Comment

Representation ID: 23165

Received: 11/10/2021

Respondent: Environment Agency

Adapting to climate change isn’t just about energy efficiency; it is also about water demand management. Climate change could result in an increase in water scarcity which is why measures to reduce demand and encourage the efficient use of water are so important. In addition, there is energy embedded in water purification, delivery and subsequent treatment of wastewater. This is acknowledged in 10.156 c), but the policy body itself only mentions water efficiency in relation to conversions (g), and greywater and rainwater collection as a means of reducing run-off (e). Although collection and re- use of greywater and rainwater does reduce the demand on potable water supplies, this hasn’t been stated explicitly.
Pressures on water supply to new and existing homes as well what is available to the environment could also have detrimental impacts on water quality due to dilution etc in the associated waterbodies (rivers and groundwater in the underlying aquifers) both in the Black Country and wider area. We recommend CC1 include reference to the need to ensure both water resources and quality are considered in this policy to ensure water efficiency and protection and enhancement of the water environment is a priority. We
note the WCS includes a recommendation for further assessment as part of the phase 2
WCS that water quality modelling in should include
sensitivity testing to a reduction in river flow. The outcomes of this should feed into this policy.

In light of the above we recommend the policy is reworded as follows:

1(i) new developments should reduce their water usage as far as possible through sustainable water demand management (in line with the requirements of ENV9)