Draft Drought Plan 2016 Statement of response

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2 Draft Drought Plan 2016 Statement of response On 21 September 2016, the Secretary of State for Environment, Food and Rural Affairs confirmed that our Draft Drought Plan 2016 could be published and publicly consulted on. The public consultation period ran for 6 weeks from 3 October to 14 November 2016 inclusive. The Draft Drought Plan 2016, and its associated documents, were published on our website and we directly notified 785 stakeholders. A hard copy document was made available for public inspection at our head office (Haweswater House, Lingley Mere). We also issued a press release and a Youtube video promoted on social media, as well as ing a display poster to public libraries. As part of the public consultation we held four stakeholder events throughout the northwest region in Ellesmere Port (19 October 2016), Workington (20 October 2016), Chorley (27 October 2016) and Kendal (3 November 2016) which were attended by 25 stakeholders. The stakeholder events covered consultation on our Draft Drought Plan 2016 as well as pre-consultation on our next Water Resources Management Plan. This statement of response documents the responses that were submitted to the Secretary of State during the public consultation period on our Draft Drought Plan 2016 and how we have taken account of the comments in the drought plan document. We received 14 responses from a range of stakeholders: Friends of the Lake District Individual respondent West Cumbria Rivers Trust Consumer Council for Water Windermere Lake Cruises Holker Group Windermere Lake User Forum Natural Resources Wales Environment Agency South Lakeland District Council Natural England Welsh Government Lake District National Park Authority River Eden and District Fisheries Association 90 issues were raised in the consultation responses and these have been grouped into the following key themes: Operational activities Drought actions (generic) Drought permits/orders Windermere Demand management during drought Drought triggers Environmental issues Communications Water Resource Management Plan Document content Responsibility of other organisations Other The pie chart below shows the proportion of issues within each theme. The key issues raised were: Copyright United Utilities Water Limited

3 Operational activities (particularly pumping from Ullswater and Windermere and the desire to review the Manchester (Ullswater and Windermere) Water Order 1966); Windermere specific issues; particularly relating to the second drought permit scenario which involves a lake drawdown and the impacts this has on the local economy and the potential for dredging as mitigation; s relating to the Water Resources Management Plan process; and s that are the responsibility of other organisations. It is noticeable that none of the respondents raised any issues relating to the material change that triggered this update to our Final Drought Plan 2014; the reduced volume of water available for abstraction at Crummock Water. We have carefully considered all the representations and, where appropriate, have amended the plan as explained in the table below. Alongside the issue of this Statement of Response, we have submitted a Revised Draft Drought Plan 2017 to the Secretary of State for Defra. The Secretary of State may direct us to modify the plan and/or hold a local public inquiry prior to publication of the Final Drought Plan. We will continue to develop our Final Drought Plan in consultation with the Environment Agency and other regulatory bodies and stakeholders. The Final Drought Plan will also be published on our website. We wish to thank all the stakeholders and other interested parties that have helped us develop this plan. UNITED UTILITIES WATER LTD 12 January 2017 Copyright United Utilities Water Limited

4 1 Friends of the Lake District There are no actions in the plan to deal with reservoirs that are no longer operational and we would welcome a copy of reports on Dubbs, Borrans, Meadley and Hayeswater Drought actions (generic) These reservoirs are all mentioned in Section 3.9 of the Draft Drought Plan We no longer hold abstraction licences for any of them and in a drought, it would be the Environment Agency's responsibility to apply for a drought order to the Secretary of State if the storage got low such that the normal compensation flow release could not be sustained if the dry weather continued. We have no plans to recommence abstraction from any of these sources. Meadley has recently undergone work to reduce the volume of water it holds and is no longer considered a reservoir under the Reservoirs Act 1976, although we do have a control structure at the outlet to manage a compensation flow release. At Hayeswater we have removed the dam in its entirety, resulting in a lowering of the water level and the lake has reverted to its natural form. We have no plans for future works at Dubbs and Borrans. We intend to continue to manage Dubbs, Borrans and Meadley to ensure they provide the required downstream compensation flow. We have removed the reference to Hayeswater from Section 3.9 as there is no longer a compensation flow requirement as it is now a natural water body with no control over the outlet flow to the downstream watercourse. 2 Friends of the Lake District 3 Friends of the Lake District Temporary use bans should be brought in at Trigger 3 to send messages to consumers that there is a potential issue, although we accept they save relatively little water Concerned that 1.7m below weir crest is now an acceptable baseline for drawdown at Ennerdale and that impacts will be more extreme as what was previously considered Water Resource Management Plan Environmental issues Plans for the long term use of non-operational reservoirs is not within the remit of the drought plan, unless recommencement of abstraction is a drought option, which is not the case for these water sources. Changes to increase the frequency of implementing temporary use bans are considered in the Water Resources Management Plan (WRMP). We considered increasing the frequency when we developed our current Water Resources Management Plan and will address the question again in the next Water Resources Management Plan. At Trigger 3 we already plan to send messages to customers about the potential issue by starting the process of introducing temporary use bans and promoting voluntary water use restraint. Following the Environment Agency's review of our abstraction licence under the Habitats Directive we are able to abstract from Ennerdale down to a lake level of 1.7m below weir crest without a drought order in place (as was the case pre-2000) in order to No changes to the drought plan made, however, we have taken this comment as WRMP preconsultation feedback and will consider it through that plan. None required Copyright United Utilities Water Limited

5 4 Friends of the Lake District 5 Individual respondent to be an unlikely lake level, is now potentially more common in the short-term and is being treated as the norm. There is still considerable uncertainty and as more information becomes available, Friends of the Lake District would like to be kept informed and involved in discussions The plan underplays the significance of the impact of drought on the Cumbrian landscape and the Lake District's temporary World Heritage Site status. The level of landscape disamenity potentially caused from drought permits/orders cannot be dismissed lightly given the areas status as a National Park, the number of visits and the economic benefits they bring. Negative impacts on landscape and visual amenity can adversely affect the local tourist economy, especially if it coincides with peak visitor numbers The plan does not mention the sale of water to fracking companies, resulting in the rapid depletion of stocks and impacts on domestic customers when restrictions occur. This is in spite of the "rip off" prices that are charged by United Utilities and Environmental issues Other sustain higher flow releases to the downstream River Ehen, required to protect the mussel population. From 2022 we plan to cease abstraction from Ennerdale, however the lake would still draw down in drought due to the need to maintain the compensation flow to the River Ehen. Over recent years we have worked closely with the Environment Agency and Natural England to increase the body of knowledge relating to Ennerdale and the River Ehen including lake macrophyte surveys and river algae and mussel monitoring. In recent years we have implemented schemes to enable us to reduce our abstraction from Ennerdale, for example the new South Egremont boreholes, which actually will result in a reduced frequency and duration of lake drawdown events. We are currently working with the Environment Agency and Natural England to develop plans for removing the infrastructure we have at Ennerdale and we will ensure that you are fully involved. We are part of the Wild Ennerdale partnership which share a common vision to renaturalise the Ennerdale valley - you could approach Rachel Oakley, the Wild Ennerdale Project Officer, to see if Friends of the Lake District can become involved. We acknowledge and appreciate the sensitive and important landscapes that are a feature of the areas in which we operate, and which are of great importance to the local economy. Landscape and visual amenity are a key component of the SEA that has been undertaken in support of the draft drought plan. In addition, each of the Environmental Assessment Reports for drought permit/orders include consideration of impacts of implementing the permit/order on landscape and visual amenity, and recreation. We have worked with shale gas operators to understand their potential water usage. Even under the most optimistic assumptions for shale gas production in the North West the water required for hydraulic fracturing would amount to less than 1% of our current water production. We are confident we can supply Table 2.10 in the SEA Environmental Report has been updated to include "The need to consider the effects of abstraction and low lake and river flows on the landscape" and Lake District World Heritage Site candidate status. None required Copyright United Utilities Water Limited

6 water should be opened up to "the market". Stop looking to domestic customers for voluntary restrictions but look to stop selling billions of gallons of water to wasteful fracking companies. That way, setting drought triggers could be a thing of the past these volumes without compromising our ability to supply water to our existing customers. 6 Individual respondent 7 West Cumbria Rivers Trust 8 West Cumbria Rivers Trust 9 West Cumbria Rivers Trust United Utilities are hiding the true facts behind the cryptosporidium bacteria outbreak. What have United Utilities got to hide? United Utilities should increase its groundwater contribution, particularly in the Integrated Resource Zone where there is capacity and "old" or need for new boreholes - there are cost implications but it would increase resource reserves which could be brought online at early drought triggers United Utilities should reduce pressure in the water network at an early drought trigger, understanding this depends on the status of the local supply network and the threat of water ingress United Utilities should undertake earlier pumping from Windermere and Ullswater Other Water Resource Management Plan Demand management during drought Operational activities The Drinking Water Inspectorate are carrying out an investigation into the cryptosporidium incident. We are cooperating fully with this investigation. Release of information into the public domain prior to the conclusion of the investigation could impact the Drinking Water Inspectorate s ability to conduct an investigation. The Drinking Water Inspectorate will publish its findings in due course. This suggestion relates to our next Water Resources Management Plan, which is where we will consider the adequacy of supplies to meet demand for the next 25 years and beyond. This is due for publication in December 2017, and we will take this feedback on board as part of developing that plan. As part of this assessment, we will consider groundwater alongside all other options to determine the most effective way of improving the supplydemand position, should this be required. In Water Resources Management Plan 2019 we will be assessing the resilience of our system to drought through a new process which assesses the benefit of measures that have in the past been covered by the drought plan. Pressure management is linked to leakage levels and discussed in Section 5.4 of the Draft Drought Plan On reaching Trigger 2 we would enhance our leak detection and repair activities beyond our normal level of activity. We have achieved our leakage targets, set by Ofwat, for each of the past 10 years which has included developing pressure management in the water distribution system. We will make it clearer in the drought plan that pressure management will form part of our efforts to manage leakage in a drought. Please refer to responses to issues 19 and 41. None required We have clarified in Section 2 the planning horizon of the drought plan, and cross referenced development of WRMP with regards future investment needs. We have added pressure management to the "Enhanced leakage detection and repair" drought option form in Appendix 9.1 See response to issues 19 and 41. Copyright United Utilities Water Limited

7 10 West Cumbria Rivers Trust 11 West Cumbria Rivers Trust 12 West Cumbria Rivers Trust when the resource is available, understanding the cost implications, resource availability and timing of such operations Ofwat should more actively support lower leakage targets and encourage asset replacement United Utilities should provide increased advice and financial support to industry e.g. promotion of best practices, grants etc. United Utilities should consider artificial aquifer recharge and tie to flood reduction schemes, habitat improvement, landowner partnerships etc. Responsibility of other organisations Water Resource Management Plan Water Resource Management Plan As noted in the response, this is an issue for Ofwat. We already undertake a wide range of activities to promote water saving. These are detailed in our Water Resources Management Plan and our annual water resources review. Options to further increase advice and financial support are considered in the Water Resources Management Plan. This issue is relevant to the development of our next Water Resources Management Plan, which is due to be published in draft form in December As part of this planning process we will consider all possible options at the outset, prior to selecting a feasible options list for appraisal. Managed aquifer recharge and aquifer storage/recovery will feature in the initial 'unconstrained list' for further consideration. Through the options and plan development process we consider whether there can be wider environmental or other benefits that could be exploited. None required No changes to the drought plan made, however, we have taken this comment as WRMP preconsultation feedback and will consider it through that plan. None 13 West Cumbria Rivers Trust United Utilities should consider providing more active support (grants/advice) and improved land management practices (infiltration) within abstracted catchments (e.g. tree planting, hedges across slopes, sub-soiling, stock reductions, land preparation for crops etc. Increased filtration has benefits to low flow, flooding, the environment and positive publicity in the farming community. Many of these also support the waste water side of the business as it reduces pollutants in the receiving waters Other Our integrated approach to catchment planning is bringing together our expertise from 10+ years of our Sustainable Catchment Management Programme (SCaMP) and looking to deliver whole catchment solutions that will address diffuse pollution and run-off. Through our Catchmentwise fund we have supported the CaBA groups, including the West Cumbria Rivers Trust, through a competitive interventions fund aimed at improving water quality by tackling diffuse pollution. An example of this is the Ellenwise project which is now in its second phase where we hope to build our understanding of the benefit of various interventions. Prior to Catchmentwise, SCaMP invested over 20 million in improving land management and land condition within the catchments that we own. This approach has None required Copyright United Utilities Water Limited

8 14 Consumer Council for Water 15 Consumer Council for Water 16 Consumer Council for Water 17 Consumer Council for Water It would be useful to indicate plans to engage with smaller businesses on the issue of drought and to help advise them of any resilience measures they might take ahead of drought circumstances It would be useful to detail how any messaging will be passed through Peel Water to its customers It would be useful to detail how communication with retailers will work in the event of a drought We wish to ensure that the company has reviewed its emergency plan to confirm that it addresses a widespread, prolonged drought where a managed reduction or withdrawal of supply becomes necessary Communications Responsibility of other organisations Communications Other continued through drinking water safeguard zones, where we are working in partnership with other land owners and managers to encourage practices that will improve the quality of water abstracted for public supply. Section of the Draft Drought Plan 2016 discusses liaison with non-households during drought however the comment relates to what we can do to help small businesses be prepared, in advance, for a drought. Advice and guidance in relation to water use and water efficiency is a service that the retailers will offer to their customers. We will respond to any requests for support from retailers in carrying out this activity. This is an issue for Peel Water to address in their own drought plan. We were consulted as they prepared their document. Section of the Draft Drought Plan 2016 discusses liaison with retailers during drought. In a drought our communications will retailers will follow Process E6, droughts or dry weather conditions, in the Operational Terms of the Wholesale-Retail Code ( appendix2-wrc-part3-operationalterms.pdf). Our drought plan does not include rota cuts or standpipes (implemented through emergency drought orders), even during extreme drought conditions such actions would have serious public health implications and result in severe social and economic disruption. In extreme drought conditions, where actual water supply loss at customer taps was likely, we would engage with Local Resilience Forums under alternative supply plans agreed with them for emergency water distribution and sanitation arrangements under the Civil Contingencies Act (2004) and the Security and Emergency Measures Direction (1998). We have added further information to Section of the drought plan regarding the support we will give to retailers to help them provide advice and guidance to businesses. None required In Section of the drought plan we have added a reference to Process E6, droughts or dry weather conditions, of the Operational Terms of the Wholesale-Retail Code. The Introduction section of the drought plan has been updated to state that our generic company incident management plan was completely revised in Copyright United Utilities Water Limited

9 18 Consumer Council for Water 19 Windermere Lake Cruises We agree that it is reasonable to ask customers to voluntarily stop using hosepipes after crossing Trigger 3 (Trigger 2 at Ennerdale) providing it is made clear that this is a request and in no way a mandatory requirement. Important to recognise in any communications that customers' circumstances vary and some will find it harder than others to meet the request Response to consultation Question 1: when the River Leven flow is above its hands-offflow we would like to see pumping from Windermere to avoid the need to abstract from Haweswater and Thirlmere. We feel that United Utilities defer taking this action and prefers to abstract from gravity sources, at lower cost, in the hope that they will be replenished by rainfall. In some years this judgement is correct but in others, when rainfall does not appear as anticipated, the levels and outflow from Windermere have already fallen before abstraction from Windermere starts. In essence Windermere is used as a "resource of last resort" and United Utilities only look Demand management during drought Operational activities Our generic company incident management plan provides the structure for managing any incident at the appropriate level within the organisation. In 2016 it was completely revised to take account of incidents where comprehensive engagement with other agencies, under Local Resilience Forum arrangements, is needed. This would be especially relevant in an extreme drought situation. In the North West there are also multiagency plans for dealing with loss of water supplies which would apply in this type of scenario. We understand your concerns and have made it clear throughout the plan that any calls for restraint on water use, ahead of a formal Temporary Use Ban, are voluntary. We appreciate that, dependent on individual circumstances, some customers may find it more difficult to meet this request. The Environment Agency raised a concern (see issue 40) that the term "voluntary water use restrictions" is not appropriate. We have considered and discussed alternatives with the Environment Agency and have concluded that the term "campaign for voluntary water use restraint" is suitable as it conveys the action we will undertake, i.e. a campaign, but that it is a call for restraint (not a restriction) which is voluntary. We fully understand and respect the concerns that underpin this response. We recognise the importance of clarity and assurance around the use of strategic pumped sources. To this end we have refined and improved our operational decision making approach to increase clarity and assurance to stakeholders on their use, and to ensure that our decision making aligns to the expected frequency of crossing triggers in the drought plan. The operation and balancing of our Integrated Resource Zone is complex and we need to maintain the flexibility to operate individual sources to meet the needs of different situations, balancing a wide range of considerations including impacts on customer bills, carbon, wider environmental impacts, society and the economy. Recognising your concerns, and those of others, we have added a new Appendix 8 specifically explaining the normal operation of We have made it clearer in the plan (for example the box in Section 5.3.2) that an individual's ability to respond to a voluntary request for water use restraint will depend on their circumstances. Added a new Appendix 8 to provide greater transparency on our operating principles, to complement the content in Section 3. Copyright United Utilities Water Limited

10 to abstract from Windermere when lake levels and flows are already falling, increasing the likelihood of a drought permit application to disregard the handsoff-flow. We feel that United Utilities should not gamble on rainfall and should be required to take water from Windermere when the River Leven flow is above its hands-off-flow and the level of Haweswater Reservoir is below the Resource State Curve our strategic pumped sources in greater detail. We are working to enhance our internal decision making process regarding strategic pumping and will embed this fully by 1 April Whilst detailed in the new Appendix 8, we have some specific comments relating to this response below. The requirement to use Windermere is not solely a function of Haweswater storage, but also of wider supply system considerations such as the level of demand and the potential for us to implement other actions to achieve the desired outcome. We feel this outcome concept is important, centred around the sustainable use of Haweswater (as well as other sources) to ensure we undertake the appropriate actions as are reasonably practical to avoid recourse to drought permits/orders at a later date, whilst taking into account our stated levels of service to customers. We recognise the expectations on us to use strategic pumped sources appropriately, alongside other interventions, to avoid recourse to drought permits/orders as far as is reasonably practical. However, it is appropriate, including in the interests of customers (and considering factors such as carbon) to meet these outcomes in the most efficient manner. What is appropriate and efficient will differ depending on the individual circumstances at the time, and it may be possible in some cases to reduce demand on Haweswater sufficiently by means other than Windermere, e.g. increasing the use of other sources such as Ullswater, from the Pennines, or from further south in our system. When considering action, our processes fully consider the decision of whether to pump in the context of future dry year conditions. We have added further clarity on this process into the drought plan, including the use of weather forecasting (the use of these to defer pumping is based on only a very short-range weather forecasts), and sought to tighten the operational principles/target outcomes to assure stakeholders. We trust that this improved clarity in the plan demonstrates that our operating practices work to fully protect customer supplies and appropriately mitigate for drought conditions. Copyright United Utilities Water Limited

11 20 Windermere Lake Cruises 21 Windermere Lake Cruises Response to consultation Question 2: we feel there is an imbalance between demand and supply side actions. Windermere Lake Cruises are directly affected by Windermere supply side actions (i.e. drought permits to reduce the hands-off-flow in the River Leven or allow draw down of the lake level in Windermere) and in the worst case, these could have a severe adverse impact on the ability to operate. Would like to see demand actions take place earlier in the hope that this avoids the need for supply actions such as drought permit/order applications that are potentially damaging to business Response to consultation Question 2: we do not feel that sufficient financial resource is allocated to leakage reduction. Current leakage levels are circa 450 Ml/d compared to the maximum abstraction possible from Windermere of 205 Ml/d. We do not feel that United Utilities' annual leakage budget of circa 25m is adequate given the volume of water lost through leakage. We understand that leak repairs cause Demand management during drought Water Resource Management Plan We would also like to note that Windermere is a frequently and routinely used source that is operated as required, not as a last resort. On average, during we pumped from Windermere at all times of the year and particularly during the early part of the drawdown period in March-April. There was a notable exception in 2014 when the Windermere pumping station was out of service for maintenance works. Based on the data for , April had the highest average pumping of all months at 64 Ml/d and March the third highest at 48 Ml/d. We have considered this representation carefully. We think that it is important to progressively increase the level of drought-specific demand actions as the dry weather situation develops. This phased approach is consistent with the Code of Practice and Guidance for Water Companies on Water Use Restrictions (UKWIR, 2014) which all water companies have adopted. We will start enhancing our water efficiency promotion upon reaching our first drought trigger. This will occur more than 10 times more often than implementation of the Windermere Scenario 1 drought permit option. We are concerned that implementing drought or dry weather related demand actions more frequently than in the draft plan could cause unnecessary public concern about the resilience of their water supply. However there is merit in considering whether an ongoing increased level of demand management could contribute to a reduction in the frequency of needing to implement drought permits/orders. The question of whether to improve our level of service for drought permits/order will be considered in the next Water Resources Management Plan. This response is of relevance to the development of our next Water Resources Management Plan, which is due to be published in draft form in December The current target levels of leakage were defined within our last Water Resources Management Plan and Business Plan, within which further leakage reduction was constrained by customer affordability, levels being above the currently economic level to reduce further. We note comments from a number of stakeholders, and the aspirations of regulators, to reduce leakage further in future, and we will fully consider this in developing the next Water Resources No changes to the drought plan made, however, we have taken this comment as WRMP preconsultation feedback and will consider it through that plan. No changes to the drought plan have been made, however, we have taken this comment as WRMP pre-consultation feedback and will consider it through that plan. Copyright United Utilities Water Limited

12 22 Windermere Lake Cruises disruption but draw down of Windermere below its weir crest jeopardises our business and the visitor economy of the central Lake District, which would be catastrophic for this part of the country Response to consultation Question 3: we welcome voluntary demand restrictions after crossing Trigger 3 but question their effectiveness. While such a proposal can only be beneficial, we wonder what research has been undertaken to ascertain whether there are more effective ways of managing demand, such as metering Demand management during drought Management Plan. As part of the next Water Resources Management Plan we will also complete an assessment of the resilience of our system to extreme droughts beyond those experienced in the historic record (i.e. those events that drought permits/orders would be needed to protect supplies) and consider the relative benefits and risks associated with the Scenario 2 drought permit at Windermere as an option in that context. New, sophisticated hydrological methods in that plan will also put greater confidence on the likelihood of the use of such drought powers in future. While we have no legal power to impose meters on all our customers, we do, however, offer a free meter option service where our customers can apply to have a meter installed free of charge. We promote this service on our website ( water bills and also during water efficiency campaigns. We are continually researching more effective ways to reach our customers, make them think about the volume of water they are using and change their behaviour towards water consumption. In 2015 we completed behavioural research and we are now trialling a new, community based, water efficiency campaign. If this approach proves successful, we will consider implementing it across the region. We will consider this comment in the development of our next Water Resources Management Plan. We are investing in new equipment that will enable us to better manage pressure on our network and as a result, reduce leak breakouts. We are also trialling new devices that should enable us to better target customer side leakage. 23 Windermere Lake Cruises Response to consultation Question 4: our comments relate to the Windermere Scenario 2 drought permit which has a Windermere We will continue our extensive efforts to keep demand as low as possible, not only in times of drought. We will consider enhanced promotion of free meters as one of demand management options in our next Water Resources Management Plan, due to be published in draft form in December We acknowledge and appreciate concerns from lake users and businesses relating to the mitigation measures required for implementing a Scenario 2 drought permit at Windermere. In A commitment to undertake a mitigation study has Copyright United Utilities Water Limited

13 0.5m draw down of the lake to allow abstraction to continue. As the plan recognises, this drought permit has major adverse impacts on tourism, socioeconomics and communities associated with Windermere and moderate adverse impacts on aesthetics and landscape of Windermere. The 2016 environmental study of the Windermere drought permit options, by United Utilities, details the importance of tourism to the Lake District National Park, worth in excess of 1.1 billion annually. The 2016 environmental study identified a need for a further study in to the feasibility of dredging to mitigate the potential adverse impacts on lake users on Windermere - the plan states this study is ongoing and its outcomes will be used to inform any future drought permit applications at Windermere that involve a lake draw down - we have not yet been involved in this study and can only conclude that the work is yet to commence - this should be undertaken as a matter of urgency and a clear timetable established for its completion. A drought permit that allows draw down of Windermere should not be granted until it is established that adequate mitigation measures can be taken to offset the major adverse impact on tourism, recreation, socio-economics and communities associated with Windermere. We are concerned at the time required to implement mitigation measures such as dredging and a Scenario 2 drought permit at Windermere should not be implemented until the necessary mitigation measures 2017, we will commence a feasibility study into mitigation options, particularly dredging, that was specified by the Environmental Assessment Report which we published in We will be consulting lake users, businesses and other interested parties as we undertake the study. We plan to complete the study within 12 months, noting this is dependent on the scale of the study and engagement with others. been included in the Windermere Scenario 2 drought option form in Appendix 9.2. Copyright United Utilities Water Limited

14 24 Windermere Lake Cruises identified in the study have actually been implemented Response to consultation Question 7: the Manchester (Ullswater and Windermere) Water Order 1966 (SI 283) has not been reviewed for 50 years and should be undertaken as a matter of urgency. Possible changes may include higher hands-off-flows in the River Leven, an increase to the rolling 12 month abstraction limit for Windermere and a requirement on United Utilities to pump from Windermere at the full capacity of 205 Ml/d whenever flows in the River Leven are above the hands-off-flow and the level of Haweswater Reservoir is below the Resource State Curve Responsibility of other organisations In May 2007, APEM (on our behalf) produced an environmental assessment of the current abstraction regime on Lake Windermere and the downstream River Leven which included recreational and commercial impacts. The outcome of this assessment was that the current abstraction licence, which enshrines the Manchester (Ullswater and Windermere) Water Order 1966 (SI 283), did not need altering to ensure environmental protection as the abstraction has negligible impacts. A review of the Manchester (Ullswater and Windermere) Water Order 1966 (SI 283) in effect means a review of the abstraction licence as this enshrines the requirements. It is the Environment Agency's responsibility to undertake any such review if they deem it necessary. As the licence holder we can also undertake a review however we did this in None required 25 Holker Group The Scenario 1 drought permit at Windermere (no lake drawdown) would cause minimal and acceptable damage. The Scenario 2 drought permit at Windermere (lake draw down of up to 0.5m) would cause great problems for the whole economy associated with the lake and the drought plan acknowledges this. Mitigation measures, such as dredging, would never get approval in time and dredging might be blocked on environmental grounds - this scenario must be avoided if at all possible 26 Holker Group The data and calculations, supporting the conclusions and proposals, are based upon We are committed to working positively with partners in the Windermere and River Leven catchments, for example the recent review of the Windermere water bank and the reviews of the Environment Agency's operation of their Windermere fish sluice and Windermere flood sluice. Windermere See response to issue 23. See response to issue 23. Water Resource Management Plan This response eludes to the uncertainty surrounding future hydrological events and the need for our plans to be resilient to New detail within Appendix 6 showing Copyright United Utilities Water Limited

15 historic weather patterns. The frequency of serious flood events in recent years must raise questions over the validity of that data. We therefore urge a more cautious approach regarding the management of water resources going forwards even if additional storage of water results in additional costs 27 Holker Group Haweswater Reservoir rather than Windermere must become the water source of last resort. There is plenty of water available from Windermere if only it was taken when it is available. The proposed new West Cumbria connection from Thirlmere also places additional pressure upon Windermere 28 Holker Group The Water Order 1966 has been in place for 50 years and needs to be reviewed to recognise changes in the local economy which is so heavily reliant upon Lake Windermere. We propose a higher year round hands-off-flow to the River Leven of 500 Ml/d and that United Utilities should be required to pump from Windermere at full capacity whenever Haweswater Reservoir is below the Resource State Curve. In these circumstances, the 12 month abstraction Operational activities Operational activities them. Whilst in Section 3.8 of the drought plan, and in the preconsultation events, we have focussed presentation on historic events, as part of the drought plan development we undertook modelling appraisals of more severe droughts than on record. While the nature of these tests were described in Appendix 1, we now recognise that there is an appetite for more visibility of this within the plan and have therefore included more detail of our severe drought testing in a new Appendix 6. For the next Water Resources Management Plan, we are developing cutting-edge 'stochastic' hydrological records to test our plans, which will create an even greater wealth of hydrological events for making risk-based decisions as part of building our plans. We are pleased to see stakeholder interest in these types of approaches. See response to issues 19 and 41. With regards the new West Cumbria connection from Thirlmere, any increase in abstraction from Windermere and Ullswater is likely to be small and within existing licence limits. This was previously assessed as part of developing our last Water Resources Management Plan and explained as part of our Statement of Response at that time. Depending on the specific situation at any time, the West Cumbria demand placed on Thirlmere will be met from a range of sources across the Integrated Resource Zone. It is also worth noting that demand in the Integrated Resource Zone is forecast to fall by roughly the same amount as the 'additional' demand resulting from the connection into West Cumbria. See response to issue 24 with regards to the Water Order review. In May 2007, APEM (on our behalf) produced an environmental assessment of the current abstraction regime on Lake Windermere and the downstream River Leven which showed that the current prescribed flows protected the downstream river; and overall the review showed our abstraction to have negligible impacts. See response to issue 19 and issue 41 regarding the issue of pumping. testing under events worse than on historic record. Please refer to responses 19 and 41. We have added a new Appendix 8 to provide greater transparency on our operating principles, to complement the content in Section 3. See responses to issues 19, 24 and 41. Copyright United Utilities Water Limited

16 29 Windermere Lake User Forum 30 Windermere Lake User Forum 31 Windermere Lake User Forum total from Windermere could be increased to 40,000 Ml or greater. While the annual cost of pumping may be in the order of 2m this is likely to be small when set against the environmental damage and the mitigation measures/compensation that United Utilities would have to pay if a Scenario 2 Windermere drought permit were implemented with a lake draw down Recommendation 1: we suggest that it would not be safe, or within the spirit of the drought plan, to consider draw down from Windermere below the existing Water Bank Agreement before the full outcome of the dredging study has demonstrated its ability to successfully mitigate against the identified and agreed major adverse impacts on the local economy and lake users. Once a dredging protocol is agreed it will need to be implemented on a regular basis in advance of any drought. Dredging takes time and is an ongoing activity and its impact measured. At the time of drought it is too late to implement to any useful effect, even if the equipment and personnel were available to undertake such a task at short notice Recommendation 2: the Manchester (Ullswater and Windermere) Water Order 1966 (SI 283) is now 50 years old and a review is essential Recommendation 3: United Utilities should be required to demonstrate that they are taking water from Windermere whenever it is possible to do so to ensure that Haweswater can be effectively used as the water source of last resort in the Cumbria area to supply the rest of the Integrated Windermere See response to issue 23. See response to issue 23. Responsibility of other organisations Operational activities See response to issue 24. Please refer to response 19 and 41 regarding operation of Windermere and response 24 regarding the water order. See response to issue 24. Please refer to responses 19 and 41. We have added a new Appendix 8 to the drought plan to provide greater transparency on our Copyright United Utilities Water Limited

17 32 Windermere Lake User Forum Resource Zone at times of drought. If the Water Order was to be reviewed, possible changes may include a higher year round hands-off-flow in the River Leven, an increase in the 12 month abstraction limit and a requirement on United Utilities to pump from Windermere when the River Leven is above its hands-off-flow and the level in Haweswater Reservoir is below an agreed level, such as the Resource State Curve Recommendation 4: we are concerned that customers in the Integrated Resource Zone are not fully informed or aware of the implications of drawing water from Windermere at times of drought. We believe that the research questions used to establish what water users are willing to pay for their water are insufficient to fully inform those who are taking part. We are concerned that the implications on quality, availability, environment and the economy within the whole Integrated Resource Zone are not made clear to the people being consulted within the urban areas such as Manchester and Merseyside. Is the true cost of supply and risk being explained and fully taken into account in this process? We have not seen any evidence of this. We recommend that research into pricing of water and charges to customers should ensure that consultees are fully informed and can demonstrate that they are aware of the social, economic and environmental impact of any proposed water resource management schemes before questions of charges are included into the consultation mechanism. Customers should understand Water Resource Management Plan This response is of relevance to the development of our next Water Resources Management Plan. Our approach to customer research is as rigorous as possible and completed in conjunction with third-party experts in completing this type of research. It is also comparable to the types of techniques used elsewhere in the industry. We always try to ensure that there is appropriate context and background for questions posed to customers, such as impacts on the environment. In our last Water Resources Management Plan, there was some willingness to pay indicated for reducing the frequency of drought permits, demonstrating that through such research, customers are aware of environmental or social considerations. However, we recognise the sentiment of the response raised, and the challenge in any customer research between providing sufficient background information to result in a valid result, whilst balancing this with 'information overload' and survey length. For this reason, in our next Water Resources Management Plan we intend to explore innovative choice-experiments to allow the customer to trade-off between different aspects of service in a way that makes the impacts of those choices as transparent as possible. We are also exploring the potential to use customer panels, whereby a discrete number of customers become more informed through the research process. In any case, we note the concern raised and will consider this as part of developing our next Water Resources Management Plan and Business Plan. operating principles, to complement the content in Section 3. Please note our response 24 regarding the water order. We will consider this comment in the context of our next Water Resources Management Plan. Copyright United Utilities Water Limited

18 33 Windermere Lake User Forum 34 Natural Resources Wales both cost, impact and the wider value of what is being proposed across the network of catchment, collection, processing and delivery, otherwise it is like the phrase "asking Turkeys to vote for Christmas" which has no value in terms of data on which to base serious decisions Recommendation 5: the investment on leakage control appears to be directly linked to the cost of this action and the impact on water charges, not the reduction of the loss of this valuable resource. The maximum that United Utilities is allowed to abstract from Windermere is 205 Ml/d, but they lose more than twice this amount every day through leakage. We understand that a criteria for issuing drought permits/orders is that the applicant must demonstrate that they have done all within their power to use existing resources to the best of their ability - this does not seem to be the case in the Integrated Resource Zone and Windermere under the current situation. We suggest that more work is done on detecting and reducing leakage from the system. Incentives to report leaks and speedy action to response should be considered along with increased investment to reduce leakage to say 15% We recommend that the environmental assessment for the Lake Vyrnwy drought permit is updated to take account of more recent environmental monitoring data, in particular in relation to fish. We have concerns that the conclusions of the most recent drought permit environmental assessment report (completed in 2010) are based on assumptions made on the basis of Water Resource Management Plan Environmental issues Please note response 21. Our leakage targets are defined as part of the Water Resources Management Plan and Business Plan processes, and take into account the costs and benefits of further leakage reduction, taking account of environmental and social costs, and also customer affordability, balanced against other water and wastewater service investment needs. The drought plan outlines enhanced leakage activity from Trigger 2 beyond our baseline or routine levels, when supplies and the environment are most in need. For the current drought plan we believe this is appropriate to demonstrate that we have done what is "reasonably possible" should a drought permit be required. However, we have noted your comments with regards development of our next Water Resources Management Plan, which will reappraise and define future leakage management activity. We have also noted the useful suggestion of incentives for customers to report leaks and the level of leakage you believe we should aspire to. The Lake Vyrnwy Environmental Assessment Report was last updated in 2010 and the findings reported in our 2014 Drought Plan. A review of this assessment would be due in 2020, but in light of your comments we will commence the study in We anticipate the study will take a minimum of 12 months to complete, and therefore, it will not be possible to reflect the findings in the current drought plan update, but we will incorporate the findings of the updated assessment in the future. We will consider this comment in the context of our next Water Resources Management Plan. We have committed in the drought plan (see Figure 31 and Appendix A1.2) to commence work on updating the Vyrnwy drought permit environmental assessment in Copyright United Utilities Water Limited

19 historic data, much from the 1990s, from a small number of locations that may/may not be representative of the habitat and fish populations of the River Vyrnwy in The impacts of the Lake Vyrnwy drought permit on the WFD objectives, geomorphology, invasive non-native species and other water users (especially the hydropower scheme at Mathrafal, near Pontrobert) should be assessed. The environmental assessment should explain what triggers will be used to indicate that mitigation measures should be implemented. As a moderate adverse impact is likely on juvenile salmon, it is unlikely that walkover surveys during the implementation of a drought permit will identify fish in distress. The drought plan HRA and SEA may need to be amended to take account of the findings of an updated environmental assessment report 35 Natural Resources Wales 36 Natural Resources Wales Natural Resources Wales should be involved in decisions on standing down of drought status in the Integrated Resource Zone and update the plan to reflect this We have no issues in relation to drought actions on the River Dee but have identified some errors regarding the River Dee in the drought plan document: - the reference to the Dee General Directions (EA, 2013) should be Dee General Directions (Natural Resources Communications Our apologies, this was omitted in error. The need to consult with Natural Resources Wales when deciding on standing down of drought status has been included in Section 3.10 of the plan. Document content Our apologies, these errors have been corrected. The reference to the Dee General Directions has been corrected in Section 3.3 and also in the references (Section 8). The title for the Dee Copyright United Utilities Water Limited