Guidance

Appendices: Water company drought plan guideline, 2025

Published 16 June 2025

Applies to England and Wales

• Publication for Northern Ireland
• Publication for Scotland

Appendix A: Drought plan process

The Secretary of State (SoS) will direct companies to publish, receive representations and will consult with Welsh Minister for sites in Wales.

Preliminary discussions (pre-consultation)

1. You should decide on the changes you wish to make to your drought plan.

2. You should carry out preliminary discussions with stakeholders.

Preparation of draft drought plan

3. You should prepare your draft drought plan in line with the directions from the SoS.

4. You should submit your draft drought plan to the SoS and, if appropriate, Welsh Ministers.

National security checks

5. Defra will check your draft drought plan for any security concerns and forward to the relevant parties.

6. You will and other third parties may make representations on security concerns to the SoS.

7. Defra will assess these representations and notify companies of the decisions made on commercial confidentiality and national security. The SoS will direct you to publish your draft drought plan.

Publish draft drought plan

8. You should publish and distribute your draft drought plan for consultation as per the Drought Plan (England) Directions.

Representations

9. You will allow a period of time for consultation and representations to be made. Representations from consultees on your plan will be sent to the SoS.

10. Defra will receive and share the representations with you.

11. You should assess the representations on your draft drought plan and publish a statement of response.

Amendments to plan (as directed by SoS)

12. The SoS will assess the need for a hearing or inquiry on your draft drought plan.

13. The SoS will direct you to amend your draft drought plan if necessary.

14. You will be able to object to the direction on the basis of commercial confidentiality if necessary.

15. The SoS will confirm the direction or issue a new direction to you.

16. You should prepare your final drought plan.

Prepare final drought plan

17. The SoS will direct you to publish a final drought plan after checks.

18. You should publish your final drought plan.

Appendix B: Worked examples – testing your drought plan against a range of drought scenarios

As part of your drought plan you should provide selected worked examples to show how you would expect your drought plan to work under a range of droughts.

Your examples should:

• demonstrate how your drought triggers would work in different droughts
• show what actions you’d take in different droughts
• demonstrate the expected time frames and durations for your actions
• show what the effects of a range of droughts such as the worst drought on record

You should test your plan against a selection of different types of drought, as detailed in the guidelines. You should explain the conditions for how each drought example developed and give detail as to which parts of your system were most significantly affected. You should present this as relevant graphs for each of your water resource zones and annotate it to show where your drought trigger points are crossed and when you will carry out the associated actions (see an example graph below). You should clearly show the timings of when you will prepare for and then carry out your various drought management actions to make sure the actions are implemented in time, as well as displaying how these various actions will improve the water resource position for your indicator site so delaying further potentially more environmentally damaging actions. You should also indicate how these actions correspond to the level of drought restrictions – in other words levels 1 to 4.

If you have decided to use alternative pathways in your plan, they can be presented on your worked examples. You should show how your plan could deviate from your core plan to address the risks and uncertainties you have identified. You can choose to start an alternative pathway at any point in your plan.

An example of the sorts of actions you may want to include on your graph are:

• actions to optimise specific existing sources
• contacting Environment Agency and/ or Natural Resources Wales to discuss the situation
• enhanced media campaigns – including requests for voluntary restraint
• enhanced leakage management
• rescheduling planned maintenance if possible
• fast tracking any infrastructure improvements
• planning for, advertising and then implementing temporary use bans, including how far in advance of any drought permits or orders you would aim to do this
• prepare to apply for drought permits or orders
• send formal application for drought permit or order
• hearing held if needed
• permit or order granted
• implement drought permit or order
• timing of implementing any non-essential use ordinary drought orders
• pressure control
• bulk transfers – either limiting your own or enhancing ones from other water companies
• discussions with neighbouring water companies about initiating a change to bulk supply arrangements

Worked example graph

The graph below shows a worked example of reservoir or water resource zone storage and how you could visualise drought triggers and their associated actions over time. The graph also shows at which drought level actions take place. This graph is shown over 3 years. The “x” axis, along the bottom of the graph, presents each month and the “y” axis, along the left side of the graph, presents the percentage storage level associated with a drought level.

The drought levels appear as a stacked bar chart where each level is associated with a lower and upper percentage storage level that varies according to the time of year. For example, percentage storage is shown as higher over the winter months and lower for the summer months for all levels except dead water and emergency storage which is more fixed. From the lower storage levels to the top, the levels shown are:

• dead water (in brown)
• emergency storage (in grey)
• drought level 4, emergency plan for drought (in dark red)
• drought level 3b, severe drought (in red)
• drought level 2 and 3a, drought (in amber)
• drought level 1, prolonged dry weather (in yellow)
• a suggested environmental stress level (in green)

A line graph shows the path of example dry weather that crosses the various drought levels and percentage storage levels. Examples of drought plan actions that could be triggered at different points along this line are shown in text boxes, illustrating the core drought plan in action. Two examples are also given of alternative pathways that could be triggered and lead to different actions away from the main line graph of the core plan.

Appendix C: Extreme drought plan management actions

You should include information in your drought plan to show what actions you plan to take to delay the need to implement your emergency plan for drought and emergency restrictions as a drought worsens. These are actions you would take after using your level 3a drought actions.

You should explain how or if you would use your reservoir emergency storage in conjunction with your extreme actions.

You should also explore the full range of actions included within the ordinary drought order legislation (section 74(2) of the WRA 1991). These include applying to:

• take water from any source specified subject to conditions
• prohibit or limit the use of water for any purpose specified
• discharge water to any place specified subject to restrictions
• prohibit or limit taking of water by an appropriate agency
• suspend or modify restrictions relating to abstraction, discharge, supply, filtration of water

Your extreme actions should:

• be assessed by you as realistic and technically feasible
• include triggers with realistic lead-in times
• be practical to implement
• be likely to be temporary
• generally not result in permanent increases to deployable output i.e. usually distinct from WRMP options

You should regularly review the viability of your extreme actions, any further work you need to do to be implementation ready and the appropriateness of your triggers and lead-in times. 

See Tables 3 and 4 for a list of example extreme demand and supply actions with some background details and examples of significant barriers.

What to include in your drought plan

You should include a summary of the extreme actions you plan to implement at level 3b in your plan. An example format for this has been provided in Table 5.

You should include information for each extreme action on:

• the type of action (supply or demand)
• the water resource zones in which it would apply
• a description of the action and the likely trigger for implementing it
• an indication of the benefit or saving made from implementing the extreme actions
• a list of any significant barriers
• an indication of the timescale for implementation

You should consider the possible constraints on the availability of each extreme action. For example, a wider drought would impact other water companies and may lead to competition for limited resources such as road and sea tankers. 

You should provide background details on the extreme actions you have selected that covers: 

• the measures you have used to screen your extreme actions
• the actions you have discounted and the reasons for this
• how you have prioritised the sequence of implementing of extreme actions
• any significant work you will need to complete in advance for an extreme action
• when and how you will review the viability and appropriateness of your extreme actions
• which actions you would fast track, if needed

Regional plans

You should engage with your regional water resources group and its members when developing your extreme actions in order to look at how to save and share water resources. You should decide what collaborative actions you could take with neighbouring water companies and across your regional water resources group.

Table 3: Examples of extreme demand actions

If you are proposing any extreme actions that may affect sites in Wales, you should discuss these with Natural Resources Wales.

Type of action	Background	Any significant barriers
Removal of non-statutory exceptions	Consider removing non-statutory exceptions under temporary use bans and non-essential use ordinary drought orders.	Not applicable
Media and communications	National campaigns to change culture, excessive water use seen as socially unacceptable, keeping customers aware of the current storage situation, Day Zero language, guides for customers to show how to restrict water use to 50 litres per person per day. Hard hitting messages and images.	Not applicable
Supply pipe repairs	Free and fast supply pipe repairs for customers.	Not applicable
Incentivisation	Reward scheme for using less water, incentive scheme, for example bill rebate, postcode scale targets and reward for all if target met.	Metering
Pressure management	Further reduce pressure while still maintaining essential services, night-time reductions.	DWI standards, vulnerable users
Relocations	Relocate farm stock and/or businesses	Feasibility, water availability
Non-potable use	Set up non-potable water refill points for businesses on a community scale, use of containers in home to capture water for re-use or collection, mobile temporary treatment units to utilise water for non-potable use, temporary rainwater capture systems on buildings, temporary barriers to help capture water in fields, mass fitting of free water butts in homes.	Volume, health concerns, workforce.
Water efficiency and metering	Specific targeting in high demand areas.	Not applicable

Table 4: Examples of extreme supply actions

If you are proposing any extreme actions that may affect sites in Wales, you should discuss these with Natural Resources Wales.

Type of action	Background	Any significant barriers
Drought orders	Use full range of powers available with drought orders, temporary increases to licences that have been reduced or revoked, compensation flow reductions, abstraction from alternative sources.	Environmental impacts, WFD objectives.
Catchment actions	Water use plans across sectors, link users to share resources, combining drought order applications.	Not applicable
Trades/transfers	Short term trades between water companies, other sectors or third parties. Plans to increase/decrease bulk supplies. For example, actions involving third parties such as water transfers via canal and abstractions from non-water company sources such as a canal reservoir source.	Water availability, Environmental impacts.
Tankering	Moving water around, road and sea tankering.	Competition and availability of tankers, scale required, assess invasive and non-native species, DWI authorisation and agreement
Supply schemes	Fast tracking of WRMP schemes.	Feasibility, time frames.
Network changes	Temporary pipelines, new supplies, speed up construction process, for example overland pipes.	Environmental impact, distance, planning consent.
Water re-use or recycling	Redirecting discharge (direct to supply or relocate to other watercourses).	Environmental impact, DWI constraints.
Desalination	Temporary mobile plants for desalination by water companies near or adjacent to coastal or brackish waters.	Competition and availability in a wider drought. Connectivity to network, environmental impact, scale. DWI authorisation and agreement.
Mothballed sources and re-purposed sources	This also refers to sources referred to as: unused, disused, re-commissioned, de-commissioned, emergency or abandoned. These may be with or without abstraction licences and with or without maintained infrastructure. When re-commissioning unused sources of water that are licensed: - if you have not used the licence for a long time, you will need to complete a new environmental assessment and address the requirements of the Drinking Water Inspectorate - where all or part of an unused licence is found to pose a risk of deterioration, we expect the company to give up that proportion of the licence and to use a drought permit or order if needed to access the water	Environmental impact, DWI constraints, infrastructure development. Confidence in deployable output.
Temporary water treatment	When a source is not currently in use due to water quality issues, considering mobilising temporary water treatment units or filtration plants in order to use this source.	Availability of treatment units and DWI authorisation and agreement.
Alternative water sources for fire fighting	Water companies could work with fire and rescue authorities to agree viable alternative sources of water for firefighting in advance of their need. For example, washout hydrants, increased use of sprinklers which reduce demand on water supplies	To be reviewed.

Table 5: Example format for actions in extreme droughts

Type of action	Such as demand or supply.
Water Resource Zone	Identify the zones affected.
Summary of action	Give brief description of the action.
Trigger for action to be used	Give brief description of the water supply situation that would trigger the action or what actions will precede this.
Estimated benefit / saving	Such as the volume of water made available or saved.
Barriers	Identify any significant barriers or actions required by others before you can implement this action - for example, DWI standards, network constraints.
Environmental impacts	Provide your assessment of the environmental impact and the EARs or monitoring completed or planned and the timelines for this work.
Timescales (in months and years)	Provide an indication of the lead in times and work that would be part of each phase for preparation, mobilisation and implementation. You should identify significant work and provide estimates for time needed to complete such as DWI permissions and environmental assessment work.
Priority order for implementation	Identify the order in which you will implement your extreme actions.

Appendix D: Advice on the structure and format of your plan

You can decide on the precise structure and layout of your drought plan. However, a recommended structure for a drought plan is presented below.

A common structure and approach will help regulators, consultees and customers to make consistent and comparable assessments of drought plans. In addition, retaining a common plan structure between draft and final plans makes it easier to see where changes have been made to a plan in response to consultation.

Section 1: Introduction

• High-level summary of supply system and drought management areas if different
• High-level summary of links to regional water resources group plans, your WRMP and your emergency plan for drought

Section 2: Drought triggers

• Drought triggers for each water resources zone or drought management area
• How you have tested your drought triggers should be in an appendix

Section 3: Drought actions

• Demand actions
• Supply actions including drought permit and order sites
• Level 1-3 category of your actions
• Environmental or other sector actions

Section 4: Extreme drought plan management actions

• An example format table is included in Table 5, Appendix C
• Triggers and the extreme actions including information on their viability and implementation order

Section 5: Customer communications

• Communication plan including triggers and level category
• How you will coordinate communication campaigns across the sector, region and with other interested groups and parties

Section 6: Environmental assessment

• Include a summary of environmental assessments of drought actions in the main guideline or an appendix. Provide a separate full technical environmental assessment report.

Section 7: Recovery from drought

• What actions you will take during recovery from a drought
• Include triggers, your modelling and related assumptions

Section 8: End of drought

• Ensure triggers for end of a drought are included in your drought plan
• How you will review your performance during and directly after a drought

Section 9: What else you should include in your plan

• Drought management structure
• Agreements and arrangements of bulk supplies and transfers as drought escalates
• Links to other plans – this may also be covered in actions and trigger section
• Compensation arrangements

Appendices

• Drought vulnerability assessment if completed as part of drought plan
• How you have tested your drought triggers
• Clearly labelled detailed environmental assessments if not available elsewhere (i.e. on request)