in our rivers and wetlands.

Simon Wightman
Water Policy Officer, RSPB

#binit4beaches to keep our bathing waters clean

This summer, organisations across the UK – charities including Marine Conservation Society (MCS) and Keep Britain Tidy, water companies, the Environment Agency, Local Authorities and beach managers – have all come come together as part of the #binit4beaches campaign, to highlight the importance of only flushing the 3P’s –  pee, poo and paper –  and always putting wet wipes in the bin.

With sandy coves, sweeping bays and towering clifftops, the UK coastline is as beautiful and unique as anywhere in the world – and with nowhere more than 70 miles from the coast, it should come as no surprise that over 14 million trips are made to our beaches each year (VisitBritain, 2015).

Spending time at the coast is good for our health and wellbeing. In the UK over 600 beaches have been recognised for the importance they play in outdoor recreation and are designated as bathing waters. Each summer, the water at these beaches is sampled and tests are done, sometimes weekly, to look for signs of pollution from sewage, run-off from farmland or even for too much poo from dogs, birds or donkeys.

Any beach which fails these tests, taken over a period of four years, must display a sign at the beach entrance advising visitors not to swim. Investigations will be done to find out where the pollution is coming from and an action plan put in place to stop it reaching the beach in the future. At beaches where pollution can be temporarily increased – due to heavy rainfall – daily forecasts are provided by the Environment Agency, and the local authority or beach owner updates signs at the beach each day. All of this work is done to ensure that people heading to the beach can enjoy a dip in the sea.

Visitors are often unaware that all this work is happening in the background to look after our beaches – but it doesn’t mean that we can’t all do our part to help make sure that they stay clean. Something as simple as remembering what you can, and can’t, flush down your toilet can really make a difference.

Wet wipes are considered essential to many people; helping clean up anything from dirty nappies to grubby faces. But, if they get flushed down the toilet they can block drains and pipes, increasing the chance of sewers overflowing during heavy rainfall and flooding.

This means that some of those wipes that were flushed down the toilet can end up in our rivers and seas and on our beaches – the MCS annual beach litter survey shows that the number of wet wipes found on UK beaches has increased by almost 700% over the last decade.

“But my wet wipe says flushable on it?”

Unfortunately, not everything does what it says on the packet. Water companies have a standard for what can be flushed safely down the toilet and wet wipes labelled as ‘flushable’ aren’t passing it, because they don’t break down quick enough once they’ve been flushed.

Over the last 12 months MCS, water companies and other organisations have been working together to improve the labelling on wet wipes and ensure that everyone knows that all wet wipes should be disposed of in the bin. This is in conjunction with the Blueprint for PR19 campaign, which includes stopping pollution as a key ask for water companies.

#binit4beaches in your home and help reduce wet wipes reaching our rivers, seas and beaches.

Rachel Wyatt
Water Quality Programme Manager, Marine Conservation Society

Preventing Pollution – progress towards a better environment

In March, Thames Water was fined for pollution incidents at six sites in the Thames Valley during 2012-14.  A combination of equipment and management failures meant the sites weren’t able to treat the volumes they were designed to, and discharged untreated wastewater to the environment.

We take full responsibility for what happened. We didn’t protect the environment we rely on – and it is up to us to put that right.

So what are we doing to make good what happened – and to reduce the risk of problems recurring?

First of all, we have paid £400,000 in compensation to organisations directly affected.  And we have added £1.5 million to our Community Investment Fund, ring-fenced for projects to help the rivers, wildlife and local environment in the vicinity of the incidents.

We’ve also strengthened the team looking after the region in which the incidents took place, so there are more staff, each with fewer sites to deal with.

Of course, people want to know what we’re doing to avoid similar problems elsewhere.  The answer lies partly in investment, with £26 million spent since the incidents to help ensure we meet sewage treatment standards, and reduce the risk of pollution from all our sites.

Severe weather and the devastating impact of wet wipes and other ‘unflushables’, were common factors across the incidents.  It is up to us to insulate our customers and the environment from these pressures, so, much of our focus has been to ensure we are more resilient to their effects.

This includes an £18 million programme to refurbish the screens that protect our treatment works from items including wet wipes, which have a crippling impact when they ball together, clogging pipes and breaking pumps.

But arguably the most significant changes we’ve made have been in our Wastewater Operational Control Room. In addition to doubling staffing levels, we’ve transformed the way we work, harnessing technology to take a much more proactive approach to managing our sewage works, pumping stations and sewer network.

This includes a new system for visualising near-live data so we can pre-empt potential problems.  We know, for example, from analysing previous incidents that sewage pumping stations can show unusual patterns of energy use before failing.

By tracking their energy use we can see where this is happening, and have intervened on up to 15 different occasions within a single month – in some cases averting potentially serious pollution incidents. By capitalising on the insights data can offer, we are shifting our focus from reacting to alarms, to intervening to prevent assets failing, flooding and pollution.

On the sewer network, our storm chasing project is perhaps the most innovative and influential change we’ve made.

Historically, we’ve used weather forecasts covering periods of hours, and large parts of our region – helpful in preparing for slow-moving weather fronts, but not the short, sharp storms that can quickly overwhelm our sewers.

We’re now using advanced weather radar, forecasting several hours ahead and showing changes at 15 minute increments, on a 2km grid, to pinpoint when and where a storm will hit. This makes it easier for us to proactively pre-position the teams and equipment we’ll need to deal with the potential impacts. It’s not so much chasing storms as getting ahead of them.

At the same time, a new Logistics Management Centre and ten distribution hubs with stocks of the kit we need to respond to events, means we can despatch crews to proactively manage the risk of potential incidents at a local level.

Taken together, these improvements have supported a significant reduction in pollution incidents from their peak in 2013.

The Blueprint for PR19 challenges companies to aim for zero category one, two and three pollution incidents and 100% self-reporting – and these are mirrored in our own aspirations. There’s much more we need to do to get there, including making our operations more resilient to the effect of storms – but we believe we’re making real progress.

Please don’t take my word for it. We are holding open days later this year at all the sites where incidents took place so you can see for yourself what we’ve done, and meet the teams who are doing everything they can to protect the environment on which we all rely.

Lawrence Gosden
Managing Director, Wholesale Wastewater – Thames Water

Pollution – The biggest problem facing our freshwater environment

For one of my first field visits for WWF, I visited the Hogsmill, a much loved chalk stream in South London. I was shocked to see evidence of raw sewage and rags entering a river that is so vitally important for wildlife and recreation within the local community.

The Hogsmill Riverside Open Space, an area much enjoyed by children and dog walkers alike, is also home to Ewell Storm Tanks. These storm tanks were added in the 1930s to increase the capacity of Hogsmill Sewage Treatment Works (STW) and were inherited by Thames Water from the local authority in the 1960s, with an operational discharge consent designed for ‘occasional use’. The tanks were to provide a relief mechanism to prevent back up of sewage through the network at times of exceptionally high rainfall and use. Although ‘occasional use’ is not defined, it is not expected to exceed a few times a year. But, when the South East Rivers Trust carried out testing in 2016, they found that there were 14 discharge events between January and May.

Last month the evidence was clear to see, even after a long period of dry weather, a path from the storm tanks down to the river had formed littered with wet wipes and sanitary products. And that is only the visible evidence. Water samples captured during a discharge event at the Ewell Storm Tanks showed elevated E. coli levels downstream of the outfall, highlighting the potential risk to human health as the river is used for recreational purposes, with children and dogs often entering the river.

An outflow drain filled with sewage rags entering the Hogsmill River (L). Rags caught in branches in the River (R).

But the Hogsmill sewer overflow is not a one off – there are thousands of these across the country in every water company area. With population growth, more and more concrete covering permeable surfaces, and rain washing straight off of roads, there is an increasing demand on the sewerage system. Therefore, it is likely that these sewer overflows will spill raw sewage into Britain’s rivers more frequently and with greater volume. This is likely to be further exacerbated by predicted climatic changes with increases in both the frequency and intensity of rainfall events.

That’s why Blueprint is calling on water companies and regulators to get a grip on sewer overflows and stop pollution of our waters. In the Blueprint for PR19, we are calling for:

  • Strategic long-term wastewater plans – these are essential to prepare for the future and should ensure sewerage and treatment systems are sufficient to prevent pollution in the context of population growth and climate change
  • Targeting zero pollution incidents – it is not enough to just reduce the number of major incidents, dealing with pollution for sewer overflows should be a top priority and we welcome an increase in monitoring to understand the impact sewer overflows are having
  • Dealing with emerging pollutants – pollutants must be dealt with at source by promoting less harmful alternatives and investing into innovative natural treatment solutions, such as wetlands
  • Sustainable Drainage Systems (SuDS) prioritised – SuDS should be prioritised within a company’s own drainage scheme and used to reduce peak flows in the sewerage system, avoiding the need to invest in large underground pipes and providing biodiversity and amenity for local communities.

Alice Moore
UK Freshwater Assistant, WWF

Protecting water through catchment management

Guest blog by Severn Trent Water on catchment management, a key theme within Blueprint for PR19.

Over 2015-20, Severn Trent is investing £21 million in making environmental improvements through catchment management, including working in partnership with farmers and landowners to reduce agricultural run-off into rivers. Through partnership working, pesticides such as metaldehyde (a chemical often used to control slug populations) are prevented from entering watercourses. In addition to improving river quality, there will be a number of other benefits, such as a reduction in treatment costs and improvement in the river environment as a whole.

In 2016-17, Severn Trent’s agricultural advisors worked with over 1,200 farms. We are now on track to engage with 4,000 farms, covering over 10,000km2, by 2020.

We are also funding two catchment schemes for farmers to tackle diffuse pollution across the region:

Severn Trent environmental Protection Scheme (STEPS)

A voluntary scheme funded by Severn Trent for livestock and arable farmers / landowners in priority catchments

  • 50% grant funding up to a maximum of £5,000, to help farmers make land management and capital infrastructure improvements that benefit water quality and the environment
  • Applicants can apply each year between January to mid-March until 2020
  • Prioritisation given to measures that help reduce pesticides
  • Over 500 applications have been received under this scheme.

Farmers as Producers of Clean Water (FaPCW)

  • Metaldehyde reduction initiative to encourage farmers to adopt practices that help reduce metaldehyde in raw water
  • Metaldehyde levels tested upstream and downstream of watercourses fortnightly from September until December each year, until 2020
  • Farmers rewarded up to £8/ha on land planted with winter wheat and/or winter oilseed rape – payment dependent on the levels of water quality improvement
  • In 2016, 26,000ha were signed up under this scheme.




To further support the catchment management approach, at Severn Trent we have been participating in the Catchment Based Approach (CaBA), working with others to address water quality issues. For example, we are involved in Moors for the Future, a project through which significant EU funding has been secured to undertake peatland restoration work around the Derwent Valley reservoirs.

Katherine Filby
Principal Catchment Management Scientist, Severn Trent Water

The importance of our Natural Infrastructure

Prioritising the identification, protection and restoration of Natural Infrastructure provides a significant opportunity to realise the Government’s ambition of us being the first generation to leave the environment in a better state than which we found it.

In every parliament, the National Infrastructure Commission sets out their views about our long-term infrastructure needs in a National Infrastructure Assessment (NIA). Looking over a 30-year time horizon, they consider the demand and supply of infrastructure services and assets, such as roads or fibre optic cables, and make recommendations to government on how these needs are best met.

They consider major sectors including transport, energy, water & wastewater, and flood risk management – areas where projects could impact significantly upon the environment. What they don’t tend to consider is whether these sectors could in fact benefit from the services that our countryside and green spaces provide.

Continue reading “The importance of our Natural Infrastructure”

Ensuring water companies deliver for nature

Over the next 12-15 months water companies in England and Wales will be drawing up plans as part of PR19 (Periodic Review 2019) for their investments between 2020 to 2025. In the blog below, Nathan Richardson sets out why it is important to influence the content of these plans so that they deliver for nature.

 Why are we engaging with water companies?

The water companies in England and Wales have invested £130 billion in environmental management over the last 25 years with a further £42 billion to be spent by 2020. Alongside the provision of safe drinking water, this investment has delivered significant improvements in river and bathing water quality and is helping address the impacts of abstraction on some of most important wildlife sites.

Continue reading “Ensuring water companies deliver for nature”

21st Century Drainage Programme – Protecting health, supporting communities, securing the environment now and for the future

Few of us think about what happens after we flush the loo or pull the plug in the sink or bath, and yet the sewerage system is essential to the nation’s physical and economic health. Billions of pounds have been invested in ensuring that this water is taken away, cleaned and returned to the environment to support our unique and irreplaceable ecosystems and wildlife – although there is still much to do.

Moreover, a changing climate, growth in population and other changes to our society mean that we are going to have to start thinking differently about how we ensure our sewerage network is efficient, affordable and supports the environment and the economy in the decades to come.

Continue reading “21st Century Drainage Programme – Protecting health, supporting communities, securing the environment now and for the future”

Wet wipes turn nasty when you flush them

Just a quick warning – what you’re about to read isn’t pleasant! Words like blockages, fat, sewage and poo are all coming up!

Most people associate flooding with extreme downpours, swelling rivers and bursting floodplains – but what if I told you that wet wipes could be the cause of a household flood? Surely those convenient, tiny white squares couldn’t be responsible for sewage filling your rooms and ruining your furniture – or could they?

Continue reading “Wet wipes turn nasty when you flush them”