The Environment
Intro: The flooding in the UK in 2006 caused some water supply  problems, what can be done to prevent this happening again?
Water Supply Problems
Sustainable Housing
Environmental Permitting


Flooding, Drought and Inundation - Impacts on Water Supply Policy, Regulation and Operation

Government, Regulators and Service Provider Reaction

The media are always prophesising global Armageddon with regards to global warming; flooding, rising sea levels and drought.  It has (hopefully) sunk in by now that these events can be attributed to environmental change, this could be due to global warming / climate change, negative anthropogenic impacts on the water cycle or even iso-static readjustment. Whatever the cause its affects are noticeable and as such action is being taken.

[i] NOT necessarily a drought!

In the UK we have many more resources to mitigate against these problems than those living in the third world. Could you see nice blue water bowsers popping up all over Africa when they have a drought there!


Regardless of our ever expanding resources, monitoring and knowledge  it has been proven time and time again that the environment can still give the UK a bloody nose from time to time, this especially true when it come to the interruption of a service we regard as vital, WATER.


So what has been has been the response to these situations? . . . .


Government’s Response

Drought: Guidance on drought can be found in Part 2 of the Water Resources Act 1981 [ii], here we see the follow chapters:

73. Power to make ordinary and emergency drought orders.

74. Provisions and duration of ordinary drought order.

75. Provisions and duration of emergency drought order.

76. Provisions of drought order restricting use of water.

77. Provisions of drought order with respect to abstractions and discharges.

78. Works under drought orders.

79. Compensation and charges where drought order made.

80. Offences against drought order.

Of particular interest is Chapter 78 Section 2/a which states:

“may authorise the Authority or that undertaker for that purpose to enter upon any land specified in the order and to occupy and use the land to such extent and in such manner as may be requisite for the carrying out and maintenance of the works”

In other words maintaining supply is seen as paramount by the government, and water companies will be given serious powers under drought condition to ensure that it is un-interrupted.

More up to date guidance is added with the Water Act 2003[iii]

Chapters 63, 64 and 65 deal with drought:

63. Drought plan

64. Drought orders and drought permits: charges

65. Procedure at local inquiries

Drought Orders and Drought Plans are both dealt with by the EA, and are dealt with the “Regulators” Chapter.

Flooding:  The Following Sections can be found in the Water Act 1981[iv], so it is clear that flooding has been very much in the minds of heads of government for nearly 30 years.

136. Flood defence functions of the Authority.

137. Establishment of regional flood defence committees.

138. Composition of regional flood defence committees.

139. Local flood defence schemes and local flood defence committees.

140. Internal drainage districts and internal drainage boards.

Additional information can be found in the following chapters of the Water Act 2003 with regards to flooding:

 66. Revocation of local flood defence schemes

 67. Membership of regional flood defence committees in Wales

 68. Regional flood defence committees

69. Grants for drainage works and flood warning systems

Flood prevention has been approached with a holistic attitude.  Development is now very much tied in with flood risk management; developments can alter the flood characteristics of a catchment over time. A small scale example to counter act this might be where new planning regulations aim to reduce run off by minimising impermeable surfaces such as asphalt in flood prone areas, whilst a large scale example might be the refusal of planning permission for a development on land that is prone to flooding. Buildings can also be designed to be flood resistant.  This style of thinking is born from PPS 25[v]. The siting of new water treatment works, and waste water treatment works will now be very carefully considered with regards to flooding (via FRAs).

However, these preventative measures do not address the problems of existing water treatment works such as the works that supplies Tewkesbury, which was inundated (shown here after protective barriers are in operation) and 100,000[vi] homes lost their supply.


If flooding is to persist and possibly worsen, will barriers always be the solution?


The 2007 floods really shocked the government so they commissioned the Pitt Review this was due to the fact that -

Two thirds of the flooding in 2007 (which affected 55,000 people in the UK) was caused by surface water flooding which happens when heavy rainfall overwhelms sewers and drains and the water has nowhere to go.”[vii]

This lead to The Flood and Water Management Act,  which sought to manage -

  1. New statutory responsibilities for managing flood risk
  2. Protection of assets which help manage flood risk
  3. Powers to carry out environmental works
  4. Sustainable drainage
  5. New sewer standards
  6. Reservoir safety
  7. Water company charges
  8. Protection of water supplies
  9. Other protection for water company customers

It would appear a lot of these concepts were already in the Public Domain but this Act formalised them, For example Sustainable Drainage has been a part of large construction projects for some years, but the planning offices remit has now been broadened to include further projects (Endnote - v).

All of this rather complicated legislation has manifested itself in the form of Planning Policy Statement 25: Development and Flood Risk which has lead in turn to the FRAs (Flood Risk Analysis) having to be compiled in the planning stage of most major developments.



Other Things to be considered:





PPS 25: Requires SUDS to be considered at planning stage in a “Sustainability Appraisal”

Good that new developments consider sustainability issues.

Add cost to project at a time when money is tight.

Not always room for SUDS ponds.

Some Policies were formulated a long time ago.

Shows government has been thinking about flooding for a long time.

Out of date policies not relevant to current systems, have not changed in the light of new knowledge.

Maybe a bit more emphasis on prevention rather than cure might be useful.





Regulators Response

Drought:South East of England faces its second year of drought”[viii], popular media covers the drought in the South East of England:

“Thames Water said that in an average year the region it manages receives less rainfall per person than Dallas in Texas, Rome or Istanbul. London receives about the same amount of rain as Athens. [ix](And we are in the same amount of national debt!)

The UK government has been very proactive in introducing legislation to prevent drought and flooding, these policy changes have normally been driven by “events” such as the droughts in the droughts in 1976 and more recently those in South East of England in 2004.

Pictures in the media such as this one lead to public pressure to change policy. Drought Management was handed to the Environment Agency (EA).


The EA is responsible for drought planning as specified in the Environment Act 1995, as the below caption demonstrates.




“The establishment of drought plans is a function of the Environment Agency, as set out in the

Environment Act 1995,  Ch. 25, Part I, s1.  The Water Act 2003 is an amendment to the

Water Resources Act 1991 and the Water Industry Act 1991.  These are to be used

alongside and in accordance with the Environment Act 1995.” [xi]

The EA has a preventative strategy and a mitigative strategy.

Preventative might include:

·         Media Campaigns

·         Hose Pipe Bans

·         Wider Implementation of Quantitative Abstraction Licenses

Once drought has set in more drastic measures may be employed [xii]:

·         Widening of Hose Pipe Bans

·         Ban on washing of buildings, cars, windows and filling swimming pools.

·         Water rationing.

·         Standpipes

These strategies are all outlined in the Regional Drought Plans that are created by the EA[xiii]. And are further backed by recommendations in the Pitt Review[xiv]  these recommendation are implemented through the Flood Water Management Act that came in to affect from 9th April 2010.

Surface Water Flooding:  Again flooding control falls in to the hands of the EA, events over the past years have lead to a greater emphasis being taken on the mapping of flood risk, the EA now have a very well developed web site where members of the public can assess there catchment area for risk by flooding.


The Catchment Flood Management Plan takes in to account any, people, property or infrastructure that may be at risk from the flooding. The Caption, left shows how in this case a waste water treatment works is deemed to be at risk.


Flood risk maps are now available to view on line, and are available from third parties for commercial reports, such as Envirocheck.


Any new water related infrastructure project should take care to avoid areas at risk from flooding.


However, when you are taking water from a river, maybe you want to be next to it in order to avoid inflated energy bills, and BIG operational carbon.


OFWAT have create an analytical system; “Asset Resilience to Flood Hazards[xvi] The end result of this system is expected to be funding is made available for the protection of key assets;

OFWAT have taken the opportunity to review current industry practice for assessing the resilience of assets to food risks. The report develops an analytical framework for assessing the risk from flooding of critical assets and identifying cost-beneficial resilience options.”

Leading to;

“The framework considers flooding events that have relatively low probability (< 1 per cent per year) and relatively high consequence of failure, in terms of service disruption. As such, the priority is large, discrete assets (treatment works, pumping stations, communication centres, major pipelines), because the failure consequences could be severe.”

Other Things to be considered:





DWI (Another Regulator)

Focuses on Water Quality

No holistic approach


Water Service Providers Response:

Drought: So why not let the taps run dry? Chapter 2 Section 37 of the Water Act 1981 states:

“37 General duty with respect to water supply

(1) It shall be the duty of every water undertaker to develop and maintain an efficient and economical system of water supply within its area and to ensure that all such arrangements have been made—

(a) for providing supplies of water to premises in that area and for making such supplies available to persons who demand them”

. . . . and perhaps a moral sense of obligation!

You may think the easiest way to prevent interruption of water supply would be to build more storage but this is a difficult option for water companies for two reasons:

1.       Planning: Lengthy Public Consultation, Environmental Impact Assessments etc etc

2.       OFWAT: Investment - Increased consumer bills. Investment by water companies is tightly controlled by the amount they can charge their customers, they could put bills up to pay for a new dam / reservoir but OFWAT would not allow that, they could borrow masses of money to fund the project, but the interest still has to be paid and where will that money come from? They can’t put the bills up. . . . so we end up with Low Capital Expenditure Projects with High Operational Costs such as Wimbleball Pumped Storage.


So in summary the water companies want to provide an un-interrupted service (They will be financially penalised by OFWAT if they don’t), but their hands are tied when it comes to investment.


Flooding:  No doubt the Water Companies will be following the “Flood and Water Management Act 2010” but also they have share holders to keep happy, this will involve maintaining a reliable supply, even during extreme environmental events, a water company that can’t supply its customers with water will more than likely have a dip in share prices - whatever the reason for the interruption.


We had seen the short term reaction to flooding (Mythe Water Treatment Works, Page 3) with the erection of barriers to prevent ingress and subsequent pumping from behind the barrier to maintain dry working area. However, what will be the long term strategies?


It would appear that Seven Trent Water have opted for a permanent solution at Mythe[xvii] -


Work on the barrier is due to get under way in mid-March, and Severn Trent Water is keen to show the public what the £5.5m project involves, and how the new barrier will help protect the county’s water supplies.”



The permanent Barrier may have a similar design to the one shown here at Calaverus County in the USA.

Looking to other countries for inspiration may be a good option with countries such as the Netherlands having a long history of flooding, and therefore an established system of mitigation against elevated water levels in localised areas. Perhaps they keep their works away from areas prone to flooding.



The table to the right shows the balance that can be made between capital expenditure and the level of protection that can be achieved.

However, structural changes are not the only aspects that need to change in order to prevent supply interruption, training must be given for manual operation of equipment in waste water and potable water plants, telemetry systems may fail under adverse conditions.




Effects on Consumer Confidence:


Consumer Confidence will have taken a large dip due to the climatic events from 2004 - 2007, can we always look to the future and expect a near 0% supply interruption? That meets water standards 100% of the time? Will water always disappear down the drains when it rains?


Perhaps though consumers are unaware that large scale investment is difficult for water companies as they as so tightly regulated, they cannot put bills up to cover work, work that needs to be done to flood proof structures, or reduce operation environmental impact. Although “flood proofing” will be covered by OFWAT’s “Asset Resilience to Flood Hazards” scheme. However, when it comes to extra storage many companies will have to:



“Keep patching up old assets” [xxi] As they put it.


The graph to the right shows how the water companies would like to play things . . . . . . and how OFWAT will dictate they behave.


From viewing the table[xxii] to the left we can see just how high customer expectations are, thanks to tight scrutiny by regulators water companies have to be extremely well run, so this make the public even less prepared / angry when things go wrong. For example in Portugal (personal experience) expectations for water reliability are a lot lower, if road works are effecting water supply then you may be given a 2 hour daily window to fill buckets and tanks and then the water goes off again.

This kind of service interruption can continue for weeks. Consumers in the UK wouldn’t stand for this kind of treatment, and even when there is a “act of god” kind of scenario like in Tewksbury people still get cross.


Reactions as Stated in Strategic direct Statements


Bristol Water



It is clear from the diagram shown that water companies (In this case Bristol Water) are considering the balance between climate change and the effects on the service they provide.

The view of change over the next 25 years is as follows[xxiv]:

-Pressure to supply more water requiring new resources

-Increased weather volatility adding to business complexity and a need for greater capacity

 -Increasing environmental concern

-Decreasing tolerance of failure even if caused by events outside our control

-Inevitable upward pressure on bills


A recurring theme throughout the SDS is that of the need for investment for long tern reliability of supply, being Bristol Water is principally a water supply company, it has to guard be certain it can maintain supply in drought  and flood conditions.


The following suggestions are made:


“Reliability – long term

·         Invest to encourage more water efficiency by customers

·         Develop alternative sources such as grey water use

·         Create extra capacity at all levels to cope with expected variability in

demand and in weather patterns

·         Use the most environmental friendly (Not a very meaningful phrase) sources of water in priority to others

·         Use “carbon footprint” as a key driver in investment decisions rather

than just financial cost”


It should be noted that investment in the system is key to achieving these suggestions, the SDS goes on to state that a water bill is on average “£2.80” a week and that relates to a pint of beer or a large latte which is very good value.


The problem is that water companies are private companies and their owners many of them overseas, are interesting in increasing the value of companies so even though increased asset investment would lead to lower operating costs / carbon it is also in line with a Company’s general aim  . . . . to grow and increase its value.


Other Things to be considered:





Fixing Leaks

Increases Efficiency, Increases quantities available.

After fixing major leaks, companies quickly approach the point of diminutive returns.

Water Meters

Make customers use less water and thusly decreases need for large storage projects


Alternate Energy Sources

Decrease in use of fossil fuels, directly or indirectly for pumping, and help mitigate against climate change.

Investment. Extra money hard to find.



Bristol Water only Supplies Water not Sewers so we will look at a company that does both. . .


Severn Trent Water (Focusing of Waste Water)


Severn Trent SDS[xxv]  was published in December 2007, approximately 6 months after the terrible flooding at Tewksbury. So as you would expect there is a lot of reference to mitigating against climate change particularly flooding.


Below are some Severn Trent’s intentions from there SDS.


“•Meet higher standards for waste treatment resulting from new legislation such as the Water Framework Directive and other legislation.

•Improve our sewerage network to ensure we have no serious pollution incidents, nor any pollution incidents caused by our assets or actions.

•Ensure that no customer community  is subjected to internal sewer flooding.

•Improve the capacity of our network to cope with all but the most extreme forms of weather.

Progressively separate foul and surface water drainage.

Promote the installation of Sustainable Urban Drainage Systems (SUDS).

•Support the transfer of privately owned sewers to Severn Trent Water” [xxvi]



Of these above points I feel that the two highlighted are the most important, as they together work towards stopping the “flashy” response that we saw in the Gloucester rivers in 2007, Seprating Surface Water and Foul Drainage means the Waste Water treatment works has leses to cope with. This decreases the likely hood of “overspill” pollution incidents, and providing the surface water drains are channelled in to a SUDS (explained below) scheme they will increase the time it takes rain water to reach the river.


Examples SUDs system: Upton, Northampton[xxvii]

SUDS are a simple yet effective way of dealing with surface water without sending it down pipes to rivers / water courses.

Clean water is channel in to permeable basins (pictured left) and water is allowed to percolate down in to the ground, this method means that less water is released in to the river “all in one go” and as such decreases the risk of flooding.


Again as with the as with the measures in Bristol Waters SDS it looks as though these objectives will be hard to meet without more funding.

Both Bristol Water and Severn Trent Water are in fairly wet locations and so there is an emphasis on mitigation against flooding, Thames Water on the other hand has extra priorities. . .

Thames Water

Thames Water’s SDS[xxviii] highlights growing demand for water and less being available, habits of consumers can exacerbate this problem;

“On average, about 6% of household  water is used in the garden, but on hot  days this can already rise to over 50%.”

Increased demand from agriculture in summer months also poses problems.


Climate change will make it ever more difficult for it to meet it targets set by OFWAT, in what is the driest and the most densely populated area of the UK. Any Water Company that is proposing a desalinisation plant must be very short of water;

“The plant will use about twice as much energy as a conventional water treatment plant and will run on biodiesel sourced in the UK (including recycled fat and oil from London restaurants and households)”[xxx]

This is yet another example of a Low Capital Cost / High Operating Cost Solution brought about by over stringent regulation of the water industry. Bills should be allowed to rise and reservoirs should be built.

[i]  David Rose SWW Lecture Notes









[x] (11/04/10)

[xi]  EA- Southwest Region Drought Plan - 2009



[xiv] The Pitt Review - Learning Lessons from the 2007 Floods.

[xv] EA - Exe Catchment Flood Management Plan - Summary Report 2009

[xvi] Pitt Review Section 5, Chapter 15.27

[xvii] (17/04/2010)



[xx]  Bristol Water - Water in the Future - SDS

[xxi]  Bristol Water - Water in the Future - SDS

[xxii]  Bristol Water - Water in the Future - SDS

[xxiii]  Bristol Water - Water in the Future - SDS

[xxiv]  Bristol Water - Water in the Future - SDS

[xxv] Strategic Direction Statement 2010- 2035 - Severn Trent Water

[xxvi] Strategic Direction Statement 2010- 2035 - Severn Trent Water