This document was created following a Save The Teifi Community Meeting - see this link 

In autumn 2023 Save the Teifi held a community meeting to explore feelings and discuss a response following the media coverage of the Cardigan sewage work spills based on a investigation and report by Peter Hammond from campaign group Windrush Against Sewage Pollution (WASP). https://www.bbc.co.uk/news/science-environment-67077510.amp

The meeting facilitated discussions to identified the keys concerns of those at the meeting and the expected actions. These were turned into a list of concerns and responses and the Save The Teifi Response: 5 Key Asks has been created.

These will be shared with CEO of Dwr Cymru [See the reply below] and Chair of the Board of NRW; politicians and media. We hope this will show that the community will not let the pollution of the river continue. We hold those responsible to account. We seek to be involved in the health of the river.

These 5 Key Asks are the start of developing The People’s Plan for The River Teifi. We hope over the next year to-work with people, communities, groups and partners to create this plan.

Welsh Water Reply

See the letter from Peter Perry (Chief Executive) here

First of all, can I say that I fully understand the concerns of your group and recognise the discontent that people feel in relation to our impact on the Teifi. Whilst we used the appropriate regulatory process to assess and target improvements, I can see that the timescales involved would seem unacceptably protracted. There is a clear lesson learnt for us here.

We are, as you are aware, expending every effort to support the ‘Teifi Demonstrator Catchment’ programme being promoted by Natural Resources Wales. As one of the main contributors we have committed resources to the proposal including a dedicated project manager, additional scientific expertise and £1m in funding to help the programmes objectives.

If I may I will respond to the five main points that you have raised:

1.
We are well advanced with the capital investment scheme to upgrade Cardigan waste water treatment works. We are planning to start on site as early as we can at the start of the 2025/26 fiscal year, in April 2025. We are assessing opportunities to start the £20m scheme sooner, involving the local authorities and NRW and will confirm in due course, if we are able to do so. Ahead of starting on site, we intend to submit our planning application to the council in the next couple of months. We will consider the opportunity to utilise a low carbon nature based solution if feasible. We are fully open to explaining our selected proposal as well as the reasoning for it and to share it with you as scheme development progresses. We will also send a newsletter to residents in Cardigan to outline our plans and timescales involved.

We have accelerated £6m phosphate reduction investment at Lampeter and Llanybydder waste water treatment works which discharge into the Teifi, with both upgrades due to be delivered by April 2025. This is part of £140m additional funding brought forward through our ‘not for profit’ structure, across Wales that is enabling us to start work to improve coastal and river quality, which under the regulatory funding structure, would not have commenced until 2025. These two schemes will remove approximately two thirds of our required phosphorous reduction needs in the Teifi catchment.

2.
Within our recent Price Review submission (PR24 covering the 2025 – 2030 regulatory period), we have proposed funds to support a live monitoring trial for the Teifi, looking at water quality. This will also be in support of the ‘Teifi Demonstrator Catchment’ project. To ensure an effective and efficient programme , it is essential that this live monitoring trial aligns with any proposals for further monitoring within the Demonstrator Catchment project, as well as the ambitions of other stakeholders such as local authorities. I would suggest that Kelly Jordon, whom you will know as our respective Coastal and River Quality Liaison Manager, reviews this potential opportunity and keeps your group informed of developments. As recently discussed with Kelly, we will also review our coastal water models and if possible, use them to assess the tidal dynamics of the estuary and share written conclusions with you.

3.
As you are aware, Dwr Cymru have a Citizen Science Support Programme available. This launched in Summer 2023, and we are keen to develop this framework to engage what we understand to be significant levels of interest in the catchment. Further to this we understand the ‘Teifi Demonstrator Catchment’ aims to include Citizen Science aspects, covering both qualitative and quantitative methods . Once again it is crucial to consider the demonstrator project and objectives that build from the pending ‘Hackathon (28th / 29th February) to ensure effective application of community efforts and time, as well as producing useful data sets.
Kelly Jordan has already set up a working group for the Teifi and will be able to keep you informed of our plans and progress through that forum. We are very open to receiving this type of community support to aid us in understanding coastal and riverine ecosystems and from that where appropriate targeting improvements.
4.
I note your comments relating to regulation and the role of Natural Resources Wales. Whilst the focus of this ‘Ask’ is aimed at NRW, I would assure you that we have and will continue to operate in an open and transparent manner when dealing with our regulators. We also apply this approach to other aspects of external scrutiny that is applied to us, such as compliance with Environmental Information Requests and liaison with water user groups. This was acknowledged by Prof. Peter Hammond in relation to his investigative work on the Teifi. We will also continue our support and liaison with the ‘Better River Quality Taskforce for Wales, for overall water quality improvements.

5.
In the current regulatory period, 2020 – 2025, all (100%) variable pay is allocated to performance targets, with 30% allocated to environmental measures. Effectively, there is no bonus scheme per se, as any variable reward is entirely based on the achievement of performance targets. These are set by our Remuneration Committee led by our Senior Independent Non Executive Director. As Executive Directors, we have no direct influence on what we are rewarded. In 2023, Ofwat, the water industry economic regulator reviewed alignment of delivery for customers and the environment in respect of companies variable pay schemes. They considered the Dwr Cymru scheme as being in the highest category for this, achieving 80% compliance with their measurement framework. In fiscal year 202
2/23 Mike Davis, our Chief Financial Officer and I as CEO, declined all our variable pay voluntarily, in recognition of a challenging year in terms of performance for the company.
I note the point about improvements to the river and treatment works must not come from customers’ bills. We receive no other form of income. Respectfully, customer bills are our only source of income to run the business day to day and to fund long term investment. We do not have shareholders meaning that any ‘gain’ or dividend, is retained in the business for the benefit of customers. Since our formation in 2001, we have used any surplus to:

• Improve the financial resilience of the business, where we have used over £2bn to reduce gearing (borrowing) from 93% in 2001 to 58% currently. Our not for profit structure also enables us to borrow at more favourable rates to fund our investment programmes. The current period to 2025 will see over £2bn invested, growing to over £3.5bn between 2025 and 20230.
• Invest an additional £500m in our infrastructure, on top our multi billion regulatory investment programmes since 2001.
• Help those who struggle to pay their water charges, by having by proportion the largest social tariff scheme of any utility in the UK. Currently committing over £12m per annum to help over 130k customers in our operating area.
  

We are always sorry for any adverse impact we have on the environment and we intend to fully engage with communities on the Teifi as we deliver our planned investment and play our part in the ambitious ‘Teifi Demonstrator Catchment’ proposal. This engagement will clearly set out our improvements and respective timescales.

Welsh Water Newsletter March 2024

See full text here

As you may be aware, we’re planning to invest around £20 million to fully replace Cardigan Wastewater Treatment Works (WwTW). We’re writing to you to update you on the next steps of our plans

Our plans
The investment will help us change the treatment process to ensure the site will work more efficiently to cope better
with the influx of salt water from the tidal river. Since identifying the issue of saline intrusion at Cardigan WwTW, we have carried out a number of mitigations and investigations to scope out options to resolve this. This involved working on the sewer network to reduce the ingress of seawater, improvements to the treatment plant to maximise the flows we treat through the works and to investigate an alternative treatment process that can help deal with the conditions in Cardigan. Some of this work has provided marginal improvement for the treatment works but we are now focussing on finding a more sustainable and long-term solution for Cardigan WwTW. In agreement with our regulators, Natural Resources Wales (NRW), we have done this by trialling two different types of treatment at the site for a period of over 12 months. This helped us to identify a new treatment process, which has proven to be the most effective in coping with the varying levels of saltwater present. The new process will enable the works to perform more effectively and help to reduce the spills from this site. During our feasibility work we explored other options, including a nature-based solution for Cardigan. However, this was found to be unsuitable due to the level of saline intrusion at the works, the topography of the site and land area that would be required.

Next steps
We have now completed our investigation and feasibility study at the WwTW and are progressing our detailed design working collaboratively with our supply chain, contractors and regulators to bring forward our plans to invest at Cardigan. The next step in this process is to apply for planning permission, which we plan on submitting to the local authority this month (March 2024). Although the planned start date for our work at Cardigan WwTW remains 1st April 2025, we are continuing to explore opportunities to bring this date forward (subject to ecological licences and planning approval).
Our new temporary treatment process, which was installed at the end of 2023, to help the works cope better during storm conditions will remain operational and in place until our work to replace the treatment works at Cardigan is complete.

Welsh Water - 5 Asks Follow Up - 20 Mar 2024

See full text here

Further responses from Welsh Water relating to our 5 Asks. They have indicated that the new works will not have a constructed wetland attached to it because:-

1. a) The water needs to be disinfected by UV treatment since it is released close to bathing waters
2. b) The saline waters rule out the use of freshwater constructed wetlands
3. c) The footprint would be too large for the site.

Given the variable saline water intrusion into the system the construction of a wetland would be more complex since it would have to cope with fresh and brackish waters and this requires different plants. It is good to see that they are exploring constructed wetlands for other sites in the catchment. 

They have also provided a simple outline of the circulation dynamics of the estuary. In essence their modelling is suggesting that the tidal movements in the estuary dilute and then flush out any sewage that is discharged from Cardigan Waste Water Treatment Works and other assets. This confirms what I would expect for this small estuary system. The incoming tide will hold back the river flow and may push some pollutants up-river. However as the tide falls the backed up water will flow out and carry the pollutants with it, particularly during periods of high river flow. There may be some areas where eddies develop where the mixing is more limited. The key issue will be where the CSO discharge. It they discharge into the main flow then the pollutants will be taken out to sea. If they discharge into eddies they may be harder to flush out.  

They also suggest that a coastal environment is better able to deal/cope with pollutants. Whilst the later may be true it is a rather weak argument.

NRW Response to the Five Asks 

Sir David Henshaw, Chair of NRW sent us a 'holding' message, that included these remarks...

Thank you for your email.

We absolutely recognise the frustrations felt by communities affected by water quality issues, and very much value the work and contributions of groups like Save the Teifi in supporting a collaborative effort to effect the changes we need to see as a society to improve water quality in Wales – from the water companies to industry and agriculture to individual consumer behaviour.

As you will no doubt be aware, regulatory action is continuing at the works in Cardigan. Our investigations into the permit breaches at the site are ongoing and any breaches will be dealt with in line with our Enforcement and Sanctions Policy.  Unfortunately, an enforcement response can take several years to conclude after the initial environmental offence. We have established a review of our responses at the site to identify learning points or process improvements that can be made, as well as capturing current good practice. We expect to provide the Senedd Committee with a report of the findings by the end of May and I will make a note for the team to share this with you.