Dear Russell Scott

Request for information

We refer to your request for information which was received on 22 July
2023.

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

In accordance with the Regulations, we will respond to your request within
20 working days of the date of receipt.

For completeness, we advise that the Information Commissioner’s Office
states that the time for responding should be calculated from the day
after the request is received.

In the meantime, if you have any queries, please contact us on email
[1][email address]

We have assigned reference EIR/1557/2023 to your request. Please kindly
note this in all correspondence with us regarding this matter.

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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Date: 16 August 2023

Our Reference: EIR/1557/2023

Dear Russell Scott

Request for information

We write further to your request for information dated 22 July 2023 which
we have been considering under
the Environmental Information Regulations 2004.

Please find attached our completed storm overflow action plan template for
Welsh Water assets located within England that was shared in June 2023.
However, the improvements required for storm overflow are to be defined by
Welsh Government through their 3-tier Strategic Steer. The Environment
Agency have confirmed that Defra’s storm overflow improvement policy does
not apply to DCWW sites in England. We have provided some commentary below
to confirm where we are unable to complete the information under the
column headings that are specific to English water companies, or where we
need to provide different information.

1. Under Column Y, where our investigations into the cause of high numbers
of discharges are ongoing and we are, as yet, unable to determine the root
cause with reasonable certainty and we have left the column blank.

There are 4 of these which have a cause identified, 3 of which are still
undergoing solution development, so we are unable to complete the
associated columns AD to AR at this time.

2. Under Column Z, we have answered ‘Y’ where an investigation has been
completed and ‘ongoing’ where our investigation is expected to complete by
the end of December 2025. There are 66 investigations in total, as above 4
have completed and 62 are in progress. 42 of these investigations are over
and above what we were expected to deliver in our AMP7 plan. However, we
have accelerated AMP8 investigations with additional funding, made
possible by our not-for-profit status and we will have impact and full
solutions for these sites by the end of 2025.

For a number of assets, we have selected ‘N’ and this encompasses all the
sites without an existing investigation funded either as part of our
original AMP7 obligations or through the additional funding made available
to accelerate our AMP8 investigations.

All sites that discharge in excess of 10 spills or the sites that
discharge less than 10 spills per year and have a dilution less than 8:1
will be included as part of our AMP8 impact investigation programme and
will form part of the AMP8 WINEP/NEP.

We have a number of unpermitted assets (8 No.) within the English
operating area. One of these assets is being investigated under our SOAF
programme.  The remainder, although we have selected ‘N’ for them, come
under a separate investigation to be classified according to EA guidance
and will be progressing towards impact assessment over the coming year.

3. Column AS: We have named 2 sites under the ‘25YEP_IMP’ driver that has
been agreed with the PR24 lead in the EA. Within our WINEP, there is also
a placeholder line for a further seven sites to be added to the WINEP once
the impact assessments have been completed if they are causing ‘Severe’
impact.

4. Column AT: We have populated this column with those sites that will be
listed on our WINEP for AMP8 under an investigation (or INV1) driver as
this is the applicable driver under the equivalent Welsh storm overflow
policy.

Sites that spill less than 10 times per year on a long-term average are
not currently named in our AMP8 WINEP/NEP.  However, they will be screened
for to check the level of dilution in the receiving water body. If they do
not meet a minimum dilution of 8:1 they will be included for investigation
in the AMP8 WINEP and NEP.

5. Columns AT to BA: We are unable to complete these columns are they are
related to the EA Storm Overflow drivers which are not applicable to DCWW
assets.

We hope that this response is clear. Should you have any questions, please
contact us on email [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, Dwr 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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