The following representatives have been invited to attend the meeting:
· Mr Black, Chief Executive Officer of OFWAT
· Ms Brooksbank, Marine Senior Advisor of Natural England
· Mr Gosden, Chief Executive Officer of Southern Water
· Mr Moody, Area Director, Solent & Downs of the Environment Agency
The members of the Committee will have the opportunity to discuss the following:
· Recent flooding and the associated drain surcharging.
· Sewage and the subsequent discharge into the harbour and water courses.
· Chichester Harbour water quality.
· Responses to planning applications including delays in connectivity.
Minutes:
The Chairman welcomed Dr Toby Willison, Director of Quality and the Environment at Southern Water; Mr Tom Scott-Heagerty from Natural England; and Michael Turner from the Environment Agency.
The following questions were received from members of the Committee and the public. The answers provided by Southern Water follow:
Please note that the questions have been grouped together in topics for easier reference.
Planning
What can SW do to prevent housing developers connecting to their network where it is know that by adding new housing this will exceed capacity as defined in CDC 2020 Position Statements?
We have a duty to enable developments to connect to water and wastewater under the Water Industry Act 1991. Water companies do not have the right to refuse connections.
There is currently a proposal to implement Schedule 3 of the Flood and Water Management Act. This would enable us to refuse a connection where surface water has not been eliminated from reaching the sewer. We are closely monitoring progress of this proposal. However, this would not apply to foul water only connections which we would still have no right to refuse.
Under the previous regime at Southern Water the Chief Executive told a leading harbour stakeholder that: "The development plans within the Emerging Local Plan are madness for the harbour." Considering the current discharge into the harbour over recent weeks what is the current view of Southern Water?
Generally, it falls to the Local Planning Authority to determine what development they support in their area. If it is in their Local Plan and planning permission is given, we are then obliged under our statutory duties to provide the services for water and wastewater.
We are statutory consultees for Local Plans and provide detailed evidence in the Chichester area on our networks and participate in the Water Quality group, as well as attending a range of ad hoc meetings to support the Council as much as possible.
Since 2017 Southern Water have declined to make such comments on the Planning Applications so what has changed?
When we receive planning applications for consultation, then we will provide comments. However,unlike the process for Local Plans, we are not statutory consultees at this stage in the planning process. We need specific details on any cases which have not received a response. Please forward further details to southernwaterplanning@southernwater.co.uk and we will be happy to provide a response.
Of recent concern a Planning Application was presented to the Planning Committee regarding an application to increase the number of units on a development site from 1 single dwelling to 8 large apartment units. The site is served by the Apuldram WTW which has no further capacity, but Southern Water were not consulted on this application. If presented with this application what would Southern Water's response have been?
Water companies, including Southern Water, are not statutory consultees for planning applications. It is not unusual for the Council to decide not to consult with us.
For clarification, capacity at the WWTW is not the same as capacity within the network. We consider large scale investment for WWTW based on Local Plan information and an appraisal of Population Equivalent growth predictions. This is part of our Asset Management Plan (AMP) cycle. We may then invest in the WWTW to increase its capacity or install a pipeline to transfer the waste to another site which has capacity, as we did with the Tangmere pipeline.
For each individual application the consideration is whether there is sufficient capacity in the local network, i.e., the pipes that carry the foul water to the WWTW. For a small development of less than 10 units the increased flow is marginal, however it there are larger developments in the area any growth plans identified would be planned to allow for future need so would include plans for additional capacity which would accommodate for this type of site.
We are currently in the process of updating how we respond to planning applications when consulted to provide a pack which is more accessible to all audiences when they are made publicly available.
Since the introduction of Nitrate Neutrality measures endorsed by Natural England to compensate for Nitrate production created by new developments, we have seen alarming areas of good quality agricultural land taken out of valuable food production to facilitate these neutrality measures. How long can this go on?
The Position Statements on Nutrient Neutrality are from Natural England. Our role is to identify where upgrades to our WWTW will improve the situation and implement the work.
If the proposed amendments to the Levelling Up and Regeneration Bill are approved there will be a requirement for wastewater treatment plants in all areas with Position Statements in place, to upgrade to Technically Achievable Limits (TAL) which will reduce the levels of nutrients in our treated effluent where TAL has not already been achieved.
Even with the latest available technology, there will still be a residual level and further innovation will be needed within the water industry to improve this.
In some areas, wetlands are being proposed to tackle the remaining nutrients in a more natural way. We are supporting some these proposals when appropriate, although they are generally at an early stage.
Change of use proposals are subject to planning permission, so it is within the gift of the LPA to determine what is appropriate for their area.
Work is already starting on huge developments in Arun which will feed into the Pagham Works; this is simultaneous with 120 more houses in the course of construction in North Mundham, with a further number to come – this in a community of about 600 dwellings. Can we be assured that major works needed by SW Water to accommodate these extra properties will be in place in time? Building is already in progress.
Wastewater from the parish of North Mundham is treated by our Pagham Wastewater System, at our treatment works at Summer Lane Pagham.
The DWMP includes thorough risk assessments, which identified the main risk to be that of nutrients in Pagham Harbour, an internationally designated site. Our focus is to investigate these issues, particularly the impact on the sea grass in the Harbour.
Details of the system:
pagham-system-map.pdf (southernwater.co.uk)
The detailed long-term investment needs identified in our draft DWMP:
pagham-pagm-ineeds.pdf (southernwater.co.uk)
What pressure is SW putting on Government to become a statutory undertaker on new housing developments and appeals?
For water companies to become statutory consultees in medium and large-scale planning applications, the Secretary of State for Housing, Communities and Local Government must make a policy amendment. The list of statutory consultees is under continual review and whilst organisations or bodies might not be statutory consultees on planning applications, it is suggested that we work proactively with local councils to identify developments where they might have an interest and comment on proposals within the statutory public consultation period.
The decision to grant or refuse a planning application ultimately rests with the local planning authority, who will consider all relevant planning considerations. You can find full information on how we work with planning authorities here:
how-we-engage-in-the-planning-process.pdf (southernwater.co.uk)
Is SW lobbying for a change in the way that sewage capacity is calculated, given the known limitation of using Dry Weather Flow methods that indicate capacity in areas when there are less residents at home in summer?
Changes to network and capacity calculations would need to be proposed by the asset team, and accepted by OFWAT regulators as part of thePR24 price review.
Bosham, Sidlesham and Loxwood sewage works were 9% to 12% over their EA permit flow limits during 2021, what plans does SW have to address this regarding capacity A) pre 2025 and B) post 2025? and
What action is being taken at Bosham and Sidlesham given both were over their EA DWF Q90 permit limit in 2021?
In Bosham, we are considering options to remove surface water/inundation. There will also be an increase in the Dry Weather Flow (DWF) permit should the Highgrove Farm development gain consent and be included in the Local Plan.
In Sidlesham, infiltration reduction works are underway. There is also a growth scheme planned to increase permitted dry weather flow (DWF) caused by increased population.
In Loxwood, network reinforcement works are taking place in partnership with Thames Water. As with Sidlesham, there is a planned growth scheme to increase permitted DWF due to increase in population.
Water quality/Environment
With the risk of microplastics in our environment and in our food system and subsequently in our blood, what actions are all the organisations taking to keep people, our food chains and our environment safe?
We have a Plastics Policy and are engaging in research and development in this area. We have a Plastics Policy which is found here:
Plastic pollution (southernwater.co.uk)
plastics-policy.pdf (southernwater.co.uk)
We are committed to working closely with groups of coastal water users, so that there is a greater understanding of the scientific methods, conclusions, and process.
Professor David Kay of Aberystwyth University is currently working on an independent review of Beachbuoy and how the data is collected and communicated. This was due to be published on the 14th February, however the report publication is currently delayed to incorporate feedback from stakeholders.
Due to threats to water supplies and changing temperatures can we be sure that there are sufficient long-term, high-level plans to ensure that future generations will have sufficient food and access to safe water?
This is set out in our Water Resources Management Plan. The draft plan was under the consultation period until 20th February 2023
Southern Water has a long-term strategy for meeting future demand for water across our entire supply area. This is set out in our Water Resource Management Plan (WRMP) which was published on 3 December 2019. All water companies must publish these plans every five years and they set out forecasts for water supply and demand for the next 50 years, and then information on the solutions needed to ensure we maintain wholesome supplies to customers.
In developing our plan, we have considered available surface and groundwater resources, the impacts of climate change and the needs of the environment. We based the core of our demand forecast on planned housing growth numbers from the published Local Area Plans and we have further extended these forecasts to 2069-70.
We recognise that the future is uncertain and so in our plan we have accounted for a wide range of possible scenarios for drought, climate change, population growth and water efficiency including looking at how we can maintain supplies through extreme drought events well beyond those known historically.
Flooding
Considering the amount of rainfall, we have had recently and the amount of flooding locally, what measures have been taken to unblock drains?
We have a regular maintenance plan in place to clean and clear the network and will always react to any emergency situations as they occur.
Cleaning and maintenance of highways drains is managed by the local Highways Authority.
CSOs, wastewater and Pathfinder projects
What part are reed beds playing in Southern Water’s plans for increased biodiversity and purifying water before release into the environment?
The UK has lost 90% of its wetlands in the last 100 years and 50% of English waterbodies are failing targets for Phosphorous. We believe that integrated wetlands provide the best solution for catchments overwhelmed by groundwater flow. They are a proven, natural mechanism for nutrient removal and are beneficial for biodiversity and community value. We plan to build 13 wetlands across the region between 2025 and 2030.
There is clear evidence given at a Chichester Harbour Conservancy Symposium that serious harm is being done to the marine life in the Harbour and surrounding coastline due to raw sewage being discharged into the Harbour. A consortium of Universities, namely Southampton, Portsmouth, Brighton and Le Harve, have conducted detailed experiments which have clearly demonstrated the chemicals found in raw sewage are the cause. Have Southern Water met with the Universities to establish what action needs to take, again in the short term, to resolve the situation?
We are only permitted to release stormwater when our sites are overwhelmed by excess flow. This is done as a last resort to prevent homes from flooding. The releases are up to 95% surface water and are not raw sewage. However, we recognise that this is no longer acceptable to the public - we agree and have a very focused approach to hugely reducing the use of storm overflows.
There are cases where overflows have harmful effects on the environment and community, and with this in mind we work closely with several Universities to measure the impact of this. We currently have two prototype water quality buoys that measure real time bacteriological data and have employed a PhD student who is helping us measure the impact of catchment interventions.
In light of climate change what assurances can you give us that future generations will be protected and safe from future flooding? Is enough being done to forward plan for safe provision of sewage services due to rising sea levels? Should more efforts be targeted now towards resilience and mitigation?
We have recently consulted and published our draft Drainage and Wastewater Management Plan (DWMP). In it, we set out our priorities for investment over the next 25 years which includes our detailed strategy for flooding and climate change. Details can be found here: Drainage and Wastewater Management Plans (DWMPs) (southernwater.co.uk)
In Bangladesh there is a campaign to store water on people’s roofs in the monsoon season to make sure it doesn’t run out in the dry season. With increasingly dry summers and unwanted discharges during heavy winter rains is there anything similar that could be achieved in this country with a bit of lateral thinking?
We think this is an excellent idea – something that the team can research in detail to assess whether it would be applicable in northern Europe.
The key aspects to consider are:
· For future developments, we work closely with Local Authorities to influence planning strategy so that future homes are water efficient and benefit from sustainable drainage.
· For existing housing stock, we wish to be the catalyst for change and see storm water as a resource. In our Pathfinder areas, we are retrofitting properties with water butts and planters fed from downpipes to capture stormwater.
What plans does SW have in place to tackle storm sewage overflows before 2025? And
I feel we need to focus on what action will Southern Water be taking in the very short term to address and rectify all of the arisings reported over the last 15 years noting that in West Wittering the schoolchildren have to wade through raw sewage when the surcharging events occur.
We’ve set up a dedicated task force to significantly reduce storm overflows by 2030. We're already working hard towards our target, delivering in six ‘pathfinder’ areas, building a regional plan, and working with partners to manage catchment flow. We have requested £50m of advanced funding prior to 2025 to accelerate this programme.
Details, including future work and reports on the efficacy of the initial pilot schemes - can be found here Pathfinder projects (southernwater.co.uk)
As these projects are rolled out throughout the region, evidence shows that they will have a significant impact on the use of storm overflows and incidents of flooding.
In times of heavy rainfall, the problems of wastewater disposal are exacerbated in my ward because excess rainwater accumulates because the local rifes and watercourses have not been cleared. What liaison is there between SW and the EA to ensure that surface drainage is looked at as an holistic problem? It seems that at present both agencies can divert some of their responsibilities on to the other.
There are many parties with responsibilities for flooding such as landowners, Local Authorities, water companies, Highways and the Environment Agency.
We work closely with all our partners to manage and reduce flood risk. Where flooding is particularly acute, we recommend communities create a flood group with regular meetings to raise issues, track progress and prepare emergency plans. We – and the other stakeholders mentioned above – work in collaboration with many flood groups in the region and would be happy to do so here.
With the increase in building, how much can we expect to be tankered in the foreseeable future?
If new developments are sensitively designed around sustainable drainage, there will be no requirement for increased tankering. If the development includes features such as swales, permeable paving and attenuation features, there is the potential for them to benefit the situation.
Tankering is generally deployed for incident management and is a last resort option to prevent flooding in homes and businesses.
The SW website tells the innocent onlooker that the CSO Taskforce has 6 Pathfinder Projects, 3 in Kent; one in the Pan Parishes of Hampshire; Sandown Isle of Wight and Fairlight East Sussex.The SW website also reveals that there are a number of Infiltration Reduction Plans with Hambledon, Hampshire, Lavant Valley, Sidlesham and Barnham, West Sussex contained in the list of 17 such projects. CDC - When will Southern Water and the EA provide detailed updates on progress made on each of these 23 identified projects?
You can find our latest update on this, and other regulatory and performance reports, here
Latest news, reports, and updates (southernwater.co.uk)
When will SW and the EA go public on the target dates/key milestone dates and the financial commitments necessary to render each of these projects a visible/tangible success-
Defra has published its storm overflow reduction plan which can be found here.
This plan will be the subject of most water companies’ 5-year plans starting in 2025. Southern Water is working to accelerate this timescale.
Given the very clear issues of CSO damage to both Langstone and Chichester Harbours from legally (for now) storm related releases of untreated/partially treated sewage into both these harbours, when will SW and the EA go public on what they will do to reduce these releases within the calendar year of 2023? 2030 is not an acceptable timeline. And
What specific actions can SW take to reduce storm sewage overflows as soon as possible?
Our pathfinder projects are already delivering results. We want to be able to roll these out on a larger scale, without waiting for the next 5-year investment period.
Water companies cannot solve the problem of Storm Overflows alone. We require owners of large impermeable areas such as offices, car parks, roads, and warehouses to manage the storm water that runs off their property.
Up to 70% of the water in sewers during rainfall comes from roads and rooves. If we remove or attenuate 40% of that flow, we can reduce storm overflows by 80%.
What is the timing for SW to be able to improve sewage capacity at the 10 Chichester area works?
We are investing heavily in drainage and wastewater systems to maximise their efficiency.
Tackling growth alongside climate change means that we have two choices: upsize the vast sewer network (that’s over 400 kilometres of sewers in the Chichester system alone), or reduce the flow of rainwater into sewage systems (for example by implementing sustainable drainage systems, known as SuDS).
We are currently developing 11 Drainage and Wastewater Management Plans (DWMPs) across our entire region.
DWMPs are long-term plans – spanning 25 years or more – that will provide an opportunity to improve water quality and drainage systems and reduce flooding and pollution for the benefit of our customers, communities, businesses, the environment and wildlife.
For more information on our DWMP please visit our website using the following link:
Drainage and Wastewater Management Plans (DWMPs) (southernwater.co.uk)
Who is validating your measurements of pollution in Chichester Harbour?
We use independent, ISO accredited laboratories. The statutory responsibility to measure land, air and water quality sits with the Environment Agency, so we also receive their figures.
Why is there a big discrepancy between your measurements of pollution in Chichester Harbour and what residents observe? and
At what state of the tide are your pollution measurements in Chichester Harbour taken? and
Approx. how many chemicals flow into an average (say Bosham & Chichester) WWTW?
There is no state of the tide when pollution measurements give a true assessment over a 24-hour cycle. We have been working closely with Aberystwyth University who have found a large variation across a 24-hour period at some, but not necessarily all, locations. This variation is very different between sites.
The chemicals used in water treatment are dependent on the water source and treatment processes required for the site in question. Each chemical has a specific purpose and is dosed in a particular order for maximum efficiency. Some of the chemicals are removed further downstream in the process. The proportion of chemical dosed is dependent on the water conditions and has an operating range dependant on the norm for that site.
The online information below details the chemicals used in water treatment processes:
Southern Water
https://www.southernwater.co.uk/help-advice/drinking-water-quality/how-we-treat-water
British standards from the Drinking
Water Inspectorate (DWI)
There are risk assessments made to ascertain safe
levels of these agents, please refer to the DWI research report
detailed in the following link:
https://cdn.dwi.gov.uk/wp-content/uploads/2020/10/27111157/DWI70-2-272.pdf
Please note that we follow the requirements of Regulation 31 of The Water Supply (Water Quality) Regulations about treatment chemicals.
Safe levels of chemicals have been assessed extensively by multiple organisations, are subject to continuous review and up-to-date information is published online (e.g. World Health Organisation (WHO’s) Guidelines for Drinking Water –
https://www.who.int/publications/i/item/9789241549950
We use information provided by UKWIR (UK Water Industry Research) and from Water Supply (Water Quality) regulations for health based and aesthetic limits for different compounds (these include WHO’s information/limits).
Treatment processes are monitored using on-line instruments and sampling to ascertain the processes are performing correctly and the levels of chemical residuals are within the limits. If the limits were exceeded, an alarm is triggered, and the works are completely shut down to prevent unwholesome water from entering supply. Sampling data and asset data are reviewed as part of Drinking Water Safety Planning (risk assessment) process to predict likelihood of failure of the limits and corrective actions are put in place if the risk is deemed unacceptable.
Approx. how many flow out of the treated discharges and untreated storm releases?
The typical composition of storm releases is 95% rainwater runoff.
Storm releases are the result of automatic releases to protect homes from flooding, they are not a manual operation. The actual proportion that makes up the 5% spill, which is a mix of foul water – water from toilets, sinks, showers, etc. – and rainwater, will vary significantly from overflow to overflow and by specific event.
When we use storm overflows, screening is undertaken to remove larger solids and debris, and may have also settled in storm tanks prior to release, further removing solids from the release.
Overflows being regulated and permitted by the Environment Agency. Those that occur during storm conditions are permitted by the Environment Agency, but any untreated sewage going into our seas and rivers is unacceptable. That is why we are acting now, working hard, and investing to stop that happening.
This will take many years and billions of pounds to resolve, but we are determined to achieve this as quickly as possible for our customers.
We publish flow and spill data on our website. To access this, please use this link Flow and spill reporting (southernwater.co.uk)and scroll towards the bottom of the page, where you can then click on the button titled ‘Individual spill data’.
It is very difficult to predict this for two reasons:
· We need third party involvement which is not guaranteed. Reducing storm overflows will require us to work with the owners of car parks, roads, and large roofs to manage the stormwater from their property. Property owners are under no obligation to cooperate.
· Storm overflows are linked to rainfall and groundwater level.
Our detailed Pathfinder plans and reports demonstrate that the work we are doing to reduce infiltration and road/roof/agricultural run-off are paying swift and meaningful environmental dividends. We are poised to roll these projects out across the network, which will then have a significant impact on the use of storm overflows.
What does best in class look like and where in Southern Water’s portfolio can we see state of the art?
Real-time monitoring of networks:
Excellent examples of real-time control of sewer networks can be found in the USA and Belgium.
Sewer level monitors are a crucial new piece of technology, and we have installed approximately 22,000 sensors across the network. This gives us an effective early-warning system to deal with issues before they cause problems such as internal and external flooding.
This is an industry-leading innovation. With 80% of pollutions being caused by blockages due to wet wipes, fat oil and grease, these monitors will make significant inroads into preventing blockages before they start.
Sustainable
Drainage
Sustainable Drainage (SuDS) deployment is crucial to
managing surface water. There are many examples around the UK
– as an example, the project in White City in London can be
found here:
SuDS in London – a guide (tfl.gov.uk)
Information on Southern Water’s SuDs programmes,
suds-outline-guidance.pdf (southernwater.co.uk)
SuDS (Sustainable Drainage Systems) for schools | WWT
Pathfinders
– reducing use of storm
overflows
The
Pathfinder project is also industry-leading. A dedicated
group of water industry experts is undertaking projects across our
region to identify – and put into practice – innovative
methods of diverting surface water from the sewer system, which
will result in a drastic reduction in storm overflow usage. The
latest Clean Rivers and Seas Taskforce report (January 2023) is
here.
Pathfinder
projects (southernwater.co.uk)
Simple, low-carbon interventions such as slow-draining water butts, creating rain gardens and reinstating our region’s natural wetlands all ‘slow the flow’ of water from hard-standings and roads and make a significant contribution to reducing the need to use storm overflows.
The Deal Pathfinder summary report is an excellent example of the work and its findings:
Deal
Pathfinder Summary Report (southernwater.co.uk)
There are currently six projects being undertaken, with the intention of putting the findings into practice across the network.
Pathfinder
projects (southernwater.co.uk)
The Chairman offered her sincere thanks on behalf of residents and the Committee to Dr Willison, Mr Scott-Heagerty and Mr Turner for attending the meeting and giving so much of their time to answering questions on this very important issue.