Thames Water Draft Plan (dWRMP19) still fails to justify a reservoir! - GARD is calling for a second consultation on a revised plan

Consultation on dWRMP19 closes – GARD's response
The consultation on Thames Water's draft Water Resources Management Plan (dWRMP19) closed at midnight on Sunday 29th April.

GARD submitted a robust rebuttal to TW's plan, in a response running to nearly 200 pages. You can read and download our response by clicking this link.

Many local residents and local organisations wrote opposing TW's plan. These include (to our knowledge) CPRE(Oxfordshire), Oxfordshire County Council (OCC), Wantage and Grove Campaign Group (WaGCG), Steventon and East Hendred Parish Councils. The Vale of the White Horse DC also wrote opposing and have called for a Public Inquiry on the plans.

GARD's view of the plan

TW have delayed the proposed start of the reservoir project to 'sometime in the early 2030s', but critically, there is still no objective justification for the mega-reservoir in the plan.

TW's cost estimates for the competing projects they have assessed were not made transparent in any way that could be assessed by stakeholders. Hiding behind 'commercial confidentiality', TW refused to release even the level of cost information that was available in the previous draft plan 5 years ago. There were very large unexplained shifts in cost estimates between the earlier and later versions of their plan – shifts which always made the reservoir appear cheaper and the competing schemes appear more costly.

The reservoir is in the 150 Million cubic metres size in all plans. This is 50% larger than the plan thrown out at the 2010 PI. Although Water Re-use schemes figure in the Preferred Plan, there is no place for Desalination or Water Transfers from the River Severn.

The main element delaying the construction of the reservoir is Thames' adoption of the 'Teddington Direct Abstraction (DRA) scheme' to be implemented 2027-2032. This is essentially the scheme put forward by GARD in 2008, and GARD welcomes the inclusion of this scheme.

TW's own population forecasts, on which their demand for water is based, have been heavily criticised, and they have been forced to abandon them post-2045 and re-estimate them based on official data.

The back-track was announced to Stakeholders on 21st March – hence the news items and OCC statements that they do not believe Thames' figures. The new figures lead to a drop of about 1.4 million people in 2100 – this is about 20% of the forecast water deficit.

GARD still believes that Thames' figures over-estimate the 2100 population by about 1 million. The combined water-usage would drop by over 300 Million litres per day if this is correct (i.e. more than the water supplied by the Reservoir).

TW initially did not meet Ofwat's targets for water company leakage reduction by 2025. They have also been forced to back-track on this. Meeting the Ofwat target saves a further 60 Million litres per day.

The Environmental Assessments of Thames leave much to be desired. The assessement of the reservoir is particularly skewed, with dis-benefits which will happen, being 'offset' by benefits which might happen. Some of these benefits refer to facilities/opportunities which already exist on site (such as equestrian centres, footpaths or bird-watching!).

The water available from all competing sources to the reservoir (Water transfers, Desalination, Direct River Abstraction, Re-use schemes) are all under-estimated, whilst every attempt is taken to maximise the figure for the reservoir (up to and including a dangerously low proposed level of Emergency Storage).

Thames claim to have performed a study of resilience to Drought, showing that the Reservoir will withstand future, more severe droughts. GARD's analysis shows that it will not, in particular it will be very susceptible to droughts including more than one dry winter.

A key feature is that Thames now intend to sell water to other SE companies outside their area. Figures show that 40% of reservoir water is for sale after 2065.

GARD will be calling for

Leakage target for TW to reduce leakage by half by 2050 (the same target as in the recent National Infrastructure Commission's report) Improvements in water-use efficiency which would match the norms of the other water companies (Thames are way behind in water efficiency).

A proper analysis of water available from the Teddington DRA (we reckon about 60% more could be available) and the Severn-Thames Raw Water transfer (about 60% more) and Water Re-use schemes (in TW's plan but under-estimated).

The three measures above will, in GARD's view, solve the water shortage and provide 1 in 200 year severity Drought Resilience.

The need for a Second Consultation

This consultation has been a shambles:

  • Thames abandoned their population projections half-way through;
  • Thames being forced to concede to Ofwat’s minimum Leakage target half-way through.
  • There has been complete lack of transparency on costings.
  • Errors on Deployable Outputs from non-reservoir sources.
  • Incomplete simulation of more extreme droughts.
  • Environmental Assessments are subjective and biased in favour of the reservoir.

From the draft proposals it appears that Thames have not actually performed a more sophisticated optimisation of options (as they advertise) but have biased heavily towards ‘Least Cost’ programmes (and then refused to release the cost figures)

GARD will be calling upon DEFRA (and the SoS) to order a second consultation when the revised dWRMP is produced. Our MP, Ed Vaizey, has promised his support. Please write to him if you support our stance.

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