Comments on Thames Water’s Draft Water Resources Management Plan (DWRMP) 2010-2035

Sunningwell Parish Council does not believe that the WRMP adequately demonstrates the need for the proposed new reservoir in South West Oxfordshire (SWOX).

The parish council has comes to this conclusion for the following reasons:

1. It is noted that the Environment Agency is yet to be consulted on the plan, and the parish would wish to see its response before the formal consultation period is ended. If this is not possible then the parish council would wish for a further period of consultation, as the long term issue of water resources is critical to the evaluation of Thames Water’s long-term proposals.

1. The DWRMP does not appear to be based on an authoritative and independent long-term view of rainfall, in particular the effects of climate change.

1. The DWRMP seems to take a very conservative view of measures to reduce long-term water consumption; these are based largely on current technology and consumer attitudes. Much water is wasted in the home and garden, and one reason is its comparative cheapness. More realistic tariffs to encourage water efficiency and reduce waste should be considered. Both energy and power will be much more expensive from now on and this will change the economics of water supply and distribution.

1. The leakage reduction targets appear to be too modest, and the assertion that further leakage reduction would be uneconomic is seriously flawed. It does not appear to take account of the likely future economic cost of water, and fails to recognise the economic benefit to the consumer of water.

1. There appears to be no sensitivity analysis concerning the long term rising costs of energy. The parish council believes that the balance of cost benefit for further reducing leakage beyond that proposed in the DWRMP could well change if realistic future oil prices, eg, $300 per barrel by 2015, are factored in.

1. The parish council suspects that Thames Water is approaching the whole question of economics from the shareholders point of view. It understands that investment in replacing existing water distribution mains does not substantially increase the regulatory asset base upon which prices are ultimately determined. Therefore there is little financial return for additional investment of this type.

1. However the cost of a new reservoir will increase the regulatory asset base, and automatically lead to OFWAT allowing a higher return and therefore higher prices for consumers. The parish council believes that the cost benefit ratio should more fully reflect the interests of consumers and the environment.
2. There appears to be little reference to the impact of the rising water table in London and the vast quantity of water that could be utilised.

1. The parish council is concerned at the environmental impact of the proposed new reservoir, and particularly that no full assessment seems to have been made. Locally a reservoir of the size and in the location proposed, would be visually intrusive. There may be significant adverse changes to the micro climate, and the ecology balance, which appear not to have been professionally assessed.

1. Finally, in the event that the new reservoir should be approved the disruption caused by construction traffic in the area would be intolerable. The main access route would seem to be the A34 which is already overused with almost daily jams, and will get much worse if the proposed new housing south of Oxford goes ahead.

(approved by the Council on 30 July 2008)