Bridging Liquid Waste Strategy 2023-2026 Review (S.R.1/2024): Response of the Minister for Infrastructure

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Comments

1

The sewerage network (made up of 109 sewage  pumping  stations  and  rising mains)  is  at  "a  critical  point"  and  a number of critical assets are now over 60 years old. It is acknowledged that pumping stations were designed when the Island's population was a fraction of the current figure, and the network has reached  the  point  where  there  is  no spare capacity in the system.

Agreed

2

To address challenges in the short-term, a  number  of  solutions  or  emerging projects'  have  been  identified  in  the Bridging Liquid Waste Strategy 2023- 2026  which  consist  of  network upgrades;  rising  mains  replacements; surface water separation and increasing storage capacity.

Agreed

3

Prioritisation of liquid waste emerging projects is based on a number of factors which  are  often  interrelated.  Key factors affecting prioritisation are age and  condition  of  an  existing  asset;

Agreed but it should be noted that there has been particular pressure arising from the provision of affordable homes as set out in the Bridging Island Plan  2022-2025.  This  has  acted  to  skew  the

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recurring  failures  or  lack  of performance; risk to public; provision for  climate  change;  provision  for growth; and other strategic drivers such as  the  Island  Plan  and  Government Plan.

prioritisation  since  the  Bridging  Liquid  Waste Strategy 2023-2026 was published.

4

The  Bridging  Liquid  Waste  Strategy 2023-2026 represents a "coherent plan to address the issues through specific asset-based  network  interventions." However, it represents more of an asset management plan, as opposed to a full strategy.  Exact  needs  are  not established  due  to  considerable uncertainty  of  where  or  when  the growth  is  likely  to  occur  and  the absence  of  information  on  service failures.  Additionally,  the  lack  of potential alternative approaches makes it difficult to assess whether the plan represents  the  best  approach  versus alternatives.

As is noted in the Bridging Liquid Waste Strategy 2023-2026, it is not a full long- term strategy. It addresses the period of 2023-26 and particularly the schemes that are required urgently while also identifying the longer term issues that I&E will need to begin to lay the groundwork for within that same period while the 2025-35 Liquid Waste Strategy is prepared (See KF14/17 and REC3).

We accept that KF4 acknowledges the lack of certainty in where development and growth will occur, however, waiting for real' developments to come forward will mean they are still delayed due to lack of capacity. If nothing else, the core of the Bridging Liquid Waste Strategy is to be less reactive and return the system as a whole to a level of robustness that is suitable for the future.

We  would  disagree  with  the  statement  that alternative approaches have not been considered. While  they  may  not  have  been  repeatedly reviewed in the context of each Emerging Project, the principals of how the preferred concepts have been arrived at are explained.

It should also be noted that every major project will be the subject of a full Feasibility Study. The

Bridging Liquid Waste Strategy is not the be all and end all' of the design selection process, this is discussed  further  against  several  other  Key Findings and Recommendations.

Similarly, the Bridging Liquid Waste Strategy is not intended to be the Business Case upon which funding is approved (See REC 23 response).

5

Despite  a  number  of  sites  being approved for re-zoning for affordable housing  in  the  Bridging  Island  Plan 2022-  2025  States'  debate  in  2022, sewerage  and  drainage  network

Agreed and this has informed I&E's prioritisation of schemes in the Bridging Liquid Waste Strategy and these have been continually refined during 2023.

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capacity issues have resulted in delays to  delivering  the  affordable  housing delivery  targets  specified  in  the Bridging Island Plan 2022-2025.

Not progressing quickly with some schemes will only extend the delay to delivery of affordable homes.

6

It is asserted that 1 in 4 existing homes in   Trinity  are  not  connected  to  the mains sewerage network and there is perception  that  there  is  a  focus  on accommodating  and  prioritising sewerage and drainage capacity for new development  but  not  for  existing homes.   Trinity  is  not  identified  as a pinch  point'  in  the  Bridging  Liquid Waste Strategy 2023-2026, however, it is acknowledged by the Infrastructure and  Environment  Department  that Trinity  is  at  capacity  and  will  need another  strategic  storage  unit  in  the West  Hill  area  to  accommodate  the additional flow.

Agreed.

Connecting existing homes is the purpose of the Foul  Sewer  Extension  schemes.  Unfortunately, Foul Sewer Extension Schemes will always be subject to a cost- benefit analysis in terms of how many properties can be connected to any new section of pipe.

The  connection  of  existing  properties  to  an existing sewer is assessed in the same way as new developments and if there is spare capacity they can  be  connected.  The  Emerging  Projects  and other programmes of work will therefore benefit any existing property wishing to do this.

Sections  3.4.3  in  the  Bridging  Liquid  Waste Strategy discusses Foul Sewer Extension Schemes

and  the  improvement  in  connected  properties since 2013.

7

Data on the number of applications to connect onto the main foul sewerage network  is  deemed  "possibly insufficient".

All Planning Applications for new developments or extensions to existing properties are recorded and assessed for their impact on the network as part of the Drainage Impact Assessment process. (REC4 also refers).

Applications for an existing property to connect to an existing local sewer have been declining in recent years (2021 – 38, 2022 – 30, 2023 – 19). They can be received for various reasons: Removal of septic tank.

Formalise an existing connection.

Failure of the existing connection.

Surface water separation.

No existing legal right to drain to the public sewer.

8

The exact location and timing of new housing development is uncertain, and the Government of Jersey's preferred strategy is to complete capacity works within the next 5 years. The Panel's expert adviser deems that if upsizing is

The intent of completing the capacity works in five years is driven by the Bridging Island Plan's stated aim to provide 4,000 homes by 2025 and 8,000 by 2030.

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undertaken  well  in  advance  of development, there  is  a risk  that the additional capacity is under-utilised or

not utilised at all if new development does not proceed. This will result in a "suboptimal investment plan".

I&E would concur that upsizing could be under- utilised in the early years, but the lack of existing capacity means that do nothing' is not an option. Addressing  the  issues  piecemeal,  e.g.  build enough to meet current demand and then build more  later  for  future  growth  will  be  more expensive in the long run. Only addressing current problems will also still delay future development as the necessary capacity will not be available.

However, short term phasing of construction (e.g. construct storage as two tanks so that one can be brought online for immediate benefit while the second is built) is being explored as part of the design development.

Given the trends of climate change and population growth there is considered to be no risk of any of the proposed assets not being utilised at all. I&E are not in a position to gamble on development not taking place and thereby not delivering the aims of the Bridging Island Plan.

The significant time required to assess, design and construct both the new assets and a substantial housing  development  does  not  appear  to  have been considered in this finding.

9

One of the less well addressed aims of the  Bridging  Liquid  Waste  Strategy 2023-2026  is  surface  water management  and  identifying  areas where  works  are  required  to  reduce flooding risks.

I&E accepts that prioritisation of surface water schemes is  limited  within the Bridging Liquid Waste  Strategy  but  the  reasons  for  this  are discussed in detail in Section 7. In summary part of  I&E's  Liquid  Waste  Strategy  is  the development of the Surface Water Management Plan,  which  relies  on  the  collection  of  actual rainfall  data  to  verify  the  model  and  identify appropriate works.

Since the Bridging Liquid Waste Strategy was published  in  2022  I&E  have  developed  the Surface Water Management Plan during 2023 for areas where data was already available, including flood maps to identify the areas at highest risk. In parallel  with  this  I&E  have  also  completed  a programme  of  installation  of  monitoring equipment in places that did not already have monitors. Data gathering has now been ongoing for 10-12 months at these sites allowing the next

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phase of the Surface Water Management Plan to be developed in 2024.

10

Emerging approaches to drainage and wastewater management across the UK go beyond asset management and both water  and  wastewater  plans  are integrated to identify efficient solutions that  address  both  services  such  as Sustainable  Drainage  Systems, rainwater  harvesting  and  reduced consumption.

Sustainable Drainage Systems is a requirement of all new developments as stated in section 7.5 of the  Bridging  Liquid  Waste  Strategy.  It  is  not always easy to fit retrospectively and it would then be at GoJ cost, not the developer's cost.

We  would  agree  that  more  Surface  Water Separation  will  help  but  Sustainable  Drainage Systems take up space, see also comments on Surface Water Management Plan above.

Making rainwater harvesting a planning policy is not within I&E's remit as part of the Bridging Liquid Waste Strategy. We would of course be happy to support in any initiatives to promote more efficient water usage.

These  emerging  opportunities  are  discussed  in section 5.4 of the Bridging Liquid Waste Strategy.

11

The Isle of Wight successfully trialled the provision of 250 free "leaky" water butts in the village of Havenstreet in summer 2022. The butts store 200 litres of rainwater each of which then slowly releases  into  the  drainage  network rather  than  arriving  as  a  peak  flow which would trigger overflows. Nearly 72  per  cent  of  households  are  using them on one road and the nearby storm overflow,  which  previously  activated 27 times a year when it rained more than 5mm, caused only one spill during a  six-month trial.  The  trial  has  been extended to a further 1000 homes in a different part of the island.

No issue with this and agree it would help but would note that relying on the public to maintain these items means they cannot be relied on as part of the permanent solution. Supply and installation of this type of initiative will need GoJ funding.

On a technical point, leaky water butts used in this way will only help on combined sewer systems. The system in St Helier is largely combined but in the more rural areas the systems are generally separated.

Inflow of surface water to foul sewers in rural areas comes from slow response' field run off getting  into  road  gullies,  manholes  and/or infiltration to pipes.

12

Sustainable  drainage  systems  (SuDS) are considered, by the Government of Jersey, as a top priority to get rid of the surface  water  for  new  developments, however,  the  Infrastructure  and Environment Department consider that SuDS will not work in all areas, for example, clay soil areas of the Island.

Refer to answers to KF9 and KF10 above re: the Surface Water Management Plan and Sustainable Drainage Systems.

Attenuation or separation

As discussed in KF11 above, most of the system outside  of  the  larger  settlements  is  already

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The Panel's expert adviser deems that there are, however, different types of attenuation or separation approaches to SuDS  which  could  be  utilised.  For example,  water  harvesting  on  new development for uses such as flushing toilets, or external use such as watering plants.

separated. We would also note that any separated surface water still has to go somewhere, such as: stored  (tank  or  pond)  soakaway  discharge  to stream or sea

Water courses around the island are small and Jersey Water has resisted discharge into reservoir catchments. Similarly, I&E have met resistance from Natural Environment Teams on schemes to discharge surface water to St Aubin's Bay.

I&E do not have carte blanche to dictate policy or simply build and/or discharge in any location they may wish. Dealing with surface water at source' is  therefore  not  a  simple  matter  of  identify  a scheme  and  construct  it.  Projects  can  be blocked/delayed by other GoJ departments as well as Jersey Water, so a wider set of priorities has to be  established  beyond  I&E  and  the  Bridging Liquid Waste Strategy.

Water Harvesting

Agreed, the benefits of this and any other water usage efficiency are clear, but I&E are not in a position to set the planning policy that would be required to enforce this on new developments. As above, I&E are happy to support any initiative in this direction. Other options and opportunities are also  discussed  in  section  5.4  of  the  Bridging Liquid Waste Strategy.

We  would  also  note  that  rainwater  harvesting inevitably creates an extra maintenance liability (pumps etc) for the building/development owner. Ownership  of  this  is  clear  for  commercial developments or blocks of flats where there is a leasehold arrangement. It is more complex for private housing developments unless it is applied individually to each house.

13

The  Infrastructure  and  Environment Department does not have direct access to  Jersey  Water's  testing  data  and therefore makes the assumption that if streams  discharging  into  St  Aubin's Bay contain nutrients then it is likely that Jersey's water sources do.

Agreed.

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14

A  stakeholder  engagement  or consultation process did not feed into the preparation of the Bridging Liquid Waste Strategy 2023-2026.

Accepted. The Bridging Liquid Waste Strategy is primarily a response to the Bridging Island Plan and to thereby inform the upcoming (at the time) Government Plan.

As  noted  in  other  key  findings,  the  Bridging Liquid Waste Strategy was prepared 'blind' of the necessary  new population  models  and  housing development programme.

Furthermore, the new population models based on the 2021 Census are still awaited as of February 2024.

15

Early engagement with the construction industry on long- term capital works planning  is  essential  for  the  smooth delivery of large-scale Government of Jersey capital projects.

This has already been recognised by I&E Liquid Waste and in 2023 we began the process of setting up various Contractor Frameworks to streamline procurement  and  facilitate  Early  Contractor Involvement  (ECI).  This  initiative  was  then adopted by I&E as a whole which has delayed the establishment of the Main Contractor Framework for construction but has not affected delivery of the key strategic projects.

16

Failure  to  engage  communities  is considered  by  the  Panel's  expert adviser to reduce the chance to gain support for more innovative approaches to  addressing  future  wastewater challenges, as well as the expectations of value  to be  created through these investments. It is advocated that there needs to be improved consultation and engagement with users over priorities, as  well  as  engagement  with communities on solutions.

I&E fully agree with this finding but consider that seeking engagement from a very wide audience of stakeholders  at  too  early  stage,  ie  without  a considered concept to discuss, can be counter- productive and alarming. Abortive work must be minimised  but  at  the  same  time  we  find stakeholders  are  more  forthcoming  when  they have something to comment on rather than asking them to fill in a blank page of what do / don't you want?'.

The above is why I&E's approach to the Bridging Liquid  Waste  Strategy  was  to  address  the requirements of the Bridging Island Plan and then progress  to  detailed  stakeholder  engagement based on the preliminary concept solutions for each key scheme.

Innovation

This is understood and I&E Liquid Waste have a track  record  of  being  early  adopters'  of technology.  Indeed,  this  was  a  key  part  of extending the life of the old Bellozanne STW. However, account must also be taken of the time

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required  to  identify  and  test  innovative approaches  given  the  Bridging  Island  Plan's aspirational programme for development (KF8).

Engagement

It would be our understanding that the Bridging Island Plan is setting the high-level priorities that we need to meet. As above, we firmly believe that the  most  constructive  engagement  with communities is based on presenting a concept so the needs are understood and can be explained. This  concept  can  then  be  adapted  to  address concerns and feedback.

17

A  comparative  analysis  from  other island jurisdictions shows that features of  good  practice  wastewater  strategy development are clarity of a strategic direction; engagement with users over priorities; clear options analysis; clarity on  the  overall  size of the  challenge; development  of  long-term  objectives and  adaptive  approaches;  and engagement  with  communities  on solutions.

This is absolutely true when the existing assets are not already approaching or at breaking point. The lack  of  past  investment  means  that  rapid reinforcement of the existing network is required now and we cannot wait any longer to begin this process.

We believe the Bridging Liquid Waste Strategy clearly  describes the  scale  of  the  challenge  in meeting  the  short,  medium  and  long-term objectives and priorities of the Island Plan and other policies.

Given  that  the  priorities  are  provision  of affordable housing as well as wider development for population growth, the liquid waste system needs to be improved in advance of these being built. We cannot wait to see whether new planning policies  or  water  usage  initiatives  give  the expected benefits before starting.

I&E  are  not  seeking  to  build  every  project immediately. The reality of funding availability means  that  this  is  an  extended  programme  of works  and  initiatives  that  have  not  yet  been introduced  can  be  taken  account  of  in  later designs. The first schemes to be built are in the areas with most immediate need and we must provide robust solutions to account for the current uncertainty.

18

The nine key characteristics of a Water Strategy are considered by Arup and Indepen UK to be: systems mindset;

We do not disagree with these principles but our response to KF17 applies here equally.

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resilient  &  adaptive  approach; distributed mix of solutions; total value perspective;  progressive  partnerships; place  &  community  outlook; collaborative citizen & customer base; and a robust social contract.

On the point of a robust social contract' we would note that this extends beyond the provision of water and wastewater services. Clearly this begins with the aims of the Island Plan (and Bridging Island Plan) and the wider social contract requires infrastructure  to  be  fit  for  purpose  in meeting those aims.

The document A future for water', which these characteristics are taken from, makes reference to moving away from grey assets' to nature-based solutions. I&E would support this but note that

land is at a premium on Jersey and grey assets', e.g. storage tanks, can have a smaller footprint and be returned to the original use after construction.

19

The total amount of funding required for key liquid waste projects between 2023-2026 is anticipated to be in the region of £39m with a further £13m required in 2027. Although funding has been agreed in the Government Plan 2024-2027 for the years 2024 and 2025, the  agreed  funding  amounts  will  not cover some of these projects through to completion  and  therefore  this  money will  need  to  be  ring-fenced  and additional funding secured in 2026 for completion  of  these  projects.  Other projects will not be able to commence until longer-term certainty of funding approval can be provided from 2026 onwards.

Agreed. I&E will require some level of guarantee of funding at the point of award of multi-year contracts.

Investigations  and  engineering  work  can  be completed in advance so that designs are on the shelf' for future years but this does not change the fact that construction could take 12-24 months depending on the scale and complexity.

20

There is a need for better longer-term planning and funding of capital projects across Government.

This  has  been  underway  between  I&E  and Treasury throughout 2023 based on the Bridging Liquid Waste Strategy. Initially discussions were for the period to 2027 but this was later extended to 2030 and now to 2050.

21

The Government of Jersey is exploring a sustainable funding mechanism which will  include  developing  user  pays' charges  in  relation  to  all  aspects  of waste  charges,  including  commercial and  domestic  liquid  and  solid  waste with a view to this being agreed in the

Following  on  from  the  response  to  KF20, sustainable  funding  mechanisms  for  long  term funding  is  being  explored.  Notwithstanding,  a Letter of Comfort is under consideration by the Treasury for the funding required in 2026 in order to complete the current liquid waste projects.

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next Proposed Government Plan 2025- 2028.

22

Although the impacts of climate change are  already  being  observed  and requiring consideration of investment for  adaptation,  funding  for  surface water drainage would not currently sit within  the  terms  of  reference  for expenditure  under  the  Climate Emergency Fund. If funding was to be drawn from the fund for this purpose it would require a change in the Fund's terms of reference.

Notwithstanding  the  terms  of  reference  of  the Fund,  flooding  is  generally  accepted  to  be worsening  due  to  climate  change  and  is  seen around the world to cause disruption and damage to people's lives and livelihoods.

Should  it  be  decided  to  draw  funds  from  the Climate  Emergency  Fund  to  carry  out construction  works  we  believe  it  would  be difficult to deny the relevance of that expenditure.

23

An amalgamation of Jersey Water is under  consideration  as  a  strategic option to addressing the current siloed and  inefficient  approach  of  water supply  being  delivered  by  an  arm's length  organisation  and  drains maintenance and management being delivered   internally   by   the Government of Jersey.

This has been under review at several points in the past  and  I&E  will  continue  to  engage  with discussions on this matter.

Any initiatives regarding water usage efficiencies

and the like will certainly be most effective if   jointly presented.

24

There  is  perceived  to  be  general agreement  within  the Government  of Jersey that development contributions to drainage should be proportionate to the scale of development and that whilst developers  should  contribute  for connection  costs  onto  the  mains network, they should not be expected to fund the historic underinvestment in the Island's sewers and drainage.

Agreed.

We would further note that if developers of the Bridging  Island  Plan's  rezoned  fields  for affordable homes are made to pay for network improvements, then the price of the affordable homes will only increase.

25

A  comparative  analysis  of  waste strategy business models in other island jurisdictions shows that all comparators have some element of user charging and can access long-term debt to spread the repayment of capital finance over many years. Likewise, all comparators have the  additional  responsibility  for integrating the management of drinking water  supply  alongside  their wastewater and surface water flood risk responsibilities.

Agreed.

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26

The  Bridging  Liquid  Waste  Strategy 2023-2026  will  increase  charges significantly per household (£659) and beyond  those  of  comparable  island states.  The  business  case  presented prefers a potentially suboptimal case by prioritising early investment to manage risk over options to phase investment based on impending need. This results in a higher cost and opportunity cost that the money is not available for other uses.

£659

We  note  that  this  figure  is  based  on  44,500 properties making a single payment to arrive at ~£30m. Why does this figure not take account of the fact that the project spend is spread across multiple years (2023-26 in the Bridging Liquid Waste  Strategy)?  It  therefore  does  not  take account of using long term financed debt as it is noted that the comparable island states do.

Query - Are the comparators based on a like for like position? The other figures appear to be based on  their  annual  spend,  albeit  in  different accounting years.

Even if £659 was (simplistically) spread across three years the cost per household is £220/year which compares very well with the other island states and would meet the notional spend profile of  £10m/year  seen  in  our  developing  Capital Delivery Programme.

Suboptimal Case

See comments on KF8.

Risk that "money is not available for other uses" If  the  projects  are  not  progressed  early,  the problem of developments being delayed due to lack of capacity will not go away. The proposals in  the  Bridging  Liquid  Waste  Strategy  are  an investment in the long-term future of the Island reflecting the Government's stated aims in the Bridging Island Plan.

It  should  be  considered  that  wastewater management  has  always  been  a  long-term endeavour – consider the fact that the original Bellozanne STW was built in the 1950's and only replaced in 2023 when population had doubled.

27

Implementation  within  the Infrastructure  and  Environment Department  is  siloed  with  separate funding  and  with  few  incentives  for management of the whole system. The approach is considered suboptimal in terms  of  both  investment  and

It is not clear if this finding is in relation to Liquid Waste or I&E as a whole?

We would disagree that delivery of Liquid Waste Revenue and Capital Projects are entirely siloed in terms of delivery. Funding is necessarily managed separately but, by assessing new projects through

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performance  and  is  potentially  less resilient. Furthermore, the strategy is based on a cost and risk approach with limited options presented and risks not quantified.  This  means  it  does  not optimise investment and phasing.

the   Island-wide  network  model,  it  is  easy  to identify whether a scheme in one area could cause detriment  elsewhere.  In  many  cases  network maintenance work is replacing existing assets on a like for like performance basis and no such assessment is required.

If the point is aimed at, for example, co-ordination between Transportation and Liquid Waste, then we would note that every effort is made to co- ordinate  work.  Indeed,  the  road  resurfacing programme  is  a  key  driver  for  the  timing  of surface  water  separation  works  in  St  Aubin's Road to be completed before the end of 2027.

Recommendations

To

Accept/ Reject

Comments

Target date of action/ completion

1

The  Minister  for Infrastructure  should ensure  that  service metrics are implemented and used to engage with and inform customers of sewer  and  drainage utilisation issues in 2024 and  beyond.  Customers should also be engaged in demand management and action  to  reduce  sewer misuse.

MI NF

Accept

REC1 is accepted in principle and we would  welcome  a  discussion to  agree which metrics would be considered most relevant.

Existing telemetry data is available to show how often pumping stations run and  the  flow  they  deliver.  Flow measurement in the gravity sections of the network is not as widely available but the same data that was used to verify the network model is available. The network model  also  clearly  shows  future utilisation issues and is the basis of the Bridging  Liquid  Waste  Strategy  as  a whole.

Other  metrics  mentioned,  such  as complaints and callouts to blockages or similar  could  also  be  gathered  in  an appropriate format.

As stated in the Key Findings above, I&E  would  be  happy  to  engage  in developing  any  public  awareness

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To

Accept/ Reject

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Target date of action/ completion

programmes in conjunction with Jersey Water and other partners.

2

The  Minister  for Infrastructure  should review the pass forward strategy from the Island's network  to  preserve capacity  at  Bellozanne Sewage  Treatment Works  (STW)  and capacity in the network in urban  areas.  The attenuation  and  pass- forward  solution  for Bonne Nuit STW should be  reviewed  in  light  of this.  The  aim  of  this would  be  to  avoid  the potential for a significant opportunity cost of these approaches.

MI NF

Reject

Preserving  capacity  at  Bellozanne  is counter to the  provisions of the 2013 WWS whereby Bellozanne was sized for a 2035 Population plus 20% for longer term  growth.  Taking  this  approach  is also effectively adopting a strategy of under-utilisation which was a  concern raised by the Panel in KF8.

There  is  no  capacity  in  the  urban networks to be preserved. If capacity is released by diverting flow to new STWs around the Island the feasibility, design, planning  approval  and  construction programme for one or more STWs will be far longer than that required for the proposed projects.

For the specific case of Bonne Nuit, the option to upgrade the existing STW was reviewed for the Bridging Liquid Waste Strategy and a subsequent Briefing Note completed.  It  is  viable  to  refit  the existing STW but there is no space to expand its capacity. Without expansion, the proposed Mont Mado Foul Sewer Extension  cannot  progress.  This  Foul Sewer Extension scheme will offer up to 67 properties in the Bonne Nuit area an opportunity  to  connect  to  mains sewerage which will otherwise never be possible.

This would appear to be counter to the intent of KF6?

3

The  Minister  for Infrastructure  should ensure,  ahead  of  the continued  roll  out  of works,  that  the programme  of  liquid waste works identified in

MI NF

Reject

I&E  consider  that  this  exercise  has already been completed in selecting the first key projects to meet the demands of the affordable homes on rezoned fields and the wider construction of houses in the areas identified by Planning as the preferred locations.

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the  short-term  is considered to be low or no  regret'  to  address urgent  need  and  that certain  aspects  of  the strategy, where there are currently  gaps  in  the evidence,  should  be deferred until the longer- term  Liquid  Waste Strategy 2025-2035.

The  key  gaps  in  evidence  are  the Population  Growth  Models  from Statistics Jersey and confirmed locations for housing development.

As discussed elsewhere, it is not viable to wait for absolute certainty and still create the required capacity in a timely way and thus minimise further delays to development of all sizes (KF4, KF14 and KF17 refer).

4

The  Minister  for Infrastructure  and Minister  for  the Environment  should work  together  to ensure that the Infrastructure and Environment Department keeps an accurate log of all  applications  (and refusals) to connect to the network  from  both existing  and  new development  which would  impact  on  the capacity of the network. This  should  include applications for planning for  redevelopment  or extension  of impermeable  area.  This log should be maintained from  2024  so  that  the demand  for  new connections  is  reflected in the longer-term Liquid Waste  Strategy  2025- 2035.

ME NV / MI NF

Accept

This  is  accepted  insofar  as  I&E  are already carrying out the majority of these actions.

Since  the  Bridging  Liquid  Waste Strategy was issued, I&E have carried out  Drainage  and/or  Flood  Impact Assessments  on  every  planning application for new build, extension or redevelopment of existing property that could  impact  the  sewer  network.  The current  Drainage  Impact  Assessment register can easily be extended to include the final accept/reject decision.

However, to date, applications relating to  extension  of  impermeable  area  in isolation have not been passed to us for review.

A brief review of the Planning Portal indicates that not all new hardstanding requires  planning  permission  and  that discharge of rainwater to the highway requires  only  permission  from  the Highway  Authority  with  no consideration of the impact of this water on the gullies and sewers.

Each Drainage Impact Assessment adds the  approved  change  to  the  network model and thus the take up' of spare capacity is monitored.

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5

The  Minister  for Infrastructure  should consider, before the end of Q2 2024, a new option of  progressing  design works  and  identifying land  for  new infrastructure  assets,but deferring  investment until housing phasing is known. The aim being to avoid unnecessary tie up of capital that might be better  deployed elsewhere.

MI NF

Accept

'Design on the  shelf' is already  being considered and will be progressed when funding allows.

There  is  a  viable  option  to  build significant  housing  developments  in parallel  with  the  construction  of  the relevant storage tank. Discussions with Developers  indicate  that  they  are interested  in  a  parallel  approach,  for example development of field J1109 has been estimated to take 2.5 years which is comparable to the programme for West Hill.

However,  there  are  inherent  risks  in waiting  for  confirmed  large developments  before  starting construction:

1. Not  progressing  the  key schemes at all will limit/prevent smaller  development  in  the meantime.

2. Only building for the immediate need  could  sterilise  a  site  by building a small' asset when we know a bigger asset is likely to be needed later. We only get one opportunity in each location as everyone  recognises  there  is limited space on Jersey.

6

The  Minister  for Infrastructure  should work collaboratively with the  Minister  for  the Environment  to  review surface  water management and identify areas  where  works  are required  to  reduce flooding  risks,  making allowance  for  climate change in the absence of a  complete  climate

ME NV / MI NF

Accept

This  is  accepted  insofar  as  I&E  are already  carrying  out  these  actions. Responses  to  KF9,  KF10  and  KF12 refer.

Surface Water Management

Reviewing  flood  risk  and  potential surface  water  schemes  is  already underway as part of the Surface Water Management Plan. The Surface Water Management Plan is currently focussed on  the  areas  known  to  experience

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change  assessment. These  considerations should be factored into a future  Liquid  Waste Strategy  2025-2035  and other  associated strategies  such  as  an Integrated  Water Management Plan.

flooding but will expand to the whole Island over time.

Allowance for climate change Including for climate change is standard good  practise  and  all  projects  and Drainage  Impact  Assessments  /  Flood Impact  Assessments  include  this provision.

7

The  Minister  for  the Environment  should ensure that consideration is  given  by  the Infrastructure  and Environment Department before the end of Q3 2024 to  reviewing  its  storm frequency  information and levels of protection in line with the UK where standards of resilience are being extended for storm return  periods  due  to increasing  frequency  of significant storms.

ME NV

Accept

The  first  phase  of  the  Surface  Water Management  Plan  was  completed  in October 2023 and the second phase is expected to be completed by June 2024 on completion of further data collection currently underway.

As a result of Event Barn and the Grands Vaux  flooding,  I&E  are  already developing  rainfall  models  through discussions with Jersey Met for use with the network model and subsequently to be used in all relevant applications to provide a consistent tool.

Once  complete  I&E  will  review  how best  to  formalise  and  publish  the conclusions with or through Jersey Met.

8

The  Minister  for  the Environment  should work collaboratively with the  Minister  for Infrastructure  and  key stakeholders  to  consider further options and bring forward proposals before the  end  of  2024  to incentivise developers to maximise  water efficiency  and rainwater harvesting  with  the  aim of minimising impact on downstream sewers.

ME NV/ MI NF

Accept

I&E  are  supportive  of  this recommendation in principle and await contact as a key stakeholder. I&E are already collaborating with Planning with a view to minimising the flows to the drainage network.

We  would  note  that  Sustainable Drainage Systems is already mandatory for  new  development  and  that incentivisation  is  perhaps  best  done through Planning Policy and conditions.

The measures referred could be included in the New Healthcare Facilities Project either in full or as a trial.

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9

The  Minister  for  the Environment  and Minister  for Infrastructure  should, before  the  end  of  Q3 2024, jointly consider the merits of implementing a trial scheme offering free leaky'  water  butts  to residents  in  flood catchments areas with a view  to  funding  being proposed for inclusion in the  next  Government Plan 2025-2028. The aim of  the  scheme  being  to slow  down  the  flow  of rainwater  into  the drainage network during periods of heavy rainfall.

ME NV / MI NF

Accept

Accepted with the caveats outlined in KF11. I&E will review the new flood maps and consult the Operations team to

identify a suitable catchment for a trial. We  assume  funding  will  be  provided separately.

Yorkshire  Water  and  Northumbrian Water  have  network  modelled  similar proposals and reviewed benefits in the past. In those studies there was found to be a benefit but, in all cases, it was not considered  reliable  enough  to  be  a permanent solution given that the public must maintain their own installation.

Note that this will only benefit load at Bellozanne through combined systems which are limited outside of St Helier.

10

The  Minister  for  the Environment should seek to establish a data sharing agreement  between  the Government  of  Jersey and Jersey Water to share information  relating  to Jersey  Water's  testing and  consumption  data before the end of 2024. This  should  specifically include water quality and water abstraction data to enable  greater understanding  of  the water  quality  in  the environment;  and household  water consumption  data  that will  provide  return  to sewer data  on predicted load.

ME NV

Accept

A  data  sharing  agreement  between I&E's  Environmental  and  Consumer Protection  section  and  I&E's  Land Resource Management section already exists.  This  will  be  reviewed  and broadened as appropriate.

Water  quality  and  quantity  data  is routinely shared between these parties so as  to  minimise  the  duplication  of monitoring  and  to  combine  data  to enable  a  better  understanding  of  the resource.

Consumption data is published annually by Jersey Water in their annual reports.

11

The  Minister  for  the Environment  should

ME NV

Accept

This  was  proposed  in  the  Bridging Liquid  Waste  Strategy  as  part  of  a

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ensure  that  a  partnered approach  is  taken  with the  Minister  for Infrastructure and Jersey Water  to  implementing an  Integrated  Water Management Plan by the end of 2025.

holistic  approach  to  water  resources, consumption and waste management. It can  only  start  after  REC10  has  been resolved.

In 2023, available funding was used to establish  the  scope  of  the  Integrated Water  Management  Plan.  A  business case to fund the development of this Plan was  submitted  to  Treasury  for  the Government Plan  2024-2027, but was not received. The funding request will be resubmitted in 2024 for consideration. The MENV will also ensure integration with the development of the Island Plan (including Statistics Jersey outputs).

12

The  Minister  for  the Environment,  in conjunction  with  the Minister  for  Sustainable Economic  Development should  consider,  before the  end  of  2024, environmental  land management payments to landowners  for ecosystem  services  – particularly  for  water storage and retention or ground  water management, as well as nutrient balancing.

ME NV

Accept

The  availability  of  incentives  to landowners  to  create  flood  plain  is anticipated to facilitate finding sites but does not guarantee it.

13

The  Minister  for Infrastructure  should ensure  that  the Infrastructure  and Environment Department facilitates  early engagement  with  the construction industry on a programme  of  planned infrastructure  capital works,  so  that  industry are able to forecast and

MI NF

Accept

This  is  accepted  insofar  as  I&E  are already carrying out these actions.

Response to KF15 refers.

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resource themselves with more  certainty  and  so they  are  able  to  deliver

what  is  needed  from them.

14

The  Minister  for Infrastructure  should ensure  that  there  is improved consultation on the  aims  of  a  Liquid Waste  Strategy  through development  of  a strategic direction ahead of  the  Liquid  Waste Strategy 2025-2035. The purpose being to ensure that  a  robust  social contract'  is  formed  to create  shared responsibility  and common purpose through co-creation  of  the strategy  by  engaging communities  in  the development of an Island Integrated  Water Management  Plan  and other  associated strategies  such  as  the 2025-2035 Liquid Waste Strategy.

MI NF

Accept

This  is  agreed  but  will  need  the recommendations of REC10 and REC11 to be in place complete.

The  development  of  a  robust  social contract'  and  any  Integrated  Water Management  Plan  must  also  be compatible  with  the  provisions  of the forthcoming Island Plan.

This may require that planning policies are  amended  such  that  proposals  to discharge  surface  water  to  sea  or watercourse will be supported by default rather  than  objected  to  under  Natural Environment policies.

15

The  Minister  for Infrastructure  should ensure  that  the  next longer-term  Liquid Waste  Strategy  2025- 2035  encompasses  the following  best  practice features:  clarity  of  a strategic  direction; engagement  with  users over  priorities;  clear options  analysis;  clarity on the overall size of the

MI NF

Accept

Agreed but bearing in mind responses to KF17, KF18 and REC23 below.

We note that the ability to fully satisfy all  of  these  aspects  will  require  the equivalent  full  Island  Plan  to  be available or to have key points agreed to ensure consistency.

It should be noted that the ultimate 'size of the challenge' is driven by growth and not the current conditions so a consistent

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challenge;  development of  long-term  objectives and adaptive approaches; and  engagement  with communities  on solutions.

set of data to be used by all parts of GoJ is essential.

While opinions will vary to a degree in different  communities,  the  feedback from Stakeholders on the initial strategic projects is expected to provide a solid baseline position.

16

The  Minister  for Infrastructure  and Minister  for  the Environment  should work  collaboratively  to ensure that a future Water Strategy  is  delivered before  the  end  of  2025 and  should  encompass the key characteristics as outlined further in Arup and  Indepen's  model  of A new future for water'.

ME NV / MI NF

Accept

Accepted with the caveats discussed in preceding points that this will require collaboration with Jersey Water and the Island Plan to ensure consistency.

17

The  Minister  for  the Environment  and  the Minister  for Infrastructure  should, within  the  timescale  of the  current  Bridging Liquid  Waste  Strategy 2023-2026,  work collaboratively to deliver a  Strategic  Direction describing,  subject  to consultation,  how  new approaches  might  take shape in the Island Plan, an  Integrated  Water Management  Plan  and other  strategies  such  as the  Liquid  Waste Strategy  2025-35. Government  should review and consult on a wider  range  of  water management  options  to

ME NV / MI NF

Accept

Accepted  with  the  exception  of  the proposed  programme,  please  can clarification of the intent be provided as below.

Noting  the  requirements  of  REC10, REC11,  REC14,  REC15  and  REC16 which  must  all  inform  a  Strategic Direction, the  proposed  programme is considered unachievable if publication by the end of Q3 2024 includes a period of consultation.

However, if the document is to be issued at end Q3 2024 for consultation to take place then the programme is ambitious but achievable.

We  would  note  that  I&E  retain  the position that the preparation of such a document cannot be allowed to delay our early  and  ongoing  projects  that  will

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give  an  adaptive  long- term resilience plan. The Strategic  Direction should  be  consulted  on during  2024  and published  on  the Government  of  Jersey website by the end of Q3 2024.

address  immediate  issues  and  the provision of affordable homes.

It should also be noted that the Planning Applications for the Key Infrastructure Projects,  including  the  immediate requirement  for  the  Strategic  Storage Projects, should be considered as critical and be given special consideration to fast track the delivery of these schemes to ensure  that  the  progress  of  the

Affordable  Homes  projects  are  not impeded.

18

The Minister for Treasury and  Resources  should work  with  the  Minister for  Infrastructure  to facilitate  a  longer-  term approach to the planning and  funding  of  key infrastructure  capital projects and to deliver a solution  prior  to  next Government  Plan  2025- 2028.

MT R  / MI NF

Accept

This  is  accepted  insofar  as  I&E  are already carrying out these actions.

Response to KF20 refers.

19

The Minister for Treasury and  Resources  and  the Minister  for Infrastructure  should work  collaboratively  to ensure  that  stakeholder engagement,  both  at  a domestic and commercial level, be facilitated from the outset of scoping any future funding proposals on user-pays' charges in relation to waste charges. Stakeholder  consultation should be undertaken in early 2024 to ensure that proposals can be brought forward  in  time  for  the

MT R  / MI NF

Accept

This  is  accepted insofar as  I&E  have already  been  party  to  discussions  on Liquid Waste charges and will continue to engage and support the Minister for Treasury and Resources on this matter.

I&E  note  that  this  subject  will  be provocative  and  controversial  so  the timescale  for  achieving  Stakeholder consensus seems unrealistic.

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next  Government  Plan 2025-2028.

20

The Council of Ministers should discount bringing forward  any  potential proposals to varying the terms  of  the  Climate Emergency Fund at this time. Alternative options and  solutions  should instead  be  explored  for funding  surface  water drainage  projects  to enable  adaptation  to climate change scenarios such  as  more  frequent extremes of weather until such time as a long-term funding solution has been identified  to  increase revenue into the Climate Emergency Fund. At this point,  the  terms  of  the Fund  should  then  be revisited.

Co M

Accept

I&E note that the reasoning behind this recommendation is that Panel consider that the Climate Emergency Fund should remain focussed on addressing carbon reduction.

This is clearly a matter for the Council of Ministers  but  I&E  would  note  that flooding is a problem now and if funding is  not  available  from  elsewhere  then projects to address an immediate issue that directly affects the communities and economy of Jersey will be delayed. If the intent is to derive funding from user pays' charging then it may be some time until a long-term funding solution is in place.

21

In  consideration  of  a long-term  funding solution, the Minister for Treasury  and  Resources and the wider Council of Ministers, should ensure that  developers' contributions  for  new development  are considered in the mix of solutions  for  funding network  reinforcement comparative  to  the additional  load  the  new development  will generate  into  the sewerage  and  drainage system and to ensure that customers (i.e. taxpayers)

MT R / Co M

Accept

Upgrades  to  nearby  sewer  network assets,  e.g.  larger  pumps,  are  already charged  to  developers  as  part  of  the approval process.

As the Panel note in KF24, Developers should  not  be  expected  to  fund  the historic underinvestment in the Island's sewers  and  drainage  and  it  can  be difficult to clearly distinguish where this stops  and  where  their  responsibility begins.

It is absolutely right that the taxpayer should  not  subsidise  development  but this discussion must also consider how to prevent new affordable homes becoming unaffordable  due  to  the  cost  of infrastructure  upgrades  being  imposed on the Developer.

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are  not  left  subsidising developers.

House building is part of the Bridging Island  Plan  with  the  intent  of  easing pressure on the housing market.

22

The  Minister  for Infrastructure  should consider an approach to phasing  some  sewerage and  drainage  network upgrades  over  a  longer period. Options, such as (but  not  limited  to)  the replacement  of  Bonne Nuit  Sewage  Treatment Works  with  a  pumping station,  should  be reviewed  in  the  longer- term  Liquid  Waste Strategy  2025-2035  to determine  whether  there is an alternative solution offering better value for money  through  an Integrated  Water Management  Plan, including  rainwater retention  approaches such  as  Sustainable Drainage Systems.

MI NF

Reject

Further extending the programme will potentially:

Delay housing developments.

Mean flooding keeps happening. Increase  frequency  of  failure  of  life expired assets resulting in disruption and loss of service.

Increase maintenance/repair costs.

On  the specific  of  Bonne  Nuit  STW, there  is  major  maintenance  /  asset replacement  required  now.  If  this  is carried out then I&E will effectively be committed  to  the  Bonne  Nuit  STW solution for at least 15 years until those new assets also expire.

As  noted  in  our  response  to  REC2, retaining the STW will prevent nearby houses  being  connected  to  main sewerage  through  the  proposed  Mont Mado  Foul  Sewer  Extension  because there is no space to expand the Bonne Nuit STW to almost double the current capacity to treat the additional flow.

Furthermore, the Bonne Nuit catchment is  already   a   separate   system   and therefore  Sustainable  Drainage Systems/rainwater  retention  schemes will have minimal benefit to the flow reaching the Bonne Nuit STW.

23

The  Minister  for Infrastructure  should ensure  that  the Infrastructure  and Environment Department reviews its risk tools and metrics  to  enable  finer tuning of its investment

MI NF

Reject

Risk Tools

It  should  be  noted  that  data  like  the population models are still unavailable. The housing development location and programme are also in a state of flux and outside  our  control.  Under  these circumstances,  changing  the  tool  is unlikely  to  have  an  impact.  It  is

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priorities.  Furthermore, future  strategic  outline business  cases  should adopt  approaches recommended by the HM Treasury  Green  Book which  sets  out  an approach to investment to meet  societal,  economy and  environment outcomes  to  create greater value. In addition, a  wider  set  of  options should be  considered in the  business  case  – specifically,  deferring investment  to  match development,  carrying out  design  work  in advance  and  identifying land  for  infrastructure assets in the next Island Plan

imperative that I&E make good timely provision that allows essential growth to progress in the short term.

Use of Green Book

The  Bridging  Liquid  Waste  Strategy (and any future Liquid Waste Strategy) is not, and never will be, intended as a Strategic Outline Case or Business Case for the projects identified therein. While the  Bridging  Liquid  waste  Strategy considers the overall drivers, costs, risks and benefits of a scheme, it only supports the  Green  Book  process  without replacing it.

Each project or programme of works has its own Business Case prepared in line with the Public Finance Manual. This is based  on  a  Feasibility  Study,  or equivalent, and goes through all of the proper approval stages. Consideration of a 'Do Nothing' option is a mandatory part of the process.

The  risks  associated  with  deferring investment  until  development  is confirmed are covered in our responses to REC3 and REC5.