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Waterwise Consultation response for Draft EA drought plans (2011)

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Waterwise praises this ambitious Environment Agency drought plan and is optimistic that, if implemented – and in combination with our suggestions – it will deliver an effective management and prevention of droughts while reconciling the interest of the environmental and water demand. Although, Waterwise is concerned whether the Environment Agency has adequate resources to implement such an ambitious plan (especially in the communications), considering the cuts that have taken place within their water resources team.

Introduction to drought management (Section 1 – Introduction)
Section 1 gives an overview to drought management for Head Office Environment Agency.

Question 1: Does this section provide you with a broad understanding of how and why drought happens? If not, please tell us if there is additional information we should consider.

The description on how and why droughts happen provided in this section is not sufficiently clear as it omits the definition of drought itself. In fact, by using the general term ‘drought’ in this context, it is not apparent if the Environment Agency is referring to hydrological drought or water resources drought. To add clarity and deliver a comprehensive description that conveys the complexity of the conditions under which drought occurs, Waterwise suggests the inclusion of a drought definition in this introductory section.

Question 2: Does this section provide you with a broad understanding of how drought affects people, business and the environment? If not, please tell us if there is additional information we should consider.

This section provides a great understanding of the severe impact of drought on people, business and the environment. Although, Waterwise recommends adding to the plan arrangements to deal with wider impact on power generators and the cascading failure that can arise from a energy shortage or blackouts.

Drought triggers and actions (Section 3 – Drought triggers and actions)

Section 3 sets out the management actions our drought teams will take to prepare for drought, during drought and after drought.

Question 3: Are our triggers and corresponding actions described clearly so that you know when and how we act, and that you know we have built in enough flexibility to manage any drought as it develops?

Triggers and actions in section 3 are, in our view, clearly described. As mentioned above (see answer 1), Waterwise recommends clarifying what the Environment Agency means when using the term.

drought in this context. With water supply drought lagging hydrological drought, it is important to explain whether this plan would apply to both hydrological and water resources or only to one of them.

Question 4: Please tell us if there are any other actions that we should consider as part of our management of drought in Head Office.

Waterwise welcomes the comprehensive set of triggers and actions set out in this drought plan. As mentioned above (see answer 2) we recommend adding a course of action to protect the power supply from the impact of drought.

Our drought plan refers to drought monitoring we carry out in addition to our routine monitoring networks.

Question 5: Do you think that the information on environmental monitoring across our drought plans shows that our drought surveillance is appropriate to the risk of drought? Please tell us if there is any additional information you think we should consider.

Waterwise welcomes and supports the monitoring measures set out by the Environment Agency in this section. We further recommend that this programme be clearly linked with water companies’ drought management plans. If these are taken separately and fail to align, there is a risk that the drought management on the ground could be negatively affected in terms of both monitoring and communications.

Question 6: Do you think it will help us to deal effectively with the impacts of drought? Please tell us if there is any additional information you think we should consider.

Waterwise believes that the monitoring plan set out in this section will help dealing effectively with the impact of drought, provided that the Environmental Agency and the water companies’ plans are synched up and complementary.

Drought permits and drought orders (Section 5 – Drought permits and drought orders)

Drought permits or drought orders are granted either by the Environment Agency or government ministers. They help to maintain public water supplies or protect the environment where there has been an exceptional shortage of rain. Section five sets out how our drought teams and National Permitting Service deal with drought permit applications and respond to ministers on drought order applications. It also explains the situations where we might apply for drought orders to protect the environment.

Question 7: Please tell us if this section sufficiently explains how we will deal with applications for drought permits and orders.

The section explains in a clear manner how the Environment Agency deals with the applications for drought permits and orders, although it does not describe how the Environment Agency balances the environmental concerns with the supply demands. Furthermore, Waterwise suggests that the Environment Agency should set out incentives for water companies to avoid applying for drought permits.

Communication during a drought (Section 6 – Drought reporting and communications)

Drought communications are an important part of drought management. This section sets how we will let others know what we are doing and how we work with others during a drought.