Our response to Thames Water ‘Draft Water Resources Management Plan’

1. Introduction

West London Friends of the Earth is a network of borough-based Friends of the Earth groups in West London.

There may be responses from individual groups such as Richmond & Twickenham Friends of the Earth. Those responses will tend to address issues of particular local concern. They will also address broader issues, including water quality/pollution, and may cover some aspects in more detail than here. The comments here should therefore be regarded as additional to (or supporting) those from local groups and not as replacements.

We have chosen not to answer the questions posed because they do not properly encapsulate the points we wish to cover. There is a severe danger in answering a set of questions that respondents are led down a path, due to selectivity, especially omission of relevant issues and options from the set of questions. This may suit the body carrying out the consultation, but it most certainly is not in the spirit of public engagement and democracy.

Where pages numbers are given, these refer to the non-technical summary.

2. Presentation of information

Although large amounts of documentation are provided, it does not greatly help consultees make informed responses. The non-technical summary document should be sufficient reading for consultees to make reasonably detailed and insightful comments without an excessive workload. We are not aware of any west London voluntary and social/charity group that has been able to fully comprehend the plethora of documents or detail within.

As an example, there is reference to leaks on pages 6, 14 and 20 but the statistics are not brought together in a coherent way. Page 20 says “reduce the amount of water lost through leaks in our network and customer pipes by 16% by 2030” but does not say the date from when the 16% reduction applies or what the volume of leakage was at the start date.

As a further example, the diagram on page 13 shows “water shortfall” but does not show alongside the numbers, presumably demand and supply under certain scenarios, which have been used to define shortfall.

3. Sustainability

TW’s policy is clearly ‘predict and provide’ though this is not admitted in the consultation documentation. Unfortunately, this approach seems to lead to a ‘need’ for ever-increasing water supply and therefore ever-increasing extraction from the environment. (We say “seems” because we are unable to quote numbers; this because, as noted in 1, the relevant numbers are not presented satisfactorily in the non-technical summary.)

To be sustainable, the amount of water extracted and supplied needs to be, as a minimum, stabilised. Not increased. This will require drastic action, as described below, on leaks and per capita demand.

With changing climate and the associated drought and unpredictability of rainfall, simply sustaining levels of supply is unlikely to be sustainable. Extraction and supply need to be reduced.

To respond to these challenges, TW needs to engage properly with the public and policy makers on big issues such as ‘predict and provide’, equity and population growth. Although it is a private company, TW has a duty to act as a social enterprise because it has monopoly control over an essential resource, namely water (also sewerage) in the TW area.

4. Leakage

A staggering 24% of water is lost to leakage (page 6). It alone explains to a large extent why TW believes it need to find new sources and undertake mega engineering projects, at massive cost and with major environmental impacts (especially climate-changing emissions and biodiversity). Given this context, TW’s proposal to reduce leaks by 16% by 2030 (page 20) is totally inadequate. (16 % reduction in leaks only saves about 16% of 24% = approx. 4% of water extracted.)

5. Per capita demand

Perhaps the biggest reason for potential shortages and for TW’s quest for new sources and mega engineering projects is reluctance to drive substantial reductions in per-capita water consumption. Huge amounts of water are used unnecessarily; for example by car washing, watering gardens and long showers. TW (and others) should do whatever it takes to drastically reduce present consumption of 141 litres per person per day (page 20). Reducing only to 125 litres by 2050 – about 0.7% pa – is pathetically inadequate. Even the government, not known for its environmental credentials or enthusiasm for managing demand, has set a national target of 110 litres.

6. Population

TW passively accepts forecasts of population growth by ONS or LAs. But these forecasts are no based on specific assumptions about availability of housing units or infrastructure such as transport, hospitals or water supply. The forecasts will only come about if it is decided to support population growth in an area such as TW’s with water and other essentials. There are choices available, especially by means of the planning system.

Population growth will mean higher costs for current consumers and greater environmental impacts. TW therefore has a responsibility to its existing customers to warn government and others of the (water) costs of unbridled population growth.

7. Charges to consumers

The estimated charges on page 28 look designed to scare respondents and, as a result, encourage them to support low standards of resilience and environmental protection. They will support the commonly heard and usually disingenuous narrative that action that is in the public good will hit poor people and should therefore not be undertaken.

In fact, the increases are quite modest in percentage terms but not shown. More importantly, they fail to reflect the fact that not everyone has to be hit by increases. Water charges could be levied differentially such that wasteful households which are affluent and easily able to afford increased charges pay more than proportionally to consumption, while poor and thrifty households pay less. This would be consistent with the ‘Polluter Pays Principle’ because, under the current system, environmental and social costs of excessive water supply are not reflected in either flat rate or water meter charging.

8. Environmental standards including biodiversity

There are many references to environmental improvement or high environmental standards in the non-technical summary. However, there is very little about what these improvements or standards actually are. There is no discussion of wildlife, habitats or biodiversity. Only one component of environment – abstraction from chalk streams – seems to be mentioned.

In the case of chalk rivers, “improvement” could mislead insofar as it implies that this is an add-on or a luxury. It needs to be made clear that it is in fact no more than restoring some of the damage already caused by abstraction.

Since wildlife, habitats and biodiversity are likely to be significantly affected by water schemes and ongoing operations, we would have expected some information on expected impacts. Instead, Environmental Forecast (Chapter 5) and Environmental Assessment (Chapter 9) of the Technical Report are just detailed and tedious text about process. Indeed, Chapter 5 barely mentions biodiversity. There is nothing about the actual impact on wildlife, habitats or biodiversity – these being what actually what matter and what most respondents would wish to know about and comment on.

9. Climate change

Water supply is a major user of electricity and hence generates a great deal of greenhouse gases. Reduction in water use is therefore an important component in addressing climate change and getting to Net Zero quickly. (We cannot afford to wait until the entire grid and all local energy production is de-carbonised.)

West London Friends of the Earth, March 2023