Guidance

7. Shadow EPA metrics

Published 15 October 2025

Applies to England and Wales

• Publication for Northern Ireland
• Publication for Scotland

7.1 Abstraction and impounding licence compliance – shadow metric for England only

Background

Water and sewerage companies abstract significant amounts of water from rivers and aquifers each year, and they own and operate numerous water impoundments. These have the potential to impact the water environment and other lawful water users.

The Environment Agency has included narrative on abstraction and impoundment performance in the annual published performance report since the 2015 data year and Natural Resources Wales since the 2017 data year. We will continue to publish information on overall sector licence compliance for all water and sewerage companies in England. Company specific data will continue to be published for companies operating in Wales.

For the Environment Agency this metric has been a shadow metric (not published) since the start of the 2021 calendar year. The Environment Agency plans to introduce it as a live Environmental Performance Assessment (EPA) metric later in the 2026 to 2030 EPA period once the process of data submission and compliance checking is working consistently and effectively. In the interim, the Environment Agency will continue to shadow report the metric. Natural Resources Wales has not applied an abstraction and impounding compliance metric as a shadow or live EPA metric and does not intend to in the period 2026 to 2030.

The shadow metric measures water and sewerage company compliance with the licences they hold and operate. These licences are issued to protect the environment, and we expect 100% compliance in line with legal requirements.

Definition of metric

This metric assesses water and sewerage company compliance with the conditions of the abstraction licences, impounding licences and drought permits they own and operate. The metric includes licences held by the Canal and River Trust that are operated by a water and sewerage company.

Obligation

This metric assesses compliance with abstraction and impounding licences and drought permits granted under the Water Resources Act 1991 (as amended by the Water Act 2003).

Calculation

The calculation for percentage compliance is (B – A) ÷ B × 100 where:

• A is the number of abstraction licences, impounding licences, and drought permits confirmed as failing in a calendar year
• B is the number of abstraction licences, impounding licences, and drought permits on the Environment Agency and Natural Resources Wales register during the calendar year (in force)

The calculation result is rounded to 1 decimal place for assessment against the thresholds that we are developing and for reporting.

An abstraction or impoundment can be confirmed as failing for the following breaches of a licence or drought permit condition:

• exceeding the daily quantity
• exceeding the annual quantity
• exceeding the annual multi-year quantity
• abstraction in breach of a flow or level-based restriction condition (when abstraction must cease or reduce if river flows and levels fall below a prescribed threshold)
• abstraction outside of an authorised abstraction period
• below compensation release flow requirement
• failure to submit a record of abstracted quantities (abstraction returns) by the date specified by us
• failure to comply with any fish, or eel, screening requirement

All breaches described above are included in the metric regardless of the compliance classification scheme (CCS) score (1 to 4) given to each breach.

Frequency of assessment

This metric is assessed annually based on a calendar year, except for annual abstraction volume compliance where the abstraction licence specifies a different definition of the period of the year. For example, financial year (April to March) or water year (October to September).

Expectation

In 2022 the Environment Agency set out its performance expectations for 2025 to 2030 in the Water Industry Strategic Environmental Requirements (WISER). Each water and sewerage company should achieve 100% compliance with the conditions on their licences and permits. The EPA red, amber or green (RAG) status thresholds set are informed by our WISER expectations.

RAG status thresholds

The RAG status thresholds are:

• red – equal to or less than 95.0%
• amber – greater than 95.0% and less than 98.0%
• green – equal to or greater than 98.0%

7.2 Waste water treatment works flow to full treatment (FFT) annual numeric permit limit compliance – shadow metric

Background

Waste water treatment works (WWTW) FFT annual numeric permit limit compliance is a new shadow EPA metric. We intend for this metric to become live for the 2028 data year. During the asset management plan investment cycle for 2020 to 2025 (AMP7) monitors have been installed on storm sewage overflows that control the flow passed forward for full treatment at WWTW. Installation will continue in early AMP8 for completion by December 2026.

The related discharge permit compliance with numeric conditions metric (section 2.4) has been part of the EPA since it was introduced for the 2011 data year – that is for compliance with water quality limits and monitoring requirements for discharging treated waste water. This new flow metric is to assess compliance with annual flow passed forward numeric limits in permits relating to overflows controlling FFT at WWTW. Compliance with other descriptive permit conditions relating to FFT requirements are not part of this metric – they are instead included in the related discharge permit compliance with descriptive conditions metric (section 2.5) which is a new metric for 2026 onwards.

Definition of metric

From the start of each EPA data year (starting 1 January) we assess WWTW compliance with FFT annual limits for flow passed forward readings taken in a calendar year. A WWTW fails where less than 95% of the readings taken whilst the overflow is operating are at or above 92% of the limit. The 92% criteria is based on the plus or minus 8% monitor accuracy required by the MCERTS standard for FFT flow monitors.

Readings are from monitors on storm sewage overflows that control the flow passed forward for full treatment at WWTW. These monitors are for:

• overflow operation (known as U_MON3 in England and W_U_MON3 in Wales)
• flow passed forward (known as U_MON4 in England and W_U_MON4 in Wales)

These will typically be for:

• overflows to storm tanks at WWTW
• overflows at last in line overflows – typically these will be at sewage pumping stations (PS) which pump directly to WWTW

These monitors will be used to assess compliance with a flow passed forward flow limit which controls the FFT to the WWTW.

Annual summary statistics are submitted by the water and sewerage companies by the end of February each year. We assess the percentage of flow readings taken whilst the FFT limiting overflow is operating which are at or above 92% of the flow passed forward limit (known as determinand 2928). Where any overflow that controls the FFT at a WWTW has a result of less than 95%, the associated WWTW has failed for this metric.

Compliance with other descriptive permit conditions relating to FFT requirements (for example monitor provision and data quality requirements) are not part of this metric. They are instead included in the discharge permit compliance with descriptive conditions metric (section 2.5).

Obligation

This metric is relevant to the Environmental Permitting (England & Wales) Regulations 2016 and the Urban Waste Water Treatment (England & Wales) Regulations 1994.

Calculation

The discharges and sites that will be included in the assessment are agreed with water and sewerage companies each autumn. The process of assessment and reporting annual summary statistics will be clearly set out in guidance.

The calculation for percentage compliance is (B – A) ÷ B × 100 where:

• A is the number of FFT monitored WWTW where annual pass forward flow limits controlling FFT (including associated remote overflows permitted to control FFT) are confirmed as failing (see note 1 below) in the calendar year
• B is the number of FFT monitored WWTW with permitted annual pass forward flow limits controlling FFT (including associated remote overflows permitted to control FFT) on the Environment Agency or Natural Resources Wales register during the calendar year (in force)

Note 1: the Environment Agency uses the compliance classification scheme (CCS), and Natural Resources Wales an equivalent method, for assessing compliance with permit conditions. Data assessment during the shadow metric period will inform which CCS scores will be included as failures for this metric.

The calculation result is rounded to 1 decimal place for assessment against the thresholds that we are developing and for reporting.

Note that this WWTW annual numeric FFT limit permit compliance metric is reported as the number of failing sites and not the number of failing permits. At WWTW without a storm overflow, FFT may be controlled by one of more upstream pumping stations. Where a WWTW has more than one numeric flow passed forward limit controlling FFT, if it fails one or more of the permitted limits, it is a failing site for this EPA metric.

Frequency of assessment

This shadow metric is assessed annually based on a calendar year. The reporting year is 1 January to 31 December each year. We intend for this metric to become live for the 2028 data year.

Expectation

In 2022 the Environment Agency set out its performance expectations for 2025 to 2030 in the WISER. The WISER performance expectation is 100% compliance with flow permit conditions. This will inform the EPA RAG status thresholds that we set when the metric is live.

RAG status thresholds

There are no RAG status thresholds at this stage of the shadow metric. Data assessment during the shadow metric period will inform our development of RAG status thresholds for this metric.

Forward look (2031 onwards)

We propose to include compliance with WWTW annual dry weather flow (DWF) permit limits in the EPA from 2031. For the period of 2026 to 2030, DWF (3 in 5 year methodology) compliance will not be a live metric but we will assess data using the definition that has been developed (see section 8.3). This allows time for the amendment of permit conditions to the new 3 in 5 year compliance methodology.

Next: 8. Forward look and future reporting.