Gap in consultation process

There are pressing housing problems in England. In some areas homes are unaffordable, in others they are being abandoned. The government is aiming to tackle these problems and develop sustainable communities so that everyone has decent homes and good quality local environments. This is a laudable aim and the Office of the Deputy Prime Minister (ODPM) has drawn up detailed plans to address the national housing crisis.

In particular the government’s sustainable communities agenda aims to deliver:

• economic prosperity,

• decent homes at a price people can afford,

• safeguarding of the countryside,

• well-designed housing, accessible and pleasant for living and working,

• effective and fair local governance with a strong sense of community. (

Specifically, the plan for the south-east of England outlines the construction of 200,000 extra new homes above those outlined in the regional planning guidance (RPG9). These houses will be built in the Thames Gateway, Milton Keynes, Ashford and the Stanstead corridor.

This development is welcome as affordable sustainable housing is critical to the social, economic and environmental wellbeing of the nation and its citizens.

Water UK welcomes the government’s initiative, in particular the way in which it addresses the issue holistically and looks at the challenges from a national perspective.

At the same time we are concerned the deputy prime minister’s statement, whilst it refers to greenbelt preservation and brownfield development, neglects the wider environmental implications of water resource availability and the ex-situ environmental impacts of new development. In particular, new housing development on the scale proposed will have major implications for water and wastewater infrastructure and water resources.

Planning in different areas is currently at different stages of development. Development in the Thames Gateway is the most advanced, with detailed proposals being drawn up for development beyond 2010. In other areas plans are being made for long-term growth. However all such plans still need to be incorporated into a new overall regional planning guidance note.

It is the uncertainty in the proposals that most concerns the water industry. However, recent discussions with ODPM have laid out a timetable for dialogue on the detail and created an understanding of the degree of uncertainty attached to each location, which should enable the industry to factor into PR04 plans.

The UK water industry supplies 60M people, has over 700,000km of water mains and sewers and has more than 2,500 WTWs and 9,000 WwTWs. The maintenance of this infrastructure and the provision of water and sewerage services requires long-term planning and investment. On average, each person in the south-east uses 150 l/d and generates around the same amount in sewage. Meeting the supply and sewerage needs of 200,000 new houses concentrated in one region of the UK will require planning. However, there has to date been no detailed consultation with the industry on this issue.

Companies will submit plans covering both resource and financial management. The developments will have a major impact on the implementation of these plans, so the lack of consultation is unfortunate.

Water resources

The UK has less available water per capita than any other major European country, and areas such as East Anglia are becoming semi-arid. Meanwhile the Environment Agency (EA) predicts that per capita water consumption over the next 25 years could grow by around 20%, unless there is a shift of public behaviour.

Water companies promote water efficiency, but in general public recognition of the need for water conservation is low, partly due to the success of water companies in maintaining a secure high quality supply. In order to maintain public supply companies have to manage a complex supply-demand balance. The EA recently published Water Resources for the Future, a 25-year strategy for water resources in England and Wales. This highlights the south and east of England as already overstreched in terms of water resources.

Unless the government develops a sustainable approach to planning and resources, we will be faced with water shortages or have to consider expensive options such as desalination to meet our water needs.

The additional housing in certain areas could be enough to trigger the need for new water resource developments. The implications of tens of thousands of new houses in a specific area could require the construction of a new reservoir or the extension of an existing one. Companies are concerned the lead time for developing new resources is such that plans need to be made now to meet resource needs even for 2031.

Sewerage services

The main area of concern is water supply, but the scale of the house building programme will also have an impact on the sewerage system which is already stressed because of the effects of climate change.

These additional stresses are due to both the increased volume of sewerage and the higher treatment requirements, the EA will require changes to WwTWs to accommodate the higher pollution loads from the new housing stock.

Catchment Effects

The building programme will also have an effect on catchment morphology. Put simply, if we tarmac and concrete over more land in river catchments rainfall will not infiltrate, thus reducing the replenishment of underground water supplies. But at the same time rainfall will also run-off more quickly, which means that peak river flows will be increased in times of storm and this will lead to increased flooding.

There are also concerns over the location of WwTWs and the effect of discharges on river flows. Firstly, from a flooding viewpoint, in areas like the Stanstead corridor, water from outside the catchment will be returned to the head of rivers thus artificially increasing

flow. The effects of these discharges on river hydrographs must be accounted for in terms of flood forecasting.

Secondly, there is a dilution issue. There are strict controls on discharges under the Urban Wastewater Treatment Directive, but in some parts of the south-east the discharge makes a significant contribution to river flow and an increase in level will reduce dilution and lead in some circumstances to a requirement for a ten-fold increase in quality of treatment to maintain compliance with the directive