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Thames Water Utilities Limited – AMP8 Lead Strategy

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

Reference: TMS-2023-00013

Acceptance Notice:

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

  1. Is satisfied that Thames Water Utilities 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 20 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) Keep the company’s current lead strategy under continuous review, and update when required.
Date: Ongoing for the duration of the Undertaking.

4c. (2) Continuation of the company’s proactive lead pipe replacement programme, targeting 54,000 lead communication pipe replacements.
Date: 31 March 2030

4c. (3) Proactive replacement of lead pipework within the company’s ownership if lead is detected at or above 5 µg/l within either regulatory or operational samples taken at customers taps. This will include engaging with the property owner to encourage them to replace their external and internal pipework.
Date: Ongoing for the duration of the Undertaking.

4c. (4) Design and deliver a series of consumer trials to explore and assess incentives which aim to influence consumer behaviours, to encourage property owners to replace both their external and internal lead pipework.
Date: Ongoing for the duration of the Undertaking.

4c. (5) In tandem with measure (c)4 above, continue to improve the information available to consumers by working with external and internal stakeholders, development of the company’s website content and the development of a consumer-friendly self- assessment tool.
Date: Trial design: 31 December 2025.
Date: Trial delivery: 31 March 2030

4c. (6) Review and confirm the number of schools and high-risk buildings within the company’s area to design and implement an ongoing strategy to reduce the lead risk in schools/early years/higher risk customers (looking beyond traditional nursery settings).
Date: 31 December 2027.

4c. (7) Continue to review and optimise the effectiveness of ortho phosphoric acid dosing as an interim risk mitigation measure.
Date: Ongoing for the duration of the Undertaking.

4c. (8) 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(8).
    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 Thames Water Utilities 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: TMS-2023-00013

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