South Staffordshire Water Plc – AMP8 Lead Strategy

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

Reference: SST-2023-00007

Acceptance Notice:

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

1. Is satisfied that South Staffordshire Water Plc. “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 29 April 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 Conduct a pilot trial to inform long-term strategy by replacing approximately 1,200 total service pipes within a single DMA, mains to tap. This will be followed by the production of an open data report outlining findings from the trial and in support of our plan for the long-term strategy to achieve lead free drinking water supplies.
Date: 30 June 2028.

4c. 2 Full-service pipe replacement (mains to tap), including both communication and supply pipes, at 373 schools and nurseries.
Date: 31 March 2030.

4c. 3 Replacement of communication pipes associated with elevated sample results at the customers tap where lead is detected above 5μg/l.
Date: Ongoing for the duration of the Undertaking.

4c. 4 Communication pipe replacement during mains rehabilitation work, where lead communication pipes are found.
Date: Ongoing for the duration of the Undertaking.

4c. 5 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:

a) All data from the monitoring of treated water in the distribution systems named in the annex.

b) Details of the remedial steps that comprise the programme of work including commencement and completion dates for investigations, design, tendering, construction, and commissioning.

c) Current state of progress with the steps referred to in (b) above;

d) A statement of implications of any slippage of the programme and details of activities planned to bring programme back on target.

e) 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.

f) Submit the company’s draft AMP9 lead reduction plans, as required in measure 4c(5).
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 the Inspectorate on the efficacy of the steps taken as part of this undertaking. Include, as evidence of closure for this scheme, appropriate documentation to confirm that the actions set out in this Schedule of Work have been completed satisfactorily.
Date: 30 April 2031.

Further Details of this Acceptance Notice:

4. The Secretary of State is satisfied that South Staffordshire Water Plc. 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
29 April 2024.
Reference: SST-2023-00007.