We are the Environment, Housing and Infrastructure Scrutiny Panel. It's our role to scrutinise Jersey's government on matters of public importance, policy and legislation which falls within these three remits.
The Policy Issue
The Bridging Liquid Waste Strategy Update 2023-26 (BLWS) was published on 2nd May 2023 and is intended to update the Waste Water Strategy previously published in March 2014. The 2014 strategy defined the requirements for a new Sewage Treatment Works (STW) at Bellozanne, as well as ‘Business As Usual’ Projects, including renewal of liquid waste assets (STW & pumping stations) and foul and surface water network improvements. The BLWS aims to plan for the further demands of the 21st century including population growth; climate change; and increasing demands on the ageing sewerage and drainage network.
Whilst the new Sewage Treatment Works at Bellozanne is now complete as of December 2023, and has the capacity to deal with increased connected population, the sewerage and drainage network requires significant investment to be able to serve the Island’s needs. Currently, it poses “serious risk” of:
- Sewage overflows/back flows into property
- Increased risk of pollution incidents
- Almost certain risk of flooding
- Restricted location/volumes of housing developments
- Network failure
An estimated £52.4m will be required to fund various projects from 2023 – 2027 to upgrade the sewerage and drainage networks before the proposed Bridging Island Plan housing developments, as well as any future developments, can be connected to the network. This funding is in addition to an estimated £49.7m required for ‘Business as Usual’ projects which are required to ‘catch up’ on the underinvestment in the network over the last few years.
The Panel's Review
In consideration of the pressing need to invest significantly in increasing capacity within the sewerage and drainage network, several key issues emerged which prompted the Panel to launch its review, namely:
- the sewerage network is ageing and already at its limit, particularly in diurnal peaks and during storms resulting in insufficient infrastructure capacity to accommodate new developments and to meet affordable housing targets set out in the Bridging Island Plan.
- Recent flooding events have further flagged the necessity to improve and maintain the drainage network and to prevent sewerage overspills from occurring.
- The investment required for upgrading the sewerage and drainage network is significant and will need to be agreed by the States’ Assembly.
- A long-term strategic approach by Government to delivery of the capital programme is needed.
The Panel has considered evidence from written submissions received from targeted key stakeholders, as well as public hearings held with Ministers. The Panel was also provided with the Infrastructure and Environment Department’s Asset Management Plans and Strategic Outline Business Case for the funding proposals included in the Government Plan 2024-2027.
The Panel’s review has also been informed by the engagement of expert advisers, Indepen UK, an advisory and policy consultancy who have a strong presence in water supporting the sector through policy, regulatory and delivery strategies to meet future challenges. Indepen’s role involved reviewing the Bridging Liquid Waste Strategy 2023-2026, analysing the evidence presented and providing their assessment and recommendations for improvement. Indepen's final report can be found in Appendix 3 of the Panel's full report.
Our review has resulted in 27 key findings and 23 recommendations which will be responded to by Ministers by the end of February 2024. A summary of these findings and recommendations follows next. Alternatively, to read them all in detail, click on the full report below.
Infrastructure capacity for new and existing homes
The Panel found that despite a number of sites being approved for re-zoning for affordable housing in the Bridging Island Plan 2022-2025, sewerage and drainage network capacity issues have resulted in delays to delivering the affordable housing delivery targets. Additionally, the exact location and timing of new housing development is uncertain with the Government of Jersey’s preferred strategy to complete capacity works within the next 5 years. However, there is a risk that the additional capacity could be under-utilised or not utilised at all if new development does not proceed and which the Panel’s expert adviser deems could result in a “suboptimal investment plan”.
In terms of existing homes, it is asserted that 1 in 4 existing homes in Trinity are not connected to the mains sewerage network and there is a 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.
The Panel has recommended that the programme of liquid waste works identified in the short-term should be considered ‘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. Furthermore, whilst design works and identifying land for new infrastructure assets should be progressed, investment should be deferred until housing phasing is known. The aim being to avoid unnecessary tie up of capital that might be better deployed elsewhere.
Improving surface water management
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. The Panel has recommended that this should be addressed fully in the longer-term Liquid Waste Strategy 2025-2035. Additionally, the Panel stresses that there is a very clear need for approaches to water supply and liquid waste management to be integrated and to move away from the current siloed approach of tackling each separately. Best practice and successful outcomes can be learned from looking at other jurisdictions and their approaches to surface water management and wastewater strategy development in general. Stakeholder and community engagement is key to this process. The Panel has recommended that a partnered approach is taken between Government and Jersey Water to implementing an Integrated Water Management Plan by the end of 2025.
Our review has found that 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 (SuDS), rainwater harvesting and reduced consumption. Our review has found that different types of attenuation or separation approaches to SuDS could be utilised. For example, water harvesting on new development for uses such as flushing toilets, or external use such as watering plants.
The Panel has made several further recommendations to Government around managing and improving the approach to surface water management, including:
- identifying areas where works are required to reduce flooding risks, making allowance for climate change in the absence of a complete climate change assessment, and factoring in these considerations to the future Liquid Waste Strategy 2025-2035 and Integrated Water Management Plan;
- reviewing 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;
- considering the merits of implementing a trial scheme offering free ‘leaky’ water butts to residents in flood catchments areas to slow down flow rates in periods of heavy rainfall; and
- establishing 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.
The importance of stakeholder and community engagement
The development of the Bridging Liquid Waste Strategy 2023-2026 has not been informed by stakeholder engagement or consultation. Having considered the expert adviser’s findings, it is found that failure to engage communities is likely 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.
Furthermore, early engagement with Jersey’s construction industry on long-term capital works planning will be essential for the smooth delivery of large-scale Government of Jersey capital projects. The Panel has recommended that Government facilitates early engagement with the construction industry on a programme of planned infrastructure capital works, so that industry are able to forecast and resource themselves with more certainty and so they are able to deliver what is needed from them.
In addition, the Panel has recommended that there should be 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 Liquid Waste Strategy 2025-2035.
The need for a more strategic approach and sustainable, long-term financing plan
Whilst it has been found that the Bridging Liquid Waste Strategy 2023-2026 represents a coherent plan to address issues through specific asset-based network interventions, 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 potential alternatives.
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.
It is acknowledged that there is a need for better longer-term planning and funding of capital projects across Government and a sustainable funding mechanism is being explored 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 next Proposed Government Plan 2025-2028.
The Panel found that 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 priortising early investment to manage risk over options to phase investment based on impending need. This results in a higher cost and an opportunity cost that the money is not available for other uses.
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.
The Panel observed that 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 performance and is potentially less resilient. Furthermore, the strategy is based on cost and risk approach with limited options presented and risks not quantified. This means it does not optimise investment and phasing.
The Panel has recommended that Ministers work collaboratively to deliver a Strategic Direction within the timescale of the current Bridging Liquid Waste Strategy 2023-2026 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 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.
In terms of long-term financing, the Panel has recommended that there should be a longer-term approach to the planning and funding of key infrastructure capital projects and that Ministers need to deliver a solution prior to the next Government Plan 2025-2028. Furthermore, that an approach to phasing some sewerage and drainage network upgrades over a longer period should be considered. 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.
Ministers should 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 next Government Plan 2025-2028.
The Panel has further recommended that the Infrastructure and Environment Department reviews its risk tools and metrics to enable finer tuning of its investment 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. A wider set of options should also 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.
Conclusion
There is a pressing need to invest in the Island’s liquid waste and drainage infrastructure, to address both ageing network assets but also issues of capacity, particularly where this is holding up much-needed affordable housing developments. However, it is clear there is a need to take a more strategic, long-term approach to planning and funding the infrastructure capital programme moving forward. We are therefore pleased to see that there is an acknowledgement from Government that this needs to be addressed to achieve successful delivery of key infrastructure projects into the future.
Overall, the Bridging Liquid Waste Strategy 2023-2026 has been found by our expert adviser to represent a “coherent plan to address the issues through specific asset-based network interventions.” However, it is more of an asset management plan than a strategy. A strategy would consider alternative options and approaches and the lack of this analysis in the Bridging Liquid Waste Strategy 2023-2026 makes it difficult to assess whether the plan represents the best value approach versus potential alternative solutions. There are, however, several ‘low or no regret’ options presented which should be progressed to deliver essential upgrades to the network. We urge the Minister for Infrastructure to ensure that where there are currently gaps in the evidence that these options should be deferred until the longer-term Liquid Waste Strategy 2025-2035 to ensure that the best, most cost-effective solutions are delivered.
Funding the full programme of liquid waste works will be considerable and the Panel looks forward to monitoring the ongoing progress of a long-term financing plan, in particular the exploration of user-pay charges for waste charging. The Panel stresses the importance that stakeholder and community engagement is used to inform these proposals from an early stage.
We hope our recommendations provide helpful, constructive feedback to Ministers. It is important that whilst action must be taken now to address the condition of the Island’s infrastructure assets, important consideration should also be given to delivering proposed solutions that offer the best value for money for the taxpayer who will ultimately be funding these works.