Valley Water: a missed objective closed with 'continue monitoring'
Valley Water supplies 210,000 customers from 62 pumping stations. Its 2024 objective was to reduce pumping energy intensity from 0.412 to 0.400 kWh/m³, a 3% improvement against the 2023 baseline. Actual 2024 performance was 0.409 kWh/m³. The action plan contained five actions; two have no owner and no start date. A VSD retrofit at four high-lift stations was completed, with a business case claiming 1.9 GWh per year based on the supplier's calculation; twelve months of measurement show 1.2 GWh. 2024 also brought 9% more water delivered and a change in source-water turbidity that increased treatment pumping. The February 2025 management review minuted 'Objective not met - continue monitoring' and closed the item. The annual report to the board still quotes 1.9 GWh, and the energy team describes the year as 'a 0.8% improvement plus 1.9 GWh of savings'.
1. Evaluate how the missed objective was handled against 10.2 and 9.3.3.
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10.2 is not satisfied. Corrective action requires reacting to the nonconformity, evaluating the need for action to eliminate the cause (root cause), implementing action, reviewing its effectiveness, updating risks and opportunities, and making changes to the EnMS if necessary, all with documented information. 'Continue monitoring' does none of these: it neither identifies why the target was missed nor commits to anything checkable. Monitoring is what should already have been happening.
The root cause is not obviously 'effort'. Candidates: two actions never resourced (a 6.2 action-plan failure - no owner, no date, no resources); an objective set without a normalisation method for volume and source-water quality, so a 3% target may have been unachievable or unfairly measured; and no in-year review to catch the drift.
9.3.3 outputs are missing. Management review outputs must include decisions on improvement opportunities and any need to change the EnMS. Closing the item produces neither.
Action now: recompute 2024 performance normalised for volume and turbidity to see what the real shortfall is; analyse each of the five actions (done, not done, effective); set a corrective action with an owner, a date and an effectiveness check; log the two unsupported actions as a 6.2 action-plan nonconformity; reopen the objective at the next review.
2. What is wrong with the savings reporting, and how should it be corrected?
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Three problems, in increasing order of seriousness.
Predicted versus verified. 1.9 GWh is an ex-ante engineering estimate from a supplier, not a measured result. Measured savings are 1.2 GWh. Reporting the estimate to the board as an achieved figure is inaccurate, and it will eventually be contradicted by the bills.
Double counting. The VSD savings are already inside the 0.409 kWh/m³ figure. Presenting '0.8% improvement plus 1.9 GWh' adds a project saving to a performance indicator that contains it. The team is claiming the same electrons twice.
Missing basis. No stated measurement boundary, baseline period, or adjustment for the 9% volume increase. Pumping savings are volume-sensitive; a larger volume delivered changes both the baseline and the achieved figure.
Correction: withdraw the 1.9 GWh from external reporting, restate it as a predicted saving, and report verified savings of 1.2 GWh with the measurement method (boundary, baseline, adjustment for volume, meter sources) and an explanation of the gap from prediction. Keep the two concepts separate in all board material - energy performance improvement (the EnPI against the EnB) and project-level energy savings. Then update 9.1 monitoring so future project claims are verified before they enter any report.
3. How should the 2025 objective and action plan be constructed so they meet 6.2 and can actually be evaluated?
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Define the indicator before the target. State the EnPI explicitly: kWh/m³, normalised by a documented model that includes volume delivered and a source-water quality term, with the method and data sources recorded (6.4). Without that, 2025 repeats 2024's argument about whether the target was fair.
Baseline. Confirm the EnB and whether the turbidity change is a permanent structural change requiring adjustment (6.5) rather than a variable. Decide once, record it.
Set the target from analysis, not aspiration. Take the energy review's identified potential across the 62 stations, rank by cost and payback, and set a figure the funded actions can deliver. If the credible number is 1.5%, set 1.5% and hit it; a 3% target with unfunded actions trains people to ignore targets.
Action plan with the five elements of 6.2: what will be done, what resources, who is responsible, when it completes, and how results will be evaluated - including the interim checkpoints, so a drifting year is visible in June rather than February.
Review cadence. Quarterly EnPI review with a defined deviation threshold that triggers investigation under 9.1; management review receives the normalised trend, not just the bills.