Our Reference: EIR/1178/2022

Dear Mr Wallis

Request for information

We refer to your request for information, received on the 21^st of June
2022 relating to the Barry Watchtower Bay as bathing beach and EDM data on
nearby CSOs.

We are dealing with your request as one made under the Environmental
Information Regulations 2004.

In accordance with the Regulations, we will respond to your request within
20 working days (calculated from the first working day after receipt).

We have assigned reference EIR/1178/2022 to your request. Please kindly
note this in all correspondence with us regarding this matter.

In the meantime, if you have any queries, you can contact us on email at
[1][email address] or to Environmental
Information Requests, Dŵr Cymru Welsh Water Linea, Fortran Road, St.
Mellons, Cardiff, Wales, CF3 0LT.

Yours faithfully,
Dŵr Cymru Welsh Water

_______________________________________________________ Dwr Cymru Welsh
Water is firmly committed to water conservation and promoting water
efficiency. Please log on to our website www.dwrcymru.com/waterefficiency
to find out how you can become water wise. Mae Dwr Cymru Welsh Water wedi
ymrwymo i warchod adnoddau dwr a hyrwyddo defnydd dwr effeithiol. Mae
cyngor i' ch helpu i ddefnyddio dwr yn ddoeth yn
www.dwrcymru.com/waterefficiency

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Our Reference: EIR/1178/2022

Dear Mr Wallis

Request for information

We write further to your request for information dated 21^st June 2022,
which we have been considering under
the Environmental Information Regulations 2004.

Please find attached the EDM data requested. It’s important to mention,
we’ve provided the start – stop times for individual discharges (columns F
and G in the tabs with data for each permit, respectively) and calculated
duration in hh:mm for each individual discharge (column H).
We do not record the volume of our Storm Overflow (CSO) discharges. 
Please see the comments in column L on Request From tab for data
availability and reliability.

The 12/24 spill block counting methodology which is used for regulatory
reporting and is the agreed reporting methodology we have with NRW and
EA.  The idea is to give us a meaningful spill number and prevents the
scenario where we have an asset continuously spilling all year but only
recording one spill.  The maximum number of spills is 366 in a year (or
367 in a leap year).

• EDM data is recorded at 15-minute intervals, with instantaneous readings
being taken at 00, 15, 30, and 45 minutes past the hour. 

o            This means that any short duration spill that occurs between
each reading will not be accounted for in EDM reporting.

o            For the purposes of reporting duration, each reading that
indicates a spill is counted as 15-minute duration.

• The first spill that is recorded opens a 12-hour window.  Regardless of
how long it spills for within that 12-hour window it will count for 1
spill.  So, it may be just one 15-minute reading, or it may be 12 hours
continuous spill – or it may start and stop spilling several times but
within that window it will count as 1 spill.    This is why it is
important to provide duration as well for context.

• Once the initial 12-hour window finishes, a subsequent 24-hour window
opens. 

o            If no spill occurs within the 24-hour window then the
counting sequence is reset and the next spill that occurs will open
another initial 12-hour window. 

o            If a spill does occur during the 24-hour window it will count
as 1 additional spill, and another 24-hour window will be opened once this
one has finished. 

• This is repeated until there is a 24-hour window that is free of spills
when the counting cycle will be reset again.

As mentioned previously, we have provided you with the individual start
stop times of each individual spill, therefore the number of total spills
and their duration might differ compared to our reported data.

With regards to your request for information on Harbour Road CSO, to
improve the performance, we have hired 6 pumps to improve the delivery of
flows from Barry West Pumping Station. The pumps have been hired and will
remain in place until new pumps have been delivered to site. The pumps
have been purchased however there is a 24-week delivery time. In addition
to the pumps, we have replaced the starter motors and completed
modifications to the 3 on site supplementary power generators to provide
more resilience to the asset during rainfall events.

The station has a robust telemetry system which informs our operational
teams if there are any performance issues; any alarms raised from Barry
West SPS are monitored 27 x 7 and attended out of hours. We ensure there
is regular maintenance and dynamic testing of the asset to ensure the
componentry is working effectively and replaced before failures occur.

Most assets that intermittently spill to the environment are monitored and
though the monitoring of this data Welsh Water prioritises the investment.
Investment surrounding environmental improvements are then discussed and
agreed with our environmental regulator (NRW in Wales and EA in England).

We hope that this response is clear. Should you have any questions, you
can contact us at [1][email address]. 

If you are dissatisfied with the handling of your request, you have the
right to ask for an internal review. Internal review requests should be
submitted within 40 working days of the date of receipt of this response
and should be addressed to Company Secretary, Dŵr Cymru Welsh Water Linea,
Fortran Road, St. Mellons, Cardiff, Wales, CF3 0LT.

If you are not content with the outcome of the internal review, you have
the right to apply directly to the Information Commissioner for a
decision.

Yours faithfully

Dŵr Cymru Welsh Water

_______________________________________________________ Dwr Cymru Welsh
Water is firmly committed to water conservation and promoting water
efficiency. Please log on to our website www.dwrcymru.com/waterefficiency
to find out how you can become water wise. Mae Dwr Cymru Welsh Water wedi
ymrwymo i warchod adnoddau dwr a hyrwyddo defnydd dwr effeithiol. Mae
cyngor i' ch helpu i ddefnyddio dwr yn ddoeth yn
www.dwrcymru.com/waterefficiency

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Our Reference: EIR/1178/2022

Dear Mr Wallis

Request for Information

We write following your email below.

We can confirm, the matter has been referred for an Internal Review and in
accordance with the Regulations, we will respond to your request within 40
working days, but we will endeavour to respond as soon as possible.

Yours faithfully
Dŵr Cymru Customer Services

══════════════════════════════════════════════════════════════════════════

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Our Reference: EIR/1178/2022

Dear Mr Wallis,

I refer to your request for an internal review of our response to your
request for information, dated the 6^th of August 2022. 

Dŵr Cymru is not subject to the Freedom of Information Act 2000.  I have
therefore been considering your request under the Environmental
Information Regulations 2004 (“the Regulations”), as referred to in our
previous correspondence to you. 

In conducting an internal review, I have considered our obligations under
the Environmental Information Regulations 2004 (“the Regulations”). I
would therefore like to explain our position based on the comments you’ve
raised below:

• There are one or more gaps in the EDM data for the Barry Harbour
discharge.  Since 28th Oct, there is only one (11 May) up to 13th July
2022.  This covers the period when the pumping system has been found
to be faulty and spewing large flows of sewage on several occasions.

Following a review, the data does not indicate spills between October 2021
and May 2022 and the data is considered to be reliable and a true
reflection of the storm discharge activity of the asset. This observed
reduction in discharge count from October 2021 is the result of the
improvements made at Barry West SSO. For reference, please see the
comments in the Request Form tab for Harbour Road Barry Town CSO.

• The 2020 EDM data for the Long Sea Outfall is not supplied, citing
doubts as to reliability.  It is not acceptable to withhold the full
year because some is suspect.  Please supply instead the full data
with any bad data indicated by some token.

We have reviewed the 2020 data that was originally withheld and can
confirm that the data was withheld as it was inaccurate and not
representative of the discharge activity of the site. As this is data that
we hold, we can provide it to you however it should be made clear that it
is not representative. The issue which was causing the erroneous data has
been remedied during August 2021, therefore data after this date is
accurate and representative.

• Please supply general information on Welsh Water's programme of
upgrading, renovation and monitoring, plus look at future capacity
investment, as mentioned at the meeting under Jane Hutt MS.  That
might be summarised in expenditure under these heads, and I'd expect
information on the review of the more frequently used CSOs and the
programme to remove or improve them.

The service we provide depends on a sustainable environment and our
ability to protect public health is enabled by how we treat and release
wastewater safely back into the environment. We have a duty of care to do
everything we can to protect it now and for future generations.

We take this responsibility very seriously and are investing £836 million
(including an additional £39 million) on improving our wastewater assets
during our current investment plan (2020–25). This overarching investment
plan is supported by a specific £250 million National Environment
Programme, developed in conjunction with our environmental regulators
(Natural Resources Wales and the Environment Agency) and based on the
following principles:

• Sound evidence.
• Value for money (i.e., affordable).
• Innovative approaches to unlocking better outcomes for the
environment, customers, and society more generally.
• Customer support. Our investment plans, performance targets and the
amount of revenue we can raise from customers are regulated and
approved by Ofwat.

With reference to Barry West SPS specifically we have committed £1m
funding to make improvements in 2023. Whilst these improvements are
currently in design, the upgrade includes upgrades and renewal of current
equipment.

More generally, in the decade to 2025, we will have invested approximately
£1.5 billion in improving and maintaining our wastewater network and this
has helped ensure that 44.5% of our rivers in Wales are in good ecological
status compared to 14% in England. We will also maintain our commitment to
Wales having the highest percentage of Blue Flag Beaches in the UK with
34% of the total awards achieved in Wales in 2021 despite having only 15%
of the UK’s coastline and 5% of the population.

But we know that we need to go further. This is why we are investing an
additional £20 million in improving our Combined Storm Overflows (CSOs)
(having already committed £83 million between 2020 and 2025) and an
additional investment to tackle nutrient pollution. Having led the
industry in installing telemetry on our assets and making that data openly
available on our website, we want to build on this progress to make best
use of the £836 million investment we are making in wastewater assets
between 2020 and 2025, which we have increased from £783 million
originally agreed with Ofwat at the last price review. Over 99% of our
Combined Storm Overflows are monitored and openly reported on our website
(the remaining 1% are currently inaccessible due to accessibility safety
constraints but we are still targeting 100% and are currently working on
solutions) to launch our interactive web-based overflow map covering our
operating area. In addition, we will be able to report all CSO discharges
within an hour of them operating by 2025 and further build on and expand
our bathing water CSO alert systems to community and representative
groups.

In order to help us achieve these goals we will be targeting evidence-led
investment to reduce the reliance on CSOs, and we have developed a CSO
Strategy which sets out our ambition for further reducing the reliance on
overflows from the sewer network. The first part of this strategy involves
investing over £100 million between now and 2025 to secure a progressive
reduction in any adverse impact caused by CSOs on our rivers and seas. We
will prioritise those which are having the most significant impact on
water quality. For the longer-term, we are working in partnership to
produce a CSO Roadmap for Wales (co-designed by Welsh Government, Natural
Resources Wales, Ofwat, Hafren Dyfrdwy and Welsh Water) and it is aimed at
ensuring that the role of CSOs in Wales is understood, improved, and fit
for the 21st century and the challenges we face.

We have also developed our first ever comprehensive Drainage and
Wastewater Management Plan (DWMP) that looks at how we can work in
partnership with stakeholders to reduce the risk of flooding and our
impact on the environment between now and 2050. Our DWMP was published for
consultation in June 2022, and it sets out strategically how the pressures
of climate change, growth and water quality improvements will impact on
our drainage systems which can be found on our website
here [1]https://www.dwrcymru.com/en/our-services....

The drainage and environmental modelling completed to date shows that we
must develop and implement new ways of approaching urban drainage, as
traditional approaches to improve CSOs will be unaffordable and also may
not be climate change proofed in their own right. Specifically, we need to
move to more integrated working with the Local Authorities and many other
parties who discharge surface (rainwater) water into the combined system
and in so doing are the primary cause of storm overflow operation. Their
assets as well as ours will need to be uprated and separated from the foul
system if we are to cost effectively reduce the operation of combined
storm overflows. Such new infrastructure will be both costly and
disruptive to install. Similarly, to reduce the polluting effects of our
storm overflows, it is very clear that further controls at source on the
entry of such pollutants as single use plastics, and wet wipes which
contain plastics, need to be implemented through new legislative controls.
Both the above changes will require the attention of Government and or
changes to the regulatory framework in which we work.

We very much look forward to continuing to work with Local Authorities,
Regulators and Government on outlining and then implementing the
regulatory changes needed to cost effectively deliver improvements to our
storm overflows.

I trust that this information and outcome will be acceptable to you.

If you are dissatisfied with the outcome of this internal review,
you can apply to the Information Commissioner, who will consider
whether Dŵr Cymru has complied with its obligations under the
Regulations. You can find out more about how to do this, and about
the Regulations in general, on the Information Commissioner’s
website at: [2]www.ico.org.uk. Complaints to the Information
Commissioner can be made via the “report a concern” section of
the Information Commissioner’s website.

Alternatively, the Information Commissioner can be contacted at:

Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire
SK9 5AF

Yours sincerely

Nicola Williams
Legal & Compliance Director
Dŵr Cymru Welsh Water

_______________________________________________________ Dwr Cymru Welsh
Water is firmly committed to water conservation and promoting water
efficiency. Please log on to our website www.dwrcymru.com/waterefficiency
to find out how you can become water wise. Mae Dwr Cymru Welsh Water wedi
ymrwymo i warchod adnoddau dwr a hyrwyddo defnydd dwr effeithiol. Mae
cyngor i' ch helpu i ddefnyddio dwr yn ddoeth yn
www.dwrcymru.com/waterefficiency

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