Defra and Natural England have published three long-term, statutory environmental targets for water, as part of the package of green targets for air, water, resource efficiency and biodiversity promised under the Environment Act. The water targets, open to consultation until 11 May, are:
water demand – reduce the use of public water supply in England per head of population by 20% by 2037 against a 2019/20 baseline;
nutrient targets – address the two principal sources of nutrient pollution by 2037: reduce nitrogen, phosphorus and sediment pollution from agriculture to the water environment by at least 40% by 2037 against a 2018 baseline and reduce phosphorus loadings from treated wastewater by 80% by 2037 against a 2020 baseline; and
abandoned metal mines – reduce the length of rivers and estuaries polluted by target substances from abandoned mines by 50% by 2037 against a baseline of around 1,500km.
Also relevant for water in the consultation was a legally binding target for species abundance by 2030, with a requirement to increase species populations by 10% by 2042.
The policy makers said they had targeted 2037 for the water goals, a shorter timeframe that several other target areas, in recognition of the fact that improvements in the water environment will support the delivery of the wider suite of proposed targets, including species abundance. They noted the targets would also support wider ambition under the Water Framework Directive, the 25 Year Environment Plan and the UK’s international commitments to protect 30% of land and sea by 2030.
Defra added that it would shortly outline its ambitions to reduce the harm caused by storm overflows in the Storm Overflows Plan.
More details about each target of direct relevance to the water industry are below. The government response to the consultation is expected in early summer.
WATER DEMAND
The consultation argued the proposed level of ambition (20% reduction by 2037) was chosen to deliver the level of demand reduction needed by 2050 – two-thirds of the extra 4bn litres of water a day expected to be required by then.
It explained: “We have arrived at the figure of a 20% reduction in the use of the public water supply per head of population by modelling a consumption level of 122 litres per person per day (l/p/d). This extends beyond the existing commitments to 2025 which aim to reduce domestic water consumption on average from 138 l/p/d to 132 l/p/d. The target of a 20% reduction in public water supply will require a 31.3% reduction in leakage (from 2017/18 levels) increased from 19% by 2025 and require the new additional target of a 9% reduction in non-household demand by 2037.”
It would, the policymakers argued, drive action “towards reaching the 110 litres per person per day we need to meet by 2050 as set out in the National Framework report”. They said the new statutory driver would ‘add value’ to existing non statutory ambitions including company pledges to cut leaks in half by 2050 and planning assumptions based on reducing household water consumption to 110 litres per person per day by 2050, and would ensure all aspects of water consumption are involved in the demand reduction push, notably brining non household consumption into the picture alongside household consumption and leakage.
The chosen metric is Distribution Input (DI) over population rather than solely DI on the grounds that this will “help to measure and improve water efficiency trends over time” and will “take into consideration the uncertainty around future population, housing needs and economic growth”.
Defra said on top of existing levers, it plans to introduce new mandatory water efficiency labels on water using products and consider how building regulations can promote efficiency, to support delivery of the proposed target.
Water efficiency specialists were highly critical of the ambition. For instance, Daniel Johns, managing director of Water Resources East and chair of the UK Water Efficiency Strategy Steering Group, tweeted that the target was “pathetically weak” and in practice means “no action at all”. He explained that putting the target on a per capita basis means any reductions achieved could be negated by population growth. He also argued the proposed target could be met by water company leakage reduction plans and less action than they are currently planning on household consumption, with no action at all from the non household sector.
NUTRIENT TARGETS
The consultation said agriculture is responsible for 70% of nitrates and 25% of phosphorus in watercourses, while wastewater discharge accounts for 60-80% of phosphorus entering rivers nationally.
The water sector target on phosphorus is intended to stimulate investment in nature-based and catchment-bases solutions, hence it is not tied to treatment at sewage works. Water companies were not given a nitrogen target on the grounds that most of that pollution originates from agriculture and that it would lead to “very high-cost nitrogen removal from wastewater treatment work for highly uncertain environmental benefits”.
According to the consultation: “During the period of 2020-2027, water companies will undertake projects to deliver a phosphorus reduction of around 50% against a 2020 baseline. We want to see a higher level of ambition and propose setting a longer-term target to build upon this progress. Beyond 2027, this will involve setting the strictest Technically Acceptable Limit, the tightest limit for Environment Agency permits, across 400 wastewater treatment works serving a population greater than 2,000. This means undertaking the more challenging and costly projects that have not been included in the current planning period.”
On top of the general targets, Defra published a policy paper on reducing nutrient pollution in protected sites – those in an “unfavourable condition” due to nutrient pollution. In these areas (previously affecting 32 local planning authorities but extended last week to an additional 42), housebuilding and other development can only take place if ‘nutrient neutrality’ can be demonstrated. This means if new nutrient load that would result from a development is mitigated through, for instance, new wetlands to strip nutrients from water or by creating buffer zones to revert to nature. This has had a significant negative impact on the number of homes granted planning permission in affected areas.
Defra said: “The government is clear that this can only be an interim solution.” It put forward a package of support measures in the policy paper. These included: practical support, financial support and legislation.
Practical support
catchment specific calculators to help developers identify the amount of mitigation required; a new framework from Natural England to assess mitigation effectiveness; £100,000 of public funding per affected catchment to pay for more catchment officers; and support for nutrient markets, including nutrient trading pilots with Entrade in Somerset and the Solent.
Moreover, Defra reported: “Ofwat is developing a proposal that could enable water companies to directly accept developer contributions for improvements to wastewater treatment works as a means of mitigating nutrient loads from new developments.The secretary of state for Defra and the regulators will shortly be writing to water companies with a call for evidence to identify suitable projects - along with attendant costs, benefits and risks - that could be funded by developers in the current water company price review period (2020 to 2025).
Financial support
Defra welcomed “proactive investment” totalling £24.5m from Severn Trent, United Utilities, South West Water and Yorkshire Water in strategic solutions to reduce nutrient pollution, including nature based solutions.
Legislation
Defra said it would explore legislation to further strengthen requirements to reduce nutrients at source, potentially via the Habitats Regulations Assessment process.
Elsewhere, the nutrient pollution policy paper pointed to: the £2.5bn being spent in AMP7 on measures to reduce nutrient pollution from wastewater; requirements for statutory Drainage and Wastewater Management Plans in the Environment Act; and the new SPS for Ofwat which makes it clear "that Ofwat and water companies should consider nutrient pollution in line with their environmental duties (which includes the Habitat Regulations), and that water companies should be challenged to prioritise improvements to protected sites and to work with wider stakeholders to support efforts to tackle nutrient pollution”.
It also highlighted that Natural England will launch five Protected Site Strategy pilots in spring, each with a tailored package of measures to tackle pressures in catchments, including nutrient pollution.
Outside water specific issues but with relevance with water
Biodiversity and nature recovery
The species recovery target will be assisted by the creation or restoration of in excess of 500,000 hectares of wildlife-rich habitat outside protected sites by 2042, compared to 2022 levels.
Alongside the target, the government published a Nature Recovery Green Paper to support its ambitions. Among other things this featured:
• a rationalised legal framework, supported by local expertise and scientific judgement, to enable regulators to be confident in making conservation decisions most appropriate for each site and ultimately ensure a better, more coherent protected site system;
• calls for proposals on how to accelerate private sector investment in nature;
• measures to scale up and de-risk a pipeline of investible nature projects through the £10m Natural Environment Investment Readiness Fund;
• a roadmap to achieve 30-by-30 – government’s intended path to achieving the commitment to protect 30% of our land and sea by 2030, as part of the global Leader’s Pledge for Nature; and
• an assessment of Defra’s delivery landscape – the Green Paper will explore what institutional and delivery arrangements would best support the government’s objectives for nature recovery.
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