List of Reservoirs (with site information - energy usage/emissions)

Viren made this Environmental Information Regulations request to Cambridge Water Company plc
You only have a right in law to access information about the environment from this authority
This request has been closed to new correspondence. Contact us if you think it should be reopened.

Response to this request is long overdue. By law, under all circumstances, Cambridge Water Company plc should have responded by now (details). You can complain by requesting an internal review.

Dear Cambridge Water Company plc,

Please could I make a request for a list of all the water reservoirs that are under your ownership, with information on their primary purpose.

I would also request for additional information on each reservoir sites energy usage/emissions (e.g. if there was a water treatment works on pumping facility on site). This information can be provided in the form of estimated kWh/y and kg.CO2 respectively.

Yours faithfully,
Viren C. Patel

Daniel Clark,

I am out of the office without access to email, returning on 2 March.

If the matter is urgent please contact a member of the Water Strategy or
Catchment team.

 

 

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References

Visible links
1. https://www.south-staffs-water.co.uk/pri...

Daniel Clark,

Dear Viren,

I am writing to let you know that we are dealing with your request for information under EIR and expect to respond to this by the end of next week 13th march.

Kind regards
Daniel

Daniel Clark
Water Resources & Environment Manager
South Staffs Water - Cambridge Region
DDI (01223) 403126
Mob (07894) 091337

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Daniel Clark,

Dear Virin,

 

Environmental Information Regulations 2004 – Request for Information

 

1.    Background

 

I refer to your email request for information under the Environmental
Information Regulations 2004 (“the Regulations”), received by us on 25
February 2020 at 10.52 am which reads as follows:

            “Dear Cambridge Water Company plc,

           

            Please could I make a request for a list of all the water
reservoirs that are under your ownership, with information on their
primary purpose.

            I would also request for additional information on each
reservoir sites energy usage/emissions (e.g. if there was a water
treatment works on pumping facility on site). This information can be
provided in the form of estimated kWh/y and kg.CO2 respectively.”

 

We have interpreted your email as a request for this information for the
Cambridge region. The reason for this is that you have addressed your
request to Cambridge Water Plc. Please note that the business and assets
of Cambridge Water Plc were transferred to            South Staffordshire
Water Plc by way of statutory transfer under Schedule 2 of the Water
Industry Act 1991 on [  ] 2013. South Staffordshire Water Plc holds
information about water reservoirs and assets in the Cambridge region.

 

This letter provides the response to your request.

 

2.    South Staffordshire Water Plc’s response

 

            I can confirm that South Staffordshire Water Plc does hold
information of the type you have requested as follows:

 

            (a)        water reservoirs that are under our ownership, with
information on their primary purpose;

            (b)        energy usage/emissions (e.g. if there was a water
treatment works or pumping facility on site),

                                    (“Requested Information”).

 

3.    Consideration of exceptions

 

3.1.We consider that the following exceptions apply to the information you
have requested:

 

3.1.1.    Regulation 12(5)(a) international relations, defence, national
security or public safety

 

We are required under The Security & Emergency Measures (Water & Sewerage
Undertakers) Direction 1998 and associated DEFRA Guidance for the Control
of Sensitive Water Company Security Information, not to disclose any
locations or details of critical national infrastructure and sensitive
sites, which includes site specific information on our water assets such
as reservoirs, water treatment works, pumping stations or any other
facilities.

 

The publication of site specific location data of water assets into the
public domain could be mis-used by individuals, were they so minded, to
deliberately introduce bacterium or bio-toxins into the water supply; or
assets could be subject to vandalism or other forms of attack by
criminals. Therefore, providing the Required Information carries a real
and significant risk of misuse were it to be released into the public
domain, with the potential to compromise water supplies with harmful
consequences for the public and the potential impact could be
considerable.

 

3.1.2.    Regulation 12(5)(g) protection of the environment.

 

The release of bacterium or other toxins into the water supply would have
a detrimental impact on the environment by potentially affecting the water
system, sub-soil and land and other animals, birds and plants, with even
wider harmful environmental consequences. 

 

Any disclosure of the Required Information which, if exploited by
criminals, would facilitate such releases and impact would have an adverse
impact on the protection of the environment. We consider that the
disclosure of the Requested Information poses a risk to the environment
and the public.

 

3.2.Public Interest Test

 

The exceptions are subject to a “public interest” test, which means that
they only apply if the public interest in withholding the information
outweighs the public interest in disclosing the information.

 

In favour of disclosure we consider that the general public interest in
making environmental information available, the general interest in
disclosure to promote transparency and accountability and greater public
awareness and understanding of environmental         matters.

 

However, we have concluded that on balance the greater public interest
lies in the Requested Information being withheld on the basis of public
safety and as required by law., other than that we can confirm that energy
usage on our reservoirs is negligible.

 

We are therefore unable to provide you with the information that you have
asked for.

 

4.    Further queries

Should you have any questions, please contact me by [insert contact
details]. 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 six months of the date of receipt of this
response and should be addressed to [insert name and contact details].

 

If you are dissatisfied with the outcome of the internal review, you can
apply, without charge, to the Information Commissioner, who will consider
whether South Staffordshire Water Plc 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: www.ico.org.uk.

 

 

Kind Regards

Daniel

 

 

Daniel Clark

Water Resources & Environment Manager

South Staffs Water - Cambridge Region

DDI (01223) 403126

Mob (07894) 091337

 

show quoted sections

References

Visible links
1. https://www.south-staffs-water.co.uk/pri...

Daniel Clark,

Dear Viren

Environmental Information Regulations 2004 – Request for Information

1. Background

I refer to your email request for information under the Environmental Information Regulations 2004 (“the Regulations”), received by us on 25 February 2020 at 10.52 am which reads as follows:
“Dear Cambridge Water Company plc,

Please could I make a request for a list of all the water reservoirs that are under your ownership, with information on their primary purpose.
I would also request for additional information on each reservoir sites energy usage/emissions (e.g. if there was a water treatment works on pumping facility on site). This information can be provided in the form of estimated kWh/y and kg.CO2 respectively.”

We have interpreted your email as a request for this information for the Cambridge region. The reason for this is that you have addressed your request to Cambridge Water Plc. Please note that the business and assets of Cambridge Water Plc were transferred to South Staffordshire Water Plc by way of statutory transfer under Schedule 2 of the Water Industry Act 1991 on [ ] 2013. South Staffordshire Water Plc holds information about water reservoirs and assets in the Cambridge region.

This letter provides the response to your request.

2. South Staffordshire Water Plc’s response

I can confirm that South Staffordshire Water Plc does hold information of the type you have requested as follows:

(a) water reservoirs that are under our ownership, with information on their primary purpose;
(b) energy usage/emissions (e.g. if there was a water treatment works or pumping facility on site),
(“Requested Information”).

3. Consideration of exceptions

3.1. We consider that the following exceptions apply to the information you have requested:

3.1.1. Regulation 12(5)(a) international relations, defence, national security or public safety

We are required under The Security & Emergency Measures (Water & Sewerage Undertakers) Direction 1998 and associated DEFRA Guidance for the Control of Sensitive Water Company Security Information, not to disclose any locations or details of critical national infrastructure and sensitive sites, which includes site specific information on our water assets such as reservoirs, water treatment works, pumping stations or any other facilities.

The publication of site specific location data of water assets into the public domain could be mis-used by individuals, were they so minded, to deliberately introduce bacterium or bio-toxins into the water supply; or assets could be subject to vandalism or other forms of attack by criminals. Therefore, providing the Required Information carries a real and significant risk of misuse were it to be released into the public domain, with the potential to compromise water supplies with harmful consequences for the public and the potential impact could be considerable.

3.1.2. Regulation 12(5)(g) protection of the environment.

The release of bacterium or other toxins into the water supply would have a detrimental impact on the environment by potentially affecting the water system, sub-soil and land and other animals, birds and plants, with even wider harmful environmental consequences.

Any disclosure of the Required Information which, if exploited by criminals, would facilitate such releases and impact would have an adverse impact on the protection of the environment. We consider that the disclosure of the Requested Information poses a risk to the environment and the public.

3.2. Public Interest Test

The exceptions are subject to a “public interest” test, which means that they only apply if the public interest in withholding the information outweighs the public interest in disclosing the information.

In favour of disclosure we consider that the general public interest in making environmental information available, the general interest in disclosure to promote transparency and accountability and greater public awareness and understanding of environmental matters.

However, we have concluded that on balance the greater public interest lies in the Requested Information being withheld on the basis of public safety and as required by law., other than that we can confirm that energy usage on our reservoirs is negligible.

We are therefore unable to provide you with the information that you have asked for.

4. Further queries
Should you have any questions, please contact me by [insert contact details]. 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 six months of the date of receipt of this response and should be addressed to [insert name and contact details].
If you are dissatisfied with the outcome of the internal review, you can apply, without charge, to the Information Commissioner, who will consider whether South Staffordshire Water Plc 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: www.ico.org.uk.

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Dear Daniel Clark,

Many thanks for your reply.

I appreciate the concerns you have regarding the disclosure of the requested information.

However, I am surprised by your response as a list of reservoirs in the UK is already public information (gov.uk). I have also made the same request to a number of other water agencies, who provided the requested information and felt they were obliged to as they hold such information.

Please may I ask that you reconsider your position as the request is only for information that is already (partly) in the public domain.

Yours sincerely,

Viren