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Drought Plan: Non-technical summary February 2013

DroughtPlan Summary v5 - Southern Water – Water and ... · PDF fileThe Environment Agency 1 definition is: “A drought ... Agency as an area of ‘serious water stress’. On average

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Page 1: DroughtPlan Summary v5 - Southern Water – Water and ... · PDF fileThe Environment Agency 1 definition is: “A drought ... Agency as an area of ‘serious water stress’. On average

Drought Plan:Non-technical summary

February 2013

Page 2: DroughtPlan Summary v5 - Southern Water – Water and ... · PDF fileThe Environment Agency 1 definition is: “A drought ... Agency as an area of ‘serious water stress’. On average
Page 3: DroughtPlan Summary v5 - Southern Water – Water and ... · PDF fileThe Environment Agency 1 definition is: “A drought ... Agency as an area of ‘serious water stress’. On average

2

Chapter pages

1. Introduction and overview .................................................................................................................... 3

This document ........................................................................................................................................................... 3

Purpose of a Drought Plan ......................................................................................................................................... 3

Overview of the Drought Plan process ....................................................................................................................... 4

2. Context for the Drought Plan .............................................................................................................. 5

What is a drought? ..................................................................................................................................................... 5

Southern Water’s area of supply ................................................................................................................................ 5

Southern Water’s water resources ............................................................................................................................. 7

Levels of service ......................................................................................................................................................... 8

3. Drought Plan Proposals ............................................................................................................................ 9

What triggers action in a drought? ............................................................................................................................. 9

Actions and restrictions on the availability of water supplies in a drought ............................................................. 11

Supply-side actions to increase the availability of water supplies in droughts ....................................................... 14

Drought Orders and Permits (supply-side) ............................................................................................................... 14

Unprecedented drought leading to emergency measures ........................................................................................ 15

Environmental assessment and monitoring of the Drought Plan proposals ............................................................ 15

4. Management and communications strategy .......................................................................... 16

Drought management structure ............................................................................................................................... 16

Drought communications plan ................................................................................................................................. 16

Post drought actions ................................................................................................................................................ 16

5. Consultation ................................................................................................................................................... 17

Southern Water Draft Drought Plan consultation

TablesTable 2.2 Target levels of service ....................................................................................................................................... 8

Table 3.1 Key to greyscale activity coding used in Figure 3.1 ........................................................................................ 11

Table 3.2 Summary of potential phasing of restrictions on demand .............................................................................. 12

FiguresFigure 1.1 Drought Plan timeline for Southern Water ....................................................................................................... 4

Figure 2.1 Schematic showing the Southern Water supply area ...................................................................................... 5

Figure 2.2 Composition of sources of supply by Water Resource Zone ............................................................................ 6

Figure 3.1 Generalised overview of relationships and phasing of triggers and drought intervention measures ............. 10

Table of contents

Drought Plan: Non-technical summary

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Drought Plan: Non-technical summary

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This document1.1. Southern Water supplies water to more than

2.3 million customers in South East England.The area supplied by Southern Water covers atotal of some 4,450 square kilometres, extendingfrom East Kent through parts of Sussex, toHampshire and the Isle of Wight.

1.2. The Company has a statutory duty to supply waterto customers. In doing so it has to carefully plan tomeet current and future demand for water and takeinto account potential changes to its supplies.An essential part of this planning is to assess theimpact that droughts can have on the demandand supply of water and to identify what actionsSouthern Water will take to respond to droughtconditions. Southern Water is legally required toprepare a Drought Plan to set out its proposalsand to consult widely on them before the Planis finalised.

1.3. This document is a non-technical summary(or NTS) of Southern Water’s Drought Plan 2013.The full Plan can be viewed atwww.southernwater.co.uk/droughtplan.

Purpose of a Drought Plan

A Drought Plan is “a plan for how the water

undertaker will continue, during a period of

drought, to discharge its duties to supply

adequate quantities of wholesome water,

with as little recourse as reasonably possible

to drought orders or drought permits.”

Water Industry Act 1991, Section 39B(2)

1.4. Drought Plans are used to ensure that the securityof public water supplies is not threatened in periodsof water shortage caused by an exceptionalshortage of rainfall. Southern Water’s Drought Planwill enable the Company to manage both the supplyof water resources and to influence customerdemand during drought conditions. The Plan willallow the Company to respond to different types ofdrought in a flexible way, allowing new actions tobe taken as drought conditions change.

1.5. Depending upon the severity of the drought, actionsmight include campaigns to encourage reducedwater use by customers, the introduction ofrestrictions such as Temporary Bans (previouslyknown as hosepipe bans), as well as enhancedcontrol of leakage and reduction in water pressure.Because of the uncertainty brought about bydifferent droughts, it is not possible to be entirelyprescriptive of the actions needed. However, theDrought Plan sets out what actions might beconsidered in response to a range of differentdrought conditions.

1.6. Since Southern Water’s last Drought Plan in 2008,new legislation has been implemented byGovernment to allow water companies to introducea wider range of Temporary Bans on water use bycustomers during drought conditions. SouthernWater’s proposals for such Temporary Bans areclearly explained in this Drought Plan.

1.7. The Drought Plan is complementary to SouthernWater’s Water Resources Management Plan(WRMP). The WRMP is a strategic plan whichdescribes how Southern Water aims to manageits supplies to meet forecast demands over the next25 years. Drought plans complement the WRMP,setting out “the range of short-term actionsnecessary to monitor and manage the impact ofdrought on their customers and the environment”(Environment Agency 2008).

1. Introduction and overview

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Drought Plan: Non-technical summary

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Overview of the Drought Plan process

1.8. Government regulations and guidance set out aclear process that must be followed in preparing aDrought Plan. These include:

• The Water Industry Act 1991 Section 39B and 39C(as amended by Section 63 of the Water Act 2003)– which makes it a statutory requirement for watercompanies to prepare, maintain and publishDrought Plans;

• The Drought Plan Regulations 2005 – which setout how Drought Plans should be prepared andpublished and how responses to representations arereceived; and

• The Drought Plan Direction 2011 – which sets outthe information that must be included in DroughtPlans and the timescales for submission.

1.9. There is also separate legislation which controlsthe way in which water companies introducerestrictions on water use and apply for DroughtPermits, Drought Orders and Emergency DroughtOrders.

1.10. Figure 1.1 sets out the key steps in the SouthernWater Drought Plan process.

Figure 1.1 Drought Plan timeline for Southern Water

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Drought Plan: Non-technical summary

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What is a drought?2.1. Droughts occur when a prolonged period of

abnormally low rainfall leads to a shortage of water.The Environment Agency1 definition is: “A droughthappens when a period of low rainfall creates ashortage of water for people, the environment,agriculture, or industry.”

2.2. Droughts can be of differing lengths and severity,affecting water supply and demand in differentways. A single hot dry summer will be very differentfrom a drought over several years. The areasaffected by droughts can also vary widely, withsome only affecting parts of Southern Water’s area,to others which might affect the whole of SouthEast England. Every drought is different and eachcan have a different effect on people and theenvironment.

Southern Water’s areaof supply2.3. Southern Water supplies water to customers in

parts of Kent, Sussex and Hampshire and to thewhole of the Isle of Wight. Other water companiessupply the remainder of South East England andseven water companies border Southern Water’ssupply areas:

• Thames Water;

• Wessex Water;

• South East Water;

• Affinity Water;

• Sutton & East Surrey Water;

• Sembcorp Bournemouth Water; and

• Portsmouth Water.

2. Context for the Drought Plan

Figure 2.1 Schematic showing the Southern Water supply area

1 Environment Agency (March 2008), Managing drought in England and Wales

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Drought Plan: Non-technical summary

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2.4. Each separate area of water supply is known as aWater Resource Zone (WRZ). There are ten WRZsin the Southern Water area. Some of these WRZshave, or could have, transfers in place to movetreated or raw water supplies between them. As aresult, actions taken in one WRZ can have animpact in connected WRZs.

2.5. Managing water resources within this area iscomplicated by the fragmented areas of supply, andthe inter-connections between Southern Water’sown supply areas as well as those with other watercompanies.

2.6. To plan effectively, Southern Water combinesindividual WRZs into three larger, sub-regionalareas, which allows water resources to be managedmore efficiently. These areas are:

• Western Area – comprising four WRZs in Hampshireand the Isle of Wight;

• Central Area – comprising three WRZs in Sussex;and

• Eastern Area – comprising three WRZs in Kent andEast Sussex.

Isle of Wight47% Groundwater

23% River30% Transfers

Sussex Worthing100% Groundwater

Sussex Brighton100% Groundwater

Sussex Hastings5% Groundwater95% Reservoir

Kent Thanet93% Groundwater

7% River

Kent Medway78% Groundwater

22% River

Sussex North35% Groundwater

51% River8% Reservoir6% Transfers

Hants Andover100% Groundwater

Hants Kingsclere100% Groundwater

Hants South37% Groundwater

63% River

Figure 2.2 Composition of sources of supply by Water Resource Zone

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Drought Plan: Non-technical summary

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2.7. Southern Water’s own water supplies come fromgroundwater, river abstractions and reservoirs.The majority (70 per cent) comes fromgroundwater, mainly from boreholes sunk into thechalk aquifer across the region. A further 23 percent comes from water abstracted from riversincluding; the Eastern Yar on the Isle of Wight; theTest and Itchen in Hampshire; the Western Rotherin West Sussex; the Eastern Rother in East Sussex;and the Medway and Stour in Kent. The remainingseven per cent of supplies come from four reservoirsowned and operated by the company. In addition toits own supplies of water, there are also a numberof supplies between the water companies.

2.8. The South East of England is one of the driestregions in the country, identified by the EnvironmentAgency as an area of ‘serious water stress’. Onaverage it receives some 730mm a year, which isbelow the average for England (around 840mm)and significantly below the average for the UKas a whole (around 1125mm)2.

2.9. It is the autumn and winter rainfall (400mm onaverage) that is critical to water supplies in theregion. During this period, rainfall rechargesgroundwater reserves, restores river flows for thefollowing year and is used to refill reservoirs.During the rest of the year most of the rainfall(330mm on average) is lost to the atmospherethrough evaporation and transpiration from plants,or runs off land directly into rivers and into the sea.

2.10. During droughts customers can experience verydifferent supply shortages depending on how thedrought has developed in relation to where theylive, even where drought conditions appear to bevery similar. This has been well illustrated duringrecent droughts, with different, often adjacent,WRZs and companies experiencing very differentlevels of supply shortages.

2.11. The primary reason for this is that different ‘types’of droughts affect different types of water sources indifferent ways. A supply shortage in an area will beaffected by the type of drought being experiencedand its effects on the mix of water sources in thatarea. Another factor is that quite small variations inrainfall across the region can lead to big differencesin the availability of water in different WRZs andsub-regional areas.

2.12. Normally, chalk groundwater sources are fairlyresilient to single dry winter droughts, due to thestorage capacity available within the chalk.However, they are more at risk and take more timeto recover from longer drought events.

2.13. Abstractions from rivers can be severely affected bya single dry winter, as this leads to lower summerand autumn river flows in the following year.Impounded reservoirs such as Weir Wood aresimilarly affected by a single dry winter. They onlyreceive water from the river catchment directlyupstream and there are no other ways of pumpingmore water into the reservoir.

2.14. Reservoirs such as Bewl Water and Darwell havewater pumped into them from sources elsewhere.As a result they are normally more resilient to asingle dry winter, but affected by long droughtsthat reduce the amount of water available fromthe other sources.

2.15. Summer droughts, featuring long hot, dry periods,tend to lead to high water demands affecting allwater sources, including reservoir storage whichcannot be replenished during the summer.

2.16. A further issue to consider is that Southern Wateris installing water meters across its supply area inthe 2010-2015 period. Research shows thatmetered households use less water on average thanun-metered households. Southern Water expectsthat as more households are metered and theirnormal level of water use reduces, any futuredrought restrictions will be less effective than isthe case now.

2.17. In planning for potential droughts, Southern Waterhas to take all of these factors into account toensure its Drought Plan is as resilient as possible.

Southern Water’s water resources

2Met Office website [accessed 19 Sept 2011], 1971–2000 averages

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2.18. In technical terms, it is possible to ensure thatsufficient water supplies could be provided to coverall but the most extreme droughts. In practice,however, Southern Water has to balance the coststo its customers of providing the infrastructure to dothis and the potential impact on the environment ofproviding that level of supply.

2.19. ‘Levels of Service’ set out the standard of servicethat customers can expect to receive from theirwater company. There are two levels of servicerelevant to drought and water resource planning:

• Customer levels of service – which indicate thefrequency and nature of restrictions that customersmay experience; and

• Environmental levels of service – which relate tothe frequency of Drought Permits and Orders atsome of Southern Water’s sources, that temporarilymodify abstraction licences to allow water tocontinue to be abstracted during droughts.

2.20. It is important to note that the targets apply acrossSouthern Water’s supply areas and that not allWRZs will experience the same number orfrequency of restrictions. In addition, not allrestrictions that are planned for are subsequentlyimplemented. For example, Southern Water mayapply for a Drought Permit or Drought Order on aprecautionary basis, but it would only beimplemented if environmental conditions require it.By their nature, droughts are unpredictable. Somerestrictions or licence variations may no longer berequired if the drought comes to an end earlier thanexpected.

Levels of service

Type of restriction/measure FrequencyCustomer target levels of service

Advertising to influence customers’ use of water 1 year in 5

Temporary Bans on certain uses of water 1 year in 10

Drought Orders to restrict wider types of water use 1 year in 20

Emergency Drought Order to implement widest restrictions on water use Only in civil emergency

Environmental target levels of service

Drought Permit/Order to increase water supplies through variations to abstraction licencesor other measures

1 year in 20

Table 2.2 Target levels of service

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Drought Plan: Non-technical summary

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3. Drought Plan Proposals

3.1. Water companies use drought triggers to identifyhow they plan to act in different drought conditions.The companies monitor rainfall, water levels andother environmental factors to determine when theyneed to take action to protect water supplies.

3.2. This enables companies to phase the differentactions they can take to influence and control thedemand and supply of water in response to theseverity and type of drought. Triggers are used toensure that measures are introduced in a timelyfashion, but only when they are actually needed tomanage the risk from a drought.

3.3. The diagram on page 10 (Figure 3.1) illustrates thisusing a simple ‘traffic light’ system, where yellowrepresents an impending drought; orange implies adrought and red a severe drought. This trafficlight system is consistently used throughout thisDrought Plan.

3.4. Figure 3.1 shows that Southern Water uses acombination of three types of triggers. The first tworelate to rainfall and river flows and reservoir levels.These are used to inform projections of the third

trigger, the balance between supply and demand forwater. Southern Water uses these three triggers incombination – there is no single indicator that isused to specify that a particular level of droughtand associated management actions should be inplace. This is a deliberate reflection of the complexmix of water resource types and vulnerability ofsupplies within the supply area.

3.5. Figure 3.1 also shows how Southern Water intendsto progress various actions as a drought becomesmore severe. These actions are cumulative and someasures introduced during less severe droughtconditions will continue to be in place as a droughtbecomes more severe and further actions areconsidered and implemented.

3.6. It is important to note that different triggers andinterventions take varying amounts of time tointroduce. They can also have very differentimplications in terms of the potential impact oncustomers, the environment and costs.These issues are summarised in Table 3.1.

What triggers action in a drought?

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Figure 3.1 General overview of relationships and phasing of triggers and drought intervention measures

Normalconditions

Impendingdrought

Droughtconditions

Severe droughtconditions

Buildingrainfall andsoil moisturedeficits

Clearrainfalldeficit insomeindicators

Significantrainfalldeficitin someindicators

Significantrainfalldeficitin most/allindicators

Severe rainfall deficitin increasing numbersof indicators

Waterefficiencymessages

Establish and maintain contact with statutory consultees throughout drought developmentand de-escalation

Droughtwarnings

Set up communications team and increasing intensity ofdrought messages

Increasinguncertaintyin supply/demandbalance

Clear risk ofsupply/demandimbalancewithouttemporarybans

Clear risk ofsupply/demandimbalancewithoutDroughtPermits

Clear risk of supply/demandimbalance withoutDrought Orders

Initial key DroughtPermits

Enhanced Drought Permitsand Orders

Re-commissiondisused sources

Drought operation of sourcesand bulk transfers

Other supply side measures(e.g tankering, prepare fordesalination)

Enhancedleakage/waterefficiencymeasures

Phase 2restrictions(DroughtOrders torestrictwater use)

Phase 3restrictions(all measuresnot introducedin Phases 1and 2)

Phase 1 customer siderestrictions (temporary banson water use)

– March/April groundwaterlevels or river flows close to1 in 10 year breach levels

– Reservoir levels nearingcontrol curves

– Groundwater levels andsurface flows below 1 in 10year breach levels

– Reservoir levels below relevantcontrol curves

– Groundwater levels andsurface flows below 1 in 20year breach levels

– Increasing risk of no winterrefill/danger of reachingemergency storage

INTERVENTIONS

Supply

Dem

and

Com

munications

TRIGGERS

Supply/dem

andbalance

Flows&levels

Rainfalldeficit

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Actions within Southern Water3.7. In drought conditions, there are a range of actions

available to Southern Water, including:

• Media campaigns to raise public awareness and tourge all customers to conserve water, especiallyduring periods of drought;

• Increased activity to control leakage during adrought. The ability to do this is, however, directlyaffected by levels of leakage at the time as well aspreceding climatic conditions; and

• Management or reductions in mains pressure,which can lead to reduced leakage and may alsoreduce demand by restricting flow rates from open-tap devices such as garden taps. However, SouthernWater has a scheduled programme of pressurereduction over the coming few years, which willmean that this option will have limited effectivenessas a drought management intervention.

Restrictions on water use3.8. Since publication of the previous Drought Plan in

September 2008, Parliament has approved theFlood and Water Management Act 2010. This Acthas significantly widened the scope of thepreviously available powers for water companies tointroduce ‘hosepipe bans’.

3.9. These restrictions are now known as ‘TemporaryBans on water use’. The Act confirms thatTemporary Ban powers can be introduced widelyby water companies as:

“a water undertaker may prohibit one or more specifieduses of water supplied by it if it thinks it is experiencing,or may experience, a serious shortage of water fordistribution.”

3.10. In addition to Temporary Bans, Southern Watermay also apply for a Drought Order to furtherrestrict water use where the drought situation issevere. However, before applying for a DroughtOrder to restrict water use, water companies wouldbe expected to have made full use of their powersto introduce Temporary Bans on water use. In orderto grant a Drought Order, the Secretary of Statemust be satisfied that:

“By reason of an exceptional shortage of rain, a seriousdeficiency of supplies of water in any area exists or isthreatened.”

3.11. The procedures for introducing a Temporary Ban ora Drought Order are different. Whilst in both casesthe water company must give notice of its intentionto introduce the restriction, a Temporary Ban can beintroduced quickly, whereas for a Drought Order thetimescales are longer and the Secretary of Statemay require a public inquiry or hearing to be held.

3.12. Southern Water’s proposed phasing of restrictions,covering both Temporary Bans on water use and aDrought Order to restrict water use, is provided inTable 3.2. This information is a summary of what isa complex set of potential restrictions. Further detailon exactly what is and is not included under therestriction categories in the Table is provided in thefull Drought Plan document.

Actions and restrictions on the availabilityof water supplies in a drought

Activity Routine Enhanced Complex Very Complex

TriggersSimple triggers basedon operationaljudgement

Some complexityrequiring evaluationof multiple triggersand simple estimateof supply/demandbalance

Triggers evaluateoverall forecast riskacross surface andgroundwaterindicators andcombine in forecastsupply/demandbalance

Careful, quantifiedconsideration of alltriggers and forecastrainfall risks inconjunction with riskbased supply/demandforecast

Interventions

Activities withlimited/no impact oncustomers usingexisting SouthernWater systems andoperationalprocurement

Activities requiringsome preparation andinteraction withcustomers

Activities requiringset up of internalorganisations, impacton customers andpreparation/liaisonwith externalregulators

Activities involvingsignificant impact oncustomers, complexlegislative processes,planning permissionand/or significantprocurement activities

<1 month lead time 1 month lead time 1-3 months lead time3 – 12 months leadtime

Table 3.1 Key to greyscale activity coding used in Figure 3.1

Drought Plan: Non-technical summary

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Table 3.2 Summary of potential phasing of restrictions on demand

Restriction activity and comments

TemporaryBan orDroughtOrder

Impendingdrought

Droughtconditions(Phase 1)

Severedroughtconditions(Phase 2)

Severedroughtconditions(Phase 3)

No restrictions. Initial water conservationcampaigns. Increasing media campaign aboutpotential need for Temporary Bans should droughtsituation worsen

N/A � � � �

Watering a garden using a hosepipe (includes parks,gardens open to public, lawns, grass verges, areas ofgrass used for sport or recreation, allotment gardens,any area of allotment used for non-commercialpurposes and any other green space)

TB � � �

• Including national or international sports eventsgrass surfaces used for sport or recreation wherewatering is undertaken in relation to particularplaying or other surfaces designated by theCompany, for no more than two hours a week andonly between the hours of 1900hrs and 0700hrs

Cleaning a private motor-vehicle using a hosepipe TB � � �

• Including businesses specialising in hand carwashing using hosepipes as part of their process �

Watering plants on domestic or othernon-commercial premises using a hosepipe

TB � � �

Cleaning a private leisure boat using a hosepipe TB � � �

Filling or maintaining a domestic swimming orpaddling pool

TB � � �

Drawing water, using a hosepipe, for domesticrecreational use

TB � � �

Filling or maintaining a domestic pond using ahosepipe

TB � � �

Filling or maintaining an ornamental fountain TB � � �

Cleaning walls, or windows, of domestic premisesusing a hosepipe

TB � � �

• Including small businesses using water-fed polesto clean domestic walls and windows where thepurpose of cleaning is the removal of graffiti

Cleaning paths or patios using a hosepipe TB � � �

• Including small businesses whose sole operationsare the cleaning of paths and patios where thepurpose of cleaning is the removal of graffiti

Cleaning other artificial outdoor surfaces using ahosepipe

TB � � �

• Including small businesses whose sole operationsare the cleaning of hard standings where thepurpose of cleaning is the removal of graffiti

Table 3.2 continues on next page

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Restriction activity and comments

TemporaryBan orDroughtOrder

Impendingdrought

Droughtconditions(Phase 1)

Severedroughtconditions(Phase 2)

Severedroughtconditions(Phase 3)

Watering outdoor plants on commercial premises Order � �

• Including watering of newly bought plants andplants watered using certain water efficientapparatus such as drip or micro-irrigation throughperforated hosepipes and sprinkler irrigationsystems

Filling or maintaining a non-domestic swimming orpaddling pool

Order � �

Filling or maintaining a pond Order � �

Operating a mechanical vehicle-washer Order � �

• Including Washers that recycle water and as aconsequence use less than 23 litres of mainswater per vehicle

Cleaning any vehicle, boat, aircraft or railway rollingstock

Order � �

• Including where the purpose of cleaningis the removal of graffiti �

Cleaning non-domestic premises Order � �

• Including where the purpose of cleaningis the removal of graffiti �

Cleaning a window of a non-domestic building Order � �

• Including small businesses using water-fed polesto clean non-domestic windows �

Suppressing dust Order � �

Operating cisterns Order � �

Cleaning industrial plant Order �

Notes:

‘TB’ refers to a Temporary Ban under the Water Industry Act 1991, as amended by the Flood and Water ManagementAct 2010

‘Order’ refers to a Drought Order to restrict water use under the Water Resources Act 1991 and in accordance withthe Drought Direction 2011

Key to colours used:

Impending drought

Drought conditions Worsening drought conditions

Severe drought conditions

Table 3.2 Summary of potential phasing of restrictions on demand – continued

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Supply-side actions toincrease the availability ofwater supplies in droughts3.13. In addition to applying for Drought Permits or

Orders (see below) to increase water supplies,Southern Water has a range of other potentialsupply-side drought measures available to it. Underdrought conditions, Southern Water would look tooptimise the use of its existing water resources andother potential sources of supplies, by considering:

• Variations to the operation of the company’s ownsources;

• Inter-company bulk transfers of water supplies;

• Re-commissioning of unused sources;

• Enhancing abstraction at existing sources;

• Tankering water from adjacent WRZs and otherwater companies;

• Emergency desalination;

• Construction of new satellite boreholes;

• Distribution network modifications; and

• Wastewater recycling.

Drought Orders and Permits(supply-side)3.14. Under drought conditions, where a serious

deficiency of supplies is threatened or exists,which has been caused by an exceptional shortageof rainfall, the Company may need to apply forDrought Permits and/or Drought Orders to increasesupplies.

3.15. For existing licensed sources, DroughtPermits/Orders are used to increase the amount ofwater that can be abstracted and, where possible,to conserve reservoir storage. This is achievedthrough one, or a combination, of the followingtemporary measures:

• Reductions in releases of water from reservoirs tosupport downstream abstraction, or compensationflows to support the environment;

• Relaxation of Minimum Residual Flow (MRF)conditions, that prevent abstractions when riverflows fall below a certain level;

• Increases in the abstraction volumes authorisedin the licence; and/or

• Variations to groundwater abstraction licenceconstraints.

3.16. Drought Orders can also be used to authorise theabstraction of water from a named water sourcewithout an abstraction licence.

3.17. Southern Water may also apply for Drought Permitsduring the winter period in order to:

• Reduce the risk of Drought Orders/Permits in thefollowing summer;

• Assist the recovery of water supply resources whichhave been excessively depleted as a result ofdrought; and

• Assist the maintenance of water supply in droughtaffected areas.

3.18. It is important to note that Drought Permits andDrought Orders are only in force for specifiedperiods of time and can only be renewed for limitedperiods. Each Drought Permit/Order may requiredetailed environmental monitoring, together withthe implementation of measures to mitigate anyadverse environmental effects.

3.19. As part of the preparation of an application for aDrought Permit or Drought Order, the Company willconduct a review of available data and its suitabilityfor evaluating the environmental impact of theDrought Permit or Drought Order. If there are gapsin the data available, which may affect ourunderstanding of the environmental impacts of theDrought Permit/Order, the Company will discuss themost appropriate way in which these gaps may befilled with the Environment Agency. Whereappropriate the Company may implement aprogramme of additional monitoring prior to, andduring, the implementation of the Drought Permit orDrought Order.

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Unprecedented droughtleading to emergencymeasures3.20. The Company will make full use of the range of

supply-side and demand-side actions available aspart of Drought Permits or Orders as a droughtdevelops. Only when those measures areimplemented or in the course of implementationwould the Company consider whether the severityof drought conditions mean that Emergency DroughtOrders might be required.

3.21. Emergency Drought Orders allow water companiesto restrict supplies to customers through theimposition of rota cuts and/or the introduction ofstandpipes. These measures exist to deal with thevery remote possibility of a more severe droughtthan any seen in the last century or more in theUK. Ministers have made it clear that suchmeasures should be avoided at all costs andintroduced only as a last resort. Emergency DroughtOrders have not been put in place in the UK since1976. It should be noted that, due to theinvestments in resources that have been made sincethen, if similar conditions to those experienced in1976 were to occur again, there would not actuallybe the need for an Emergency Drought Order.

3.22. The range of measures available to watercompanies under Emergency Drought Orderlegislation includes power to:

• Limit the use of water for such purposes as itconsiders necessary;

• Introduce rota cuts; and

• Set up, and supply water by means of, standpipesor water tanks.

3.23. In the highly unlikely event of Emergency DroughtOrders being authorised and implemented, theCompany will give as much warning (minimum72 hours) as is possible to the local Fire Authoritybefore it decides to enact an Emergency DroughtOrder. The Company will also take all reasonablemeasures to secure adequate supplies of water forthe Authority’s use in the event of fire. FireAuthorities will be consulted closely during allstages of a drought event (not just when consideringEmergency Drought Orders) and will be madeaware of the implications that any measures takenby the Company might have on the availability ofadequate supplies for fire fighting.

Environmental assessmentand monitoring of theDrought Plan proposals3.24. The Southern Water supply area contains a large

number of sites that are nationally and/orinternationally designated. While these sites varysignificantly in type and nature, many will beaffected by the lack of rain associated withdroughts. However, only a small number of sitesare ecologically linked to water bodies that couldbe affected by the drought measures available toSouthern Water.

3.25. The primary objective of the Drought Plan is toensure that adequate quantities of wholesome waterare supplied, with as little use of DroughtPermits/Orders as possible. However, it is alsoimportant that the Drought Plan enables the phasedintroduction of interventions in a drought in amanner that balances the benefits in terms of watersaved or delivered, against the environmental andsocial impacts.

3.26. An environmental assessment of the potentialimpacts of implementing each supply-side droughtmanagement action has been conducted as part ofthe Drought Plan process. The StrategicEnvironmental Assessment (or SEA) EnvironmentalReport was published for consultation alongside theDraft Drought Plan. The report summarises thefindings and results of the SEA process andpresents information on the likely significant effectsof the drought intervention options.

3.27. Under the Conservation of Habitats and SpeciesRegulations 2010 (known as the HabitatsRegulations), Southern Water must also determinewhether the proposed supply-side droughtintervention options pose any significant effects onEuropean designated sites. Southern Water hasundertaken an assessment of where measures havethe potential to affect European designated sites,and this is also published for consultation.

3.28. The Drought Plan is not the end of the process forassessing environmental effects. The environmentalimpacts of Drought Permits/Orders would also beevaluated in detail as part of the preparation of anapplication.

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Drought managementstructure4.1. Once a drought is threatened or already exists,

Southern Water will convene a number ofmanagement groups, who will be responsible formanaging the Company’s response to the drought.In the first instance, a Drought Technical Group willbe formed. Where a more severe event isthreatened or existing, a Drought ManagementGroup will also be convened.

4.2. The Minutes of meetings of both groups will providean audit trail for the Company’s key decisions,actions and responses to a drought. From an earlystage in the identification of a drought, regularliaison is important between these groups, theEnvironment Agency and, where appropriate, otherwater companies and external stakeholders.

Drought communications plan4.3. In normal (non-drought) conditions, Southern Water

routinely provides information to its customers topromote water efficiency and to provide informationon water resources.

4.4. As drought conditions begin to develop, theCompany will increase this communications activitysignificantly. The objective of this is to increasecustomer awareness of the limited availability ofwater resources and the steps the Company istaking to manage its resources. There is a strongemphasis on the need for water conservation in thiscommunication.

4.5. Appropriate communications with customers andstakeholders prior to an anticipated drought arecritically important, to ensure that customers arekept fully informed as drought conditions begin todevelop. As a drought continues, the Company willprovide information on the status of water suppliesand how drought response interventions (bothsupply-side and demand-side) may affectcustomers.

4.6. In order to increase the effectiveness of itscommunications to customers and otherstakeholders during a drought, Southern Water hasdeveloped a Drought Communications Plan (DCP).The DCP covers not just communication activitiesbefore and during a drought, but also the periodafter the drought, when water resources recover.The DCP is informed by previous experiences, forinstance from the drought in 2004-07.

4.7. As drought conditions become more serious, therewill also be additional liaison with the EnvironmentAgency and other water companies.The objective ofthis liaison is to share data and exchangeinformation, as well as to coordinate mediacampaigns and other drought-relatedannouncements and to develop commonapproaches to managing the scarce water resourcesacross the south east region.

Post drought actions4.8. When a drought ‘breaks’, it often does so with

a period of much higher than normal rainfall.However, it may take some time for water resourcesto fully recover. Until there has been sufficientexcess rainfall to restore river flows and beginto recharge groundwater, available water suppliesmay still be restricted. A return to normal waterresource conditions can often take some time,especially for groundwater when effects can lastfor seasons or years depending on the severity andlength of the drought.

4.9. Where restrictions have been in place over asummer, Southern Water may need to wait untilFebruary or March the following year to establishwhether the supply situation has improvedsufficiently over the winter to allow waterrestrictions to be lifted.

4.10. Southern Water recognises that the importanceof retaining restrictions after drought conditionshave eased can often be difficult for customersand stakeholders to understand. This is especiallyso if high rainfall leads to flooding. However, theCompany needs to be reasonably certain that therewill be a return to normal water resource conditionsbefore it can lift its drought restrictions.The Company also has to be sure that in theshort-term it would not need to reverse itsdecision to lift restrictions.

4.11. The final stage of the post drought action is areview of the Company’s performance during thedrought, assessing the effectiveness of the DroughtPlan and building on lessons learnt. This review willevaluate the effectiveness of Southern Water’scommunication activities based on feedback fromrepresentatives from customer groups, individualcustomers and other stakeholders.

4. Management and communications strategy

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5.1. As required by legislation, prior to preparing itsDraft Drought Plan, Southern Water consulted withthe Environment Agency, Ofwat and Defra, during apre-consultation phase. The Company also took theopportunity to widen this consultation to include itsneighbouring water companies and the ConsumerCouncil for Water.

5.2. The Draft Drought Plan was issued to the Secretaryof State on October 1, 2011. The Secretary of Stategave Southern Water permission to publish its DraftDrought Plan on January 24, 2012.

5.3. Southern Water published the Draft Drought Planfor consultation on February 6, 2012. It wasavailable in both paper form and on the companywebsite.

5.4. Southern Water set an eight week consultationperiod for the submission of comments, witha closing date for consultation responses ofMarch 30, 2012.

5.5. Following the close of the consultation period, theCompany published a statement of response torepresentations on May 18, 2012. This statementwill detailed:

• The consideration the company gave torepresentations received;

• The changes made to the Draft Drought Plan as aresult of consideration of those representations,and the reasons for so doing; and

• Where no changes were made to the Draft DroughtPlan as a result of consideration of representations,the reason for this.

5.6. The Secretary of State gave Southern Waterpermission to publish the final Drought Plan inFebruary 2013.

5. Consultation

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www.southernwater.co.uk/droughtplan

If you would like further information please contact:

Drought PlanSouthern WaterSouthern HouseYeoman RoadWorthingBN13 3NX

Email: [email protected]

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