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AMP7 Statutory ObligationsSummary Chapter 7: Supplementary document

Document Reference: S6005

This document sets out the evidence that demonstrates that United Utilities business plan 2020-2025 will enable the company to meet its statutory and licence obligations and will deliver the Environmental Requirements, as set out in the Water Industry Strategic Environmental Requirements, the Blueprint for PR19 and the Drinking Water Inspectorate Guidance to water companies: Long term planning for the quality of drinking water supplies.

United Utilities Water Limited

Chapter 7: Supplementary Document – S6005 unitedutilities.com

Contents 1 Executive summary ................................................................................................................................. 2

1.1 Purpose of this document ............................................................................................................... 2

1.2 Background and introduction .......................................................................................................... 2

2 Meeting our fixed obligations ................................................................................................................. 3

3 Meeting our AMP7 specific obligations ................................................................................................... 5

3.1 Introduction ..................................................................................................................................... 5

3.2 Overview of the documents included within this review ................................................................ 5

3.3 Drinking Water Inspectorate Guidance to water companies .......................................................... 6

3.3.1 Drinking Water Safety Plan ...................................................................................................... 6

3.3.2 Technical Submission ............................................................................................................... 6

3.3.3 Long Term Drinking Water Quality Plan .................................................................................. 8

3.4 WISER and Blueprint for PR19 ......................................................................................................... 9

3.4.1 Enhancing the Environment: Water body status (Water Framework Directive) .................. 10

3.4.2 Enhancing the Environment: Bathing Waters ....................................................................... 12

3.4.3 Enhancing the Environment: Shellfish Waters ...................................................................... 14

3.4.4 Enhancing the Environment: Biodiversity and ecosystems ................................................... 15

3.4.5 Enhancing the Environment: Sustainable fisheries ............................................................... 17

3.4.6 Enhancing the Environment: Invasive non-native species (INNS) ......................................... 18

3.4.7 Enhancing the Environment: Urban Waste Water ................................................................ 19

3.4.8 Enhancing the Environment: Water Resources ..................................................................... 20

3.4.9 Enhancing the Environment: Chemicals ................................................................................ 21

3.4.10 Improving Resilience: Flood Risk Management .................................................................... 24

3.4.11 Improving Resilience: Future Drainage ................................................................................. 27

3.4.12 Improving Resilience: Water Resources and Security of Supply ........................................... 29

3.4.13 Improving Resilience: Climate Change .................................................................................. 32

3.4.14 Improving Resilience: Resilience Strategy ............................................................................. 33

3.4.15 Excellent Performance: Regulatory Compliance and Sludge ................................................ 34

4 Conclusion ............................................................................................................................................. 39

5 Appendices ............................................................................................................................................ 40

Copyright © United Utilities Water Limited 2018 1


1 Executive summary

1.1 Purpose of this document The UUW Board Assurance Statement says: “The business plan will enable the company to meet its statutory and licence obligations, both now and in the future - We have actively worked with our quality regulators to understand and - where appropriate - challenge their expectations for the AMP7 period and the longer term. The delivery of key obligations has been incorporated into our suite of performance commitments and outcome delivery incentives”.

This document provides the evidence to support this statement and sets out how United Utilities business plan for the 2020-2025 period will enable the company to meet its statutory and licence obligations and take account of the UK and Welsh Government’s strategic policy statements.

1.2 Background and introduction As a regulated water and wastewater company UUW is subject to a number of obligations, which can be considered as falling within one of two categories:

• Fixed obligations either defined by legislation - such as the Water Industry Act 1991 - or defined through the Instrument of Appointment; or

• AMP7 specific obligations - defined through the price review, or related cyclical processes, such as the performance commitments and the quality enhancement programmes.

Each year the UUW Limited Board signs a Risk and Compliance statement, which is published within our Annual Performance Report. This statement describes the systems and processes that are used to demonstrate that UUW has complied with its relevant statutory, licence and regulatory obligations or, where relevant, highlight material areas where these obligations were not met.

This document summarises the processes that we have put in place to ensure that we will be able to continue to demonstrate that we are meeting our fixed obligations through the AMP7 period. It also sets out in detail the work that we have undertaken to enable our AMP7 business plan to meet the obligations which will be developed through the price review or other related cyclical processes.

The document is structured as follows:

Section 2 – Meeting our fixed obligations

Providing further detail on the governance arrangements that are in place to ensure that the company will continue to comply with its obligations and report its performance transparently.

• We have effective; governance, processes and systems that allow the UUW Board to sign an annual Risk and Compliance statement, which demonstrates that we currently comply with our regulator, statutory and licence obligations.

• We will incorporate the new AMP7 obligations into this process to ensure that we are able to continue to provide this annual confirmation

• We have worked with our regulators to understand and where appropriate challenge the specific regulatory obligations which will be imposed for the AMP7 period

• We have allowed investment and set performance commitments within our business plan that will allow us to demonstrate that we are delivering our obligations in AMP7.



Section 3 – Meeting our AMP7 specific obligations

Providing further detail on the process that we have undertaken to understand our obligations and the work that we have undertaken to review and where appropriate challenge: the need for the enhancement; the scope of the solution and the cost of the delivery of this scope of work.

Section three is structured around three main publications:

• Water Industry Strategic Environmental Requirements (WISER) • Blueprint for PR19 – Environmental Outcomes for the Price Review • Drinking Water Inspectorate Guidance to water companies: Long term planning for the quality of drinking

water supplies

2 Meeting our fixed obligations This section of the document demonstrates how the company currently manages its “fixed obligations that are either defined by legislation - such as the Water Industry Act 1991 - or defined through the Instrument of Appointment.

Each year the UUW Limited Board reviews and signs a Risk and Compliance statement, which is published as part of our Annual Performance Report (APR). These reports are published on our website1.

This annual statement confirms that the company has complied with the relevant statutory, licence and regulatory obligations for the provision of services to its customers for the report year. The 2017/18 statement confirmed that:

“The Board considers that the Company has applied its processes and internal systems of control in a manner that has enabled it to satisfy itself, to the extent that it is able to do so from the facts and matters available to it, that the Company:

Has a full understanding of and has complied with its statutory, licence and regulatory obligations in all material respects in 2017/18.

• Has taken appropriate steps to understand and meet customer expectations. • Has sufficient processes and internal systems of control to fully meet its obligations. • Has appropriate systems and processes in place to identify, manage and review its risks”.

The Board is able to make this statement each year as a consequence of the governance and control processes that are now firmly established within the company. Key elements of this approach are:

Authorisations, approvals and procedures. These are set out in the United Utilities Group PLC (UUG) Internal Control Manual (ICM) to provide guidance to employees as to the system of internal controls that they must follow when acting on behalf of UUW and UUG as a whole. The ICM sets out a framework within which underlying detailed procedures and policies operate.

Policies. The Board has adopted an overriding set of business principles. These are supported by a range of underlying policies that provide guidance to its employees as to how they should conduct themselves when acting on behalf of UUW and UUG as a whole. Everybody working for or on behalf of UUW must comply with the policies (to the extent they are applicable to their roles). Failure to do so may result in disciplinary action being taken. This could lead to dismissal and possible civil or criminal proceedings in serious cases.

Governance and control. The Board delegates responsibility for specific matters to a number of committees and working groups. This provides a framework that employees are expected to be aware of and comply with where relevant to their role to ensure business decisions are taken in accordance with best business governance practices. Processes and systems. The processes and systems of control the company uses are adequate for it to meet its obligations.

1 Annual Performance Report landing page: https://www.unitedutilities.com/corporate/about-us/performance/annual-performance-reports-2015-2020/ Copyright © United Utilities Water Limited 2018 3

https://www.unitedutilities.com/corporate/about-us/performance/annual-performance-reports-2015-2020/

https://www.unitedutilities.com/corporate/about-us/performance/annual-performance-reports-2015-2020/


To ensure that we fully understand and are able to meet and demonstrate that we are meeting our statutory and regulatory obligations we established a Compliance Working Group (CWG). The CWG is made up of subject matter experts from all relevant areas of the business. The CWG undertook a structured and detailed review of legislation that was relevant to UUW (approximately 130 articles). This review involved a risk assessment of each piece of legislation, with the risk assessment being based upon the potential financial or reputational impact of the obligations to the business. Low risk legislation is routinely monitored by the CWG, which also reviews any new legislation. Each piece of medium or higher risk legislation was assessed in further detail and as part of this process specific accountabilities for the legislation were determined with a RACI assessment (responsible, accountable, consulted and informed) undertaken. This process confirmed who within the business was responsible for each piece of legislation and has ensured that all medium and high risk legislation has a named manager who is accountable for ensuring that UUW is able to comply with and is able to demonstrate that it is complying with this obligation. The process also identified a responsible manager, who is required to review the legislation that they are responsible for against relevant company policies, to confirm that the company has processes in place that are sufficiently robust to allow the manager to demonstrate compliance with the obligation each year. All medium and high risk obligations are now covered by this process with all medium or high risk legislation having a defined manager who is responsible for ensuring that the company is compliant with this piece of legislation and a defined manager who is accountable for this process working effectively. This process is managed on a SharePoint site, which is kept up to date with all the information derived through this process and which contains links to the relevant business policies within the Internal Control Manual (ICM). Due to the significance and complex nature of the Water Industry Act (WIA) and the company licence, we analysed these obligations at a more granular level and have assessed and assigned accountability and responsibility for each sub-measure individually. Relevant sub measure have also been cross referenced to the AMP6 performance commitments, which can be used to evidence and report compliance against these obligations. Obligations are also cross referenced to business risks that are recorded and managed on the company’s central risk management database (RADAR). This process works to ensure that any potential risks to compliance with existing obligations or any potential risks that may arise as a consequence of new obligations or new interpretations of existing obligations can be identified at an early stage. With the structured risk management process being use3d to ensure that appropriate mitigation plans and controls are established and that potential risks are escalated within the business potentially up to UUW Board level. As part of the annual regulatory reporting process, each business area is responsible for ensuring and demonstrating on-going compliance with all legislation relevant to that area of the business. With the process summarised above being used to ensure that the relevant Directors can demonstrate that they have complied with their obligations and to support their signature of the annual “Management Control Self-Assessment” process. These management and executive reviews and signatures being used to support the Board in signing the annual Risk and Compliance Statement. This process is supported by second and third line assurance, with the level of assurance that is applied to the reporting in these areas being based upon the risk assessment of the obligation or the supporting performance commitment. This is now a well-established and demonstrably effective process, with the compliance working group continuing to identify changes to legislation or relevant new legislation for example GDPR (General Data Protection Regulation). This is then risk assessed against accountabilities, reporting and assurance arrangements defined and incorporated within the annual Self-Assessment process. This process will continue into the AMP7 period, with the new AMP7 performance commitments, reporting and assurance being mapped to relevant legislation and forming part of this reporting framework.



3 Meeting our AMP7 specific obligations 3.1 Introduction This section of the document demonstrates how the company currently manages its “Periodic delivery” obligations defined through the price review, or related cyclical processes. These obligations for the AMP7 period are set out in:

• The Drinking Water Inspectorate Guidance to water companies: Long term planning for the quality of drinking water supplies;

• The Water Industry Strategic Environmental Requirements; and • The Blueprint for PR19.

Two of these documents were developed by our Regulators (the Environment Agency, Natural England, the Drinking Water Inspectorate), and the third by a coalition of key environmental non-governmental organisations. These document contain a mixture of statutory requirements, and non-statutory enhancements which these organisations expect water companies to consider within their business plans for 2020-2025. This section of the document sets out all of the obligations and expectations contained within these three documents, and demonstrates how we have ensured that they would be met through the delivery of our business plan for the 2020-2025 period.

3.2 Overview of the documents included within this review Drinking Water Inspectorate Guidance to water companies: Long term planning for the quality of drinking water supplies This guidance note, produced by the Drinking Water Inspectorate (DWI), is intended to give water companies and stakeholders support for long term planning in relation to the quality of drinking water supplies. It does not set out any new policy initiatives, or any new legal obligations. In it, the DWI give details of the arrangements for information submissions to the DWI, as part of the Price Review process, and sets out a time line of their engagement in the PR19 process. Our information submissions are then reviewed and challenged by the DWI and formalised in legal instruments. Water Industry Strategic Environmental Requirements (WISER)

The WISER was jointly produced by the Environment Agency (EA) and Natural England (NE), as a “Strategic steer to water companies on the environment, resilience and flood risk for business planning purposes”. It replaces Defra “Statement of Obligations” and the Environment Agency “Letter of Expectations” which were produced for PR14. The WISER is intended to help Water and Sewerage Companies to understand the statutory obligations which apply to them, and highlight enhancements to these statutory minimum requirements which the EA and NE request that Companies consider, where there is customer support for them. Blueprint for PR19 – Environmental Outcomes for the Price Review

The Blueprint for Water is a campaign of the Wildlife and Countryside Link, and the Blueprint for PR19 document is published by the Blueprint for Water Coalition. This Coalition is made up of 18 Environmental Non-Governmental Organisations (NGOs) (Appendix 1), whose mission is “to develop solutions to the water issues facing England…[to] ensure a vibrant future for water, people and nature”. The Blueprint for PR19 does not set out statutory or regulatory requirements. Rather, it is an environmental manifesto in which the Blueprint for Water Coalition set out their view of the key challenges and opportunities for the Water Industry in AMP7. It also gives some indication of what they believe the next steps for the Water Industry should be. Although the document does not set out statutory requirements for United Utilities, it has been developed with input from a number of significant organizations, many of whom United Utilities works in partnership with. It is therefore appropriate that its content are fully understood, and that United Utilities should strive to meet the Blueprint for Water Coalition’s PR19 expectations. Copyright © United Utilities Water Limited 2018 5


3.3 Drinking Water Inspectorate Guidance to water companies The Drinking Water Inspectorate Guidance to water companies: Long term planning for the quality of drinking water supplies, guidance note sets out DWI’s views on issues that water companies may need to address for the PR19 period and beyond, gives details of the arrangements for information submissions to the DWI as part of the Price Review process, and sets out a time line of their engagement in the PR19 process.

It differs from the WISER and Blueprint for water, in that it does not set out a summary of the obligations or expectations of Water Companies for AMP7. In the guidance note the DWI request water companies identify improvement schemes they consider are required. The DWI then assess and challenge the justification for those schemes, before agreeing and formalising the drinking water quality programme.

There were three major requirements which the DWI expected water companies to undertake, in response to the document:

• Drinking Water Safety Plans: complete and submit revised Regulation 28 reports for risks associated with proposed water quality schemes for AMP 7 by November 2017

• Technical Submission: for any schemes identified to deliver drinking water quality improvements in AMP7, provide sufficient justification of the need by completing “Annex A” documents by 31 December 2017

• Long Term Water Quality Planning: provide assurance that risk assessments include a long term view, by the end of May 2018

3.3.1 Drinking Water Safety Plan In order to produce our revised Drinking Water Safety Plan (DWSP) risk assessments, our Water Asset Managers identified any projects that had been raised through our Wholesale Risk and Asset Planning (WRAP) process that met the DWI’s criteria for schemes to improve the quality of drinking water, which needed to be factored into our DWSP. WRAP is our process to identify, quantify, validate, assess, prioritise and cost our water quality and resilience risks in a systematic way, monitor strategic performance requirements and prioritise these for investment or operational management. This process aligns with the International Standard for Asset Management (ISO55000).

In addition to the WRAP process, a methodology was developed specifically for assessing the risk of geosmin and 2MIB. In November 2017, the DWSP was reviewed regionally for these risks by the DWSP team. The individual DWSP reviews were attended by representatives from Water and Scientific Services with site specific knowledge. Supporting information included both operational and regulatory quality data from raw waters, treatment works, in distribution and at the customer’s tap, catchment specific plans and local expert knowledge.

In line with the requirement in the DWI’s guidance note, on 30th November 2017, the revised DWSP risk assessments were submitted to the DWI for four schemes that were required to reduce a longer term risk associated with the presence of geosmin and 2 MIB in the raw water..

3.3.2 Technical Submission Where we had identified schemes in our DWSP to deliver drinking water quality improvements in AMP7, the DWI guidance note required that we complete “Annex A” documents by 31st December 2017. Annex A documents were completed for:

• Castle Carrock WTW- Taste and odour • Rivington WTW- Taste and odour • Mitchells WTW- Taste and odour • Laneshaw WTW – Taste and odour • Lead



In addition to the “Annex A” documents that were developed through the standard DWSP process for the schemes above, bespoke documents were also completed for the following long term water quality schemes and initiatives:

• Manchester Pennine and Resilience project • Water Fittings campaign for homes and public buildings • Thirlmere catchment resilience project

Prior to the submission we also discussed our plans regarding water quality for 2020-2025 and beyond with the Inspectorate in person on 30th November 2017. All work on the December Technical submission was subject to robust assurance and governance through a variety of means. From conception to completion, the work aligned to the Company’s assurance and governance structures, and was governed through Strategic Steering Group, which met in September and November 2017. These additional levels of governance enabled us to ensure the submission was robustly scrutinised before submission to the DWI. The completed Annex A and bespoke documents were submitted to the DWI on 22nd December 2017 in advance of the deadline of 31st December 2017. The Company met with the Inspectorate on 31st January 2018 to specifically provide additional information on the Manchester and Pennines resilience project. The Company did not receive any written requests for additional information or queries following the Technical submission. On 30th May 2018, the DWI formally responded to the Company’s December Technical Submission. Where we submitted an “Annex A” document, the DWI supported the need for a programme or work and agreed that it would be formalised in a legal instrument. They have currently provided a letter to that effect. This is evidence that we met the requirements of DWI and provided sufficient justification of the need for the scheme for drinking water quality reasons (see green schemes in Table 1). Where we submitted a bespoke document, the DWI has provided a letter confirming that they agree with our approach and that the work should be included in the business plan (see blue schemes in Table 1).

Table 1: Summary of the schemes in the Technical Submission

PR19 DWI ref Scheme Name Quality parameter Scheme type Preferred option

UUT 1 Castle Carrock WTW Taste and Odour Treatment GAC installation

UUT 2 Laneshaw WTW Taste and Odour Catchment/Treatment Continuing catchment management/GAC installation

UUT 3 Lead strategy Lead Treatment/Distribution Implement lead strategy

UUT 4 Manchester and Pennines - Manchester Resilience Resilience Distribution Network maintenance

UUT 5 Mitchells WTW Taste and Odour Treatment GAC installation

UUT 6 Rivington WTW Taste and Odour Catchment/Treatment Continuing catchment management/GAC installation

UUT 7 Thirlmere catchment Resilience Catchment Various catchment management activities

UUT 8 Water fittings Multiple parameters Distribution Various water fittings solutions

The DWI has supported the schemes that we put forward to address the risks from taste and odour and lead. They have also welcomed the approach and have provided their support, without the need for a legal instrument, for the remaining schemes that we proposed..



3.3.3 Long Term Drinking Water Quality Plan For the first time the Drinking Water Inspectorate also required a concise summary to be provided by 31st May 2018 of our long term plan for water quality. The narrative in our Long Term Water Quality Plan was developed to address the specific requirements in the DWI’s guidance note, for example references to current good practice within a long term planning context at Paragraphs 1.2 to 3.5. We worked with Subject Matter Experts (SME) from across the business to ensure each of the best practice requirements and considerations in Paragraphs 1.2 to 3.5 of the guidance were met. For example the Water Asset Managers, Network Teams, Strategy Leads, Catchment, Process Engineering and Water Quality Public Health Team. In addition we also reviewed our current performance and identified the key themes to build on our current transformation programme. We also included case study examples to demonstrate information the DWI requested in their guidance note. For example, we included detail of the Manchester and Pennine resilience project and Thirlmere catchment resilience to demonstrate information as set out in paragraphs 5.3.3 to 5.35 of the DWI guidance note. As set out in Paragraphs 5.3.3 to 5.35, a meeting was also arranged with the DWI and the Your Voice group on 17th April 2018. The development of the Long Term Water Quality plan was subject to robust assurance and governance through a variety of means. From conception to completion, the work aligns with the Company’s assurance and governance structures. The activity has been governed through the Strategic Steering Group and the Policy and Regulation group. Prior to the submission we also discussed our plans regarding water quality for 2020-2025 and beyond in outline with the Inspectorate in person on 30th November 2017 and 31st January 2018. This was to have a preliminary view of DWI’s opinion on the draft submission content, which they supported in principle, and to provide further information specifically on the Manchester and Pennines Resilience project at the latter meeting. The Long Term Water Quality plan was submitted to the DWI on 31st May 2018, and at the time of writing have received no further queries or comments from the Inspectorate.



3.4 WISER and Blueprint for PR19 The WISER and Blueprint for PR19 contain a number of very similar, complimentary or overlapping expectations, and as such they have been reviewed together. The expectations in these documents have been structured under the three objectives set out in the WISER:

• enhancing the environment • improving resilience • excellent performance

Within each of these categories, the expectations have been grouped by the main legislative driver to allow some consistency with the approach taken at PR14 to the review of the Defra “Statement of Obligations”. The expectations set out by the EA and NE within the WISER are identified as either statutory (S), statutory plus (S+) or non-statutory (NS) (Appendix 2). These labels are used throughout this document, to distinguish the legal obligations (S and S+ where cost beneficial) from the expectations of the EA and NE, which are not driven by a statutory obligation (NS). All expectations in the Blueprint for PR19 are non-statutory and have also been marked NS to distinguish them from statutory requirements. The following sections of this document provide a table for each main legislative driver. This table summarises the expectations in both the WISER and the Blueprint for PR19. The tables provide the detail for how each of the statutory and non-statutory obligations from the WISER and Blueprint for Water will be met. They also highlight which of our strategies will deliver this expectation, how we will measure this via our Performance Commitments and, where applicable, outcome delivery incentive mechanism (ODIs), and gives a commentary to illustrate how the expectation will be delivered. The performance commitments referred to within these tables are detailed in Chapter 5 of the UUW AMP7 business plan and cover our current view of the quality enhancement programmes. The percentage of water bodies that should achieve “good” status by 2027 is currently under development, and will be signed off by the Secretary of State in 2021. Due to the timing of this exercise, we have developed a WINEP3 Cost Adjustment Mechanism, which is designed to work alongside the ODIs and account for revisions to the final programme and should enable UUW to be able to accommodate increases to the programme and which will protect customers from the non-delivery of schemes. On 17th July 2018, we received a report from the EA which states that “Through the WINEP and updated Water Resource Management Plan we believe that UU are proposing enough to address the majority of their statutory obligations as outlined in WISER” (Appendix 3). This is positive confirmation from the EA that they have confidence in United Utilities to meet the obligations in the WISER, and the tables below..


Chapter 7: Supplemetary Document – S6005 unitedutilities.com

3.4.1 Enhancing the Environment: Water body status (Water Framework Directive)

Expectation Source Document

Strategy to deliver expectation

Performance commitment

Commentary

Wat

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ody

stat

us (W

ater

Fra

mew

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Dire

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1.1.1 Measures to prevent deterioration in current water body status.

WISER (S) Rivers Improved Strategy Supply and Demand Strategy

C07-CF Note this is a cost adjustment mechanism not an ODI

The Water Industry National Environment Programme version 3 (WINEP3), sets out all of the investment we will make in the period 2020-2025 to achieve our obligation under the Water Framework Directive. We have committed to 196 individual Water Framework Directive requirements in the WINEP3 (WFD driver), 29 have a specific no-deterioration driver (WFD_ND, WFD_ND_WRHMWB, and WFD_NDINV_WRFlow drivers). We have also developed an AMP7 WINEP3 Cost Adjustment Mechanism, which is designed to account for revisions to the final programme and should enable UUW to be able to accommodate increases to the programme and which will protect customers from the non-delivery of schemes.

1.1.2 Measures to improve water body status. WISER (S+) Rivers Improved Strategy Bathing and Shellfish Waters Strategy

C05-WWN Improving river water quality

The Water Industry National Environment Programme version 3 (WINEP3), sets out all of the investment we will make in the period 2020-2025 to achieve our obligation under the Water Framework Directive. We have committed to 196 individual Water Framework Directive requirements in the WINEP, 123 have a specific improvement driver (WFD_IMPm, WFD_IMPg, and WFD_IMP_WRHMWB drivers). We have also developed an Improving River Water Quality performance commitment for AMP7 which is specific to WFD improvements. We are predicting 100% delivery against this measure. Details of this measure can be found in Table App1.

1.1.3 Companies commit to addressing their pressures on the environment, including contributions towards ensuring 75% of water bodies achieve "good" status by 2027, as required by the WFD

Blueprint for Water (NS)

Rivers Improved Strategy

C05-WWN Improving river water quality

The percentage of water bodies that should achieve “good” status by 2027 is determined by the Environment Agency through their River Basin Management Plans (RBMPs), which are currently under development, and will be signed off by the Secretary of State in 2021. Consultation is currently underway on these plans, and we are fully engaged in this process. WINEP3 has been developed in order to ensure that we deliver our fair share contribution towards improving river quality, in order for the WFD river status targets in the RBMPs to be met, based on the EA’s best understanding of what these targets will be. We have committed to delivering our obligations set out in WINEP3, and our Rivers Improved Strategy includes all of the river improvement schemes to be delivered by 2024.

10





Commentary

1.1.4 Work with stakeholders and Catchment Based Approach (CaBA) partnerships to explore integrated solutions at a catchment scale.

WISER (NS) Integrated Catchment Strategy

C08-CF Enhancing natural capital value for customers C05-WWN Improving river water quality

During AMP6 we have successfully demonstrated a new way of delivering WFD phosphorus requirements in the Petteril Catchment, and we are currently working jointly with the EA to develop a new way of permitting these integrated solutions at a catchment scale. United Utilities’ Sustainable Catchment Management Programme (SCAMP) is a well-established programme of work to manage our catchment land to deliver improvements in raw water quality. We will continue to invest in our SCAMP programme in AMP7. In AMP7 we have 5 catchment schemes named in the WINEP3, where we will be exploring integrated catchment solutions (WFD_IMPg, WFD_IMPm and NERC_IMP1 drivers). The delivery of tose with a WFD_IMP driver as a primary or secondary driver will be measured as part of our improving river water quality performance commitment. Across our whole programme we have identified 13 catchments where we will be exploring integrated solutions at a catchment scale in AMP7. In these catchments we will be building on our successes in AMP6 delivering catchment scale solutions by working with stakeholders, and looking to expand our integrated catchment approach to deliver multiple drivers within a catchment. We will continue to work in partnership with stakeholders, including the CaBA partnership in order to deliver our AMP7 integrated catchment solutions.

1.1.5 Companies significantly extend investment in catchment management supporting delivery of water resources and wastewater outcomes. Companies show leadership in the Catchment Based Approach and commit to working with partners, sharing best practice, and valuing the benefits of this approach to water quality, water resources, flood risk, carbon and recreation.




3.4.2 Enhancing the Environment: Bathing Waters




Commentary

Bath

ing

wat

ers

1.2.1 Measures to achieve at least sufficient class.

WISER (S) Bathing and Shellfish Waters Strategy

C07-CF (Cost Adjustment Mechanism) C02-CF Treatment works compliance C01-WWN Pollution incidents

We do not currently expect to have any requirements for Bathing Water investment as part of our business plan 2020-2025. We have made significant investment in our Bathing Water Assets over previous AMPs, and all Bathing Waters in the North West have now achieved sufficient status, or more. WINEP3 identifies 3 schemes at Dearham, Allerby and Crosscannonby Wastewater Treatment Works (WwTWs), to reduce the number of spills from these assets. These are the only Bathing Water no deterioration schemes identified for United Utilities in AMP7. However, all three of these WwTWs impact upon the Allonby South Bathing Water, which is likely to be de-designated as a Bathing Water, removing the requirement for these three schemes. If we do not deliver these schemes, the money will be removed from our business plan via the cost adjustment mechanism - quality enhancement programme, ensuring that our customers are protected. We have a C02-CF Treatment works compliance performance commitments relating to the performance of our Wastewater Treatment assets (which include our Bathing Water assets). Through these will be able to track our performance, with the intention that we will be compliant with our permits under the Environment Permitting Regulations, and will have a minimal negative impact on the environment from pollution incidents. This will allow us to ensure the performance of our wastewater assets does not contribute to a deterioration in the bathing water status of any North West beach.

1.2.2 Measures to prevent deterioration in class. WISER (S)

1.2.3 Event monitoring of storm overflows impacting on bathing waters.

WISER (S) Not Applicable

Not Applicable This has already been achieved, following our investment as part of our AMP6 business plan. In AMP7 we will already have Event Duration Monitors installed on storm overflows which impact on bathing waters, which were required in the AMP6 National Environment Programme. There are therefore no requirements for United Utilities to deliver against this expectation in AMP7.

1.2.4 Measures to achieve good / excellent class. WISER (NS) Bathing and Shellfish Waters Strategy

Not Applicable In WINEP3 we have 22 Bathing Water investigations (BW_INV3 and BW_INV4 drivers) to identify which of those Bathing Waters currently achieving sufficient status could potentially achieve good or excellent status in the future. As part of this, in AMP 7 we will assess the benefits of our AMP6 Bathing Water requirements, and identify any locations where further investment could be delivered in AMP8 as part of our fair share towards






Commentary

delivering good or excellent Bathing Water status. These investigations in AMP7 will include a cost benefit analysis to ensure customers are protected.



3.4.3 Enhancing the Environment: Shellfish Waters




Commentary

Shel

lfish

wat

ers

1.3.1 Measures to prevent deterioration in current water body status.

WISER (S) Bathing and Shellfish Waters Strategy

C07-CF (Cost Adjustment Mechanism)

There are 4 Shellfish no-deterioration investment drivers in WINEP3 (SW_ND driver), 1 at Newbiggin WwTW, and 3 at Carlisle WwTW. All of these are included for delivery in our business plan for 2020-2025. If the requirement to deliver these scheme changes the cost adjustment mechanism – quality enhancement programme will ensure funding for alternative schemes, or in the event the schemes do not need to be delivered, the money will be removed from our business plan, ensuring that our customers are protected.

1.3.2 Measures to achieve shellfish water protected areas objectives.

WISER (S+) Not Applicable

Not Applicable No cost beneficial deliverables to support the achieving of these objectives were identified through the joint work between the EA and United Utilities during the WINEP development process to improve shellfish waters. However we are investing to prevent deterioration of shellfish waters in AMP7.

1.3.3 Event monitoring of storm overflows impacting on shellfish waters.

WISER (S) Not Applicable

Not Applicable This has already been achieved, following our investment as part of our AMP6 business plan. In AMP7 we will already have Event Duration Monitors on our storm overflows which impact on shellfish waters.



3.4.4 Enhancing the Environment: Biodiversity and ecosystems




Commentary

Biod

iver

sity

and

eco

syst

ems

1.4.1 Measures that contribute to meeting and or maintaining conservation objectives of Natura 2000 sites (Special Areas of Conservation (SAC) & Special Protection Areas (SPA)) and Ramsar sites.

WISER (S) Water Resources strategy

C04-WR Improving the water environment C08-CF Enhancing natural capital value for customers

There are 11 projects identified in WINEP3 (HD_IMP driver) where we will be taking action in AMP7 to improve the site in order to contribute towards it achieving the conservation objectives of a Natura 2000 or Ramsar site. Similarly, there are 7 additional investigations that we will be undertaking in AMP7, which are also included in WINEP3 (HD_INV driver),to determine the impacts of our activities, or permits or licence standards, on a Natura 2000 or RAMSAR site, or to determine the costs and technical feasibility of new targets. Delivery of this investment will be monitored via the performance commitment measuring our delivery of the water schemes in the WINEP, C04-WR Improving the water environment.

1.4.2 Measures that contribute to meeting and/or maintaining Favourable Condition targets for Sites of Special Scientific Interest (SSSI).

WISER (S, S+) Water catchment strategy


There are 3 projects identified in WINEP3 (SSSI_IMP driver) where we will be taking action in AMP7 to improve a site so as to contribute towards it meeting the conservation objectives of a SSSI. There are a further 2 projects in we will delivering in AMP7 which contribute towards a site meeting the conservation objectives of a SSSI is a secondary driver and 1 where it is a tertiary driver. Delivery of this investment will be monitored via the performance commitment measuring our delivery of the water schemes in the WINEP, C04-WR Improving the water environment. Details of these measures can be found in Table App1.






Commentary

1.4.3 Measures that contribute to priority habitat and species outcomes as well as other biodiversity actions and measures to enhance ecosystem resilience on your own land or in the catchments within which you operate

WISER (S+) Water catchment strategy Land Management Strategy Natural Environment Strategy


Our Water catchment strategy sets out in details the measures we will take to ensure that we meet this requirement for our own land. We also work with partners to support measures to meet this requirements on land that we do not own. Through our Land Management Strategy we will also identify opportunities where our land could be leased to organisations, such as The Wildlife Trust, who will manage the land to the benefit of biodiversity. Through our Land Management Strategy we will also implement Biodiversity Management Plans at some of our operational sites. These will form the basis for conserving biodiversity, and identify opportunities to enhance it. In AMP7 we also have 2 requirements in WINEP3 with a Natural Environment and Rural Communities Act, biodiversity priorities driver (NERC_INV1 and NERC_IMP1). One is an investigation into the feasibility of different options for a fish pass at the Wyre Calder intake. The other is a biodiversity improvement project at Leigh WwTW, looking to reclaimed lagoons in the non-operational part of the site. This will create a mosaic of open water, tall fen / reed bed and wet woodland, which will act as an ecological stepping stone between key sites in the Greater Manchester Wetlands Nature Improvement Area. Through our Natural Environment Strategy we are exploring the potential of moving towards Net Gain and habitat banking opportunities for future AMP cycles. We already have a target for No net loss in biodiversity in the delivery of capital projects for AMP 6. Delivery of this investment will be monitored via the performance commitment measuring our delivery of the water schemes in the WINEP, C04-WR Improving the water environment.

1.4.4 Measures that contribute to the conservation objectives of Marine Conservation Zones (MCZ).

WISER (S+) Not Applicable Not Applicable Only activities which have a detrimental impact on the designated features of a Marine Conservation Zone are regulated. The regulators of the Marine Conservations Zones in the North West have not identified any requirements for investment on behalf of United Utilities, and so there are no such activities in WINEP3. There are therefore no requirements for United Utilities to deliver against this expectation in AMP7.



3.4.5 Enhancing the Environment: Sustainable fisheries




Commentary

Sust

aina

ble

fishe

ries

1.5.1 Screen abstractions and outfalls to prevent the entrainment of eels and salmon.

WISER (S+) Rivers Improved Strategy

C04-WR Improving the water environment

United Utilities activities are regulated under the UK Eel Regulations and the Salmon and Freshwater Fisheries Act. By delivering our Rivers Improved strategy, particularly in relation to our abstraction activities, we will meet our obligations under these regulations. Our high priority sites under the UK Eel Regulations have been identified and our business plan includes projects to install screens at 4 sites and other measures to benefit eel populations at 3 locations. These are all included in WINEP3 and will be delivered in AMP7 (EE_IMP driver). Delivery of this investment will be monitored via the performance commitment which measures our delivery of the water schemes in WINEP3, Improving the water environment.

1.5.2 Address barriers to the passage of fish. WISER (S+)



3.4.6 Enhancing the Environment: Invasive non-native species (INNS)




Commentary

Inva

sive

non

-nat

ive

spec

ies (

INN

S)

1.6.1 Prevent deterioration by reducing the risks of spread of INNS and reducing the impacts of INNS.

WISER (S) Land Management Strategy Natural Environment Strategy

Not Applicable The grounds maintenance of our operational sites is managed by a dedicated team who record all invasive species and manage the treatment programme. In our business plan 2020-2025 have committed to delivering 4 different INNS activities on WINEP3 (INNS_ND and INNS_INV drivers), in order to meet our requirements relating to the identification and management of INNS. These 4 activities are detailed below. In AMP7 we will be creating a companywide invasive species plan (1), and producing a biosecurity e-learning package for staff (2), with the aim of reducing the risk of spread from activities and assets. We will also undertake an activities and recreational pathway investigation to risk assess our assets (3). As part of this investigation we will also undertake an options appraisal of the potential mitigation measures which would address pathways of spread from our activities and assets. Lastly, in AMP7 we will undertake a raw water transfer investigation to risk assess our raw water assets (4). As part of this investigation we will undertake an options appraisal of the potential mitigation measures which would address pathways of spread from raw water transfers.

1.6.2 Reduce the impacts of INNS, where INNS is a reason for not achieving conservation objectives or good status.

WISER (s, S+)

1.6.3 Understand pathways of introduction and spread of INNS.

WISER (NS)



3.4.7 Enhancing the Environment: Urban Waste Water




Commentary

Urb

an w

aste

wat

er

1.7.1 Measures to protect newly identified sensitive areas.

WISER (S) Rivers Improved Strategy

C07-(Cost Adjustment Mechanism)

There are 10 WwTW which have been identified in the WINEP (U_IMP2 driver) as needing measures to comply with the 2016 review of freshwater Sensitive Areas. We have also developed a performance commitment for AMP7 which is a WINEP3 Cost Adjustment Mechanism ODI, which will protect customers from the non-delivery of schemes.

1.7.2 Measures to improve wastewater treatment where population thresholds are exceeded.

WISER (S) Rivers Improved Strategy


One site in our region has been identified as having crossed a population threshold in the Urban Wastewater Treatment Regulations. This is Ainsdale WwTW and investment is included in WINEP3 to address this (U_IMP1 driver). We have also developed a cost adjustment mechanism for our quality enhancement programme in AMP7, which will protect customers from the non-delivery of schemes.

1.7.3 Maintain sewers to demonstrate sewer leakage to ground is minimal, especially in Source Protection Zones.

WISER (S) Water Catchment Strategy

Not Applicable United Utilities has already carried out an investigation into leaking sewers in Source Protection Zones. The investigation showed that sewer leakage was not a large contributor to nitrates in Source Protection Zones in our area. We therefore do not have a specific programme of work on this in AMP7, but any issue that arise with sewers in Source Protection Zones during AMP7 will be investigated and prioritised for repair as part of our sewer maintenance programme.



3.4.8 Enhancing the Environment: Water Resources




Commentary

Wat

er R

esou

rces

1.8.1 Catchment measures to prevent deterioration in water quality and to reduce the need for additional treatment.

WISER (S) Water Catchment Strategy


There are 12 projects identified on WINEP3 to implement catchment actions to prevent water quality deterioration to avoid the need for additional treatment (DrWPA_ND driver). In agreement with the EA, one of these project is currently going through a process of change control to remove it from WINEP3, so 11 projects have been included in our business plan 2020-2025, and their delivery will be monitored through the C04-WR Improving the water environment, WINEP3 delivery performance commitment.

1.8.2 Catchment measures to improve water quality to reduce the level of existing treatment.

WISER (S+) Water Catchment Strategy

Not Applicable No specific catchment measures to improve water quality (DrWPA_IMP driver) were identified in WINEP3 as requirements for delivery in AMP7. There are therefore no requirements for United Utilities to deliver against this expectation in AMP7. However, United Utilities’ Sustainable Catchment Management Programme (SCAMP) is a well-established programme of work which outlines all of our catchment measures for water quality. It will continue to run into AMP7. In AMP7 we have also committed to undertake 11 catchment investigations (DrWPA_INV) to fully characterise groundwater and surface water safeguard zones. As part of this we will undertake an options appraisal and identify and recommend measures for catchment schemes which may be included in AMP8.

1.8.3 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).


Water Catchment Strategy

Not Applicable This is not a statutory requirement, but was considered as part of our Water Catchment Strategy. It was discounted as a viable option after we received feedback from our regulator that they would prefer the continuation of a voluntary approach.

1.8.4 Companies commit to addressing abstraction where it is preventing achievement of "good" status or poses a risk of deterioration.


Water Resources Management Plan (WRMP)

C04-WR Improving the water environment C03-WR Abstraction Incentive Mechanism

All our abstractions identified as Category 1 (most serious impact) in the EA's sustainable catchments assessment (Feb 2017) will be addressed by the end of AMP6. We had no Category 2 sites, so there is no requirement for further action on these for United Utilities in AMP7. Where we have Category 3 sites, the risk of deterioration occurs beyond 2027 (i.e. AMP8), and only if abstraction exceeds recent abstraction rates. We will investigate these sites in AMP7 to assess the risk of deterioration and identify solutions to implement in AMP8 and beyond (this requirement is on the WINEP3).






Commentary

1.8.5 Companies use mechanisms such as the Abstraction Incentive Mechanism (AIM) to reduce abstraction pressure around sensitive sources.



C03-WR Abstraction Incentive Mechanism

We have adopted the Abstraction Incentive Mechanism (AIM) in AMP6 and will continue to do so AMP7. We will measure our performance through this commplusory performance commitment which is detailed in Table App3.

1.8.6 Companies ensure that where new water supply options are considered, they are transparent about environmental risk and include mitigation measures to support good status.



Not Applicable We have completed a thorough options identification and appraisal process as part of the development of our Water Resources Management Plan. These appraisals are supported by detailed environmental assessment reports. The process to produce our Water Resources Management Plan includes a thorough consultation, which ensures the transparency of the decisions made, and we can demonstrate that we have made changes to our plan throughout the process in response to feedback we have received.

3.4.9 Enhancing the Environment: Chemicals




Commentary

Chem

ical

s

1.9.1 Measures to prevent deterioration (includes load standstill measures).

WISER (S) WW Network Plus Business Plan Rivers Improved Strategy


The full scope of CIP3 (Chemical Investigation Programme) is included within our business plan 2020-2025. There are 29 chemical investigation requirements in WINEP3 (WFD_INV_CHEM drivers), with the investigations to be undertaken ranging from antimicrobial resistant to micro plastics. The purpose of these investigations is to gain greater certainty in order to allow cost beneficial measures to be identified in future AMP cycles. There are a further 5 trend monitoring requirements (WFD_MON_CHEM driver) and 4 no deterioration load standstill measure (WFD_NDLS_CHEM drivers) set out in WINEP3. We have also developed a cost adjustment mechanism for our quality enhancement programme in AMP7, which will protect customers from the non-delivery of schemes.

1.9.2 Companies include ongoing monitoring of the presence and treatability of emerging pollutants (pesticides, pharmaceuticals and microplastics), using results to inform appropriate management (product and usage controls, upgraded treatment and natural solutions).


1.9.3 Measures to achieve compliance with environmental quality standards (EQS).

WISER (S+) Not Applicable Not Applicable There are no requirement for United Utilities to meet EQS on discharges for chemicals set out in WINEP3. There are therefore no requirements for United Utilities to deliver against this expectation in AMP7.






Commentary

1.9.4 Work with business customers and catchment partners to explore alternatives to end of pipe treatment solutions.

WISER (NS) Integrated Catchment Strategy

C08-CF Enhancing natural capital value for customers

During AMP6 we have successfully demonstrated a new way of delivering our WFD phosphorus requirements in the Petteril Catchment, and we are currently working jointly with the EA to develop a new way of permitting these integrated solutions at a catchment scale. In AMP7 we have 5 catchment schemes named in the WINEP3, where we will be exploring integrated catchment solutions, as an alternative to end of pipe treatment solutions. Across our whole programme we have identified 13 catchments where we will be exploring integrated solutions at a catchment scale in AMP7. In these catchments we will be building on our successes in AMP6 delivering catchment scale solutions by working with stakeholders, and looking to expand our integrated catchment approach to drive multiple benefits within a catchment, by promoting more sustainable solutions. We will continue to work in partnership with stakeholders, to deliver our AMP7 integrated catchment solutions, through the development of alternative markets to bring in wider investment from other sectors, and to develop innovative greener alternatives to end of pipe solutions.



3.4.10 Enhancing the Environment: Natural Capital




Commentary

Nat

ural

Cap

ital

1.10.1 Companies commit to assessing the Natural Capital they depend on, with the intent to grow it and to integrate it into decision making.


Water Catchment Strategy Integrated Catchment Strategy

C08-CF Enhancing natural capital value for customers

In AMP6 we are piloting three Natural Capital approaches: Natural Capital Accounting using natural capital accounting to see where value is generated to help make better decisions; Natural Capital Solutions investing in land and green infrastructure where they can deliver outcomes in a more efficient manner; and Natural Capital Funding exploring innovative funding and markets that deliver broader outcomes. We have created a corporate Natural Capital account for our owned land holding, and a full Natural Capital account for the Petteril catchment. We also used Natural Capital to review different approaches as part of our Water Resources Management Plan. In AMP7 we are committed to developing further capability in this area, and this is reflected on the development of our bespoke AMP7 performance commitment on "enhancing natural capital for customers". Natural Capital is also one of the drivers behind the our Water Catchment Strategy In AMP7 we want to ensure that we identify opportunities to deliver innovative and sustainable schemes which deliver multiple benefits beyond our statutory requirements. We will achieve this by working in partnership with local and regional stakeholders to achieve the best environmental outcomes in the most cost-effective way. This approach builds on our Sustainable Catchment Management Programme, applying a systems thinking philosophy to address environmental drivers. So far we have identified 13 catchments to develop a bespoke integrated approach for AMP7 and we will continue to ensure we adopt these approaches across all appropriate catchments. We believe that by the time we get to AMP8 natural capital approaches will be part of business as usual and a key aspect of providing more value to stakeholders but also resilience in the natural systems we rely on as a business.

1.10.2 Companies consider the value of natural capital and benefits of water left in the environment within water resource option appraisals.




3.4.11 Improving Resilience: Flood Risk Management




Commentary

Floo

d ris

k m

anag

emen

t

2.1.1 Co-operate with other risk management authorities in exercising your flood risk management functions.

WISER (S) Flooding Strategy Surface water Management Policies (in development)

Not Applicable We have a strong track record of partnership working with other flood management authorities, and will continue to do so in AMP7. We regularly participate in Strategic Flood Partnership meetings and Making Space for Water meetings. We are also creating a new Flood Partnership Manager role, jointly funded by United Utilities and the Regional Flood and Coastal Committee, which will further facilitate the promotion of collaborative activities that reduce flood risk from sewers and other non-water company drainage assets. We have a surface water management policies in development such as Surface water Management Policy and Sustainable Drainage Systems in new development, which will allow us to identify clear and consistent messages and intent to other (flood) Risk Management Authorities (RMAs).

2.1.2 Co-ordinate and share information with Cat.1 and 2 responders.

WISER (S) Incident Response Methodology

Not Applicable In AMP7 we will continue to collaborate when an incidents is declared and we cooperate with the Lead Local Flood Authorities (LLFA) in their development of Section 19 reports.

2.1.3 Comply with statutory reservoir safety requirements.

WISER (S) Reservoir and safety strategy and methodology

B10-WR Keeping reservoirs resilient

Dam inspections are a regular activity carried out by Headworks Controllers, Supervising Engineers and, as appropriate, external Panel Engineers. Safety inspections are an aspect of the risk reduction activities that are performed. We have comprehensive systems and governance in place to ensure we meet safety and regulatory expectations. Actions identified as part of inspections are progressed and governed through the Dam Safety Group. We also report every 2 months to the corporate Dam Safety Group, chaired by the director of engineering. Every quarter a risk update is undertaken, to recalculate the risk of every dam in our asset base. Once a year a dam safety report, jointly compiled by Asset Management and Engineering, is made to the Board. We also have a performance commitment which measures the number of people benefiting from reduction of risk of dam failure. This is how we will track our performance in AMP7.






Commentary

2.1.4 Develop a clear and systematic understanding of service and system risks and include options for reducing the likelihood of future service failures and service failures that lead to flooding.

WISER (NS) Flooding Strategy

G02-WWN Internal sewer flooding incidents G03-WWN External sewer flooding incidents G05-WWN Hydraulic internal flood risk resilience G06-WWN Hydraulic external flood risk resilience G01-WWN Risk of flooding in a storm

In AMP6 we have developed a methodology for producing Integrated Drainage Area Studies (IDAS), which allow us to better understand our wastewater network at a local scale, and to better manage the risk of failure. We will continue to roll out this approach in AMP7. IDAS takes a risk based approach using network performance data, modelling and operational feedback to assess incidents and develop prioritised catchment interventions. Plans have been produced which included a series of proposed opportunities to manage the integrated risks which we face. Through collaborations & partnerships we hope to be able to prioritise interventions and identify alternative delivery routes. We are committed to a trend towards zero for sewer flooding of homes, and to reducing the number of properties at risk of flooding. We recognising that this is an aspirational ambition, as flooding caused by severe weather and customer behaviour is extremely difficult to fully control. In AMP7 we will have a capital investment programme dedicated to reducing the risk of hydraulic flooding to properties which have historically repeatedly hydraulically flooded. We are also going to undertake our biggest ever customer engagement campaign to raise awareness of what not to flush and pour down drains. Over a third of sewer flooding incidents in our area are caused by customer flushing behaviour, and we believe that targeting this will deliver significant reductions in sewer flooding. The Drainage and Wastewater Management Plan (DWMP) methodology currently under development will help us set out our long term plans for extending and maintaining a resilient wastewater system. The DWMP will examine a 25 year period to ensure value, resilience and sustainability. The main driver of the DWMP is the need for clear engagement with both customers and stakeholders; it is envisaged this will be achieved by a more coherent approach to planning through the use of greater stakeholder engagement. Within our DWMP we will be able to demonstrate long term links to local Risk Management Authorities’ (RMA) long term plans; in practice this means we will be able to show how our DWMP links to both River Basin and Flood Risk management plans.

2.1.5 Reduce sewer flooding of homes and businesses trending towards zero.

WISER (NS)

2.1.6 Reduce the number of properties at risk of flooding.

WISER (NS)

2.1.7 Take every opportunity to increase the number of partnership flood schemes achieving multiple benefits.

WISER (NS) Flooding Strategy Surface water Management

Not Applicable A number of partnerships have been forged in recent times and have created lines of communication which have ultimately delivered collaborative opportunities and solutions. We intend to continue this collaborative approach into AMP7. Our Flooding Strategy for AMP7 sets out our intention to identify opportunities to separate surface water out and to drain more effectively, working with 3rd parties where






Commentary

Policies (in development)

possible. We will also work with key partners, for example developers, to encourage sustainable drainage practices through initiatives such as Sustainable Urban Drainage (SuDS) adoption.

2.1.8 Work with others to actively identify and build in sustainable drainage options.

WISER (NS) Flooding Strategy Surface water Management Policies (in development)

Not Applicable We have invested in new technologies which will enable us to identify SuDS options in AMP7. Our SuDS Studio modelling tool allows us to identify and prioritise SuDS. It enables the identification of sites where SuDS would be most effective and deliver the biggest benefit, and allows benefits to be identified at catchment level. In AMP7 we will continue to work collaboratively with organisations such as the Environment Agency, the Rivers Trust, schools, developers and local authorities to actively identify and build in sustainable drainage options.

2.1.9 Companies extend investment in green infrastructure and SuDS (new and retrofit) to reduce flooding and provide biodiversity, recreation and water quality benefits.


2.1.10 Work with government and other utilities to take forward the recommendations of the National Flood Resilience Review.

WISER (NS) Flooding Strategy Surface water Management Policies (in development)

Not Applicable Through our participation in national groups, forums and project steering groups (DWMP Project Steering Group, EA Workshops, Water UK groups) we regularly take the opportunity to lobby Defra, National Infrastructure Committee and EA on such matters.



3.4.12 Improving Resilience: Future Drainage




Commentary

Futu

re d

rain

age

2.2.1 Use the 21st Century Drainage Programme work streams on storm overflows and drainage capacity metrics to inform business plans.

WISER (NS) DWMP methodology

Not Applicable The Drainage and Wastewater Management Plan (DWMP) methodology currently under development will help us set out our long term plans for extending and maintaining a resilient wastewater system. The DWMP will examine a 25 year period to ensure value, resilience and sustainability. The main driver of the DWMP is the need for clear engagement with both customers and stakeholders; it is envisaged this will be achieved by a more coherent approach to planning through the use of greater stakeholder engagement. Within our DWMP we will be able to demonstrate long term links to local Risk Management Authorities’ (RMA) long term plans; in practice this means we will be able to show how our DWMP links to both River Basin and Flood Risk management plans.

2.2.2 Maintain networks and WwTWs to reduce the risk of future failures.

WISER (NS) Wastewater Network Operating Model Wastewater Network Strategy

G02-WWN Internal sewer flooding incidents G03-WWN External sewer flooding incidents F02-WWN Sewer blockages F01-WWN Sewer collapses C01-WWN Pollution incidents C02-CF Treatment works compliance

In AMP6 we have undertaken a significant investment in our mobile asset resource scheduling (MARS) system. This has provided the foundation for a step change in how we plan, schedule and deliver maintenance activities, which will enable us to effectively manage the maintenance of our assets in AMP7. In AMP7 we will continue to develop and refine our Wastewater Network Strategy, Operating Model, and Cyclic Maintenance Programmes to improve operational performance and reduce the number of serviceability incidents across our networks. In combination with outputs from our Wastewater Network Management Programme and the restructuring of our wastewater management teams we will continue to reduce both repeat and first time sewer incidents. The use of innovative technologies that can link real time performance and forecast rainfall data will allow us to identify deteriorating trends and where our network begins to operate outside of normal historical parameters. The delivery of this requirement cuts across a number of our performance commitments, demonstrating our commitment to undertaking appropriate maintenance in order to deliver our performance commitments.






Commentary

2.2.3 Event duration monitoring on high significance storm overflows.

WISER (S) AMP 6 programme of work

C01-WWN Pollution incidents C07-CF (Cost Adjustment Mechanism)

In AMP6 we will have delivered c.2000 EDM installations across our asset base, meaning we will have already addressed high significant storm overflows, before AMP7. In AMP7 we have 5 EDM installations requirements in WINEP3 (U_MON1 driver), which will be delivered as part of our business plan 2020-2025. We have also developed a cost adjustment mechanism for our quality enhancement programme in AMP7, which will protect customers from the non-delivery of schemes.

2.2.4 Ensure compliance with permitted flow to full treatment settings.

WISER (S) Wastewater Treatment Maintenance Strategy

Future EPA measure

We intend to address flow to full treatment compliance issues as part of our AMP7 business plan, to ensure full compliance by AMP8. The EA are currently developing their flow related permit conditions and compliance assessment methodology. Uncertainly around regulatory expectations for flow compliance will remain until these are fully understood. It is anticipated that the EA will issue their new flow permit conditions and compliance methodology during AMP7. Internally we will continue to monitor our flow compliance using our own assessment methodology, until the EA’s own compliance assessment methodology is published. We will continue to share this with the business through the Flow Compliance Report. Flow compliance performance is also report to the Chief Operating Officer on a quarterly basis. We will continue to internally monitor flow compliance throughout AMP7. We anticipate that when EA finalise their methodology for measuring flow compliance, and there will be a standard approach that will form part of the Environmental Performance Assessment (EPA). We will then adopt this measure to monitor our own performance.



3.4.13 Improving Resilience: Water Resources and Security of Supply




Commentary

Wat

er re

sour

ces a

nd se

curit

y of

supp

ly

2.3.1 Solutions to meet water resources management plan outcomes or measures to protect the environment form the supply-demand component of business plans.

WISER (NS) WRMP Not Applicable We are not proposing Supply-Demand Enhancement as part of our water resources management plan (WRMP). We have no supply-demand deficit, so no enhancements are required in AMP7.

2.3.2 Assess resilience of your water supply system to predicted droughts and other non-drought water supply hazards.

WISER (NS) WRMP Ofwat common measures for resilience and drought resilience

We have developed sophisticated, industry-leading tools and techniques for assessing drought resilience. These include stochastic hydrology and very fast water resources models for undertaking System Simulation and Robust Decision Making (RDM). As a result we have been able to establish that we have a very high level of resilience to severe and extreme droughts. It also allowed us to assess the benefits of our plans to enhance leakage reduction to drought resilience. We undertook a wide-ranging assessment of non-drought hazards including those such as flooding, freeze thaw and malicious damage. One of the strategic choices in our WRMP is to address a significant resilience risk to supply in Manchester and the Pennies, linked to the deterioration of the Haweswater aqueduct. As such resilience to non-drought hazards features very prominently in our WMRP.

2.3.3 Measures to reduce demand and per capita consumption.

WISER (NS) WRMP Demand Management Strategy

Not Applicable In terms of demand management, both leakage and PCC are common Performance Commitments for the industry and both have targets that make percentage reduction from an end of AMP6 baseline position. These performance commitments align with our WRMP targets and demand forecasts and reduce over time.

2.3.4 Achieve a downward trend for leakage with rates at or below the sustainable economic level of leakage.

WISER (NS) Demand Management Strategy

B01-WN Leakage In our WRMP, we have committed to a leakage reduction target of 15% for AMP7, and over 40% by 2045. We are already below our SELL and this reduction is a very stretching target and will deliver a significant reduction in leakage rates from current levels of leakage.

2.3.5 Assess universal metering in water stressed areas.

WISER (S) Not Applicable Not Applicable We are not in a water stressed area based on the Environment Agency’s assessment which identifies the areas classed as water stressed.SThere is no requirement for United Utilities meet this expectation in AMP7

2.3.6 Ensure agreed and up to date plans are place to manage a drought.

WISER (S) Statutory Drought Plan

Not Applicable Our Statutory Drought Plan was updated in June 2018. It outlines in detail our full plan and business processes for managing drought. We will continue to keep this plane updated in AMP7.






Commentary

2.3.7 Demonstrate that Defra’s Guiding principles for water resources planning have been met.

WISER (NS) WRMP Not Applicable Defra’s Guiding principles for water resources planning have been fully embedded into our WRMP.

2.3.8 Incorporate sustainability changes into supply forecasts.

WISER (NS) Yes - this is detailed in the WRMP

Not Applicable In our WRMP we have incorporated sustainability changes into our supply forecasts. These include changes to abstraction licenses, as part of EA’s Habitats Regulations review of consents.

2.3.9 Current abstractions and operations, and future plans support the achievement of environmental objectives.

WISER (S, S+) Rivers Improved Strategy


The details of projects will be specified in Measure Specification Forms (MSFs) which we will agree with the EA. Some MSFs have already been discussed with the EA and the remainder should be completed over the course of the coming months as we finalise our plans for AMP7.

2.3.10 Companies significantly scale up their demand management programmes to increase resilience. This includes ambitious water efficiency measures, through both offering and fitting products and behaviour change engagement, increasing overall metering of households as well as the proportion of smart meters and reducing leakage.


WRMP Demand Management Strategy

B01-WN Leakage B05-WN Per capita consumption A04-WN Helping customers look after water in their home

We will continue to offer water efficiency visits to customers’ homes, where we fit water efficiency devices, and to distribute free water efficiency pack via our website. We have completed behaviour research project. Result of which are now used by Domestic Retail to find better way of engaging with our customers. We have started trials on "price promise" and connected homes. Results of these will inform our future strategies on metering and water efficiency.

2.3.11 Companies ensure no overall increase in the amount of water abstracted from rivers and groundwater despite increases in population and climate change - a "water neutral" PR19


WRMP C03-WR Abstraction Incentive Mechanism

We will continue in AMP7 to comply with our obligation to preserve water and manage abstractions in line with our licences provided by the EA. In AMP7 we are confident we will meet this expectation using existing resources and by the application of our WRMP. Our WRMP preferred plan for 2020-45 consists only of demand options (leakage reduction).

2.3.12 Companies increase the availability, promotion and take-up of social tariffs and efficiency retrofit to protect vulnerable customers and all those struggling to afford their bills, combining these with water efficiency measures to help manage bills down.


North West Affordability summit action plan

PR19UU_E01-HH Number of customers lifted out of water poverty PR19UU_D03-HH Priority Services for customers in

We have sought to put in place an effective approach to helping customers in financial stress and to ensure that assistance is accessible to all low to middle income customers. This includes offering reduced tariffs, promotion of water metering, and campaigns to raise awareness of the cost benefits of water efficiency. We seek to provide financial support to a large number of customers and to ensure the degree of support provided is significant in the context of each customer’s individual circumstances. We aim to effectively target support for those customers who will benefit most from our assistance.






Commentary

vulnerable circumstances

2.3.13 Companies develop plans to incentivise customers and communities to reduce consumption during dry periods and in catchments most at risk from abstraction, setting out specific and ambitious programmes to manage demand during period of peak use.


Statutory Drought Plan

B05-WN Per capita consumption A04-WN Helping customers look after water in their home

Our Drought Plan contains a list of specific activities we undertake in times of drought, and we will fully implement these in AMP7



3.4.14 Improving Resilience: Climate Change




Commentary

Clim

ate

chan

ge

2.4.1 Report on understanding of risks from climate change and how they are being addressed via Adaptation Reporting Power (ARP) reports.

WISER (S) Risks related to climate change adaptation and mitigation are embedded within many strategies – see commentary

No Risks related to climate change adaptation and mitigation are embedded within many strategies, but particularly: Water Supply Demand Strategy, Sewer Flooding Strategy We reported the understanding of risks from climate change and how they are being addressed in our Adaptation Progress Report in 2015. The report was published and is available on the UU corporate website. A new paper is produced every 3-5 years, when requested by Defra. We plan to publish an updated Adaptation Progress Report in late 2019 / early 2020, timed to feed into Defra’s national view. Our Adaptation Progress report will report progress on the actions we have taken since 2015, and identify any new actions we intend to deliver in AMP7.

2.4.2 Reduce total carbon emissions. WISER (S+) Carbon Strategy No In AMP6 our carbon emission have reduced. In AMP7 we will continue to deliver our carbon management strategy. We will continue to monitor our progress towards reducing carbon emissions and publish a full report on the reduction of greenhouse gas emissions as part of our company corporate annual report.

2.4.3 Ensure Adaptation Reporting Power (ARP) report commitments are consistent with, and embedded within, business plans.

WISER (NS) Risks related to climate change adaptation and mitigation are embedded within many strategies – see commentary

No Risk Management including risks related to climate change adaptation and mitigation is embedded in multiple company strategies and methodologies, reflecting the fact that many different elements of our business need to have strategies in place to mitigate and adapt to the risk climate changes poses to them. Our Business Plan 2020-2025 has been developed to deliver these strategies, including the climate change adaptation and mitigation actions.



3.4.15 Improving Resilience: Resilience Strategy




Commentary

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2.5.1

Companies set out how they will deliver and report on long-term resilience (and the resilience of the ecosystems they rely on to operate) in their investment planning.


Resilience Strategy

Not Applicable

Our Resilience strategy sets out our aim to reduce risk at a sustainable rate using the most appropriate control mechanism for the situation. In AMP7 we will continue to reduce the vulnerability of single points of failure prioritised on risk reduction ( cost of action vs probability of failure x consequence of failure); define an acceptable/desirable level of risk based on customer and stakeholder expectations and company acceptability; strengthen contingency planning for catastrophic events working with customers, stakeholders and employees to create capability; improve our understanding of risk of failure of key assets and develop plans to mitigate the risk in the short term and as far as practicable eradicate in the medium to long term; and look for opportunities to enhance resilience more cost effectively through integrating with other needs. As well as out resilience strategy, long-term resilience is a consideration in a number of strategies. For example, we have received good feedback on our approach to resilience in the Draft Water Resources Management Plan. We consider ecosystem resilience as a key driver behind drinking water protected areas, where restoring ecosystem functions is needed to improve water quality, particularly in relation to colour. We also promoting integrated catchment approaches which providing benefits across the water and wastewater programme in delivering more sustainable solutions that will benefit ecosystems and resilience in the long term. We plan to continue to monitor the long term ecological changes to demonstrate the benefit of our investment. The principal of ecosystem resilience is also embedded in a number of our performance commitments, including: Natural capital, abstraction incentive mechanism, improving the water environment, improving river water quality, innovation to further improve river water quality, protecting the environment from the impact of growth and new development, pollution incidents, treatment works compliance and improving bathing and shellfish water quality.



3.4.16 Excellent Performance: Regulatory Compliance and Sludge




Commentary

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udge

3.1.1 A plan in place to achieve 100% compliance for all licences and permits.

WISER (S) Environmental Compliance Improvement Plan

C02-CF Treatment works compliance

We have an established process for inspecting and assessing each WwTW, (numeric or descriptive permit) over a rolling 12 month programme, which we will continue to follow in AMP7. The process involves the use of a checklist of points for inspection and confirmation which have been taken directly from the clauses and conditions of our environmental permits. This allows operations staff to quickly and accurately record potential non compliances. The checklist is then reviewed at an appropriate level and corrective actions determined and raised via the corporate action tracking system. The corporate system is used to track and report on unresolved issues, to aid prioritisation and close out. Following the initial roll out of the Permit Checklist Task process, investigation into developing an app based system for use on operations staff smart phones has been initiated and suitability for scheduling the inspections via the recently deployed Mobile Asset Resource Scheduling system is being assessed. This process ensure that our assets are regularly checked and that compliance remains and area of focus whilst also improving permit conditions knowledge across our operational teams. We also have the maintenance requirements of our assets captured in our MARS system, to ensure they are managed effectively in order to keep sites running in line with their permits.

3.1.2 100% compliance with environmental permit conditions at WwTWs with descriptive not numeric limits.

WISER (S) Environmental Compliance Improvement Plan

Not applicable Compliance at descriptive works is excluded from the EA’s Environmental Performance Assessment and from our AMP7 Treatment works Compliance performance commitment. However, it is monitored internally and all WwTWs are inspected on a rolling programme, to check that they are fully compliant with their permit, and to take action where required. We also have the maintenance requirements of our assets captured in our MARS system, to ensure they are managed effectively in order to keep sites running in line with their permits.

3.1.3 Serious pollution incidents must continue to trend towards zero.

WISER (S) Wastewater Network Operating Model

C01-WWN Pollution incidents

Our pollution performance in AMP6 has been industry leading, and we have been rated a four star company by the EA as part of their Environmental Performance Assessment for 3 consecutive years. We also have a 4 star rating by the EA.






Commentary

3.1.4 Trend to minimise all pollution incidents (category one to three) by 2025. There should be at least a 40% reduction compared to numbers of incidents recorded in 2016.

WISER (S) Wastewater Network Strategy and Pollution Strategy documents


In AMP7 we are committed to continuing to trend towards zero serious pollution incidents, and have set ourselves a very stretching target which will see us reduce the number of wastewater pollution incidents to their lowest ever level, , both within the North West and in England & Wales (normalised data). This will mean the delivery of significant improvements from a level that is already classed as frontier. This is in the context of effectively managing the risk of potential incident number increases from EDM and transferred assets.

3.1.5 Effective management of transferred private sewers and pumping stations with low levels of pollution incidents.

WISER (S) Wastewater Network Operating Model Wastewater Network Strategy and Pollution Strategy documents


We have taken an early adopter approach in AMP6 bringing stations onto our asset base in a phased manner from 2012 to 2016, meaning we have already carried out a pre-adoption surveys on all private assets prior to automatic transfer that took place on 01/10/16. This gives us a greater, longer term understanding of the pollution risked posed by these assets, allows us to manage their transfer more effectively and has enabled us to target remedial investment on a prioritised basis. Works to bring up to a minimum operable standard have been carried out immediately on adoption and a prioritised programme of additional remedial work, which will be carried out during AMP7.

3.1.6 No D, E, or F rated sites under Operational Risk Appraisal OPRA for waste related sewerage service Environmental Permitting Regulations permits.


Not Applicable In order to manage our OPRA banding, we have processes in place to ensure the compliance of our waste installations. Our Environmental Regulatory Advisors routinely inspect our waste installations and monitor their compliance. Any actions required to safeguard compliance are raised and recorded on our action tracking AIRline system. These actions are reported internally across the whole business until they have been completed. This inspection regime will continue in AMP7. We also have the maintenance requirements of our assets captured in our MARS system, to ensure they are managed effectively in order to keep sites running in line with their permits. During AMP7 (2021) the EA have proposed moving away from the OPRA system. United Utilities will engage fully with this consultation process and put appropriate plans in place to adapt to the new regime.

3.1.7 Compliance with flow requirements, including MCERTS certification, at WwTWs



We have an MCERTS Management System in place which is annually audited by SIRA on behalf of the EA. In AMP6 we have improved our MCERTS certification compliance, which has been noted as part of the audit process. We have the maintenance requirements of our assets captured in our MARS system, to ensure they are managed effectively in order






Commentary

Environmental Compliance Improvement plan

to keep sites running in line with their permits. In AMP7 we will continue to ensure compliance with the MCERTS requirements, as measured by our performance at the annual audit. The EA are currently developing their flow related permit conditions and compliance assessment methodology. Uncertainly around regulatory expectations for flow compliance will remain until these are fully understood. It is anticipated that the EA will issue their new flow permit conditions and compliance methodology during AMP7. Internally we monitor our flow compliance using our own assessment methodology, and this is shared with the business through the Flow Compliance Report. Flow compliance performance is also report to the Chief Operating Officer on a quarterly basis. We will continue to internally monitor flow compliance throughout AMP7. We anticipate that in AMP8 the EA will have finalised their methodology for measuring flow compliance, and there will be a standard approach and this will form part of the Environmental Performance Assessment (EPA)

3.1.8 High levels of self-reporting of pollution incidents with at least 80 per cent of incidents self-reported by 2025. More than 90% of incidents self- reported for WwTWs and pumping stations.

WISER (NS) Wastewater Treatment Maintenance Strategy Environmental Compliance improvement plan Wastewater Network Operating Model Wastewater Network Strategy and Pollution

The Environment Agency’s Environmental Performance Assessment

Our self reporting performance in AMP6 has consistently met or exceeded the EA’s AMP6 target of 75%, and we have been rated a four star company by the EA as part of their Environmental Performance Assessment for 3 consecutive years. We already routinely see our self reporting rate exceed 80%, and will continue in AMP7 to provide the training and support to our frontline staff to ensure that we to see self reporting rates at 80% (or 90% for WwTWs and pumping Stations) through to 2025. The installation of circa 2000 EDM monitors throughout AMP6 can only improve our understanding of how our assets are performing in real time – this could actually lead to an increase of pollutions reported, such incidents would inevitably be self reported. We will continue to internally monitor our self reporting rate, and use the EA’s Environmental Performance Assessment metric to externally report our performance on this measure.






Commentary

Strategy documents

3.1.9 Business plans include all measures identified within the Water Industry National Environment Programme and these are planned well and completed to agreed timescales and specification.

WISER (S) Business Plan 2020-2025

C04-WR Improving the water environment C07-CF (Cost Adjustment Mechanism) C05-WWN Improving river water quality

In our business plan 2020-2025 we commit to delivering the Water Industry National Environment Programme (WINEP) in full. This will be measured via our WINEP deliver measures (C04-WR Improving the water environment, and C05-WWN Improving river water quality), this means that customers will be protected should there be changes to the WINEP during AMP7.

3.1.10 Sample and provide data in relation to self-monitoring under Operator Self-Monitoring (OSM), Urban Waste Water Treatment Directive (UWWTD), Flow monitoring and UV disinfection.

WISER (S) Treatment Works Compliance


In AMP7 we will continue to maintain our established quality management systems for UWWTD and OSM which include documented processes to ensure sufficient samples are planned, collected and results are reported in line with permit requirements. Samples are taken by trained operators or a UKAS accredited independent sampling team. Flow monitoring and UV disinfection are similarly covered by quality documentation and as the data is obtained via telemetry.

3.1.11 Manage sewage sludge treatment and re-use so as not to cause pollution to land, surface water or groundwater.

WISER (S) Bioresources Strategy

C09-BR Recycling biosolids

We have set a performance measure for AMP7 where will intend to achieve 100% satisfactory sludge disposal (in line with the EA’s Environmental Performance Assessment measure) and to comply with the Biosoilds Assurance Scheme (BAS) in each year of AMP 7. Achieve both 100% Satisfactory sludge disposal, and BAS compliance will enable us to demonstrate that our sewage sludge treatment and re-use so dose cause pollution to land, surface water or groundwater.

3.1.12 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


Wastewater Network Operating Model

C01-WWN Pollution incidents G02-WWN Internal sewer

In AMP6 we have developed a methodology for producing Integrated Drainage Area Studies (IDAS), which allow us to better understand our wastewater network at a local scale, and to better manage the risk of failure. We will continue to roll out this approach in AMP7. IDAS take a risk based approach using network performance data, modelling and operational feedback to assess incidents and develop prioritised catchment interventions. Plans have been produced which included a series of proposed






Commentary

despite population growth and climate change.

Wastewater Network Strategy and Pollution Strategy Documents

flooding incidents G03-WWN External sewer flooding incidents

opportunities to manage the integrated risks which we face. Through collaborations & partnerships we hope to be able to prioritise interventions and identify alternative delivery routes. Our Integrated Drainage Area Strategy (IDAS) is aimed at understanding and managing the underlying risk on the Network. This leads to a long term intervention plan aimed at pro-actively preventing incidents while adapting to changes.

3.1.13 Companies aim for zero pollution incidents (cat 1, 2 and 3), 100% monitoring of CSOs and 100% self-reporting of incidents.


Wastewater Network Operating Model Wastewater Network Strategy and Pollution Strategy Documents


Our pollution performance in AMP6 has been industry leading, and we have been rated a four star company by the EA as part of their Environmental Performance Assessment for 3 consecutive years. In AMP& we are committed to continuing to trend towards zero serious pollution incidents, and have set ourselves a very stretching target which will see us reduce the number of wastewater pollution incidents to their lowest ever level. This will mean the delivery of significant improvements from a level that is already classed as frontier. This is in the context of effectively managing the risk of potential incident number increases from EDM and transferred assets. In our business plan 2020-2025 we will deliver the 235 EDM installations identified in the WINEP (U_MON1 and U_MON3 drivers). This builds on our extensive EDM installation programme in AMP6 and ensure we continue to trend towards monitoring on all CSOs. The profile for EDM installation in AMP7 can be found in Table WWS4 Line 7. Our self reporting performance in AMP6 has consistently met or exceeded the EA’s AMP6 target of 75%, and we have been rated a four star company by the EA as part of their Environmental Performance Assessment for 3 consecutive years. We already routinely see our self reporting rate exceed 80%, and will continue in AMP7 to provide the training and support to our frontline staff to ensure that we to see self reporting rates at 80% (or 90% for WwTWs and pumping Stations) through to 2025. We will continue to internally monitor our self reporting rate, and use the EA’s Environmental Performance Assessment metric to externally report our performance on this measure.



4 Conclusion This document has set out the review that has been undertaken to ensure that United Utilities business plan 2020-2025 will deliver the Environmental Requirements, as set out in the Water Industry Strategic Environmental Requirements, the Blueprint for PR19 and the Drinking Water Inspectorate Guidance to water companies: Long term planning for the quality of drinking water supplies. They contain a mixture of statutory requirements, and non-statutory enhancements which these organisations expect water companies to deliver through their business plans for 2020-2025. All of these requirements and the plans to deliver them have been reviewed. For all of the statutory requirements which are relevant to United Utilities, there is assurance that they will be met through the delivery of our business plan 2020-2025. It should be noted that a number have already been met, either through the AMP6 business plan, or in the case of the DWI guidance document, as part of the PR19 process. For the non-statutory enhancements which are relevant to United Utilities, many set out to be aspirational, rather than for immediate delivery, and United Utilities supports them, where it is in the best interest of customers in the North West to do so. Where the non-statutory enhancements which are relevant to United Utilities, are focused delivery during AMP7, United Utilities will deliver these through our business plan 2020-2025, where it is in the best interest of customers in the North West to do so.


5 Appendices Appendix 1 The 18 NGOs who from the Blueprint for Water Coalition


Appendix 2: Definitions of Statutory, Statutory Plus and Non-Statutory expectations given in the WISER Statutory obligations (S): Statutory obligations principally arise from legislative requirements and the need to comply with obligations imposed directly by statute or by permits, licences and authorisations granted by the Secretary of State, the Environment Agency or other body of competent jurisdiction. Other statutory obligations include ministerial directions and meeting specific planning requirements. While it is important to understand the costs and benefits of measures needed, these statutory obligations must still be achieved. Statutory plus obligations (S+): Statutory plus obligations are categorised as legal requirements where economic evidence forms part of the decision making process, that is the balance of costs and benefits, and affordability considerations. In cases where action is considered disproportionately expensive to meet statutory plus obligations, alternative objectives or timescales to meet them may be set. Non-statutory actions (NS): Some expectations are not driven by statutory obligations. There may be a public need but this may not be underpinned by a specific Act or piece of legislation. You should demonstrate that there is an environmental requirement and/or customer support and that such investments provide best value for customers over the long term. Effective customer engagement should reveal whether customers (and which types of customers) want to see further environmental improvements, and over what timescale. Source: Water industry strategic environmental requirements (WISER), Section 1.3 Summary of the expectations of water companies, page 14.



Appendix 3: Link to “Environment Agency Your Voice Commentary on United Utilities PR19 Business Plan” “Environment Agency Your Voice Commentary on United Utilities PR19 Business Plan”


http://flow/Asset/MA/IAP/EnvReg/Topics%20Library/PR19%20Non%20Statutory%20Environmental%20Requirements/WISER/EA%20Your%20Voice%20report_final%2017%20June%2018.pdf

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