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Sustainable Management of Natural Resources

“Using natural resources in a way and at a rate that maintains and enhances the resilience of ecosystems and the benefits they provide”.

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SMNR is defined in the Environment Act as: “using natural resources in a way and at a rate that maintains and enhances the resilience of ecosystems and the benefits they provide”. Through this we can contribute to the achievement of the wellbeing goals in the Wellbeing of Future Generations Act.

NRW will apply specific principles that contribute to the wellbeing goals (left).

Solutions that SMNR promotes

SMNR will influence multiple areas of our sector, such as ‘working at the catchment scale’ and ‘harnessing nature-based solutions where appropriate as they can offer wider benefits to the environment as opposed to conventional, hard engineered solutions’. Considering the wastewater NEP, practical solutions which could be considered include:

  • Nutrient offsetting - where a nutrient removal load obligation is either partly or fully delivered by another separate activity or sector. NRW has prepared draft guidance on this.

  • Integrated Constructed Wetlands (ICW) - effluent treatment solution, considered as nutrient offsetting, which typically has a large open-water surface area to encourage the realisation of wider benefits.

  • Catchment permitting - consideration and balancing of all permit changes in a catchment to determine and manage a collective nutrient reduction target for maximum benefit.

DCWW is already considering these principles and for other drivers (e.g. Brecon Super Catchment & Dee P Removal strategy). In England, the EA has formalised guidance and these solutions are being implemented (below examples of Mott MacDonald projects, client information withheld).

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The challenges

There are challenges in embedding these solutions into the delivery of wastewater quality improvements in AMP7, but with consideration and collaboration with the regulator and based on lessons learnt in England these can be addressed.

  • Schemes need to prove equivalent or better improvement. Solid evidence must prove measures could work and reduce risk of non-compliance.

  • Requirements for compliance need to consider the time lag to implement solutions and observe the improvement in the waterbody.

  • Standardised approach to measuring benefits needed, agreed with regulator, focusing on whole environmental outcomes, aligned with SMNR.

  • Uncertainty of CAPEX vs. OPEX vs. TOTEX; these solutions are typically lower CAPEX than traditional treatment solutions and have different operational cost demands.

  • Agreement on point of compliance and enforcement of solutions. This may need to consider shared regulatory risk.

  • Given the relative immaturity of implementing SMNR, consideration of policy alignment, especially if there is future tightening of standards.

  • Higher risk schemes with environmental drivers such as Habitats Directive, SSSI and No Deterioration would need further consideration and appraisal for a SMNR approach.

  • Schemes must be proportionate and consider fair share.

  • Implementation of solutions likely to involve different supply chain partners than are currently used. These could be smaller SMEs and NGOs with different contractual demands.


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The opportunities

There are significant opportunities for embedding SMNR principles into the delivery of, and solutions considered in, AMP7, and formalising methods that will develop environmental resilience in AMP8.

  • Targeting point sources only is becoming more expensive; investment schemes have diminishing environmental cost benefit. There is opportunity to maximise whole-life cost benefit associated with scheme delivery.

  • Across Wales & England, the AMP7 National Environment Programme totals £4.8bn investment. With Ofwat’s steer to encourage ‘companies to use efficiently delivered nature-based solutions, which provide wider environmental benefits, instead of capital solutions’, and additional drivers for water resources and water quality, there is opportunity for connecting implementation and wider cost savings and benefits.

  • Given the scale of the AMP7 programme there could be questions about long-term affordability; it is therefore prudent to consider a wide range of options to derive the most cost beneficial approach.

  • These solutions widen the supply chain, reducing risks associated with utilising limited number of ‘standard’ suppliers.

  • The delivery of multiple benefits that can be achieved through these alternative solutions include: reduction in embodied and operational carbon (and increases in sequestered carbon). These schemes can engage customers and empower community action and involvement, unlock additional funding from other sectors, reduce flood risk and sedimentation issues, align with circular economy principles, and provide landscape-wide biodiversity value.

  • Catchment and nature-based schemes offer opportunities for engagement with research institutes to further refine understanding around effectiveness of measures and the links to wider benefits e.g. benefits wetland has for bacteria (as a solution for UV treatment), and the benefits on plastic pollution.

  • Aligned with SMNR principles, catchment thinking considers the potential for Catchment System Operators, as proposed in England and by Ofwat, and as indicated by the 7 NRW Area Statements.

  • A Drainage and Wastewater Management Plan will be delivered in 2022, an example of where SMNR approaches can be aligned across multiple planning requirements.

  • The number of environmental commitments in AMP7, and considering SMNR early in AMP7, presents opportunity to review schemes at high level and formalise guidance for assessing projects against SMNR to ensure consistency.

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