Chair: Ali Morse, The Wildlife Trusts
Vice Chair: Nik Perepelov, RSPB
Link: Ellie Ward, Policy Officer
Link’s Blueprint for Water Group works on freshwater policy issues and current work prioritises environmental resilience, sustainable abstraction, water quality and agricultural pollution (through joint work with Link’s Agriculture group).
In August 2023, Blueprint members wrote to the Secretary of State to share our concern with the steer given to the water industry to explore the deferral of many environmental projects under PR24. Deferring vital environmental projects will not drive nature’s recovery, will not meet public expectations for a clean, healthy and thriving water environment, and nor will it represent good use of public money. The letter was covered in national press. Blueprint also responded to the consultation on extending the growth duty to Ofwat, Ofgem and Ofcom. Our response explains why we disagree with this extension; that the duty will weigh the balance too heavily toward economic costs, at the expense of environmental costs, benefits and needs. Economic considerations already enjoy considerable focus from economic regulators; we do not accept the need or justification for introducing a further specific economic growth duty on these bodies. Instead, Government should consider a Green Growth Duty.
In July 2023, Blueprint for Water worked alongside Link's Marine Mammals and Marine Working Groups to respond to the Storm Overflows Discharge Reduction Plan consultation on bringing all coastal and estuarine overflows within scope. We welcomed these proposals, and have called for all Marine Protected Areas to be added to the list of high priority sites within the Plan. Pollution from storm overflows is one of many interacting pressures on the health of the water environment; efforts to improve overflows and reduce sewage pollution must form part of wider holistic action to tackle threats and improve the state of inland, coastal and marine waters.
In May 2023, Blueprint for Water engaged with a number of consultations, several of which follow announcements made in Government's Plan for Water. We welcomed the Government's proposal to remove the cap on penalties that the Environment Agency can pose, though have called for further detail on how this will work and how increase penalties will act effectively as a deterrent. We also shared our concern that unless funding and resourcing for the regulator is increased, their ability to impose these larger penalties - and therefore the benefit to removing the cap - will be undermined. We similarly welcomed Ofwat's proposals to strengthen guidance on performance-related pay, to ensure that this reflects delivery of both environmental and social obligations. We called for further detail about how this process will operate, and for Ofwat to take an even stronger approach to regulating performance-related pay in PR24 and beyond.
Blueprint also responded to consultations on Ofwat's Accelerated Infrastructure Delivery Project draft decisions, the proposed performance commitment for storm overflows in PR24, and on continuous water quality monitoring. Blueprint for Water also wrote to Ofwat CEO David Black to share thoughts on how the Price Review can better drive the use of catchment and nature-based solutions.
In February 2023, Blueprint for Water responded to the draft Water Resources Management Plans and draft Regional Water Resources Plans, through a blog and letters to each of the regional groups. There are positive commitments included in some of the plans, but if we are to achieve sustainable water resources management we hope to see the plans’ shortcomings resolved before final adoption. This includes making greater use of nature-based solutions, increasing focus on tackling non-household demand, and stepping-up work to reduce the water footprint of new developments. The group also coordinated an e-action, encouraging members of the public to get involved in the consultation, urging their water company to show greater ambition for driving water demand down and efficiency up.
In September 2022, Blueprint for Water responded to the Ofwat draft PR24 methodology consultation. PR24 has huge potential to drive action to protect and enhance our water environment, but the methodology must be strengthened and improved to deliver on this potential. We set out our recommendations for how this should be achieved, including the need to place greater responsibility on companies - not customers - to foot the bill for poor performance, and the need to better incorporate natural capital and facilitate the greater use of nature-based solutions. This follows and builds on the release of our 'Environmental Manifesto for PR24' in September 2021, setting out what Government, regulators and water companies must do if PR24 is to deliver a step-change for people and nature. The group continues to engage in the PR24 process.
In May 2022, Blueprint for Water responded to the consultation on Government's draft Storm Overflows Discharge Reduction Plan. The plan has huge potential to drive action to tackle sewage pollution and improve the water environment. However, the current draft falls far short of this potential, failing to capture the severity and urgency of the water quality crisis. In our response, we set out why this is the case, and key recommendations for how the plan should be strengthened - including a requirement that 100% of Storm Overflows that cause harm and discharge in or near to priority sites should be improved by 2030. This follows our April 2022 parliamentary briefing on the plan, developed in partnership with the #EndSewagePollution coalition.
In September 2021, Blueprint released the report 'Actions to Recover England's Waters and Wildlife'. This sets out our vision for the freshwater environment and our ‘how to’ strategy for bringing our freshwaters back to health, before it is too late, with recommendations under three key themes - Recover Biodiversity, Drive Down Pollution, and Re-think Our Relationship With Water.
For further information, contact Ellie Ward, Link’s Policy Officer.
Last updated: 5 December 2023
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