The preparation of strategic water resource plans requires several supporting environmental assessments to be undertaken alongside plan development. A water company must determine if its plan falls within the scope of the Strategic Environmental Assessment (SEA) Directive and whether any elements require a Habitats Regulations Assessment (HRA). The plan must also be able to demonstrate that implementation of it would not cause a deterioration in waterbody classification and/or demonstrate that it would not preclude the delivery of measures to facilitate the improvements needed to attain good status, as required under the Water Framework Directive (WFD). Drought plans also require consideration under the SEA Directive and Habitats Regulations, although WFD assessments are usually undertaken as part of the ‘shelf-copy’ drought permit/order environmental assessments prepared in support of the drought plan in line with regulatory guidance.
Relevant UKWIR guidance relating to SEA and HRA of WRMPs and drought plans was last updated in 2012. Since then, there have been several developments in regulator guidance and current best practice (including a 2019 revision to Environment Agency drought plan guidance), and several important Habitats Directive rulings with implications for strategic water resource plans in particular, including the 2018 ‘People over Wind’ judgment. The requirement to prepare a stand-alone WFD assessment is an additional requirement since the 2012 UKWIR guidance was published.
With an increased focus on development of water trading and regional transfer schemes, it is crucial that environmental assessments of strategic water resource plans for both regional and company level plans adopt the same methodology including the approach to environmental valuation to allow direct comparison of intra- or inter- company or region water resource options. This applies to all aspects of assessment including SEA, HRA, WFD and Ecosystems Services (ESS)/Natural Capital Accounting (NCA).
Therefore, an update to the current UKWIR SEA and HRA guidance, and development of standard methodology for WFD and NCA/ESS assessments for strategic water resource plans is now required. It is essential that Regulators are fully involved in the project steering group to ensure they are signed up to the approaches and guidance developed at a National level.
Drought plans are different to strategic water resource plans in that they do not comprise a preferred plan or programme of water resource options, but rather a basket of measures that will be considered for implementation during a future drought event. The measures selected and the programme of use will depend on other factors including the timing, duration and spatial extent of the dry weather event experienced. The drought plan SEA Environmental Report is therefore a comparative assessment of the environmental effects of implementing each drought option, which should be used to review the potential environmental impacts of implementing supply side or drought permit/order options should they be progressed in the future. However, although a fundamental requirement of the Directive (and demonstrated by the SEA post-adoption statement) there is a need for better integration of SEA into the decision-making process for both drought plan implementation and strategic water resource plan preferred programme selection.
The environmental assessments required to be undertaken in support of strategic water resource plans and drought plans add a significant cost to plan development and have implications for programme. During this project there may be the potential to agree some stream-lining of the assessment process, potentially reducing assessment burden and therefore, costs of strategic water resource plan and drought plan production.
Development of a standard methodology for environmental assessments of strategic water resource plans and drought plans which has been agreed with Regulators will reduce the potential for future challenge by Regulators and third parties. This will be increasingly important in view of likely increased costs due to the requirement to plan to a regional scale.