1. Objective setting in practice
Peter Pollard UK
Workshop on Disproportionate Costs, 10./ Copenhagen

2. 45 + % at risk
4 months to
set draft objectives
1,000s of water bodies

3. Failure of phosphorus standards
36%
18,462 km

4. Overly complicated approaches won’t work!
Must keep it simple!
Keep in mind its environmental directive not an economics directive

5. Prioritise

6. Aim for progressive improvements over successive planning cycles
Focus on the big problems first
Aim for progressive improvements over successive planning cycles

7. Is there really an adverse impact?
High
certainty
Medium
certainty
Low
certainty
Uncertainty not an issue – prioritise
Low priority for measures
Prioritise for monitoring & investigation
Action to prevent deterioration
Continue to monitor, assess and review
Is there really an adverse impact?

8. Disproportionately expensive
Insufficient certainty there is a problem to solve

9. But if we don’t yet know the cause of the impact
Technically infeasible
No known technical solution is available
Cause of adverse impact is unknown
High
certainty
But if we don’t yet know the cause of the impact

10. Sense check Break down the problem Water quality Water resources
Morphological

11. Work out what improvements will be delivered by existing measures – before spending time on exemptions

12. Pre-WFD national and EU measures UWWTD; Habitats Directive; CAP; etc
Existing local initiatives
Fisheries management projects;
etc

13. Tackling phosphorus Load from discharges < good Cost (NPV) Current
55%
36% -
UWWTD
Habitats
45%
35%
€4.5 billion

14. Develop simple planning assumptions
Simple rules (or models if available) for estimating effects of new measures
National rules about new locally targeted measures (e.g. BAT emission limits; lead-in times; judgements on cost-effectiveness)
Decisions on new national measures (e.g. general binding rules; product controls)
Mercury;
Phosphorus in detergents;
Agricultural GBRs

15. Indicative planning thresholds
Abstraction pressure (rivers, lochs and groundwater)
Indicative planning thresholds
2015
2021
2027
Volume abstracted < 20 % larger than the 'good' standard
Good
Volume abstracted % larger than the 'good' standard
2008 status
2008 status + 1 class
2021 status +1 class
Volume abstracted > 40 % larger than the 'good' standard
2008 status +1 class

16. Technically infeasible
No known technical solution is available
Cause of adverse impact is unknown
Practical constraints prevent implementation by an earlier deadline
Major new capital works likely to take longer to implement (e.g. new reservoir)

17. Judgement about what is reasonable
Comparison with action by others in sector
Unusually high costs
Recognised difficult period for sector
Unusually large investment in recent years
or at other sites
Agreement to act over an extended timetable
Disproportionately expensive
Insufficient certainty there is a problem to solve
Implementation by an earlier deadline would impose disproportionate burdens

18. Agricultural diffuse sources of phosphorus (rivers and lochs)
Current class
Scenario
2015
2021
2027
Moderate
Standard failed by < 20 %
Good
Standard failed by > 20 %
> 20 % plus targeted management plan in place
Poor
Bad
Targeted management plan in place

19. Tackling phosphorus Load from discharges < good Cost (NPV) Current
55%
36% -
UWWTD
Habitats
45%
35%
€4.5 billion
Non-UWWTD
treatment works
35%
31%
€2.3 billion

20. -5.5%
31%
… 15,532 of 50,400 km

21. Based on 0.7 million sample results
Mix …
Load from discharges
Load from diffuse
Based on 0.7 million sample results

22. Diffuse and Discharges
% length
< good
extra Km
complying 36
200 31
2,800
then
30% 27
2,200
reduction
In diffuse
Total
5,600

23. Limits on tackling phosphorus
Load from
discharges
< good
Cost (NPV)
Current
55%
36% -
UWWTD
Habitats
45%
35%
€4.5 billion
Non-UWWTD
treatment works
35%
31%
€2.3 billion
Complete removal
at treatment works &
40 % reduction in diffuse
12 %
€10s billions

24. Disproportionately expensive
Insufficient certainty there is a problem to solve
Implementation by an earlier deadline would impose disproportionate burdens
Not worthwhile in cost verses benefit terms

25. Screening criteria based on costs per kilometre improved
Focus for more
detailed assessment
Unlikely to be disproportionate, except in exceptional circumstances
Likely to be disproportionate except in very exceptional circumstances
Increasingly large benefits needed to balance costs

26. Use the draft plan consultation
Manage expectations – some problems will take longer than 3 cycles to address
Take account of stakeholder responses in setting of final objectives

27. Using simple prioritisation rules
And generalised planning assumptions….
…based on available national analyses
Refine objectives in 2009 and then in each cycle