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Southern Water Services Limited – AMP8 Lead Strategy

Water Industry Act 1991 (as amended) (“the Act”): Section 19(1)(b)

Reference: SRN-2023-00012

Acceptance Notice:

The Drinking Water Inspectorate, on behalf of the Secretary of State for Environment, Food and Rural Affairs:

  1. Is satisfied that Southern Water Services Limited “the Company” in supplying water from multiple assets which may be at risk of exceeding the standards for lead. This means that the Company is likely to contravene its duty in respect of supplying water which meets the Regulations under Section 68(1)(a) of the Water Industry Act 1991 and meets the requirement set in regulation 4(2)(c) of the Water Supply (Water Quality) Regulations 2016 (as amended) (“the Regulations”).
  2. Has notified the Company on 20 October 2023 that the Secretary of State is considering making in relation to the company an enforcement order under Section 18 of the Act.
  3. Notes that the Company has on 22 May 2024 given a new undertaking under Section 19 (1) (b) of the Act, to take the following steps by the dates shown.

Steps to be taken:

4a. Ensure that the Lead parameter has been assessed as a hazard as part of the regulation 27 Risk Assessment for the supply system that includes the water supply zones listed in the Annex to this Schedule according to a Drinking Water Safety Plan approach. Ensure that regulation 28 documents are reviewed, and updates provided as necessary.
Date: Ongoing for the duration of the Undertaking.

4b. Keep under review the company’s strategy for the protection of public health and for compliance with drinking water quality standards with respect to lead.
Date: Ongoing for the duration of the Undertaking.

4c.(1) Replace all communication pipes and supply pipes (offer first 10m free of charge), where a failure of the lead parameter is identified and the property owner agrees.
Date: Ongoing for the duration of the Undertaking.

4c. (2) Offer to replace up to 10 metres of consumers pipe when communications pipes are replaced.
Date: Ongoing for the duration of the Undertaking.

4c. (3) 200 proactive communications pipe replacements to public buildings in high lead-risk areas, identified through the company’s lead tool, which serve young children (nurseries and primary schools). Replace communication pipes and external supply pipes, then work with the building owners to replace internal supply pipes, other lead pipework and fittings within the buildings.
Date: 31 March 2030.

4c. (4) 600 proactive communications pipes as encountered through leakage and WRMP mains replacement programmes.
Date: 31 March 2030.

4c. (5) Offer an additional 1,200 lead communication pipe replacements.
Date: 31 March 2030.

4c. (6) Operate a customer pipe replacement grant scheme.
Date: Ongoing for the duration of the Undertaking.

4c. (7) Develop the company’s draft Lead reduction plans for AMP9, demonstrating the required ramp-up pipe replacement rate.
Date: 31 July 2027.

Reporting:

4d. At regular intervals provide DWI with reports on progress made with carrying out the steps set out in the Action Plan.
Reports to include at least the following details:

  1. All data from the monitoring of treated water in the distribution systems named in the annex.
  2. Details of the remedial steps that comprise the programme of work including commencement and completion dates for investigations, design, tendering, construction, and commissioning.
  3. Current state of progress with the steps referred to in (b) above.
  4. A statement of implications of any slippage of the programme and details of activities planned to bring programme back on target.
  5. Whether the company has any other reason to believe it may not be able to meet any of the key dates set out in this Schedule of Work.
    Date: Annually for the duration of the Undertaking. Reporting periods are Jan – Dec. Reports to be submitted by 31 January each year that the Undertaking is in place.
  6. Submit the company’s draft AMP9 lead reduction plans, as required in measure 4c(7).
    Date: 31 August 2027.

4e. Continue to monitor at an enhanced frequency for Lead for a period of 12 months following commissioning of any work associated with the Action Plan to demonstrate the effectiveness of the remedial measures taken.
Date: 31 March 2031.

4f. Provide a final report to DWI on the efficacy of the remedial measures taken as part of the lead strategy. Include as evidence for closure for this scheme appropriate documentation to confirm that the actions set out in this Schedule of Work have been taken and that the company’s lead strategy is in place.
Date: 30 April 2031.

Further Details of this Acceptance Notice:

  1. The Secretary of State is satisfied that Southern Water Services Limited has given and is complying with an undertaking to take all such steps as appear to the Secretary of State for the time being to be appropriate to secure or facilitate compliance with the requirement of regulation 4(2)(c) of the Water Supply (Water Quality) Regulations 2016 (as amended).

Authorised by the Secretary of State to sign in that behalf.

Nicholas Adjei
Deputy Chief Inspector, Drinking Water Inspectorate
23 May 2024.
Reference: SRN-2023-00012

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