Andrew Smith
Managing Director
Three Valleys Water,
PO Box 48,
Bishops Rise,
Hatfield,
Herts AL10 9HL
17 July 2008
Dear Andrew,
I am responding to the Three Valleys Water Consultation for the draft Water Resources Management Plan (WRMP).
Environmental impact
I am concerned that the draft WRMP does not include sufficient measures to reduce the pressure upon the over-abstracted [1] rivers of Hertfordshire, namely the Beane and the Mimram. These rivers currently fail to meet the flow requirements of the environment between 90% and 99% of the time in an average year respectively [2], yet the WRMP does not include any actions to reduce the pressure upon these resources.
The Hadley Centre’s Regional Climate Model predicts much hotter and drier summers and an increase in droughts in the future [3], all of which imply less water will be available; so I welcome the inclusion of “a reduction in water availability of around 5% by 2030 as a result of climate change” in the WRMP [4]. However I am concerned that there are no plans to relieve this increased pressure upon the chalk river system.
The Environment Agency’s chosen method for improving the resource availability statuses of the rivers of the Upper Lee are mainly centred on water efficiency measures of consumers [5]. Yet the primary use for metering in the WRMP is to recover water from existing customers for the supply of future customers, not to improve river flows.
Health hazards
Over-abstraction of an aquifer can cause it to dry out, which in turn can cause subsidence. Such subsidence can cause sewers to crack and leak into the aquifer causing contamination of the drinking supply. This is not covered in the WRMP and I would like to know to what extent Three Valleys expects the anticipated reduction in water reaching the aquifer, due to climate change and abstraction, will increase the cracking of sewers and subsequent instances of contamination, namely Cryptosporidium.
Metering estimates
The WRMP summary states Three Valleys has derived its figure of 12% savings achievable by metering from “our experience across the water industry” [6]. I am concerned that Three Valleys has not conducted sufficient research into this important part of the WRMP. The WRMP strategy is to maintain a water neutral strategy [7], reducing existing demand to absorb population growth without increasing supply, making the accuracy of water savings achievable paramount. Yet according to Ofwat, the UK Water Industry Research reports that “the average effect of metering on consumption is approximately 9%” [8], and I find a 3% difference too great to be reassured that Three Valleys will be able to maintain a water neutral strategy. You are being over optimistic.
The need for more water
It seems to me that in order to provide adequate water in the face of development pressures, climate change and the uncertain nature of metering estimates, that water will need to be imported from additional reservoirs and it is unrealistic to expect to able to meet the water needs and tackle the environmental measures without additional water supplies. Although I welcome the investment into Abingdon reservoir and the strategic water transfers Three Valleys intends [9], I believe the situation requires more.
Increased cost to customers
I am concerned that the draft WRMP will result in an increase in water bills for my constituents. I see that the cost of compulsory metering will be £61 million [10] yet in a note provided to my researcher on 13 June 2008, Three Valleys state that they only expect to save £0.5 million to £1.5 million a year [11], meaning that it will take at least 40 years until any financial saving to the customer is achieved despite an instant reduction in water consumption. I find this an extremely long period of time for a plan which is supposed to cover the next 25 years.
I am concerned that metering will increase bills for large families in the constituency. Large family households have larger daily water needs than the average household and I think it will be unfair to penalise them.
I am concerned that the reference to variable or seasonal tariffs in the draft WRMP [12] will mean large increases in water bills for many of my constituents, and that coupled with the requirements upon them to reduce their overall consumption will mean they will end up paying more for less. As climate change results in longer and hotter summers, it is very likely that hygiene concerns will encourage my constituents to use more water to clean themselves and it will be unfair to charge them extra for this necessity.
I would welcome your assurance that you will take a full account of my views.
Yours sincerely,
(signed Oliver Heald MP)
Notes
1. Pages 20,21 Upper Lee CAMS
2. Environment Agency briefing document “Water Resources in the Beane and Mimram Catchments” received 24 June 2008
3. PQ 209636, column 477 c395W topic “Water Supply: East of England”
4. WRMP: Overview and Stakeholder Consultation, p5
5. Environment Agency’s Catchment Abstraction Management Strategy (CAMS) for Upper Lee, p5
6. WRMP: Summary of our Plan, p22
7. WRMP: Overview and Stakeholder Consultation, p6
8. Correspondence with Ofwat Parliamentary Public affairs team, 3 July 2008 referred to “a report carried out by UK Water Industry Research, titled ‘A framework methodology for estimating the impact of household metering on consumption – supplementary information’.”
9. WRMP: Summary of our Plan, p37
10. WRMP: Summary of our Plan, p38
11. Correspondence with Mike Pocock of 12 June 2008, attached note: “Our metering programme should deliver savings of approximately 38Ml/d. The marginal cost of our most expensive source is around £100/Ml. If we could cut back on this source to the extent of 38Ml/d (which strictly we can’t at present without some significant changes to the network) the saving at the end of the metering programme would be £1.3 Million per year. Taking a more realistic marginal cost of £40Ml, the saving would be around £½ million.”
12. WRMP: Summary of our Plan, p22