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Notice of Regulation: United Utilities Water Ltd – Discolouration

Completion Date: 30/04/2031
Ref: UUT-2020-00005

NOTICE UNDER REGULATION 28(4) OF THE WATER SUPPLY (WATER QUALITY) REGULATIONS 2016 (AS AMENDED)

United Utilities Water Limited: Consumer Acceptability – Discolouration

Reference: UUT-2020-00005

Water undertaker as appointed under the section 6 of the Water Industry Act 1991 (as amended): United Utilities Water Limited, with registered number 02366678 (hereinafter called ‘the Company’).

Assets affected:

Water quality zones listed in Annex A

  1. The Drinking Water Inspectorate (‘the Inspectorate’) has received a set of regulation 28(1) reports of the Water Supply (Water Quality) Regulations 2016 (as amended) (‘the Regulations’) from the Company on 21 October 2020, which state that there is or has been a significant risk of supplying water from the zones listed in annex A (and associated assets as applicable) that could be unwholesome.
  2. Consequently, this Notice is served on the Company by the Inspectorate on behalf of the Secretary of State, under regulation 28(4) for the assets listed above, for risks associated with:

Hazard/Hazardous Event/Parameter

Description of Risks

Iron (Total)

Consumer acceptability including discolouration

Manganese (Total)

Consumer acceptability including discolouration

Aluminium (Total)

Consumer acceptability including discolouration

Turbidity

Consumer acceptability including discolouration

  1. The Company are required to satisfy the following:

Requirements

(a) to maintain the following measures for the period specified in each case:

Date: Ongoing for the duration of the notice.

  1. Undertake regulatory and enhanced monitoring as defined within section (c)1 from treatment works, reservoirs and the water supply zones identified within Annex A as being at risk of discolouration.
  2. Investigate any failure of the parameters listed in Section 2.
  3. Record and monitor customer contacts in appropriate detail and trend data to inform the forward programme of work.
  4. Deliver a programme of proactive and reactive flushing work on the distribution network, based on consumer contacts, to manage discolouration risks whilst the programme of work in 3(b) is being delivered
  5. Optimisation of existing treatment processes with particular regard to the removal of Aluminium, Manganese, Iron, turbidity and other parameters relevant to discolouration.

(b) to review, revise or make operational the following measures, by the dates specified in each case:

  1. Develop a discolouration root cause analysis methodology to understand the reasons for discolouration utilising all sources of data, with input from relevant stakeholders.
    Date: 30 April 2021
  2. Review discolouration data from all sources and prioritise zones for root cause analysis
    Date: Annually for the duration of the notice.
  3. Undertake a root cause analysis to understand discolouration within the Company’s zones using all available sources of data.
    Date: Annually for the duration of the notice.
  4. Complete an independent verification of root cause analysis methodology and outputs.
    Date: 30 June 2021
  5. Benchmark the Company’s discolouration strategy against other water companies and current industry good practice.
    Date: 30 April 2021
  6. Using the outputs from the root cause analysis, develop bespoke solutions specific for each zone, to reduce the risks of discolouration to consumers.
    Date: Annually for the duration of the notice.
  7. Implement bespoke solutions as identified in 3(b)6, prioritising zones to an agreed programme with highest risks for discolouration, consumer contacts and consumer acceptability to achieve the following;
    Date: Ongoing for the duration of the notice.
    • Phase 1 – By 2025 a reduction in consumer contacts for discolouration to below the target of 1.15 per 1000 population per zone and to reach an overall company contact rate of 66% of the defined company Outcome Delivery Incentives (ODI) for Taste, Smell and Appearance (0.81 contacts for BBO per 1000 population)
      Date: 31 March 2025
    • Phase 2 – Agree with the Inspectorate a percentage target for year on year reductions in the BBO contact rate per 1000 population for the AMP8 period (2025-2029). This target to be defined using consumer contact data from all companies to establish a current industry average. The target is to be set to bring the company into line with the rest of the drinking water industry by the end of AMP8 and based on current industry performance is most likely to require a 10% year on year reduction in BBO contacts for each year of AMP 8.
      Date: 31 December 2023

(c) to audit whether the measures have been effective by the following means:

  1. Define an audit strategy to monitor the effectiveness of the measures specified in sections 3(a) and 3(b), to include:
    Date: 28 February 2021
    • a. Enhanced sampling programme for iron and manganese, aluminium, turbidity within the supply network
    • b. In-depth review of all consumer contacts related to water quality and discolouration
    • c. Annual review of performance against the Black/Brown/Orange (BBO) component of the OFWAT ODI for Taste, Smell and Appearance
  2. Implement, and keep under continuous review, the audit strategy defined in measure (c)1.
    Date: Following completion of measure (c)1 and for the duration of the notice.

(d) not to supply water for regulation 4(1) purposes from the zones listed in annex A, or not to so supply unless the specified conditions below are satisfied:

Not applicable

(e) to provide the following information in the time and manner specified below to enable monitoring of progress towards the mitigation of the risks:

  1. Provide a progress report annually by 31 January and against the following milestones:
    Date: Annually by 31 January
    • a) Provide the audit strategy as defined in measure 3(c)1.
      Date: By 31 March 2021
    • b) Provide a report detailing the root cause methodology as developed in measure 3(b)1.
      Date: By 31 May 2021
    • c) Provide a report detailing the outcome of the benchmarking of the Company’s discolouration strategy, as completed in measure 3(b)5 and the independent verification of the root cause analysis as completed in measure 3(b)4.
      Date: By 31 July 2021
    • d) Submit an annual report covering: Annually by 30 April
      1. Review of root cause analysis for priority zones with independent verification on both analysis undertaken and actions proposed as detailed in section 3(b)
      2. Update on the prioritised programme of WSZs
      3. Which zones will be added to this legal instrument, based upon consumer contact rates for discolouration being >1.15 per 1000 population for phase 1 and the target for phase 2 and submit an updated Annex A with associated evidence to the Inspectorate for approval.
    • e) Provide a report with evidence to confirm the company has met the phase 1 target as defined within section 3(b)6
      Date: 30 April 2025
    • f) Provide a report with evidence to confirm the company has met the phase 2 target as defined within section 3(b)6.
      Date: 30 April 2030
    • g) Provide a report with evidence detailing which zones have had successful work undertaken to meet the phase 1 and phase 2 targets. Any zones which have met this requirement and have had an updated Regulation 28(1) risk assessment may be removed from Annex A. This report should include information on the measures undertaken to manage and reduce the risks of discolouration along with an independent assessment of actions and results.
      Date: From time to time and as required incorporating 12 months’ data following completion of remedial work
  2. Submit a report with evidence in the event that any completed measure of this Notice needs to be altered in any way, for any reason
    Date: As required for the duration of the notice.
  3. Review the risk assessments for the zones listed within Annex A as required by Regulation 27(4) and subsequently submit a revised regulation 28 report accompanied by a signed board level declaration.
    Date: From time to time, as required, by 21 April 2025 and by 21 April 2030.
  4. Submit an interim completion report with evidence detailing the consumer contact rates and the bespoke improvement works undertaken in each zone and demonstrating achievement of the phase 1 target.
    Date: 30 April 2026
  5. Submit a final completion report with evidence detailing the consumer contact rates and the bespoke improvement works undertaken in each zone and demonstrating achievement of the phase 2 target.
    Date: 30 April 2031
  1. Any product or substance used as a result of the requirements in this Notice must comply with regulation 31.
  2. Under regulation 28(6) the Inspectorate, on behalf of the Secretary of State, may by notice served on the Company, revoke or vary this Notice.
  3. Failure by the Company to comply with this Notice may result in enforcement proceedings under section 18 of the Water Industry Act 1991(as amended).

Signed
Milo Purcell
Deputy Chief Inspector, on behalf of the Secretary of State for Environment, Food and Rural Affairs
20 January 2021
Reference: UUT-2020-00005
Version Number: 1

ANNEX A

Zone reference and name

Carried over from AMP 6

Current (2019) consumer contact rate for discolouration per 1000 population

Z330 – Alston

Yes 

9.99

Z163 – Congleton Mow Cop

Yes

4.52

Z102 – Mitchells 

Yes

4.36

Z243 – Westwood South 

Yes

3.95

Z017 – Bowscar 

Yes

3.82

Z238 – Haweswater Hatters

Yes

3.27

Z320 – Newton Le Willows

3.26

Z004 – Quarry Hill

Yes

3.11

Z227 – Haweswater Shuttleworth

Yes

3.09

Z219 – Haslingden Grane

2.92

Z313 – Blackley

Yes

2.69

Z203 – Ormskirk 

2.68

Z260 – Whaley Bridge

Yes

2.67

Z125 – Haydock

2.67

Z084 – Dunsop

Yes

2.65

Z187 – Childwall

2.60

Z270 – Stockport

Yes

2.60

Z008 – Tarnwood

Yes

2.50

Z304 – Adlington

Yes

2.44

Z220 – Nangreaves

2.42

Z235 – Rochdale

Yes

2.38

Z115 – Wigan South

Yes

2.36

Z178 – Liverpool City Centre

Yes

2.34

Z229 – Clarkes Hill

Yes

2.33

Z216 – Little Lever

Yes

2.31

Z179 – Aubrey

2.30

Z141 – Heswall

Yes

2.30

Z233 – Bamford East

Yes

2.19

Z318 – Parbold 

2.14

Z188 – Huyton East

2.14

Z221 – Loveclough 

2.13

Z214 – Halliwells

2.11

Z161 – Winsford

2.08

Z215 – Turton

Yes

2.06

Z121 – Ashton

Yes

2.05

Z267 – Cheadle Hulme

Yes

2.02

Z123 – St Helens South

1.89

Z189 – Liverpool Ctm 40 Inch

1.88

Z281 – Moston

1.88

Z283 – Prestwich

Yes

1.87

Z103 – Burnley Road

1.82

Z132 – Warrington South

1.82

Z097 – Lowcocks

Yes

1.77

Z213 – Egerton/Heaton

1.74

Z264 – Greavefold

Yes

1.72

Z211 – Top O’Th’Cow

1.71

Z217 – Bolton Centre

1.71

Z212 – Westhoughton

1.70

Z109 – Burnley Mixed 

1.70

Z134 – Gorsehill 

1.69

Z236 – Watergrove

1.68

Z120 – Lightshaw

Yes

1.68

Z239 – Chadderton

Yes

1.64

Z164 – Kelsall

Yes

1.63

Z228 – Bury Town Centre

1.62

Z100 – Gt Harwood/Rishton

1.60

Z038 – Paddy End

1.50

Z001 – Castle Carrock

1.47

Z268 – Hazel Grove

1.45

Z095 – Blackburn North

1.45

Z044 – Barrow Town Mixed

1.44

Z003 – Carlisle South

1.44

Z234 – Bamford West

1.42

Z184 – Toxteth

1.42

Z157 – Northwich West

1.41

Z222 – Clough Bottom

1.37

Z261 – Crossacres

Yes

1.37

Z094 – Blackburn West 1.37

Yes

Yes

Z114 – Wigan North East

Yes

1.34

Z068 – Warbreck Tower

1.34

Z138 – Crosshill 2b

1.32

Z101 – Accrington West

1.32

Z154 – Alsager

1.31

Z133 – Appleton

1.31

Z046 – Highfield

1.28

Z087 – Sunnyhurst/Hoddlesden

1.28

Z166 – Audlem

1.27

Z218 – Walkden

1.23

Z292 – Stretford

1.21

Z190 – Liverpool Ctm 44 Inch

1.20

Z302 – Sale

1.20