WATER WORLD | SPECIAL REPORT
Who’s who in water regulation The UK’s Department for Environment, Food and Rural Affairs oversees water and environment policy and regulation, although some water policy is devolved to England, Scotland, Wales and Northern Ireland. Monopoly water and sewerage companies provide water for both business and domestic users. Ofwat is the economic regulator holding the water companies to account on the delivery of five-year plans produced by the privatised water companies. The water companies are also required to produce long-term water resource plans. Water is used by water companies and other users (such as agriculture and large industry) under abstraction licences granted by the Environment Agency (EA). The EA also leads on
the development of the Water Industry National Environment Programme and is responsible for assessing the water resource planning for each water company. Natural England is the government’s advisor on the natural
environment. It is tasked with protecting and improving England’s natural environment and advise on the impacts on water dependent habitat sites. Similar bodies also exist in the separate devolved administrations. Across the UK, water quality is currently maintained in
accordance with the environmental objectives set out under the European Union’s Water Framework Directive. However, post-Brexit and the UK’s objectives may diverge from those in the EU Directive. ■
NWL initially said it could supplement the supply, if
necessary, in four ways: new water main supply pipes to bring water from other areas; trading abstraction licences with other local licence holders; storing water on-site; and water efficiency measures to reduce demand from mains supply.
During the development consent process, interested
parties expressed ‘significant concerns’ about whether a sustainable supply for Sizewell C would adversely affect already stressed water resources. Natural England joined with other groups to ask for further information. NWL suggested that the plant would require a new water main pipeline from another catchment area and said the additional infrastructure required would take until September 2026 at the earliest. But in addition, extra water supply and water and
wastewater disposal would be required during the construction period of 10 years or more, both to meet the needs of thousands of temporary workers housed locally and for construction processes such as providing water cooling during tunnelling activities. NNB wanted to take over an existing water main to serve the accommodation campus and NWL was concerned it may be compelled to supply water, creating a critical risk to its existing customers in the absence of additional infrastructure. In response, NNB submitted a revised strategy, which included a temporary desalination plant to supply potable water during the early construction phase until such a time as the NWL supply transfer main could be operational. Until the desalination plant started up (up to a year), water would supplied by tankers. The desalination plant comes with its own environmental concerns, including power consumption, sustainability, cost and wastewater (brine) discharge. In its report to the Secretary of State, the ‘examining
officer’ from National Infrastructure Planning said that the plan “does not address the need to fully consider the cumulative assessment of the environmental effects of the proposed water supply solution that is fundamental to the operation of the Proposed Development”. The examining officer makes a recommendation to the Secretary of State on whether to grant development consent for a project but the Secretary of State’s decision can go against the recommendation. The Secretary of State sought further information from other sources including the nuclear regulator, the Office
for Nuclear Regulation (ONR). The ONR said there is no specific Licence Condition covering the requirement for a reliable water supply but that it “would expect the licensee to put in place a reliable source of water before nuclear safety-related activities take place on the site that are dependent on such a supply. This may be during the later stages of commissioning, but such a supply will certainly be needed before the station begins to raise power from nuclear reactions in the core”. The examining officer noted that there was a possibility that a sustainable water supply would not be identified and therefore a possibility that the plant may not be able to operate. NNB argued that the reason a long-term water supply is not known at this stage is that the long-term planning of water supply is subject to separate statutory provisions and processes that will result in Water Resource Management Plans (WRMP) for the region. This WRMP24 process is now under way and plans were published in draft for consultation in October 2022. It said that, with regards to the Development Consent, the Secretary of State was required not to duplicate other licensing processes and to assume that they would be properly carried out and “because on the evidence the source of the supply is unlikely to be a constraint to the construction and operation of the new power station, the source does not need to be known for the purposes of the Application”
In his decision the Secretary of State noted that the
Sizewell C development consent and the WRMP24 process for the sourcing of water are separate projects, and said, “This is evident from their separate ownership and because they are subject to distinct and asynchronous determination processes”. As a result the lack of a water strategy at this stage was not a bar to granting consent. The decision means NNB can continue to work with NWL on its plans to source water while it progresses the project towards final investment decision. It may mean that the desalination plant first proposed to cover the construction phase will become permanent. Other options for securing long-term water supplies include import from neighbouring catchment areas; effluent reuse and desalination; and longer-term (post-2035) winter storage reservoirs. Whatever the final proposals, they must also be proof against climate change for a plant that could be in operation for up to a century. ■
www.neimagazine.com | May 2023 | 19
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49
