Consultation outcome

Water company drought plan update – consultation response summary (2025)

Updated 19 March 2025

1. Introduction

We consulted on our proposed changes to the water company drought plan guideline.  This guideline tells water companies what they must and should include in their statutory drought plans to manage public water supplies and protect the environment during a drought. Water companies will be writing their new drought plans and consulting on them later this year.

This document provides a summary of the responses we received and how we have dealt with these responses.

2. How we ran the consultation

We consulted on the drought plan guideline for 6 weeks from 16 December 2024 to 26 January 2025.

We promoted the consultation through direct email correspondence with water companies, regulators and non-governmental organisations. We asked our area colleagues to promote the consultation with their local stakeholders such as abstractor and environmental groups. We published a blog on GOV.UK and promoted the consultation through our social media platforms.

We received online responses from the consultation on GOV.UK and by email. We have listed those respondents who agreed for their names to be published in Appendix A.

We received comments from 35 respondents (32 were published online) and have considered over 100 comments in response to the 6 questions we asked. The respondents included 10 water companies, 19 other organisations and groups and 6 individuals.

In Appendix B we have presented a summary of the answers we received (percentage) by each question. This summary was generated by the online consultation and does not include two responses that were reviewed directly. We received comments from respondents who both agreed or disagreed with the questions asked. We also received some responses which did not relate to the questions asked and so were discounted.

We also received some comments related to work being completed by other teams in the Environment Agency. We have passed on comments related to operational drought and emergency drought plans.

3. Summary of key findings and actions we will take

In the following sections, we explain how we have considered the responses to each consultation question, whether we have updated the guidance or why we have not made any changes. We have also listed any future work we will do. 

Some of the larger changes that we have made following the consultation include:

• all (relevant) “shoulds” have been highlighted in bold throughout the guideline
• section 4.2.2 on further demand actions has been re-written to better explain the ask and explain that the Environment Agency will work with the water companies to improve this area in the future
• section 4.3 when applying for a drought permit or order, text has been included to ask water companies include a programme of work for any outstanding environmental work in their draft plan and final plan
• section 9.4 on agreements and arrangements includes a new paragraph on water supplies for firefighting (as provided by the National Fire Chiefs Council)
• several areas of the guideline have been re-written or re-ordered to improve readability. These include section 1.6 links with other plans (how drought is managed in England and emergency plan for drought) and section 4.4.1 demand and supply extreme actions (supply extreme actions considerations)

3.1 Question 1.  Is the guideline clear on what water companies “must” and “should” include in their drought plans?

Of the respondents through the online consultation:

• 69% of respondents agreed
• 22% were neutral

We received 26 comments.

We have changed the guideline

We have reviewed the definitions we provide in section 1.2 for “must” and “should” and added a new definition for “could”. We’ve clarified that a water company does not need to justify in its drought plan if it does not follow a “could” in the guideline.  We reviewed the language we use and highlighted relevant “shoulds” in bold.

In section 2.1, we list who water companies must hold pre-consultation discussions with (as required by legislation) and who water companies should (best practice) consult with. Who water companies should consult with will depend on each water companies location and the list provided in the guideline is not a definitive list. We have added the Fire and Rescue Services and internal drainage boards the to the list of should consult and clarified that water retailers and self-suppliers are also included here.  

We have updated the text in the supplementary guidance on drought permits and orders section 2.4.1 on pre-applications. Water companies should include a trigger/s for when they would need to apply for a drought permit which should factor in the time they would need to prepare for (including pre-application time and application determination) and carry out the action.

We’ve made changes to section 1.6 on links with other plans to improve how it reads.   

Where we have not changed the guideline

The guideline only covers what water companies should include in their operational drought plans. It does not cover the long term supply of resilient and sustainable water supplies as this is covered in the water companies’ 25 year strategic plans – their water resources management plans. 

It is for the water companies to decide who they “should” discuss their draft plans with in advance of consulting on their plans, see section 2.1. The guideline does not provide a conclusive list.

The legislation states to whom water companies must send a copy of their draft drought plan that is being consulted on and this includes, for example, any National Park Authorities, English Nature and the Historic Buildings England. See reference in section 2.4. 

We were asked for what constitutes “sufficient justification” for a water company not following a “should” in the guideline and how this would be assessed. Water companies must consult on their draft drought plans and this allows any individual, group or organisation to make a representation on the contents or approach used by a water company in its drought plan. Water companies must explain how they have responded to these representations in their statements of response which are also published, see sections 2.5 and 2.6 in the guideline for more details on this. 

The Drought Plan (England) Directions are reviewed and published by the Department for Environment, Food and Rural Affairs (Defra) during each new planning round. You can request a copy of the latest directions and any of the supporting technical guidance from our mailbox as stated in Drought: how water companies plan for dry weather and drought.

We provided a link to this page from the consultation site.

3.2 Question 2. Is the guideline clear on how water companies should show the actions they will take at each drought level?

Of the respondents through the online consultation:

• 63% of respondents agreed
• 22% were neutral

We received 23 comments in total of which 11 were directly relevant.

We have changed the guideline

We have reviewed the text on demand actions, including temporary use bans (TUBs), regarding having them in place long enough to have a measurable impact on demand. We’ve clarified that water companies should allow enough time to carry out their demand actions, and that they should be in place long enough to have had an opportunity to have a measurable impact on reducing customer demand before they apply for a drought permit or drought order.

We have changed section 4.3.1 to say demand actions should be in place for long enough in advance of an application for a drought permit or order to see if they have had a measurable impact on reducing demand.

We have amended the text on the drought response framework for England, this is now called “Drought: how it is managed in England”. We have clarified that if the Environment Agency drought stage is declared for a different sector (for example agricultural stress), a water company may not need to implement its drought actions for that drought stage.

Where we have not changed the guideline

We reviewed our guidance and processes on reviewing and issuing permits during a drought using the lessons from the 2022 drought. Details of this were shared with water companies at a workshop in January.  As a minimum, water companies should be application ready for their more frequently or more likely to be used drought permit or order sites; details on the requirements to be application ready are set out in the guideline.

We received comments that said including the full implementation timetable for each drought action in water company drought plans may be confusing to customers and not allow for flexibility to respond to different drought situations. The drought plans should show regulators and customers when a company plans to act. We believe the drought plan guideline does give flexibility as companies can show through worked examples how they would implement their actions in a range of droughts.

Further work before next drought round

The emergency drought plan guidance is being developed outside of the drought plan guideline and will involve water companies. We will also consider the link between level 3 and level 4 actions in terms of any impacts on decision making.   

We welcome the offer from some companies to work with us on any future work to develop demand reduction monitoring methods, tools and reporting best practice.

3.3 Question 3. Are the further demand actions proposed to reduce residential customer water use in the guideline adequately explained for the water companies?

Of the respondents through the online consultation:

• 44% of respondents agreed
• 28% were neutral

We received 25 comments in total of which 18 comments were directly relevant.

While many responses supported this new section, some respondents did not think this section was sufficiently clear and questioned how this would work alongside existing demand actions including extreme and emergency drought actions.

We have changed the guideline

We have thoroughly reviewed this section as a result of the consultation response received. We have explained in the guideline that currently this is an action that water companies could develop themselves as a desktop exercise and that it applies to the domestic water use of both household and non-household customers. 

We have added that the Environment Agency will work with the water companies to explore and develop the further demand actions more fully in time for the next planning round. This work should also involve the water retailers and MOSL (market operator of England’s non-household water market). 

We have also clarified that the further demand actions:

• are more than the standard communications that water companies are doing with their customers to reduce demand as shown in their plans
• could be seen as a scale of increasing demand reduction actions that start in a drought but could also be implemented in a severe drought as an extreme demand action

We have provided some examples of further demand actions including incentivising reductions in demand at a customer or community level and providing guidance on how customers can reduce their water use in the home. 

We have explained that water companies could choose to implement further demand actions such as incentive schemes alongside (but not instead of) TUBs and non-essential use bans (NEUBs) and use the demonstrated reductions in demand as part of their drought permit applications. 

Where we have not changed the guideline

We recognise that the roll out of further demand reducing actions at the more extreme end of the scale (that is, an extreme demand action) would require more communication and coordination between water companies, the Environment Agency, the government and others. The further work between the regulators, water companies and others should look at what this means in action.

We agree that the new growth targets are a challenge for water companies, but that these should be managed through the water companies long term plans (their water resources management plans, or WRMPs). Some water companies already use an adaptative planning approach in their WRMPs. The water company drought plans are operational plans and these challenges may be reflected by water companies in these plans, for example, by increasing the need for additional demand reduction actions in areas of the higher growth or where supply/demand balances are most acute.

The guidance provides examples of how water companies could reduce demand, in addition to general communications, and the actions a company already takes to reduce leakage or implement temporary use restrictions.  We agree that it is important that consumers understand the urgency of the situation at this point. Companies are responsible for developing these actions in their plans, including whether they consider financial incentives are needed.

The information provided by the National Fire Chiefs Council will be passed to the water companies as part of the further development work.

3.4 Question 4. Do you think the information provided on extreme drought management actions will help water companies in planning for a more severe drought in the future?

Of the respondents through the online consultation:

• 50% of respondents agreed
• 25% were neutral

We received 26 comments in total.

We have changed the guideline

We have updated section 4.4 on extreme drought management actions:

• we have acknowledged the need to review the prioritisation of the extreme actions as more information becomes known (that is, less uncertain) and in relation to the drought being experienced on the ground
• we have reviewed and presented more clearly the extreme supply action considerations in section 4.4.1
• we have removed references to “tariff changes” in the guideline as an example of an extreme demand action. We will check the practicality and legitimacy of including this as an extreme action
• we have clarified expectations around environmental assessment for extreme drought actions in section 4.4.1, stating that if companies aren’t application ready they should have a plan in place to undertake all further work and to collect monitoring data

We have updated Appendix C on the extreme drought management actions:

• we have added “alternative water sources for firefighting” as an example extreme supply action to table 3 in Appendix C. Water companies should discuss this as part of their pre-consultation discussions and agreement with their local fire and rescue services
• we have clarified that it is removal of “non-statutory” exceptions in relation to temporary use bans and non-essential use ordinary drought orders (Appendix C, table 3, example extreme demand actions). We have added some further details to Table 4 on extreme supply actions concerning examples of third party related actions
• we have referred to temporary mobile desalination plants as an example of an extreme supply action and have included this in Table 4 in Appendix C. It is possible that current Drinking Water Inspectorate (DWI) regulation would only make this a viable option in, for example, multi-year droughts but it is for a water company to assess the viability of any extreme actions they choose to use. We have updated the significant barriers column for table 4 to include “DWI authorisation and agreement, DWI constraints”.  Other extreme supply action are also highlighted as needing authorisation from the DWI such as water recycling and temporary water treatment

We have updated the supplementary technical guidance we provide to water companies on performing environmental assessments of their drought plan actions. We have added a reference to the need to engage with Historic England and consider the historic environment. We say, “Where there are potential risks to heritage sites (designated or not) you should discuss understanding and mitigation of these with Historic England and local authority heritage services”.  There was already a reference in this guidance but further references added to sections 3.5 and 3.6 of the supplementary guidance.

Where we have not changed the guideline

We say in the introduction to Appendix C that water companies should explain how or if they propose to use their emergency reservoir storage in conjunction with their extreme drought actions. Tables 2 and 3 include examples of extreme demand and supply actions. While some water companies may consider using some of their emergency reservoir storage as an extreme action, we do not want to encourage the use of this water that has purposely been reserved for an emergency drought level 4.  Reservoir dead storage is the very bottom level of a reservoir and should only be considered as part of an emergency plan.

The drought plan guideline we are consulting on covers the operational actions a water company will take in a drought (up to level 3a). A water company plans for more severe droughts through its emergency plan for drought. These plans are not in the public domain but are required to follow the legislation outlined in section 1.6 in the guideline.

We include a summary level of detail on drought permits and orders in section 4.3 of the guideline. The supplementary guidance includes much more on drought permits and orders such as who water companies need to consult when they apply for a drought permit or order. 

Section 5 in the guideline includes information on how water companies should scale up their communications at each drought level and consider the different customers and sectors that would be impacted. This also involves how the company will collaborate with other water companies and their regional water resources group. No further change is required to this section.

Water companies would work through the water retailers to influence communication with the non-household customers and would not require customer contact information. 

Extreme drought actions should only be implemented when triggered in a severe drought and after level 3a demand and supply actions have been implemented and been in operation long enough to provide the associated benefits. A water company could choose to bring forward its demand actions (ahead of its triggers) if required.

Further work before next drought round

We plan to look into the comments we received regarding the difficulty one water company referred to for including and representing in a clear way for customers the “set” triggers for extreme drought management actions. We do recognise in the guideline that flexibility is needed and say in the guideline “You may need to build in flexibility to these phases based on the situation on the ground.”

3.5 Question 5. Do you think customers and stakeholders will gain a better understanding of their water company drought plans through the water company summaries?

Of the respondents through the online consultation:

• 72% of respondents agreed
• 22% were neutral

We received 23 comments in total of which 11 responses suggested changes.

We received 11 responses on the updates to the customer and stakeholder summary, previously called the ‘Non-Technical Summary’. Respondents were mostly in support of the summary, providing suggestions for ways to improve the text.

We have changed the guideline

We:

• amended section 9.1 to say water companies could consider using the customer and stakeholder summary during dry weather to support their media campaigns
• clarified that the customer and stakeholder summary covers non-household customers as well as household customers
• have suggested that water companies could use simple graphics for each stage of a drought to show customers what happens as a drought worsens
• have included more emphasis on the impact on the local area and the importance of and relevance of water in our lives
• in section 5, amended the guideline to suggest a company uses other water company experience and lessons from previous drought events when developing its plan and messaging

Where we have not changed the guideline

We:

• have not removed the suggestion that water companies signpost to the WRMP and other plans within the customer and stakeholder summary, as we suggest that customers should be able to easily find further reading resources
• have not included reference to specific research on communicating water management during a drought within the customer and stakeholder summary
• have not included a reference to flooding within Section 9.1 as to not confuse what is included in a drought plan
• in section 9.1, have not included specific examples of environmental impacts that might occur at each stage of a drought, as this will vary across the country at different geographies. We have clarified this in the text
• have not included reference to year-round communications and messaging as this is regarded as business-as-usual messaging, whereas the drought plan is outlining how a water company will scale up its business-as-usual demand management actions before, during and after a drought

3.6 Question 6. Is there anything in the guideline which you think is unclear, missing or wrong?

Of the respondents through the online consultation:

• 72% of respondents said yes
• 28% said no

We received 26 comments in total.

Where responses to this question either duplicated issues already raised and answered in another question, we have not repeated the issue here.

We have changed the guideline

We:

• amended section 1.6 to say the level of service a company presents in its drought plan should align with its WRMP
• amended section 4.3.1 so demand actions should be in place for long enough in advance of an application for a drought permit or order to see if they have had a measurable impact on reducing demand
• amended section 8.2 on reviewing a plan after a drought to ask water companies to consider views of other groups such as local resilience forums

We have amended the supplementary guidance on environmental assessment to include references to Historic England (sections 2, 3.5 and 3.6) and Table 1 (section 3.6) is updated to remove the word minimum and to be clear it is a “should” rather than a “must”. We have also included additional text to recognise that all actions, including licensed sources, should have some level of environmental assessment to support prioritisation and undertaking the strategic environmental assessment (SEA).  

Where we have not changed the guideline

We received responses on the following topics:

• it is up to the water companies and the Association of Drainage Authorities or IDBs to further discuss how IDB assets could be used during drought
• the focus of the guideline is on the operational actions water companies need to take during a drought. There are other projects that have looked at how, for example, water company owned reservoirs can be used to reduce the flood risk while at the same time still maintaining duty to provide public water supply
• comment “…little consideration of environmental drought” – the guideline covers how water companies should manage a public water supply drought. Water company abstractions that are deemed or are unsustainable are dealt with through other mechanisms such as the water industry national environment programme (WINEP).  Further information on environmental drought is covered in the Environmental Agency’s document “Drought: how it is managed in England”
• linking to local resilience forum (LRFs) plans – we don’t link to other stakeholders plans in our guidance for the water companies on managing a drought
• drought level 4 guidance (the emergency plan for drought) is not covered in our guideline and the section on communications advises when companies should engage with customers, stakeholders and others. LRFs and others can review what individual water companies propose when they consult on their draft drought plans in 2025
• flexibility in how a water company responds to a drought is discussed in the introduction to the guideline and is part of alternative pathways as discussed in the section on extreme drought actions
• an SEA would include an assessment of landscape and archaeological features if appropriate, this does not need highlighting in the main guideline. Historic England is a statutory consultee for environmental assessment and not a regulator so is not listed in section 6
• we have reviewed and updated our procedures following water company drought permit and order applications in 2022. It is for water companies to ensure they are application ready and some applications were delayed because this was found not to be the case
• water efficiency communications are a legal obligation for water companies all the time not just during drought
• references to pre-consultation discussions concern the need for water companies to discuss with regulators and others what actions a water company proposes to include in its drought plan, before it publicly consults on is draft plan
• environmental groups should be consulted and while further examples have been added to section 2.1 as a result of this consultation, it is for the individual water company to look at which groups it should contact in relation to its location and geography
• the guideline says, “To minimise the impact on the environment, you should consider what other actions can be implemented instead of relying on any abstractions:” This does not undermine WINEP, but asks water companies to consider including abstractions they know are unsustainable after less damaging drought actions in their prioritised list of drought actions
• a water company is responsible for its messaging and could choose to work with other partners. We don’t direct that. In the 2004/6 drought, all the south east England water companies pooled to make a “beat the drought” website.  The regional water resources groups are looking into what communications and coordination role they will play in future droughts. Water companies should be clear on accessibility requirements for vulnerable customers as they communicate with them all the time, not just in drought
• no change to section 4.3.1 with regards “increasing volumes above recent actual abstraction during a drought.“ Although a licenced abstraction can legally be used to its full volume, we are appealing to water companies to consider that if they don’t normally abstract full volume or above recent actual, to think if doing so would be more damaging than another supply action
• the supplementary guidance on drought permits and orders includes a summary of the differences between a drought order and a drought permit and the different circumstances where one or other would apply
• we have not amended the wording in section 4.3 supply actions. Supply actions must be prioritised based on their impact on the environment. The impact on customers, as referred to in the legislation, is not relevant to the supply actions. The supply actions should then be prioritised based on the benefit they provide.

Further work before next drought round

This work includes the following:

• consider what future changes could be made to the drought plan guideline to account likely general increase in smart metering and how this could be used to drive further demand savings
• we have reviewed references to LRFs and Fire and Rescue services throughout the guideline. There are existing references in the communication sections 5.2 and 5.4.  We will follow up with our national drought team on how these organisations are included the Environment Agency’s operational management of drought
• we will review the comments received from the Centre for Climate Change and Social Transformations
• we have committed to doing further work on environmental triggers that will consider the comments we have received but the ask still stands for the water companies on what they can do locally
• the inclusion of section 4.2.2 on further demand actions is an ambitious step to do more to reduce the need for supply actions that may have an environmental impact and to reduce or delay any move to emergency drought plan measures such as standpipes and rota cuts. However, this is only a first step and we plan to do more work with water companies and others
• we will review the findings of the UK Water Industry Research (UKWIR) project on non-essential use bans (NEUBs) once completed and then consider what changes may be required to the guideline and if any further guidance is required in relation to the NEUBs process

4. Next steps

We will review the draft drought plans that the water companies write using this guideline. Water companies will start consulting on their draft plans in autumn or winter 2025.  We will work on future work listed in this document in preparation for the next planning round.

5. Appendix A: List of respondents

The following water companies responded:

• Affinity Water
• Anglian Water
• Portsmouth Water
• Severn Trent Water
• South East Water
• South West Water
• Thames Water
• United Utilities Water
• Yorkshire Water
• ESP Utilities group

The following organisations and groups responded:

• Canal and Rivers Trust (CRT)
• Consumer Council for Water (CCW)
• MOSL – the operator of the business water market in England
• National Farmers’ Union (NFU)
• Association of Drainage Authorities (ADA)
• Historic England
• Centre of Climate Change and Social Transformations (CAST)
• Blueprint for Water
• Friends of the Lake District
• National Fire Chiefs Council (NFCC) and Kent Fire and Rescue Service
• Open University academic
• Local Resilience Forums (LRFs) – Kent LRF and Suffolk LRF
• Maidstone Borough Council
• Swale Borough Council
• Chartered Institution of Water and Environmental Management (CIWEM)
• Hobson’s Conduit Trust
• Arqiva – a smart metering operator

6. Appendix B: List of consultation questions and percentage responses

The following data is based on the responses received or uploaded to the consultation software and if the respondent chose to answer the question.

Question 1. Is the guideline clear on what water companies “must” and “should” include in their drought plans?

There were 31 responses to this question and 26 comments.

Answer	Total	Percent
Very clear	5	16%
Clear	17	53%
Neutral	7	22%
Unclear	1	3%
Very unclear	1	3%
Prefer not to answer	0	0%
Not answered	1	3%

Question 2. Is the guideline clear on how water companies should show the actions they will take at each drought level?

There were 30 responses to this question and 23 comments.

Answer	Total	Percent
Very clear	8	25%
Clear	12	38%
Neutral	7	22%
Unclear	2	6%
Very unclear	1	3%
Prefer not to answer	0	0%
Not answered	2	6%

Question 3. Are the further demand actions proposed to reduce residential customer water use in the guideline adequately explained for the water companies?

There were 30 responses to this question and 25 comments.

Answer	Total	Percent
Strongly agree	4	13%
Agree	10	31%
Neither agree or disagree	9	28%
Disagree	3	9%
Strongly disagree	4	13%
Prefer not to answer	0	0%
Not answered	2	6%

Question 4. Do you think the information provided on extreme drought management actions will help water companies in planning for a more severe drought in the future?

There were 30 responses to this question and 26 responses.

Answer	Total	Percent
Strongly agree	2	6%
Agree	14	44%
Neither agree or disagree	8	25%
Disagree	4	13%
Strongly disagree	2	6%
Prefer not to answer	0	0%
Not answered	2	6%

Question 5. Do you think customers and stakeholders will gain a better understanding of their water company drought plans through the water company summaries?

There were 31 responses to this question and 23 comments.

Answer	Total	Percent
Strongly agree	7	22%
Agree	16	50%
Neither agree or disagree	7	22%
Disagree	0	0%
Strongly disagree	1	3%
Prefer not to answer	0	0%
Not answered	1	3%

Question 6. Is there anything in the guideline which you think is unclear, missing or wrong?

There were 32 responses to this question and 26 comments.

Answer	Total	Percent
Yes	23	72%
No	9	28%
Not answered	0	0%