Friday, 14 January 2022

Major environmental challenges for the water sector

 A quick post on some of the major environmental challenges for the water sector:

1. Climate change – water is a key medium through which we feel the impacts of climate change but the sector is also energy intensive

A major challenge is achieving Net Zero carbon emissions, including Net Zero operational emissions by 2030 and for all emissions by 2050. Embedded emissions currently account for a fifth of industry emissions but are the hardest area to address and require changes in national and global supply chains. The latest costs of carbon from BEIS for use in policy evaluation could have a major impact on investment decisions based on carbon.

Mitigation options such as bioenergy and hydrogen production also have impacts on water demand and the water environment.

Adaptation is another challenge that needs to be addressed at the same time to reduce the impacts on our infrastructure. Climate change is a key driver of investment in water resources (with an additional 111Ml/d needed in the South East alone) as well as increasing surface water flooding and drainage. The CCC Climate Change Risk Assessment identifies wider impacts and investment needs – flooding, freeze-thaw and heatwaves.

2. Water Quality

England’s rivers, including 85% of the world’s rare chalk streams, are a valued resource, yet only 14% are in good ecological health. They face impacts from agriculture, the water sector and urban and transport sectors, which creates a complicated picture around who is responsible and who should pay for improvements.

More than 400,000 CSO events in 2020, investment is required to reduce the impact of these, especially in light of public pressure but it is also extremely costly.

3. Water Resources

We face the challenge of finding 720 Ml/d to replace unsustainable abstraction and improve the environment. In terms of drought, there is a1 in 4 change of a serious drought between 2018 and 2050. Work by NIC suggests greater costs to address this than are currently accounted for.

Tackling these challenges

A strategic approach is required for the water sector to address these challenges and should be:
  • Developed along with conversations linked to WINEP and WISER
  • Include a review of water company Net Zero plans, adaptation plans and previous environmental outcomes
  • Developing approaches to Natural Capital, nature recovery and environmental net gain (in context of wider six capitals and public value)

There is a need to influence policy on national water and environmental policy, including:
  • Environment Act targets
  • Planning and supporting housing growth
  • Farming and land management
Supporting an adaptive planning approach. 
  • Given the nature and scale of the environmental challenges, particularly those longer-term linked to climate change, this supports the use of an adaptive planning approach
  • Some water companies taking this approach in WRMPs but there is a need to join-up with DWMPs - nature-based solutions separately – need to join-up for efficient delivery
Supporting innovation required to tackle these challenges 
  • Culture change and institutional innovations are key to enabling nature-based solutions – needed at all level within organisations as there is often disconnect and this varies widely between companies



The Government’s role in building the UK’s resilience to climate change

We are already facing the impacts of climate change and regardless of mitigation actions and emissions scenarios we need to increase resilience in the UK.  The Met Office 2020 State of the climate report highlights these:


We have seen the impacts of shocks to our economy and society from Covid-19 and recent economic change. Climate resilience needs to form a major part of wider national resilience measures. This post briefly sets out the role of Government in the UK and how adaptation actions can be prioritised.

Role of Government

The Government has a key role in building the UK’s resilience to climate change. This includes:

  • Leading on resilience for the UK and promoting the importance of adaptation alongside mitigation efforts
  • Prioritising and facilitating actions across government 
  • The Committee on Climate Change third climate risk assessment (CCRA3) has recognised the need to include adaptation more within wider policies, highlighting that 11 of 15 relevant major UK Government announcements didn’t include adaptation alongside mitigation policy
  • Formal role in producing the National Adaptation Programme (NAP), under the Climate Change Act (2008)
    • Respond to the CCRA3 risks identified
    • Identify actions across Government but also devolved administrations, local authorities, infrastructure provides and wider
    • Delivery, monitoring and reporting against the NAP
  • Adapting essential services and infrastructure: Adaptation Reporting Power
  • Adaptation at the international level – COP26 core goal - call on countries to increase action on adaptation and reduce loss and damage; C40 Cities and other programmes increasing focus on adaptation
  • Research and innovation for adaptation
  • Note - devolved governments also have a key role to play with different approaches being taken in Wales, Scotland and Northern Ireland

How to prioritise actions?

The Committee on Climate Change's Third Climate Change Risk Assessment provides a range of actions and a framework for adaptation. It sets out 61 risks and opportunities with 8 highest priorities for adaptation in the next two years. Many risks and actions are relevant to the environment – habitats, farming, soil health etc. but health and business/ energy risks also and indirectly influenced by transport, housing and other sectors. The Adaptation Reporting Power will highlight specific risks for sectors and organisations reporting also.

Adaptive Planning provides another approach. This can be based on water resources and flood risk (e.g. Thames Estuary 2100) approaches as well as international examples - identifying the decision points and where we can do the planning but not necessarily implementing all the changes, with a range of actions and options to take in the future.

Taking an impact assessment approach using costs and benefits, including:
  • Ecological, economic and social impacts
  • Inequalities – impacts on poverty
  • Multiple benefits from measures
  • Impact on sectoral climate resilience assessments
Considering stakeholder and political elements:
  • Citizen assembly – this approach is being used by many local authorities and has been successful internationally on adaptation or specific resilience topics e.g. water resources
  • Consultations - the more traditional stakeholder consultation approach over 12 weeks can engage with industry and others on adaptation
There is an opportunity to build on COP26 and the leadership position the UK is taking on climate change action. The Government has a central role in coordinating and promoting an integrated approach to adaptation and mitigation.



Friday, 10 December 2021

A Plan for Net Zero

 Originally published on Affinity Water's website (https://www.affinitywater.co.uk/news/plan-for-net-zero) I'm reposting the Net Zero Plan I prepared working with many colleagues. The challenges for the water sector on Net Zero going forward will be in the detail of implementation, innovations and partnerships needed to deliver this efficiently and reduction of regulatory barriers to enable a low carbon transition. 

Our plan for Net Zero

While we at Affinity Water have been working hard to be “carbon neutral”- reducing our emissions by around 40% in the last five years, our recent work has led us to conclude that this is an area where we’re far better served by humility at the task still to be completed than pride in our achievement. And we believe this is true not only for ourselves, but for every business and organisation in our region and across the planet.

Climate change impacts our business and customers in terms of drought and reducing water resources, flooding, extreme weather such as heatwaves and freeze / thaw events and physical factors such as rising sea level. Significant investment will be required to support resilience of our supplies and protecting our communities from the impacts of climate change. There is global agreement that we all need to take action to keep the average global temperature rise below 1.5°C to avoid further damaging impacts.

This route map to Net Zero is a living document and we will update it regularly based on the innovations and partnerships needed for delivery and in response to policy and regulation changes. We will also need to adapt our approach in response to wider resilience issues such as the increase in demand for water we have seen during the Covid-19 pandemic. We welcome an ongoing conversation with our stakeholders and customers on how we can best deliver our ambitions.

 

Affinity Water: Carbon net zero by 2030

While the UK has committed to reach net zero by 2050, those of us who can move faster and go further should do so. That’s why we are announcing an ambitious goal and a new plan to reduce and reach net zero by 2030 for our operational emissions.

We recognise that progress requires a detailed plan to support this bold goal. We will achieve Net Zero operational emissions by 2030 through:

  • Reducing our carbon footprint (energy efficiency, demand reduction, fleet);
  • Developing renewables (solar and wind);
  • Sequestration (planting new forests, restoring soils, chalk grassland restoration in the Chilterns, and regrowing seagrass forests in the estuaries of Essex); and
  • Purchasing green electricity tariffs.

Below is a summary of our proposed actions to achieve our Water UK commitment to achieve net zero operational carbon emissions by 2030 including: energy efficiency, renewables, transport and nature based solutions for sequestration. We have also outlined our additional plans we will develop to address whole life carbon (our embedded emissions in infrastructure we build), additional nature-based solutions and eliminating fossil fuel use.

Beginning next year, we will also make carbon reduction an explicit aspect of our procurement processes for all of our supply chain. We will ensure that our progress on all of these fronts will be published in our Annual Report and updated in this plan. We are working with our communities to help them save water and are working on innovative projects to make new homes water neutral. About 20% of a UK average energy bill is from energy used to heat water. By saving water we can save carbon and help to reduce fuel poverty.

We will continue with innovative reverse auctions and engagement with farmers to promote better water sensitive farming which in turn creates carbon sinks. All this work will be supported by our voice and advocacy supporting public policy that will accelerate carbon reduction and removal opportunities.

This route to net zero confirms our commitment to reducing carbon emissions and we will continue to engage with and support other sectors to achieve this vision.

 

The scientific consensus is clear and the situation we face in the South East is stark

There is growing urgency for both businesses and governments to limit global warming to no more than 1.5°C, to protect human health and economic growth. At current rates of emissions, we have until 2030 before we reach this threshold of dangerous climate change. Avoiding it will require rapid and radical transformation of every sector of the global economy - halving global emissions by 2030 and reaching Net Zero carbon emissions by 2050 .

Climate experts agree that the world must take urgent action to bring down emissions. We must reach “net zero” emissions, meaning that humanity must remove as much carbon as it emits each year. It is easier to decarbonise some sectors of the economy than others. And the water sector must take a lead and has committed to achieve Net Zero operational emissions by 2030. It is an ambitious goal and is of fundamental importance to every person alive today and for every generation to come. No sector, company or individual can solve the problem alone, but we know that we need to make our contribution.

Additionally, the South East of England is already classified as a severely water stressed area. This means it gets less rainfall than other parts of the country. The Affinity Water area is one of the driest in the country. For example, between July 2016 and April 2017 the area received 33% less rainfall than the national average. The National Water Resources Framework has identified that we face a deficit 76Ml/d due to climate change in the East and 111 Ml/d due to climate change in the South East. Affinity Water are working with regional planning groups to develop this evidence further and find shared solutions to provide resilient water supplies .

We are currently producing our third climate adaptation report for Defra. The previous report identified drought, flooding and peak water demand as the key risks posed by climate change and provided a range of actions to mitigate these. The Committee on Climate Change’s Third Climate Change Risk Assessment identifies a range of risks with specific links to our Net Zero objectives, including soil health and risk to natural carbon stores (figure below) [4].

 

Our approach to achieving Net Zero

With a new and complex global societal issue, we strive first to learn and then to define a principled approach to guide our efforts. This has been fundamental to our recent work around chalk streams, and it’s the approach we’re taking to pursue our carbon goals as well. We’ve concluded that six principles will be vital as we continually innovate and take additional steps on an ongoing basis.

  1. Addressing the full scope of our emissions. We will develop carbon accounting and improve our baseline assessments in order to help us reduce our emissions.
  2. Taking responsibility for our carbon footprint. We will take responsibility for all our emissions – reducing first, offsetting next.
  3. Empowering customers. We will develop and deploy technology to help our customers reduce their carbon and water footprints.
  4. Ensuring effective transparency. We will publish our progress in our Annual Report and updating this route map.
  5. Using our voice on carbon-related and environmental public policy issues. We will support new public policy initiatives to accelerate carbon reduction and removal opportunities.
  6. Enlisting our employees and partners. We recognise that our employees and partners will be our biggest asset in advancing innovation and driving behavioural change, and we will create new opportunities to enable them to contribute to our efforts.

 

1. Addressing the full scope of our emissions

A big part of the challenge is that, as a society we have not committed sufficiently to reduce emissions. Scientists account for carbon emissions by classifying them into three categories, or “scopes.”

Scope 1 emissions are the direct emissions that our activities create — like the exhaust from the car you drive, or for a business, the trucks we drive to transport the products we use from one place to another or the generators we might run.

Scope 2 emissions are indirect emissions that come from the production of the electricity or heat we use, like the traditional energy sources that light up our homes or power the buildings owned by a business.

Scope 3 emissions are the indirect emissions that come from other activities in which we’re engaged, including the emissions associated with producing the food we eat, or manufacturing the products that we buy. For Affinity Water these emissions include emissions from some outsourced services and business associated travel in addition to our own vehicle fleet but do not include chemical manufacture, capital infrastructure and associated emissions (non-operational) or our customer’s energy use to heat water for example. Given this broad range, a company’s scope 3 emissions are often far larger than its scope 1 and 2 emissions put together. We may not have direct control over these emissions but will work with our supply chain and stakeholders to measure our impact and reduce these.

Clearly we need to measure all three of these scopes. At Affinity Water, we expect to emit about 40,000 metric tons of carbon this year from our operational activities. But scope 3 emissions, beyond those we currently report, are likely to be large too. Given the wide range of scope 3 activities, this higher percentage of the total is probably typical for most organisations, particularly those in infrastructure.

We’re committing to becoming carbon negative for all three scopes. Scopes 1, 2 and 3 as defined above by 2030. We also commit to reporting on non-operational scope 3 emissions by 2022/23.

 

2. Taking responsibility for our carbon footprint

We have set out a range of actions to take responsibility for reducing our own carbon footprint. These are summarised below in terms of reducing our operational emissions and taking a whole life carbon approach.

Reducing our scope 1 and 2 operational emissions

First, we will drive down our scope 1 and 2 emissions to near zero through the following steps:

  • We’ll reduce our energy use by 7.5% by 2030, by replacing and refurbishing equipment and plant and using smart and AI controls and analytics. In the last year we’ve assessed 155 pumps for example, focusing on pumps with a power rating over 100kW to gain maximum operational and we’ve reduced greenhouse gas emissions by 719t CO2e which equates to a 1% reduction of our total emissions.
  • We have shifted to a 100 percent supply of REGO (or Renewable Energy Guarantee of Origin) backed renewable energy, meaning that we will have power purchase agreements for green energy contracted for 100 percent of carbon emitting electricity consumed by all our pumping stations, buildings, and sites.
  • We will reduce or eliminate our fossil fuel use in standby generation and replace end-of-life gas heating with electric options (e.g. heat pumps).
  • By 2030 we’ll generate 10% of our energy usage from our own renewables like solar, wind or hydropower.
  • We are bringing forward electric vehicles to replace our existing fleet. We will also reduce mileage through use of virtual meetings as much as possible and have refurbished our offices to enable hybrid working.

Using this approach will leave a minimal amount of carbon to offset from 2030, which we commit to doing. We will achieve this through a portfolio of natural capital solutions - including afforestation (planting new forest on land without trees) and reforestation, soil carbon sequestration, seagrass restoration, wetlands, wet woodlands, and chalk grasslands.

  • We’ll plant 110,000 trees by 2030 and work with communities to ensure these provide wider benefits for drought and flood resilience.
  • Using a market-based approach we’ll work with farmers to plant cover crops on otherwise bare soil. This helps to restore soil health and depth and sequesters carbon.
  • We will work with landowners and conservation bodies to restore over 250 hectares of chalk grassland by 2030. Chalk grassland was once one of the defining features of the area we serve from Dunstable to Dover. Much of it has disappeared with different farming practices. Bringing it back will help us manage water supplies, will absorb carbon and will help recharge the water that goes into our globally rare chalk streams.
  • Our river restoration programme also has the potential to significantly improve carbon storage and we will develop and apply methods to assess and certify this.
  • We will develop a ‘blue carbon finance framework’, a seagrass nursery and trial seagrass restoration to capture carbon off our Essex coast as part of our Innovation in Water Challenge project.

 

Taking a Whole Life Carbon Approach (addressing Scope 3 emissions)

A large proportion of our emissions comes from the construction and operation of new infrastructure. We are taking a whole life carbon approach to our investment programme to help us reach net zero.

We will publish our baseline embedded emissions in 2022/23 and develop targets and a strategy to reduce these emissions.

We are developing our approach following PAS2080 – Carbon Management in Infrastructure. This includes the four principles to: build nothing, build less, build clever and build efficiently.

We are partners on the project ‘Enabling whole life carbon design’. This project will develop an industry wide approach to using carbon in decision making by considering data and visualization, process and governance and people and culture. In parallel to this project we will develop and apply a reduce carbon, reduce costs approach to our investment and procurement programme.

We are applying a risk and value approach to our AMP7 investment programme. We will utilise operational and capital carbon assessments in our decision making tools to support our route to net zero. This will require additional carbon calculation tools and databases as well as improving skills within our teams and our supply chain.

 

3. Empowering customers

We believe that one of our most important contributions to carbon reduction will come not from our own work alone but by helping our customers reduce their carbon footprints through saving water. Although we don’t count this as part of our emissions, it is critical to Affinity Water’s drive to become sustainable. We also want to support our vulnerable customers and address both water and fuel poverty.

For many customers, sustainability is already a core part of their lives, while others are beginning their work to mitigate their carbon impact. Regardless of where we all are on our journey, we’re committed to being of help.

Of all the CO2 emissions in the UK, around 6% are from overall water use. Around 89% of this comes from heating water in our homes and 20% of a typical household gas bill is due to heating water in the home.

The average carbon intensity of a person in England who uses the average amount of water is around 2.6kg of CO2 per day or one tonne per year. The majority of Affinity Water’s customers have consumption higher than this average. Even a very modest 5-6% reduction in water consumption could deliver around 50 kg CO2 saving per household in a year or 1.4 mega tonnes of CO2e per year based on 27.8 million households in the UK .

Affinity Water is aiming to reduce water consumption per head by 130 million litres a day in 2025 from a 2020 baseline. We’ve started a major campaign called Save Our Streams which is already helping one hundred thousand customers to save millions of litres per day. We are delivering in-home and virtual water wastage checks that are immensely popular with customers. Working with a new portal available to all customers we are supporting them faster, delivering more comprehensively, and, most importantly, delivering their bespoke needs. By 2030 we will have offered half of our customer base an actual or virtual home water saving visit. To sign up and find out more please see saveourstreams.co.uk

 

4. Ensuring effective transparency

When it comes to carbon reduction, real progress requires real transparency. Affinity Water will continue to disclose the carbon footprint of our work. We will support strong industry-wide standards for transparency and reporting on carbon emissions and removal, and we will apply these ourselves.

We will publicly track our progress in our Annual Report. We’ll continue to improve our ESG reporting to our investors. We also commit to signing up to the Carbon Disclosure Project by 2025. Through this process we will report on our climate risks and adaptation actions in an integrated way with our progress towards achieving net zero.

 

5. Using our voice on carbon-related public policy issues

We will also use our voice to speak out on four public policy issues that we think can advance all of the world’s carbon efforts:

  • Empowering consumers through transparency and information about the carbon content of goods and services. We are pleased that Defra have announced their intention to introduce mandatory water labelling which would give consumers clear information on how sustainable water using home appliances are. We called for this through our #WhyNotWater campaign two years ago and raised awareness of the issues by producing a ten tonne block of ice outside St Albans Cathedral.
  • We are advocating for the need to expand global basic and applied research efforts on carbon and sequestration and reorient them towards targeted outcomes and enhanced cross-border collaboration to develop the breakthrough technologies needed to achieve Net Zero global emissions. We will engage with Ofwat’s innovation competition by leading and partnering on projects that help achieve Net Zero and supporting design of future competition rounds and the approach for PR24.
  • We want the removal of regulatory barriers to help catalyze markets to enable carbon-reduction technologies to scale up more quickly. We are pursuing and an active role in the UK voluntary carbon market but we need to do more and work more closely with partners and government to expand this work further. We also support the Government’s proposals in their 10 point plan for a Green Industrial Revolution to increase public EV charging infrastructure, and driving the growth of low carbon hydrogen, which will support decarbonising our Heavy Goods Vehicles in future.
  • We are advocating the use of market and pricing mechanisms so people and businesses can make more informed carbon decisions. We already use market mechanisms but are trialling further refinements to market mechanisms to create a wider set of benefits – improving biodiversity, water quality, soil health and sequestering carbon through the same investment. We also want partners, local authorities, financial services companies, landowners, farmers, and environmental NGOs to work with us and invite potential partners to approach us through.
  • Working with regulators to ensure that our business plan and investments from 2025 to 2030 help us achieve net zero. Ofwat’s PR24 and Beyond framework recognises the challenge of achieving Net Zero and the review of the Water Industry National Environment Programme (WINEP) provides a further opportunity to take a lower carbon and nature-based approach.
  • Integrating adaptation and net zero policy and strategy - the Committee on Climate Change’s third Climate Change Risk Assessment identified that only four of fifteen government announcements in the past 3 years included integrated goals on adaptation and reducing emissions. The water sector is a large energy user and needs support to move to net zero.

 

6. Enlisting our employees and partners

Finally, we’ll capitalise on the energy and intellect of our employees by inviting and encouraging them to participate in our carbon reduction and removal efforts. We believe that sustainability is a cause that is not only important to our employees, but an area where they can generate important insights and innovations across the company.

We know that others who have begun the journey to net zero have changed the culture in their organisations to focus on sustainability. As we’ve started to put Chalk Streams at the heart of our business we will also create more opportunities for our employees to become actively involved, both in company-wide activities and in the work of their individual teams.

We’re launching an expanded internal website where our employees can learn more about climate change and the role they can play. Each year this work will culminate during an annual sustainability hackathon event “SusHack” that will include a specific focus and call for proposals on carbon reduction and removal.

We need to equip our teams with the tools and knowledge to reduce carbon. Awareness raising and training across an organisation has been shown to reduce carbon by 5-15% in other organisations. In addition to in-house training we will give specific training from the Institute of Civil Engineers for engineers and projects managers on infrastructure carbon assessment.

We will begin to implement new procurement processes and tools to enable and incentivise our suppliers to reduce their scope 1, 2, and 3 emissions. We will work with our suppliers to implement consistent and accurate reporting and pursue effective steps to make progress against our targets.

We will aim to support all our partners and ask that they have a Net Zero plan in line with our own by 2025 or sooner. This will be key to ensure that we do not export emissions to other countries and sectors where it is harder to decarbonize. Our data and communications suppliers are already aiming to achieve Net Zero by 2025 and we will work with those that are further ahead to help our wider supply chain.

 

Rising to the challenge

Reducing carbon is where the world needs to go, and we recognise that it’s what our customers and employees are asking us to pursue.

It won’t be easy for us to get to Net Zero by 2030. And even harder to reach net zero for embodied carbon. In particular, we need to move very quickly on scope 3 emissions and will report on our progress in our Annual Reports. We believe it’s the right goal. And, with the right commitment, it’s an achievable goal. We will need to continue to learn and adapt, both separately and even more importantly in close collaboration with others around the world.

We launch this route map with our initial plan and a line of sight, but we have problems to solve and will work with our customers and stakeholders, including our supply chain, to achieve net zero. We will develop this conversation as we begin our business planning process for PR24 and beyond.

 


  1. See summary of IPCC report on limiting global warming to 1.5°C https://post.parliament.uk/research-briefings/post-pn-0594/
  2. https://www.gov.uk/government/publications/meeting-our-future-water-needs-a-national-framework-for-water-resources
  3. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/477213/climate-adrep-affinity-water.pdf
  4. https://www.theccc.org.uk/wp-content/uploads/2021/07/Independent-Assessment-of-UK-Climate-Risk-Advice-to-Govt-for-CCRA3-CCC.pdf
  5. Net Zero and the role of Water Efficiency, Waterwise, 2020

Monday, 28 June 2021

Ofwat's PR24 and beyond - what does it mean for the environment?

Ofwat have released PR24 and beyond: Creating tomorrow, together (131 pages), which sets out their initial views on the framework for PR24 and future price reviews.

In summary, the implications for the water sector on the environment include:
  • Ofwat see climate change and increased customer interest and expectations on the environment as key divers for PR24
  • Partnership working and nature-based solutions will be a focus in PR24, however Ofwat want to see third parties picking up a fair share of the costs (and will likely question where customer money is spent). However, Natural Capital approaches and Biodiversity Net Gain aren't specifically mentioned as tools and more explicit consideration of these from Ofwat will help companies engage with other sectors to deliver nature-based solutions.
  • A market operator approach won’t be considered in PR24 for the environment. We need to effectively engage with cross-sector groups from a whole company perspective for PR24 if we want nature-based and joined-up solutions. 
  • Ofwat consider price reviews as staging posts. Given environmental improvements (e.g. Net Zero and WINEP) are long term we can expect this to be reflected in their approach for PR24, potentially setting outcomes across AMPs.
  • We are likely to see targeted challenges linked to incentives on the environment and will need to continue to engage with Ofwat’s innovation competition.
  • Although not able to influence non-discretionary regulatory related spending on the environment, customers may have important views on how we deliver environmental improvements.
  • Companies need to ensure they are joined up across the many strategic plans on the environment with their PR24 business plan. Ofwat will join up with other regulators but “will ultimately assess companies’ business plans independently of other regulators”
  • Companies will need to consider outputs related to the environment (separate to outcomes) in PR24 and also the potential for some community engagement on the environment to be considered outside price controls. This will be through PCDs (Price Control Deliverables), something Ofgem currently uses.
  • Cost assessment for the environment will most likely be benchmarked 
  • Companies will need to account for climate change in base and enhancement programmes with an efficient additional cost allowance for carbon reduction. Ofwat want to focus on emissions reduction before offsetting in AMP8.
This summary collates out some of the main details related to the environment and I hope it can help our sector-wide discussions as we progress through the PR24 business planning process. Ofwat are consulting on this document with responses due 22 July 2021.

Facing into the future – what do Ofwat see as the challenges?

  • “Climate change threatens resilience, both of our networks and our water supply. We’re already seeing drier summers, more frequent and intense rainfall, more variable river flows and biological changes in water bodies. In England, it’s estimated that there is a 25% chance of the worst drought in recorded history within the next 30 years.
  • Customers are increasingly concerned about damage to the environment from taking water from rivers and chalk streams, discharging waste through storm overflows, and addressing carbon emissions and biodiversity pressures. Future targets likely to come from the environment bill”.
  • Moment for fresh thinking and real change – focus on collaboration outside the sector, nature based solutions and game-changing innovations. The figure below outlines some of the long-term targets and commitment for the water sector.

Ofwat see climate change and increased customer interest and expectations on the environment as key divers for PR24.

Markets and systems operation

The UK government has outlined a long-term ambition to move towards a system operator approach for managing natural capital and stakeholders such as UU are proposing catchment operators for the water sector. However, Ofwat are going to focus on co-ordination across the sector through regional water resources groups, DWMPs, WRMPs, RAPID and the WINEP Task Force.

We will need to effectively engage with cross-sector groups from a whole company perspective for PR24 if we want nature-based and joined-up solutions.

Increasing focus on the long term

Ofwat are keen for to support companies to develop a long-term perspective. For example, the five year price review should be seen as a staging post within a longer term context. They highlight that “Net zero, in particular, may require a fundamental change in how the sector operates. All areas of company operations impact on net zero – this transition will impact with all other long-term goals and ambitions. Solutions will need to involve significant innovation including within the supply chain, behavioural changes by customers, and the far greater adoption of nature-based solutions”.

Ofwat are working with others to reform the WINEP. They want to move towards a more outcomes focused WINEP that encourages water companies in England to pursue broader catchment management and nature-based solutions to deliver multiple environmental and social outcomes.

Ofwat consider price reviews as staging posts. Given environmental improvements (e.g. Net Zero and WINEP) are long term we can expect this to be reflected in their approach for PR24, potentially setting outcomes across AMPs.


Targeted Challenges and Innovation

Ofwat see business plan incentives remaining in PR24 (reputational, procedural and financial – performance commitments). They are considering targeted challenges given the impact of the 15% leakage reduction challenge in PR19 leading companies to go further. They will initially look at water efficiency and harm caused by discharges from the wastewater network – the first directly affecting us and the second impacting on our raw water quality. They will also consider challenges coming out of targets from the Environment Bill, which is currently being debated in Parliament.

Ofwat will be reviewing the Innovation Challenge. Their priorities have been around the environment and resilience to date. They will consider the innovation fund when assessing the level of productivity improvements and will also look at a future fund in PR24.

We are likely to see targeted challenges on the environment and will need to continue to engage with Ofwat’s innovation competition.

Customer Engagement

Ofwat plan to simplify how companies engage with customers and develop a collaborative national approach. For the environment they highlight that a significant proportion of enhancement spend is driven by schemes that follow directions from Environment Agency, Natural Resources Wales, Drinking Water Inspectorate or Defra (over 75% of funds allocated for enhancement in PR19). In PR24 this non-discretionary spend is likely to increase given statutory requirements from the Environment Agency and further long-term government ambitions. This may limit customer influence on the expenditure but they will still have important views on how it is delivered. 

Although not able to influence non-discretionary regulatory related spending on the environment, customers may have important views on how we deliver environmental improvements.

PR24 in the context of other strategic planning frameworks

The timing and overlap between PR24 and other strategic plans can have major impacts for how well outcomes are delivered. Ofwat are planning to work with other regulators to join-up these processes and input earlier to them to ensure join-up with PR24. There is also a range of evolving government policy and legislative changes on the environment to consider:
  • Environmental Land Management Schemes (ELMS)
  • Storm Overflows Taskforce
  • Environment Bill including Local Nature Recovery Strategies to increase collaboration with local authorities on nature
  • Strategic Policy Statement from Defra following the Environment Bill


Ofwat plan to work more closely with other regulators, however “will ultimately assess companies’ business plans independently of other regulators”.


Companies need to ensure they are joined up across the many strategic plans on the environment with our PR24 business plan. Ofwat will join up with other regulators but “will ultimately assess companies’ business plans independently of other regulators”

Long term outcomes – Form PCs to PCDs (Price Control Deliverables) and performance outside the price review

Ofwat have identified environmental outcomes to incentivise: These include outcomes that help protect the environment, such as encouraging water efficiency or enhancements to the environment where these are delivered as part of core water company services. This could include measuring greenhouse gas emissions. The WINEP Task Force is looking to develop more outcomes, however some aspects will continue to be outputs delivered. Ofwat propose to rename these Price Control Deliverables (PCDs) based on the approach Ofgem have taken. Ofwat plan to review common PCs and reduce the number of bespoke PCs, which will impact on the number of PCs we have around the environment in PR24.

Ofwat have also identified some areas that could be outside the price control. For instance, Anglian Water has partnered with Keep Britain Tidy who deliver Beachcare and Rivercare. These schemes helped community led volunteer groups to effect positive change. Anglian Water’s engagement in these schemes was not part of the price control or its incentives, but the company has still continued to support these schemes. This would allow water companies to seize opportunities as they occur, when they work with their communities, better enabling them to deliver core services differently and provide greater value. 

Companies will need to consider outputs related to the environment (separate to outcomes) in PR24 and also the potential for some community engagement on the environment to be considered outside price controls.


Cost Assessment

On the environment Ofwat are asking questions on:
  • How we can take into account of key emerging issues such as net zero, public value and partnership working?
  • How we can improve our assessment of nature-based solutions, so that they are appropriately incentivised through the cost assessment framework?
For the environment Ofwat use cost benchmarking to identify efficient costs for enhancement programmes. They used benchmarking for most of the environmental programmes, to improve drought resilience and metering programmes, which covered 70% of enhancement proposals.

Moving to Net Zero
Ofwat suggests companies need to consider how each five-year period provides a checkpoint on the route to Net Zero. The sector has started considering operational emissions but will need to consider embedded carbon to meet the UK government commitment by 2050. Ofwat have set out their view on offsetting below – I’ve copied it across in full as it will be key to delivering our Net Zero Action Plan: 

“To achieve net zero, substantive decarbonisation of water and wastewater services is fundamental. Offsetting, where emissions are offset by alternative measures such as tree planting, does not address the root cause of emissions and so should only be used as a last resort when other alternatives have been exhausted at this point in the transition to net zero. We currently consider that the primary focus at PR24 needs to be on driving carbon emissions down, rather than offsetting them”.

And on costs:
“Such a fundamental change of approach to delivering water and wastewater services could mean a change in the costs of providing those services. Seeking opportunities to reduce carbon may reveal opportunities for reducing cost and increasing environmental benefits via nature based solutions. We also recognise that transition to net zero may increase costs of service. Potentially there are some areas where higher upfront costs are offset by lower energy and chemical costs, meaning no higher costs over the whole life of the assets for customers to pay. We recognise that investment required by companies, for example to deliver environmental improvement programmes, can deliver net zero benefits.

Ofwat are considering how best to reflect the transition to net zero in our cost assessment approach. Potential options we are considering include:
  • Asking companies to identify the carbon reduction benefits resulting from base expenditure and existing enhancement programmes as part of their business plan; and
  • Using the outcomes framework to compensate companies if they go beyond the carbon reduction that can be delivered through base costs and existing programmes; and/or
  • Allowing additional or incremental carbon reduction costs where proposals are well evidenced and demonstrate benefits over and above purely carbon benefits alone, and, where feasible, benchmarking incremental unit costs of carbon reduction to provide an efficient additional cost allowance for carbon reduction.”

Cost assessment for the environment will most likely be benchmarked


Companies will need to account for climate change in base and enhancement programmes with an efficient additional cost allowance for carbon reduction. Ofwat want to focus on emissions reduction before offsetting in AMP8, however the industry recognises the wider benefits of offsetting and that it will be required due to process emissions.




Thursday, 10 December 2020

What does the Government’s 10 Point Plan for a Green Industrial Revolution mean for the water sector?

The Government released their 10 Point Plan for a Green Industrial Revolution in November 2020. This builds on announcements around a green recovery and to deliver the ambition for the UK to achieve net zero carbon emissions by 2050. This plan also pulls together all the wider policy and strategy that we expect to see in 2021 – the environment is now seen as central to Government policy going forward.

The headline is £12bn investment, however this is closer to £4bn in new announcements. Although the plan may only help reduce UK emissions by 5% between 2023 and 2032 (see Utility Week article) there are elements that will support the Water UK Routemap to net zero by 2030 and the sector's ambitions on natural capital.

In this blog post I've highlighted some of the key areas that will have implications for the water sector. There will be wider implications as the range of supporting policies and strategies are consulted on in 2021 (see the summary image at the end of this post).

Implications for the water sector

Hydrogen – “Working with industry aiming to generate 5GW of low carbon hydrogen production capacity by 2030 for industry, transport, power and homes, and aiming to develop the first town heated entirely by hydrogen by the end of the decade”

A move to hydrogen for transport will support the green vehicle fleet ambitions in Carbon Reduction Strategies and the commitment to net zero operational carbon emissions by 2030. Larger vehicles (e.g. HGVs) don’t currently have feasible electric alternatives. A Hydrogen Strategy will be consulted on in 2021 and it will be important that this considers the demand side strategy (e.g. filling networks) in addition to production, so that the water sector and other users of HGVs can have access to alternative fuels to enable our net zero ambitions. There will also be a need to consider the water demand impacts of new hydrogen infrastructure.

Electric Vehicles – “Backing our world-leading car manufacturing bases including in the West Midlands, North East and North Wales to accelerate the transition to electric vehicles, and transforming our national infrastructure to better support electric vehicles.”

The new 2030 phase out date for petrol/ diesel cars and vans supports the timing needed to meet the 2030 net zero routemap ambitions. The grants for charging infrastructure and for electric vehicles may help this transition. The £1.3bn for wider public charging infrastructure may also support delivery of EV strategy and support flexibility of operations with EVs.  

The range of challenges for developing EV programmes within a water company have been outlined by SES Water and this announcement from Government will help address charging and whole life costs. Additionally, by making EVs mainstream and the positive support from Government and the media it can support employee use and uptake/ acceptability.

Homes and buildings – “Making our homes, schools and hospitals greener, warmer and more energy efficient, whilst creating 50,000 jobs by 2030, and a target to install 600,000 heat pumps every year by 2028.”

The energy efficiency announcements focus on space heating and a move to lower carbon sources such as heat pumps. Heating hot water in the home is the largest source of emissions after space heating (CCC, 2019). There is a need to join-up water and energy efficiency programmes to provide more cost-effective energy efficiency through water efficiency, provide green jobs and reduce the issue of homes needing to be visited twice. Joint programmes will also support PCC reduction targets and deliver public value through green jobs. There is also a need to understand how to account for carbon emissions from hot water through any partnership programmes delivering water efficiency.

The Water UK 2030 Routemap to Net Zero highlights the need for Government to support to reduce water and energy use:

  • Introduce a mandatory labelling scheme for water-using appliances like washing machines and dishwashers, backed by minimum performance standards
  • Change Part G of Building Regulations to stop the constantly-increasing stock of water inefficient homes

Nature – “Protecting and restoring our natural environment, planting 30,000 hectares of trees every year, whilst creating and retaining thousands of jobs.”

A £40m second round Green Recovery Challenge Fund may support the sector's ambitions to bring forward investment for the green recovery. There is a need to engage with the new National Parks, AONB designations and Landscape Recovery projects that will protect up to an additional 1.5% of natural land in England.

A Nature Strategy and a Tree Strategy will be consulted on in 2021 and these will have implications for delivering natural capital and environmental net gain. Water sector catchment programmes will also need to engage with new Environmental Land Management pilots as we move away from the Common Agricultural Policy, alongside Productivity Grants for farmers.

What next?

Actions that water companies and the sector can take to engage with the 10 point plan include:
  • Identify opportunities from the Green Recovery Challenge, Nature Climate Fund, landscape recovery and ELM pilots to support natural capital ambitions.
  • Develop partnerships to utilise these funds.
  • Establish sector positions on consultations to support responses in 2021.
  • Respond to the Hydrogen Strategy in 2021 to support our HGV transition to net zero
  • Respond to consultations on energy efficiency in homes in 2021
  • Respond to the England Tree Strategy and the Nature Strategy in 2021

The long-term targets in the Environment Bill will be consulted on in 2021/22 and will also support the water sector's ambitions. Ofwat have also now launched the PR24 and beyond publication, which sets out a range of environmental and resilience ambitions with 12 key questions that they are engaging on through a Future Ideas Lab.







Wednesday, 18 September 2019

How water companies operate - environmental responsibilities

I was recently asked to present on how water companies operate in terms of their environmental responsibilities (in England). A complex regulatory environment exists in relation to environmental management and water companies. This blog post provides a high level overview on managing responsibilities in relation to planning, monitoring and reporting and future challenges faced by water companies.

Planning


There are many challenges for sustainable water management. The figure below from Anglian Water provides a useful summary. There are increasing challenges from Ofwat in terms of markets and innovation that are pushing for efficiencies and resilience (though there is tension between these two elements in the draft determinations for PR19).



We face a very complicated regulatory landscape in the water sector (see figure below). This has driven investment to improve environmental and public health outcomes and regulations have more recently evolved to support this through outcome based approaches, TOTEX and greater voluntary reporting. This complex regulatory landscape for the environment includes the Environment Agency, Natural England, Ofwat, Defra, DWI, CCWater, the Committee on Climate Change and the National Infrastructure Commission. Tensions arise in meeting the objectives of all stakeholders as they aren't always aligned or being delivered on the same timescale.



Resilience planning is an increasing requirement linked to environmental responsibilities. This is wider than climate change impacts on long term water resources and quality as we increasingly need to account for heatwaves and peak demand as well as freeze/thaw events (both seen in 2018). Managing flood risk impacts on infrastructure, IT and networks as well as potential issues from Brexit also need to be considered for resilience.

The Government's 25 Year Environment Plan sets out a range of actions that impact on water company environmental responsibilities. Actions on Environmental Net Gain and requiring developers to consider the needs of the environment in terms of water for new properties will also impact on water management, in addition to requirements to demonstrate improvements to natural capital by water companies.

The three elements that inform the environmental responsibilities that need to be met by water company plans are outlined below (EA 2017).



WISER - Water Industry Strategic Environmental Requirements

The WISER document provides details across a range of environmental areas (see image below), including the Water Framework Directive, bathing waters, biodiversity, urban wastewater, invasive species, chemicals, resilience and compliance with Environmental Permitting Regulations. For each the document sets out legislation and duties, expectations, and good practice approaches.


WINEP - Water Industry National Environment Programme

The Water Industry National Environment Programme (WINEP) 3 sets out the actions needed by water companies to meet their environmental obligations. The number of obligations by water company is set out below. I'll use Anglian Water as an example as they have the highest number of obligations, driven by topography of the region, with intensive agriculture and slow moving rivers. Through their digital engagement programme, Anglian Water found that 74% of customers voted for high investment in protecting the environment. The Ofwat draft PR19 determination sets out £729m for Anglian Water to deliver this programme, however this is after pushing through many efficiencies in the process, which may be hard to implement.

Government strategy

The Government’s 25 Year Env Plan pushes the need to consider natural capital approaches and net environmental gain. These will be pushed forward in the forthcoming Environment Bill. Water companies have been looking into natural capital approaches for some time (Anglian Water example below). This includes moving beyond natural capital accounting to actively using it and the concept of net gain within planning. Concepts such as the Urban Greening Factor (now applied across London but also Southampton) might be useful for LDPs in other regions to help drive green infrastructure and manage water quality and sewer capacity issues. This area is evolving quickly with developments such as Natural England’s Biodiversity Metric (linked to Biodiversity Net Gain) and tools such as BEST from CIRIA (new version being released that accounts for the 6 capitals).





Water recycling long term plan and Drainage and Wastewater Management Plans

Anglian Water released a Long Term Water Recycling Plan in February 2019. This sets out their approach to strategically planning for wastewater capacity but also delivering against environmental obligations. Water UK's 21st Century Drainage Project has led to the development of guidance for Drainage and Wastewater Management Plans. These are being taken forward to meet requirements for the 2024 Periodic Review. As I outlined in my previous blog post, there are many changes occurring in water resources planning and it makes sense to join up with DWMPs to take an integrated water management approach to better enable resilience.




PR19 Performance Commitments

In additional to the regulatory and planning approaches to water companies delivering their environmental responsibilities, Ofwat will also be monitoring and incentivising these through performance commitments. Examples of these are provided below for Anglian Water and include commitments in common with other companies (C) and bespoke (B).


Monitoring and reporting

Environmental Performance Assessment

As set out in the WISER document, a key monitoring and reporting mechanism is the Environment Agency's Environmental Performance Assessment. The most recent assessment is below and this found many issues in 2018 and that they are continuing into 2019, which may lead to tougher regulatory approaches. Recent large fines handed down to Southern Water, Thames Water and others may also impact on the regulatory approach being applied (this could impact voluntary monitoring and reporting against EPR).



Annual reporting against the business plan

Water companies are required to report annually against their business plan, which includes performance commitments linked to the environment (example from Anglian Water below). Elements of this are included in company environmental and sustainability reports as well as dashboards that may be updated more frequently. In the future water companies will also report against their public interest commitment - this element of the hydro-social contract in Australia has led to more integrated water management.


The future

Research and innovation

There is a clear need for greater innovation and research to meet the environmental responsibilities of the water sector. Ofwat are consulting on proposals that could allow the sector to raise up to £200m and on new structures to support greater collaboration.

The UKWIR Big Questions include wastewater collection and recycling as ways to driver environmental improvements. This builds on the work that Water UK has been leading to support collaboration on 21st Century Drainage and moving to DWMPs.


At an individual water company level, several companies have been pushing forward their own innovation platforms. Anglian Water has been promoting their Innovation Shop Window in Newmarket. The aims of the shop window are below and include zero pollution and flooding and becoming carbon neutral.



Catchment based approaches

The Catchment Based Approach will increasingly lead to more efficient approaches to dealing with diffuse pollution issues. This includes water companies working with rivers trusts and other local organisations. Rather then relying on end-of-pipe engineering based solutions this approach can be more cost effective and deliver wider benefits through community engagement. A catchment based approach will also be key delivering natural capital approaches. The figure below highlights the benefits of this approach in 2017/18.



Transitions for resilience

There is also a need for a wider transition towards resilience that will also help meet environmental responsibilities of the water sector. This transition approach was mapped for the UK in a 2013 report by CIRIA (image below). Although we know this isn't always a linear transition across all elements of water management this approach can help visualise the line of sight towards a water cycle city and water sensitive city for the UK.


Based on the experience in Australia, there are also a range of transition factors and those identified for the UK in the 2013 CIRIA report (many are still yet to be delivered) include:
  • Presence of a co-ordinating body - the question remains around "who is responsible" for many aspects of water management within fragmented regulatory and operational elements of the water sector in the UK.
  • Evidence base, guidance and training - some provided at a national level by SuSDrain or local levels such as in London.
  • Presence of Water Sensitive Urban Design champions - SuSDrain is aiming to drive SuDS champions, however we need champions for wider elements of integrated water management also.
  • Supportive planning and design process and legislation - this is complicated by elements of the Flood and Water Management Act 2010 not having been enacted.
  • Reliable science and research - this area is a focus for many universities however Ofwat's proposed approach to research and innovation or greater focus on academic and industry partnerships through Innovate UK may help this to influence policy and practice.
  • Fostering environmental expectations - with climate and ecological emergencies being declared and pressure on government in relation to the 25 Year Environment Plan, there is an opportunity for this transition to get greater political support.
  • Strategic funding and incentives - DWMPs may enable a more strategic funding approach with partners. This could link up with innovations such as the Greater Manchester Combined Authority's Natural Capital Investment Plan.

Conclusions

Overall water companies operate within a complicated regulatory regime to deliver environmental obligations. There is a need to balance costs, risk, customer and regulatory expectations. Monitoring and reporting are key and potential changes to EA regulation may arise due to recent poor performance. In the future this will be supported by DWMPs, building on catchment-based approaches and transitioning to integrated water management.

Join the conversation at the IWA World Water Congress 2020 in Copenhagen


The call for papers and workshop proposals is open until 30 October 2019. Theme 6 is calling for papers on water resources and large scale water management, including delivering against environmental responsibilities relating to:

Groundwater

  • Groundwater mapping, monitoring and modelling
  • Protection of groundwater quality and quantity
  • Soil contamination and groundwater remediation
  • Governance, management and institutional arrangements

Surface Water

  • Surface water monitoring systems and models
  • Protection of surface water quality and quantity
  • Source-to-sea pollution management
  • Pollution from point sources – agriculture, industry, urban
  • Diffuse pollution – sources and mitigation
  • Water-related ecosystems and environmental flows

Integrated Water Resources Management

  • Water stress, droughts and floods, including impact of climate change
  • Catchment management and ecosystem services on different scales
  • Large-scale nature-based solutions and biodiversity
  • Water rights, trading and partnerships

Holistic Assessments

  • Life cycle assessment, water efficiency, water footprint, virtual water, etc.
  • Planetary boundaries and science of sustainability
  • Water resource management towards Sustainable Development Goals (SDGs)

Find out more at: https://worldwatercongress.org/


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