For 13 years South West Water have failed to meet their pollution “incident” targets.

That’s every year since the Environment Agency started reporting on Environment Performance metrics, worse than any other water company. 

South West Water has 12 non-compliant discharge sites  for treated wastewater. It’s amongst the worst three companies and it’s performance is declining.

South West Water is one of two companies whose investment targets in water quality schemes are not within planned deadlines. Ofwat determines what the water companies can charge us for investment. If these deadlines are not being met where has our money gone?

According to the report in the Plymouth Herald: Pennon Group, which owns South West Water, insists that

“delivering improvements in our environmental performance remains our top priority”.

Below, Owl posts the Chair’s forward to the Environment Agency’s environmental performance report 2023 who expresses “frustration and disappointment” with extracts from the key sections that catalogue South West Water’s failings. “The results we see are, yet again, simply not good enough.”

The Chair also says: “Lack of investment in assets over a long period and particularly the last decade means that problems have often been addressed reactively.”

And adds: “But it is not just about money. The culture within some water companies can also perpetuate poor practices. For example, some simply do not understand the root cause of their problems and incidents are not reported in a timely manner.”

Fine words, but are the Environment Agency doing enough? Or are they still a toothless “paper tiger”? – Owl

Water and sewerage companies in England: environmental performance report 2023

A summary of the environmental performance of the 9 water and sewerage companies operating in England. www.gov.uk 

1. Chair’s foreword

It is with a mix of emotions that I write this foreword to the 2023 performance report containing the Environmental Performance Assessment (EPA). My over-riding sense is one of frustration and disappointment. The results we see are, yet again, simply not good enough.  

The good news is that three companies achieved the maximum four EPA stars compared to one in 2022 – Severn Trent Water, Wessex Water and United Utilities. Credit to Severn Trent for achieving this for the fifth year running. But the performance of most companies lags far behind. We are seeing polarised performance as shown by the number of serious pollution incidents. Over 90% were caused by four water companies – Anglian Water, Southern Water, Thames Water and Yorkshire Water. This is unacceptable.   

Improvements will not happen overnight. Lack of investment in assets over a long period and particularly the last decade means that problems have often been addressed reactively. We welcome Ofwat’s draft determination for the next five year control period which should allow investment in many of the critical pieces of infrastructure needed to meet legal requirements. We will play our role in ensuring that the companies deliver these projects.  

But it is not just about money. The culture within some water companies can also perpetuate poor practices. For example, some simply do not understand the root cause of their problems and incidents are not reported in a timely manner – this is vital for improving transparency and trust across this sector. We know that with a changing climate, the country is going to experience more extreme weather patterns, increased rainfall and more rapid drought. Water companies must ensure that assets are resilient enough to withstand these challenges. We will not take ‘bad weather’ as an excuse for poor environmental performance.  

We take our responsibility to protect the environment very seriously. The regulations are clear, and we enforce them robustly. We have taken tough action against companies breaking the rules and have several serious investigations in progress. But we need to go further. 

We have agreed with the Department for Environment, Food and Rural Affairs (Defra), our sponsor department, a major increase in Environment Agency inspections of water company assets to provide assurance that they are meeting the requirements. We will carry out 4,000 such inspections this financial year and over 10,000 next year.  To support this, we are investing in our digital systems, regulatory tools and increasing our enforcement activity. You can find the full list of our commitments in our business plan 2024 to 2025. We will ensure that the findings of these inspections are made public. And we are working closely with Steve Reed MP, Secretary of State, on new legislation to strengthen our legal powers and penalties for pollution.

We have worked with companies to review their first drainage and wastewater management plans. These will ensure companies change to proactive investment in asset health and maintenance, to reduce risks and put headroom into their systems to deal with future challenges like climate and population growth. 

Since 2011 the EPA and wider reporting have provided an independent and objective comparison of water and sewerage companies’ performance As the regulator we constantly tighten EPA targets – which has been fundamental in driving better performance.  If the tighter standards we now apply had been in place in 2011, water companies would only have achieved 11 stars in comparison to the 25 they achieved in 2023.  Whilst this shows some improvement over that time, current performance is still a long way from meeting our expectations. We are reviewing the EPA to strengthen and broaden the metrics from 2026. 

With additional resources in place, a focus on transparent inspection and regulation, tightened EPA metrics and new legal powers, we are bringing stronger regulation to this sector in the coming year. We shall continue to drive for improved performance.

Alan Lovell, Chair of the Environment Agency

2. Performance facts for 2023

For 2023, the main performance facts for the sector are that:

• 5 water companies are rated as requiring improvement (2 stars) in our EPA, 1 is rated as good (3 stars) and 3 achieved 4 stars – all water companies should be able to achieve 4 stars
• there was a small improvement in star ratings with some water companies meeting our metric targets consistently in this EPA period so far (since 2021) – however the majority continue to underperform as they are not getting the basics right, such as minimising pollution incidents and achieving permit compliance
• the number of serious pollution incidents (category 1 and 2) increased to 47, remaining unacceptably high and not trending towards zero – mainly due to the performance of 3 water companies, resulting in a very polarised performance picture across the sector
• for the serious pollution incident EPA metric, Northumbrian Water and Severn Trent Water had zero incidents, however 4 water companies performed significantly below target (red) – numbers are dominated by serious pollution incidents from the assets of Anglian Water, Southern Water and Thames Water, with Yorkshire Water also rated red
• total pollution incidents from sewerage and water supply assets (category 1 to 3) increased to 2,174 – the second consecutive annual increase and highest number recorded since 2019
• total pollution incidents from sewerage assets increased to 1,902 with no water company achieving target (green), the first time for any metric since the EPA began in 2011 – Southern Water and South West Water continued to perform significantly below target (red) with Anglian Water also rated red
• self-reporting of all pollution incidents by water companies was 84%, and 93% for just pumping stations (PS) and sewage treatment works (STW) combined – this was the best since the EPA began however 3 water companies performed below target (amber) including a notable deterioration by Southern Water
• 98.8% of STW and water treatment works (WTW) were compliant with numeric permit conditions for discharging treated wastewater – although 6 water companies achieved target (green), the poor performance of 3 water companies, including South West Water (the only red water company), means the sector is not improving
• for the satisfactory sludge use and disposal EPA metric, all water companies performed better than target (green)
• for the Water Industry National Environment Programme (WINEP) EPA metric 99.2% of planned environmental improvement schemes were completed – 3 water companies failed to meet all requirements within planned deadlines (Thames Water rated red, Anglian Water and South West Water rated amber)
• for the Supply Demand Balance Index (SDBI) EPA metric all water companies achieved target (green)

4. Pollution incident performance

Pollution incidents lead to the release of harmful substances into air, land or water, and some can cause significant harm to the environment. We categorise all incidents based on their impact. Incidents are assessed as having a major (category 1), significant (category 2), or minor (category 3) impact on the water environment. Please refer to our EPA metric guide for more information……

• there were 1,902 sewerage pollution incidents, compared to 1,658 in 2022 – this is the worst performance since 2019 with 8 water companies having an increase compared to the previous year
• no water company achieved our EPA target (green), the first time for any metric since the EPA was introduced in 2011 – and a disappointing decline from the previous 2 years when we reported 4 water companies achieved green in each of those years
• 3 water companies performed significantly below target (red) for this EPA metric – Anglian Water for the first time, Southern Water for the fifth year in a row and South West Water for all 13 EPA reported years
• 6 water companies performed below target (amber) for this EPA metric
• if all water companies had achieved green EPA status in this metric there would have been at least 764 fewer sewerage pollution incidents and less environmental harm
• most of the incidents were from foul sewers (670), followed by STW (487) and PS (472)

5.1 Discharge permit compliance (numeric)

This section is about water company compliance with permits to discharge treated wastewater from STW and WTW (not storm overflows). As part of the EPA we assess compliance with conditions in these permits that set numeric limits for pollutants in the discharges….

Compliance for the sector is not improving. It is a statutory obligation to comply with permits. Our WISER performance expectation for 2020 to 2025 sets out that water companies should have a plan in place to achieve 100% compliance. In 2023:

• 98.8% of STW and WTW were compliant, compared to 99.0% in 2022, 98.7% in 2021, 99.2% in 2020 and 98.7% in 2019
• out of 3,800 STW and WTW permitted discharge outlets there were 45 non-compliant sites compared to 38 in 2022, 49 in 2021, 31 in 2020 and 49 in 2019 – no water company achieved 100% compliance with their permits
• South West Water performed significantly below target (red) with 12 non-compliant sites (96.2%) – a disappointing decline in performance from green status and 2 failing sites in 2022, and showing inconsistency in recent years
• Anglian Water had the most non-compliant sites (13) performing below target (amber) alongside Northumbrian Water (3)
• 6 water companies achieved target (green) for this EPA metric – of these Severn Trent Water, Thames Water, Wessex Water and Yorkshire Water have been consistently green in this EPA period so far (since 2021)
• there would have been at least 16 fewer non-compliant sites if all water companies had achieved green EPA status

7.1 Water Industry National Environment Programme (WINEP)

In 2019 Ofwat set the prices that water companies could charge their customers between April 2020 and March 2025. As part of that price review (PR19) we developed and published a WINEP for each water company. Our expectation for all planned schemes (including asset improvements, investigations and monitoring) to be completed to agreed timescales and specification was not met by all water companies. The EPA WINEP metric assesses completion of all improvement schemes and most investigation schemes…….

For the financial year ending March 2024 (cumulative progress for years 1 to 4 of the WINEP) for WINEP schemes in the EPA:

• 5 water companies are rated as requiring improvement (2 stars) in our EPA, 1 is rated as good (3 stars) and 3 achieved 4 stars – all water companies should be able to achieve 4 stars
• there was a small improvement in star ratings with some water companies meeting our metric targets consistently in this EPA period so far (since 2021) – however the majority continue to underperform as they are not getting the basics right, such as minimising pollution incidents and achieving permit compliance
• the number of serious pollution incidents (category 1 and 2) increased to 47, remaining unacceptably high and not trending towards zero – mainly due to the performance of 3 water companies, resulting in a very polarised performance picture across the sector
• for the serious pollution incident EPA metric, Northumbrian Water and Severn Trent Water had zero incidents, however 4 water companies performed significantly below target (red) – numbers are dominated by serious pollution incidents from the assets of Anglian Water, Southern Water and Thames Water, with Yorkshire Water also rated red
• total pollution incidents from sewerage and water supply assets (category 1 to 3) increased to 2,174 – the second consecutive annual increase and highest number recorded since 2019
• total pollution incidents from sewerage assets increased to 1,902 with no water company achieving target (green), the first time for any metric since the EPA began in 2011 – Southern Water and South West Water continued to perform significantly below target (red) with Anglian Water also rated red
• self-reporting of all pollution incidents by water companies was 84%, and 93% for just pumping stations (PS) and sewage treatment works (STW) combined – this was the best since the EPA began however 3 water companies performed below target (amber) including a notable deterioration by Southern Water
• 98.8% of STW and water treatment works (WTW) were compliant with numeric permit conditions for discharging treated wastewater – although 6 water companies achieved target (green), the poor performance of 3 water companies, including South West Water (the only red water company), means the sector is not improving
• for the satisfactory sludge use and disposal EPA metric, all water companies performed better than target (green)
• for the Water Industry National Environment Programme (WINEP) EPA metric 99.2% of planned environmental improvement schemes were completed – 3 water companies failed to meet all requirements within planned deadlines (Thames Water rated red, Anglian Water and South West Water rated amber)
• for the Supply Demand Balance Index (SDBI) EPA metric all water companies achieved target (green)

4. Pollution incident performance

Pollution incidents lead to the release of harmful substances into air, land or water, and some can cause significant harm to the environment. We categorise all incidents based on their impact. Incidents are assessed as having a major (category 1), significant (category 2), or minor (category 3) impact on the water environment. Please refer to our EPA metric guide for more information……

• there were 1,902 sewerage pollution incidents, compared to 1,658 in 2022 – this is the worst performance since 2019 with 8 water companies having an increase compared to the previous year
• no water company achieved our EPA target (green), the first time for any metric since the EPA was introduced in 2011 – and a disappointing decline from the previous 2 years when we reported 4 water companies achieved green in each of those years
• 3 water companies performed significantly below target (red) for this EPA metric – Anglian Water for the first time, Southern Water for the fifth year in a row and South West Water for all 13 EPA reported years
• 6 water companies performed below target (amber) for this EPA metric
• if all water companies had achieved green EPA status in this metric there would have been at least 764 fewer sewerage pollution incidents and less environmental harm
• most of the incidents were from foul sewers (670), followed by STW (487) and PS (472)

5.1 Discharge permit compliance (numeric)

This section is about water company compliance with permits to discharge treated wastewater from STW and WTW (not storm overflows). As part of the EPA we assess compliance with conditions in these permits that set numeric limits for pollutants in the discharges….

Compliance for the sector is not improving. It is a statutory obligation to comply with permits. Our WISER performance expectation for 2020 to 2025 sets out that water companies should have a plan in place to achieve 100% compliance. In 2023:

• 98.8% of STW and WTW were compliant, compared to 99.0% in 2022, 98.7% in 2021, 99.2% in 2020 and 98.7% in 2019
• out of 3,800 STW and WTW permitted discharge outlets there were 45 non-compliant sites compared to 38 in 2022, 49 in 2021, 31 in 2020 and 49 in 2019 – no water company achieved 100% compliance with their permits
• South West Water performed significantly below target (red) with 12 non-compliant sites (96.2%) – a disappointing decline in performance from green status and 2 failing sites in 2022, and showing inconsistency in recent years
• Anglian Water had the most non-compliant sites (13) performing below target (amber) alongside Northumbrian Water (3)
• 6 water companies achieved target (green) for this EPA metric – of these Severn Trent Water, Thames Water, Wessex Water and Yorkshire Water have been consistently green in this EPA period so far (since 2021)
• there would have been at least 16 fewer non-compliant sites if all water companies had achieved green EPA status

7.1 Water Industry National Environment Programme (WINEP)

In 2019 Ofwat set the prices that water companies could charge their customers between April 2020 and March 2025. As part of that price review (PR19) we developed and published a WINEP for each water company. Our expectation for all planned schemes (including asset improvements, investigations and monitoring) to be completed to agreed timescales and specification was not met by all water companies. The EPA WINEP metric assesses completion of all improvement schemes and most investigation schemes…….

For the financial year ending March 2024 (cumulative progress for years 1 to 4 of the WINEP) for WINEP schemes in the EPA:

• 99.2% (3,481 out of 3,508) met requirements within planned deadlines
• Thames Water performed significantly below target (red) due to 19 water quality schemes not meeting requirements within planned deadlines (93.4%)
• 2 water companies performed below target (amber) due to water quality schemes not meeting requirements within planned deadlines – Anglian Water (99.6%, 3 schemes), South West Water (98.8%, 5 schemes)
• 6 water companies met all requirements (100%, green) within planned deadlines – of these Northumbrian Water, Severn Trent Water, United Utilities, Wessex Water and Yorkshire Water have been consistently green in this EPA period so far (since 2021)