Ofwat’s senior director, PR19, David Black has expressed ongoing concerns with Affinity Water’s revised draft Water Resources Management Plan (dWRMP).
In a letter to the secretary of state sent on 26 April but published last week, Black welcomed the changes made by the company since its original draft plan, but raised further points for Affinity to address in its statement of response and forthcoming final plan. These concerned:
Regional coordination and strategic solution planning – Black said inconsistencies of timing and magnitude remain between Affinity Water’s transfer options and those of its neighbours; and that while the company identifies its preferred regional strategic solution, it does not clearly evidence its assessment of each alternative option and the rationale for rejecting options like the River Severn to River Thames transfer. Ofwat expects “Affinity Water to work collaboratively with others to fully evaluate feasible options and select the optimum portfolio that will ensure short, medium and long-term resilience for the south-east, offering best value to customers, and realising appropriate wider environmental and social benefits.”
• Consideration of all available options – Black welcomed Affinity’s inclusion of third-party options such as the Grand Union Canal transfer but said the “revised draft plan does not provide sufficient evidence that all unconstrained supply and demand options have been adequately considered and developed”. He highlighted in particular: its choice to reduce the frequency it intends to use drought permits and orders to a 1-in-200 year level of service; the rejection of unconstrained options to reduce outage without providing sufficient justification; lack of clarity around the Supply 2040 programme; and a decrease in metering ambition from 90% in its original dWRMP to 79% in the revision.
• The validity of some planing assumptions – “We identified material uncertainty in areas of the revised draft plan and have concerns regarding the validity of the assumptions made.” Black set out in particular target headroom of 12% “the highest in the industry and significantly so in comparison to an average of 8%”.
Black also noted concern with “the significant length of time that it has taken to produce the revised draft plan and commence public consultation”.
Affinity Water predicts that many of its water resource zones would be in deficit in the future, without additional action to reduce demand or provide additional supplies, including four zones in the early 2020s, driven primarily by abstraction licence changes.