Are AMP cycles and discharge consents holding UK water back?

The UK water sector should be applauded for its bold commitment to achieve net zero carbon by 2030. But some of the industry’s regulations could be holding it back from delivering solutions that maximise long-term sustainability for both people and planet.

Site-based compliance, as opposed to catchment-wide permitting, offers limited incentive for water companies to embrace nature-based solutions, which could lower carbon emissions further. Meanwhile, the five-year AMP cycle can hinder much-needed strategic change. How to adjust these to improve the sector’s sustainability?

A difficult balancing act

These are challenging times for the UK water sector. Water companies commitment to reach net zero carbon emissions in 2030 will require major changes throughout the industry.

In wastewater treatment, operating in a way that not only meets discharge consents but also maximises energy efficiency – and minimises carbon emissions – is very complex. We’re only just beginning to get sufficient volumes of reliable process emissions data to support this decision making.

Currently, most wastewater treatment sites control to meet discharge consents. A few will also be looking to optimise energy usage, but virtually none will already be able to control on a least carbon basis which considers process emissions as part of the overall carbon assessment and control strategy.

This will take time. Gathering data is just the start – it then needs to be analysed and interpreted before any changes can be implemented.

In the medium term, carbon emissions from wastewater treatment will become an important KPI and I would expect that they may even be regulated in addition to then current final effluent permits

This raises a complex issue: rather than site-based discharge consents, should the UK adopt a catchment-based approach? It could help the industry to do the right thing overall for the environment – without compromising watercourse quality overall.

Enabling more natural solutions

UK water companies show a desire to invest more in nature-based solutions to help meet discharge consents, rather than relying primarily on chemicals.

But there’s a problem. For example, whilst chemicals aren’t environmentally sustainable, they provide predictable, year-round results. That makes them a safe bet when it comes to consent compliance.

The issue for the water companies is that, comparatively, natural solutions like wetlands, reed beds and so on carry a higher risk. At certain times of the year, when the plants aren’t growing and/or the natural processes may become less active this may influence the way the process responds to the applied loads.

This poses an important question: Does the current site-based consent system deliver enough benefits to compensate for the carbon we’re emitting to meet its requirements?

At a time when so much needs to be done in land use and carbon capture, why should water companies shoulder extra risk for trying to do the right thing? It certainly feels like the industry needs a system that protects water quality, while making it easier to invest in natural solutions.

A different approach to consent

Rather than focus on individual sites along a river, it might be better to adopt a more flexible, collaborative approach that looks at the watercourse and its surrounding environment as a whole.

That may mean varying consent levels at different times of the year, depending on what makes most sense for each location while still benefitting the wider area.

There’s already some work underway in this direction. The Catchment Based Approach is a civil society-led initiative that unites government, local authorities, water companies and other businesses to deliver environmental, social and economic benefits across river catchments.

Currently, there are more than 100 ‘catchment partnerships’ across England. Wessex Water, for example, is involved in several projects across the region. These include restoring peat habitats to sequester carbon and store rainwater, and encouraging farmers to reduce the use of nitrates via more nutrient-efficient practices.

Time to revamp AMP?

Of course, funding plays a major part in the water sector’s drive to reach net zero carbon by 2030. And I believe there’s work to do here, too.

The current five-year AMP cycle has its benefits: it provides certainty around funding levels for fixed periods; it’s well suited for implementing incremental changes; and it’s certainly efficient at meeting current requirements and regulations.

But could it also be holding the water sector back in some areas?

When we talk to some industry representatives, we often hear that for fundamental, large-scale changes the AMP setup can be a hindrance. Major infrastructural changes – of the sort that will be required to go beyond net zero, or tackle future challenges like micropollutants – take more than five years.

Again, Ofwat might benefit from a more flexible approach. For example, it might consider taking certain projects out of the five-year AMP cycle and running them on a longer timeframe.

Evolution for regulations

Policymakers have done a fine job in creating an effective regulatory system to efficiently deliver clean water across the UK. However, as the focus shifts more and more towards sustainability, the industry could soon need bigger changes than the current frameworks will allow.

As a start, greater flexibility might enable water companies to adopt more nature-based solutions. And a longer-term approach to financing could help deliver more ambitious change that will help the sector achieve its sustainability goals for 2030 and beyond.

I’m always interested in hearing views on which technological and business-oriented solutions can bring UK water closer to its net zero carbon future. If you have comments or suggestions, please don’t hesitate to get in touch.