Water industry calls for WRMP29 to be paused – or corrected

(by Karma Loveday)

Water UK has urged that the Water Resources Management Plan (WRMP) 29 process be paused to allow companies to engage with the development of a new water supply planning framework.

In the interim, it said companies should divert to the highest scenarios of WRMP24 and be allowed to re-open their 2024 plans if they feel their water resource needs have diverged significantly since they were drawn up.

The trade body reasoned that WRMP29 guidance contains many of the “fundamental flaws” of WRMP24. These have already resulted in water constraining housebuilding and impeding economic growth, “with businesses blocked from expansion in parts of Sussex, Essex, Cambridgeshire, Oxfordshire, Norfolk, parts of the Humber and Suffolk.” It went on to argue that if existing WRMP forecasts for the volume of water put into supply were re-forecast to correct for current population projections and to assume demand and leakage reductions follow recent trends rather than targets, “there is already a potential 400m litre a day shortfall in water available for use by 2030 – equivalent to the daily output of more than four of the ten reservoirs in the current supply scheme pipeline”.

Responding to the Environment Agency’s draft Water Resources Management Plan guidelines for PR29, the water industry argued that if the advice to pause is not heeded and the process goes ahead, the fundamental flaws need to be addressed. It listed these as follows:

• Contradictory ambitions – the guidelines say WRMPs should not constrain growth, and that they must contribute to Defra’s non-household demand reduction target of 9% by 2038. Water UK argued: “Water companies should either be asked to meet targets for non-household demand reductions or to support growth – they cannot do both.” 

• Unrealistic targets – the guidance requires companies to meet stringent domestic demand and leakage reduction targets which, if not realised, will result in a large gap between supply and demand. There is already a 220m litre a day gap between estimated and actual water put into supply in 2024-25 because demand reductions have not been achieved.

• Risk with ‘headroom’ – the guidance suggests water companies should accept more risk in future in terms of spare capacity in the system to allow for the uncertainty in forecasts. Water UK said headroom should in fact reflect the cost to the environment, society and the economy of not having enough water, compared with the cost of delivering slightly too much supply infrastructure.

• Environmental destination – Water UK said targets are inflexible and "not necessarily based on actual environmental harm”. But challenging them is difficult and requires up to 15 years of environmental data. It called for a “clear and proportionate governance structure” so environmental destinations can be challenged. 

• Flood risk – this should be considered where groundwater abstraction reductions are required.

• Growth modelling – this should be consistent across the country, especially as water transfers become an increasing feature of the system.

• Peak demand – Water UK described the fact that a target for peak demand is optional as “dangerous”. It called for a peak demand resilience standard, which companies should invest towards.

• New appointments and variations (NAVs) – a lack of clarity about how NAVs should engage with incumbent water companies regarding the levels of resilience that should be included in their WRMPs risks water companies adding spare capacity to the contractual volume of water asked for by NAVs, even if the NAV has already calculated required spare capacity in their contractual volume. This risks double counting the volume of spare capacity required.