Blueprint for the 2019 Price Review in Wales. Delivering for Future Generations through the Price Review

Transcription

1 Blueprint for the 2019 Price Review in Wales Delivering for Future Generations through the Price Review

2 Llais y Goedwig The voice of community woodlands in Wales We believe that we can work together to manage our water more sensitively to ensure we achieve wellbeing for future generations. Wales Environment Link (WEL) is a network of environmental, countryside and heritage Non- Governmental Organisations in Wales, most of whom have an all-wales remit. WEL is officially designated the intermediary body between the government and the environmental NGO sector in Wales. Our vision is a healthy, sustainably managed environment and countryside with safeguarded heritage in which the people of Wales and future generations can prosper. This document represents the consensus view of a group of WEL members working in this specialist area. Members may also produce information individually in order to raise more detailed issues that are important to their particular organisation.

3 Developing the Blueprint for PR19 3 Water challenges and opportunities 4 High level outcomes 6 Protect and restore catchments from source to sea 8 Stop pollution of our waters 10 A step change for biodiversity 12 Keep our rivers flowing and wetlands wet 14 Use water wisely and price it fairly 16 Blueprint for the 2019 Price Review in Wales 1

4 Wales Environment Link cares about the 2019 price review (PR19) because its outcomes will have a significant impact on nature.

5 Developing the Blueprint for PR19 Wales Environment Link cares about the 2019 price review (PR19) because its outcomes will have a significant impact on nature. We want to see healthy rivers, thriving wildlife, safe drinking water, reduced flooding, clean beaches and coastal waters. That means stopping pollution, improving how we manage our catchments from source to sea, addressing issues which threaten our rivers and wetlands such as over abstraction and adverse land use practices, whilst pricing it fairly. Water companies in Wales are investing over 3 billion on water and environmental and water management between We want to ensure that investment delivers for nature and people. A healthy natural environment is at the heart of a resilient and successful water industry. We believe that Dŵr Cymru Welsh Water, Severn Trent Water and Dee Valley Water can meet the needs of their current and future customers and help Wales make progress towards the seven Wellbeing Goals for the Wales we want. Blueprint has been engaging with the Welsh Government, regulators and water companies, along with our members and supporters to develop our thinking on environmental priorities for PR19. We are extremely grateful to all the organisations and individuals who took time to engage with us. We will play our part by continuing to work with the water industry in the development of their PR19 plans and in their successful implementation. We also want to celebrate the contribution the sector has already made to improve the environment and ensure that best practice is shared. Finally, we want to explore areas where together in partnership we can achieve more for customers and the environment; through joint working in the policy arena, in conversation with our members and supporters, and through delivery on the ground. We urge Dŵr Cymru Welsh Water, Severn Trent Water and Dee Valley Water to adopt our Blueprint for PR19. This document sets out our Blueprint for PR19 in Wales. It highlights the challenges and opportunities we see ahead, the five headline outcomes we want to see delivered and the commitments we believe the companies need to make in their long term visions, water resource management plans and business plans. Blueprint for the 2019 Price Review in Wales 3

6 Water challenges and opportunities Water challenges: Despite some progress over the last few decades there is a long way to go in addressing the health of Welsh rivers and water bodies. Wales faces a number of challenges in improving the health of our freshwater ecosystems. Pollution poses one of the greatest challenges. Land use in Wales is dominated by agriculture and forestry; these industries are contributing to the failure of water bodies across Wales through a lack of nutrient and soil management as well as contributing to acidification and the loss of wetlands. Water Framework Directive assessments indicate that 171 water bodies in Wales are failing due to agricultural pollution, 61 water bodies are failing due to acidification 1. We urge water companies to find new ways of working with these sectors to find solutions whilst maintaining the polluter pays principle. Dealing with emerging pollutants from pharmaceuticals, plastics and endocrine disrupting substances is considered to be an increasingly pressing challenge that requires innovation in sewage outflow and treatment today. These pollutants pose risks to ecosystems and the deterioration of bathing and shellfish waters. These new challenges are set against a legacy of past environmental damage. This includes dealing with localised over-abstraction, combined sewer overflows, peat land drainage, coniferous afforestation and outputs from mines. Looking ahead there will be increasing pressure from climate change and population growth. We believe that all water companies have to play their part in demand management before they look to take more water from the environment. With increasing threat of drought and water shortages across the UK it is essential that we commit to the transfer of water only when it leads to no deterioration of water body status at home, and will not detract from achieving good WFD status. Water opportunities: We are at a crossroads politically, economically and environmentally. The decisions we make and the direction we take in the next two to three years will be absolutely critical if we truly want to meet the seven Well-being Goals for the kind of Wales we all want to see. Following EU transition we cannot afford to backslide on the achievements we have made over recent decades in river and bathing water quality. We support the Welsh Government s commitment to maintaining current standards in respect of water quality and environmental protection as a minimum 2. This presents an opportunity for the sector to work with environmental NGOs to secure the best environmental policies for Wales following EU transition. The reform of the agricultural support system presents an opportunity for collaboration. We believe payments from the public purse should achieve best value for money and contribute towards sustainable land management. A new approach would enable our farmers, growers and other land managers to manage our environment in ways that provide essential public goods and services such as improved water quality, reduced flooding and enhanced biodiversity whilst producing sustainable amounts of high quality food, timber and other commodities. Effective reform of existing public policy offers an opportunity to finally make real progress in addressing the agricultural pollution issues that are currently blocking the achievement of good status of our water bodies. 4 Water challenges and opportunities

7 Water Framework Directive assessments indicate that 171 Water bodies in Wales are failing due to agricultural pollution. We have an opportunity to refresh our approach to natural resource management and do things differently to secure a sustainably managed environment. The Environment Act (Wales) has put in place a framework for achieving ecosystem resilience through maintaining and enhancing biodiversity. This legislation provides for a more collaborative approach to enhancing the quality of the natural environment through techniques such as river restoration and improved catchment management. We passionately believe that a healthy natural environment is important not just for nature but for our society, our economy and our individual wellbeing. As the major private investor in water and environmental management in Wales the water industry have a pivotal role to play in the stewardship of the environment we all cherish and that the sector relies on to operate. We also look forward to a new Water Bill to deliver reform of our archaic abstraction regime and to ensure that companies develop strategic long terms plans for our wastewater systems as they do for water resources. Customer needs and the Environment We recognise the need to ensure that customer bills are affordable. However this is not a reason for inaction when it comes to the environment. It is essential that companies recognise the risk of environmental deterioration and the unequal impact unsustainable practice will have on customers. Investment in ecosystem resilience could provide the opportunity to lower operation costs in the long term and could prevent costly interventions. Companies should recognise the benefits to the customer and view the environment as a customer they rely on. The following pages set out our Blueprint for PR19 in Wales, including five high level outcomes and the commitments we want to see companies include in their plans. Blueprint for the 2019 Price Review in Wales 5

8 High level outcomes and the commitments we want to see companies include in their plans Protect and restore catchments from source to sea 1. Companies commit to addressing their pressures on the environment, including contributing towards ensuring 97% of water bodies achieve good status by 2027, as required by the Water Framework Directive. 2. Companies significantly extend investment in catchment management supporting delivery of water resources and wastewater outcomes. 3. Companies show leadership, commit to working with partners, sharing best practice and to valuing the benefits of this approach to water quality, water resources, flood risk, carbon and recreation. 4. Companies advocate the use of regulatory measures when voluntary measures are insufficient to protect water sources and customer interests (e.g. controls on agricultural pollution). How could we measure success? Catchment Management Hectares of land in better stewardship due to water company catchment management interventions. % number of drinking water safeguard zones where improvements in water quality are being seen. WFD Improvements KM of river length with improved status as a result of water company actions. Stop pollution of our waters 1. Companies underpin investments by long term strategic wastewater plans, to ensure sewerage and treatment systems are sufficient into the future to prevent pollution incidents, CSO spills and flooding, despite population growth and climate change. 2. Companies extend investment in green infrastructure and SUDs (new and retrofit) to reduce flooding and provide biodiversity, recreation and water quality benefits. 3. Companies aim for zero pollution incidents (categories 1, 2 and 3), 100% monitoring of CSOs and 100% self-reporting of incidents. 4. Companies include ongoing monitoring of the presence and treatability of emerging pollutants (pesticides, pharmaceuticals, micro plastics), using results to inform appropriate management (product and usage controls, upgraded treatment, including natural solutions). How could we measure success? Long-term Strategic Wastewater Planning % of catchments with a long term strategic wastewater plan. Pollution Incidents Total number of pollution incidents in each category each year, and a trend to zero pollution incidents. % pollution incidents, where the company has a role, that are self-reported. Flooding and SuDS % sewerage capacity dealt with through SuDS. 6 High level outcomes and the commitments we want to see companies include in their plans

9 A step change for biodiversity 1. In collaboration with stakeholders, produce an ambitious biodiversity plan that contains measures to help achieve the objectives in the Nature Recovery Plan for Wales. Including but not limited to establishing a biodiversity baseline through regular species monitoring across the full range of operations. 2. Take all possible steps to ensure that protected sites within company landownership are in favourable condition/ favourable conservation status, and contribute to improvement of condition of protected sites within the wider operating area. 3. Commit to assessing the company s natural capital with the intent to grow it and to integrate it into decision making. How could we measure success? Biodiversity strategy Ambitious biodiversity strategy produced and reported on in line with the requirements of the Environment (Wales) Act Protected sites % of protected sites within land ownership and operating area at favourable status. % of actions within NRW actions database completed. Natural Capital Natural Capital Account created and target set to grow it (stocks & services). Keep our rivers flowing and wetlands wet 1. Companies commit to addressing abstraction where it is preventing achievement of good status or poses a risk of deterioration. 2. Companies reflect the value of natural capital and benefits of water left in the environment within water resource options appraisals. 3. Companies ensure that, where new water supply options are considered (e.g. bulk transfers, reuse), they are transparent about environmental risk and include mitigation measures to support good status. How could we measure success? Abstraction from Sensitive Sources % of total abstraction that is from groundwater sources that are in poor quantitative status. % of total abstraction that is from surface water sources in water bodies where recent actual flows are below the EFI at Q95. Use water wisely and price water fairly 1. Companies fully consider reducing demand (such as promoting water efficiency, increasing metering of households and reducing leakage) and promote demand management a key mechanism to increase resilience. 2. Companies ensure no overall increase in the amount of water abstracted from rivers and groundwater despite increases in population and climate change. 3. Companies extend the availability and promotion of social tariffs and efficiency retrofit to protect vulnerable customers. 4. Companies develop plans to incentivise customers and communities to reduce consumption during dry periods and in catchments most at risk from abstraction. How could we measure success? Demand Management Per capita consumption in litres/household/day dry year annual average/peak day multiple. Leakage per km of network (Ml/d/km). Proportion of metered/smart metered households (% of total households). Water Consumption Total water volume put into distribution (Ml/d). Affordability % of the households eligible for social tariff that actually receive one. Smart Tariffs % of households on a tariff or financial incentive scheme that rewards water saving. Blueprint for the 2019 Price Review in Wales 7

10 Case Study Weed Wiper Trial In 2015 Dŵr Cymru Welsh Water worked with Natural Resources Wales and the farming industry on an innovative campaign to tackle rising levels of grassland herbicide MCPA. The campaign provides land managers and farmers better advice on handling, applying and disposing of grassland sprays as well as guidance on mechanical control of rushes. STEPS to cleaner water The Severn Trent Water Environmental Protection Scheme (STEPS) is investing over 20 million up to 2020 in catchment initiatives to improve water quality and provide wider benefits. One innovative element of the programme is that landowners are paid based on improvements to water quality and not based on specific or prescriptive land management.

11 Protect and restore catchments from source to sea The Need for Healthy Catchments: Healthy functioning catchments can deliver multiple benefits for water companies and their customers through improved water quality, reduced flood risk, increased availability of water for abstraction and greater resilience to climate change. In addition, they can provide significant biodiversity, recreational and health benefits. By viewing catchment management strategies as the first line of defence, ecosystems can be restored and operating costs reduced. The State of National Natural Resources Report (SoNaRR) indicates that the benefits of ecosystem services are not being optimised, it is recognised that a more integrated catchment approach can improve water quality as well as regulate high and low flows resulting in more resilient ecosystems. The health of our water bodies provides an excellent indicator of the health of our catchments. We are calling for water companies to address their share by 2027 and where appropriate work more closely in partnership with environmental NGOs to address the barriers to achieving good status. Progress so far: It is heartening to see the catchment initiatives supported up to 2020; including Dŵr Cymru Welsh Water s launch of Watersource and Severn Trent Water s Environmental Protection Scheme (STEPS), we want to see them extended and enhanced in PR19. To help support this we want companies to get better at capturing and sharing the multiple benefits delivered as well as lessons learnt. Where voluntary catchment work is insufficient to protect customers interests then we want to see the use of regulatory option, such as Water Protection Zones (WPZs) being pursued by companies. WPZs can provide a legal mechanism to ensure that appropriate action is taken where voluntary action is failing to deliver for customers. We are strong advocates for water companies playing a greater stewardship role in the catchments they and their customers depend on, working in partnership with others to address problems at their source rather than end of pipe. We believe South West Water s (SWW) Upstream Thinking project is an example of catchment management that could be adopted in Wales. SWW turned their thinking up stream to tackle unsustainable farming practices that were the sources of pollution within the catchments. Using Rivers and Wildlife Trusts as intermediaries, they offered capital investments to improve farm infrastructure, and provided long-term contracts to farmers to manage land to minimise water pollution. Comprehensive water quality monitoring stations at SWW s downstream abstraction sites made the effects of the scheme clearly quantifiable, and pollution incidents could be picked up rapidly and addressed. We would also urge water companies in Wales to consider the highly effective approach taken by United Utilities to addressing water issues via catchment management through their SCaMP programme. Blueprint for the 2019 Price Review in Wales 9

12 Stop pollution of our waters Tackling pollution Water quality in rivers in Wales has generally improved over the last 25 years. Much of this progress can be attributed to water companies improving sewage discharges. Nevertheless, pollution continues to be the biggest problem facing the freshwater environment. Currently only one in six freshwater habitat types in Wales are in favourable conservation status 4. We recognise the need to share responsibility for this across sectors, including the agricultural and forestry sector and would welcome joint policy working to encourage Welsh Government to address this. However there is still work for the water sector to do. Many sewage treatment facilities and sewerage pipes are under-sized to deal with peak flows in wet weather periods, and raw sewage can spill straight into rivers and streams. There is more to be done on identifying and remedying combined sewer overflows. Pollution from septic tanks has been largely ignored. Climate change and population growth will increase this risk and unregulated but can also be significant in some catchments. Progress has been made by the water sector in reducing the number of serious (category 1 and 2) pollution incidents. However the picture is not so good once category 3 incidents are included. We want all companies to target zero pollution incidents and 100% self reporting of incidents. We certainly don t believe companies should be rewarded through the Outcomes Framework for causing pollution incidents as they are at the moment. At the heart of the problem is a lack of strategic long term planning by the water sector to ensure that the sewerage system has the capacity to cope now and in the future. Companies already develop 25 year plans to support their investment decisions on water resources. We want to see to see strategic long term plans prepared for the sewerage system. Chemicals in the water system Monitoring by the water industry through the Chemicals Investigation Programme is finding a number of potentially harmful chemicals are present in the water system, including pesticides, pharmaceuticals and fire retardants. Removal of these chemicals at treatment works can be ineffective and very expensive. Rather than default to end of pipe solutions we want companies to join us in lobbying for better controls on usage and disposal, for less harmful alternatives to be promoted and for innovative natural solutions such as reed beds to be developed. There is still much to be learnt about the impacts of new and emerging chemical substances and we d like to see the water companies contributing to this research to consider the effects on water quality and ecology. Sustainable Drainage Solutions Sustainable drainage solutions (SuDS) are a critical part of the tool kit in dealing with flood risk. For water companies and their customers they can help reduce peak flows in the sewerage system and lower the risk of sewer flooding whilst avoiding the need to invest in larger underground pipes. They can also provide biodiversity and amenity benefits to local communities. We are calling on water companies to prioritise and promote drainage solutions that include sustainable drainage schemes in their own drainage schemes and those of third parties looking to connect to the sewerage network. We are heartened to see the steps already taken by Dŵr Cymru Welsh Water through the Rainscapes programme and call for wider roll out of these tried and tested solutions. 10 Stop pollution of our waters

13 Case Study RainScape (Dŵr Welsh Water) The Rainscape schemes aim to reduce the amount of surface water entering sewers and catch, redirect and slow the flow of surface water as it enters the sewerage network. The solutions, referred to as Rainscape solutions include, swales, basins, planters, porous paving, grass channels and geocellular storage. 21st Century Drainage Wet Wipes Campaign The water industry 21st Century Drainage initiative is shining a light on the challenges we face around drainage. Blueprint for Water were pleased to sign-up to the campaign to stop wet wipes getting into the sewerage system and the environment. Pollution continues to be the biggest problem facing the freshwater environment.

14 Case Study Nature After Minerals Nature After Minerals (NAM) is a partnership programme, led by the RSPB and supported by Natural England, the Mineral Products Association and the British Aggregates Association. NAM promotes strategic opportunities for delivering biodiversity through habitat creation on mineral sites. The programme works with mineral planners, industry, statutory bodies, conservation organisations and local communities.

15 A step change for biodiversity Wildlife in Wales Wales has a deserved reputation for its wildlife and is thought to be home to 50,000 species. However, despite this there have been considerable changes in Welsh wildlife in recent decades. Biodiversity has declined markedly with many culturally and ecologically important species disappearing. The 2016 State of Nature report identified 354 species known to occur in Wales that are at risk of extinction from Great Britain and 56% of UK species identified have declined in the long term 5. The Environment (Wales) Act 2016 The Environment (Wales) Act 2016 requires all water companies operating within Wales and Ofwat, to take steps to maintain and enhance biodiversity and achieve ecosystem resilience 6. Operators are required to set out a strategic plan showing how they will take action to reverse biodiversity declines within the functions of their operation. Further to this they must, report on the progress of their efforts and review the plan s contents based on this evidence. We urge water companies operating in Wales and Ofwat to engage with a range of stakeholders in particular Welsh Government and NRW, to ensure the strategic plans are meaningful and aligned with objectives and actions in Wales biodiversity strategy, the Nature Recovery Plan, our country s response to the International commitments and targets in the Convention on Biological Diversity. This level of joined up thinking is essential if Wales is to meet its international commitments to halt and reverse the decline of biodiversity, and to ensure maximum benefit for wildlife and people. Improving our evidence, understanding and monitoring of biodiversity, is a specific objective in the Nature Recovery Plan 7. Only systematic monitoring will enable the measurement of change in species populations and ranges an area where water companies have a key role to play by establishing biodiversity baselines across the full extent of their operations. Natural Capital We passionately believe that a resilient natural environment forms the basis of a sustainable and resilient water sector. The Wellbeing of Future Generations (Wales) Act 2015 recognises that healthy, diverse ecosystems are much better at coping with change. Therefore investing in healthy ecosystems will provide a first line of defense for water supplies and increase the resilience of water companies to challenges such as future growth. The Natural Capital Protocol (2016) offers a new approach to assessing and valuing the environmental assets an organisation is responsible for and the ecosystem services those assets provide. This information can then be incorporated into decision making. Water companies are currently investigating how they could use the Natural Capital approach to inform decision making. Welsh Government and NRW are investigating opportunities for natural resource accounting aligned to the development of future State of Natural Resources reports and area statement evidence bases. We are supportive of the concept and can see the potential for companies to have developed a Natural Capital Account by the start of the next investment period with a commitment to grow it through the 5 year investment window. Blueprint for the 2019 Price Review in Wales 13

16 Keep our rivers flowing and wetlands wet Unsustainable abstraction Although Wales is perceived to be water rich, we are facing challenges. Reduced flows caused by abstraction present risks to migratory fish and other wildlife. The 2016 State of Nature report linked hydrological change to biodiversity loss, identifying it as the 3rd most significant driver for negative change after agricultural practices and climate change. The State of Natural Resources Report (SoNaRR) 2016 identified changes to hydraulic conditions have an impact or are likely to have an impact on 45 of 112 (40%) of Natura 2000 protected sites 8. Whilst progress has been made addressing unsustainable abstractions through the Restoring Sustainable Abstraction programme (35 licences have been changed by NRW to date) there are still more licenses being investigated. In response to population growth and climate change, existing abstraction licenses could be used even more heavily which poses a further risk to the environment and to the Water Framework Directive s principle that there should be no deterioration in ecological status. By the 2030s, an additional supply of water equivalent to twice the current household consumption of Cardiff (50Ml/d) may be needed 9. Changing rainfall patterns SoNaRR indicates that climate change is predicted to affect the amount and distribution of rainfall which would impact on flows and water levels, drought and flood events and an increase in water temperatures. These changes may lead to a decline in water quality, impact some species negatively, increase the risk from invasive species and lead to changes in the way ecosystems function. Environmental analysis of the impacts of changing rainfall patterns should be considered within water resource management plans. We welcomed the 2016 Water UK Resources Long Term Planning project but were disappointed at the absence of environmental analysis at a comparable scale. This is critical where strategic supply solutions include inter-basin water transfers which pose risks to both donor and receiving catchments, such as the transfer of invasive non-native species. We believe that any water transfer schemes put forward need to be able to demonstrate that they will not result in a deterioration of Water Framework Directive status and will contribute to achieving good status. Looking forward we need reform of our archaic abstraction licensing system to ensure that it is fit for the future and capable of meeting the needs of abstractors whilst protecting the environment in the face of climate change and population growth. 14 Keep our rivers flowing and wetlands wet

17 Case study The Usk Wye Abstraction Group (UWAG) Faced with extreme difficulties in meeting the demands of the Habitats Directive, public water supply and keeping the Monmouthshire and Brecon canal filled, the group devised novel ways of modelling the needs of migratory fish and abstractors, ultimately producing a dynamic scheme that enabled these requirements to met, within budget.

18 Case Study A new Water Efficiency Strategy Water Wise has worked with the water sector to develop a Water Efficiency Strategy for the UK. It brings together current thinking on the next steps and actions required to achieve a water efficient UK. Metering success Between 2010 and 2015 Southern Water nearly doubled its household meter penetration to 83%. Over the same period the company achieved a 12% reduction in per capita water consumption and a reduction in leakage of 15%.

19 Use water wisely and price it fairly Reducing water demand Using water wisely is a win win for customers and the environment. If we waste less water then we need to abstract less water from the environment, making our supply system more resilient to drought and helping lower costs as companies have to treat and pump less water. To realise these benefits we need companies to go much further and faster on metering and leakage reduction as well as working with customers to help them reduce consumption. We think there should be a customer commitment to meet the target of 120 litres per person per day. Water poverty The impact of water bills falls disproportionately on the poor. For those experiencing water poverty their water bills represent over 5% of income. We welcome the development of social tariffs to help customers who struggle to pay, although acknowledge that levels of awareness and sign up have been disappointing. The Welsh Government encourages the inclusion of social tariffs in future charging schemes. We are calling on Ofwat to set % take up of social tariffs by those who are eligible as a common outcome and performance commitment across the sector. 11 We want to see smart meters allied to incentive schemes that encourage the behavioural changes needed to ensure we are using water wisely. We should develop and trial community rewards linked to reduced water use during drought periods. Consumer Council for Water research 10 has found that 66% of respondents questioned have made a conscious decision to use less water in the last three years. This shows the level of customer will to reduce consumption. By rewarding customers for their efforts the company would benefit from protecting supplies and not having to progress expensive alternative drought measures; the environment would be better off and the community would be rewarded for taking positive action. We believe it is necessary to build better water efficiency into homes. Ideally this should be a requirement in Building Regulations but if that is not happening then we should give companies the freedom to work directly with developers to ensure the right water efficiency measures are built in to new developments in our most vulnerable areas. Public sector buildings should demonstrate the most water efficient products, and rain/grey water re-use. Blueprint for the 2019 Price Review in Wales 17

20 We would like to thank all of the organisations, partners and supporters who provided comment and advice during the development of our Blueprint for PR Diffuse Pollution in Wales; Issues, Solutions and Engagement. Natural Resources Wales. 2. Welsh Government. (2017) Securing Wales Future. Transition from the European Union to a new relationship with Europe. 3. The Environment (Wales) Act Available at: biodiversitywales.org.uk/environment-wales-bill 4. Natural Resources Wales. (2016) State of Natural Resources Report (SoNaRR): Assessment of the Sustainable Management of Natural Resources. Part 3. Technical Report. Natural Resources Wales. 5. Hayhow DB, et al. (2016) State of Nature The State of Nature partnership. 6. See Section Six The Environment (Wales) Act Available at: biodiversitywales.org.uk/environment- Wales-Bill 7. Welsh Government. (2015) Nature Recovery Plan for Wales: Setting the Course for 2020 and Beyond. Cardiff. 8. Natural Resources Wales. (2016) State of Natural Resources Report (SoNaRR): Assessment of the Sustainable Management of Natural Resources. Part 3. Technical Report. Natural Resources Wales. 9. Wales Environment Link. (2013) Valuing our Freshwaters: The Importance of our Rivers, Lakes and Wetlands. Cardiff Bay. 10. Consumer Council for Water. (2016) Consumer Attitudes to Tap Water and Using Water Wisely. Birmingham. 11. Welsh Government. (2015) Water Strategy for Wales.