Water UK

Water Framework Directive river basin assessments consultation

23/12/04

Summary and key points

Water UK submitted the water industry’s initial comments on the River Basin Characterisation and Pressure and Impacts Assessment in September 2004. In our response we identified, as requested, “significant errors” in the draft assessment, sought clarification on a number of issues, and made suggestions for bridging some of the gaps.

This response provides additional information focusing on future refinement of the initial assessment. Three topics have been reviewed for the November deadline – metals, diffuse nutrients and the impact on waters for drinking water abstraction. All have great relevance to the water industry and its role in the Water Framework Directive. By concentrating on three topics rather than reviewing all the maps and methods, we have been able to provide more detail within the timescale.

For completeness and to ensure that key issues are not lost we have appended our initial response to this report.

We recognise that the Environment Agency acknowledges the “broad brush” nature of its first iteration of risk maps. More detail needs to be provided for a number of the method statements to allow detailed comments on the approaches to be made. However, we have assessed the scope for further improvement in several of the methodologies in future iterations. A summary of overall key points from our reviews is provided below.

Key points

 •  We recognise the effort the EA has put into the risk assessment, which is a significant step forward.
 •  It is, however, fundamentally flawed. The absence of a consistent approach means that it fails to identify the risks and impacts required for effective implementation of the WFD.
 •  In their current form the maps do not help water companies identify the impacts of their operations or the risks to their assets.
 •  We do not understand why the EA did not properly engage stakeholders in this assessment: the method and timing of its consultation were inadequate to enable detailed or substantive input.

Recommendations

To facilitate the next iterations of the impact assessments we make the following recommendations:

 •  Validation against river water quality data
 •  Consideration of naturally derived inputs
 •  Quantification of diffuse inputs of substances and the development of catchment based “budgets” for substances such as nutrients
 •  Use of monitoring data rather than consent conditions to estimate load from Authorised Point Source Discharges
 •  Quantification of intermittent discharges
 •  Consideration of the fate and behaviour of substances
 •  Integration of Priority Substance EQS
 •  Development of comparable maps

Ends

For more information please contact:

Steve Ntifo, Environment and Science Adviser
020 7344 1822 or
Barrie Clarke, Director of Communication
020 7344 1804

Full Response