(Picture above: the Mel near Cambridge. Cinderella chalk streams like these – and there are many in the eastern region – must be protected too)

I have submitted a reply to the WRE emerging plan consultation, posted below for those interested in protecting chalk streams. You will see I have highlighted the need for a greater level of detail, down to the tributary level, especially because so many eastern chalk streams are tributaries of larger, heavily modified lowland river systems and can get overlooked or inadequately assessed / protected as a result: all points highlighted in the CaBA chalk streams restoration strategy. I encourage anyone passionate about chalk streams to take the time to make an online submission to WRE.

You can read the WRE plan HERE

And you can submit a response HERE

1. Name and organisation

Charles Rangeley-Wilson: this is a personal submission but is informed by my roles as chair CaBA chalk stream restoration group / spokesperson for the Chalk Streams First coalition / vice-chair of environmental advisory group WRSE

2. Email and contact number

3. Member of WRE? n/a

4. In our emerging plan, have we gained a clear initial view of the problem of future water deficits across all sectors and the environment?

Table 5.1 identifies the considerable future water deficits, of which sustainability reductions are by far the largest portion with a range of 795 – 1,325 Ml/d out of a total 703 – 2,267 Ml/d. These are huge deficits which will require intelligent and bespoke analysis of prioritisation and strategies for a staged delivery that gives the greatest ecological gain, in the shortest time-frame. 

The EA’s waterbody abstraction tool has applied a numerical methodology to what is also, and perhaps ultimately, a value-judgement exercise in assessing ecological sensitivity. My concern is that by delegating the process solely to tools, models and numbers we will address large deficits in places where we might not need to, or where the need is of a lower order (surface flows at the lower ends of very heavily modified waterbodies) or conversely, fail to identify deficits in places where we really need to, especially chalk streams, and especially because eastern England contains so many small “Cinderella” chalk streams whose assessments are currently lost within much larger waterbody assessments at WFD level and in other methodologies. 

The Appendix of the CaBA Chalk stream strategy shows, for example, that the Oughton is part of the middle Hiz waterbody (thus the special ecology of the Oughton is not properly assessed). Across the catchment boundary to the east the Cheney and Chardle are part of the upper Rhee (none of which are assessed). In the same catchment the Whaddon, Mel and Hoffer Brooks are not assessed. Further down the Cam, the Wilbraham and Fulbourne are part of the Quy Water waterbody and none are assessed. The Bourne (a chalk tributary) is part of the Granta waterbody. In north east Norfolk, the Hun is not assessed. Are these chalk streams going to be seen, let alone protected, by these higher level number-crunching exercises? Thus far there is just not enough granular detail at the catchment and tributary level to give assurance. 

The map reproduced on page 92 appears to have captured the ecological sensitivity of the upper River Nar, and Wensum, for example, but not the neighbouring River Babingley (one of the most heavily abstracted chalk rivers in the country), nor the chalk streams of the Cam and Hiz catchments mentioned above, while the Hun has been abandoned to the North Norfolk fringe where up to 40% abstraction is deemed acceptable. 

In the interests of protecting the region’s chalk streams, which are a priority habitat, I would like to see far more detail and a principle of groundwater / flow protection as defined in the Recommendation 1 of the CaBA Chalk stream restoration strategy whereby abstraction is limited to that which ensures of flows within 10% of natural on all chalk streams. All the information on chalk stream waterbodies is contained in the CaBA strategy and the revised priority habitat map, but I’d be happy to help identify and outline ALL the chalk tributaries in the WRE region. I have some other concerns about the blanket methodologies which I will outline in the answer to Q7 below.

5. In our emerging plan, are we taking the right approach to identify potential solutions to mitigate the challenge?

I found Section 6 “Our Approach” a confusing read (too much jargon) and I wonder how many non-specialist readers will get through it, let alone understand it. Lines like these mean nothing to the lay reader, really: “Our decision support tool, brought to life through Polyvis, consolidates numerous complex analytical outputs against our best value search and tracked metrics, to illustrate performance and inform discussions” or “Polyvis simplifies the multi-dimensional trade-off space to provide a useful tool to support the decision-making of supply option portfolios, through the presentation of option performance against our key search and tracked metrics”. I’d really like to see this translated into plain English, at least as a summary: explaining the approach in fewer than 500 words without using any jargon at all.

6. Does our emerging adaptive plan, including the immediate low-regret options such as reservoirs, look like it will help address the problem?

It does look like it will help. But there isn’t enough detail to be wholly reassuring: what savings can be realised through demand management and leakage reduction? What is the cost of desalination per Ml/d versus the prioritisation of the deficits? In terms of low-regret options there is no mention anywhere of using flow recovery (the Chalk Streams First model) to combine ecological recovery with water resource options by re-aligning abstraction from upper catchment groundwater to lower catchment surface flows. 

Not only that, but there appears to be a counter-intuitive staging in the methodology of abstraction reduction (see Q7 below) which flies in the face of the flow-recovery option. This would seem to me a considerable oversight, especially if early-doors, no-regrets options are the order of the day up to 2050. Chalk Streams First flow recovery goes hand in hand with no-regrets storage options such as the Fenland reservoir. 

7. In our emerging plan, are the technical methodologies, processes and decision support tools which we have used robust and appropriate for the task?

I have described above my concerns that many of the regions chalk streams are being lost and that the level of deficit analysis should be analysed at a catchment and tributary level. 

I am very pleased to see that principle of upstream first as the first stage in the address of abstraction reductions. This is excellent news.

But I do have concerns about the prioritisation as described on page 93 Appendix C especially where surface water licences are reduced before groundwater licences on the basis that this would impact DO less during periods of low flow. I can see the logic of this and indeed I feel that the capacity for allowing exceptional groundwater abstraction as a 1:100 or 1:500 resilience measure may be prudent. BUT this ordering of reduction appears to contradict the potential to use flow recovery to realign abstraction from upper catchment groundwater abstraction to lower catchment surface water abstraction. 

It is also worth highlighting what I feel is an anomaly (for chalk streams specifically) in the EFI whereby higher groundwater abstraction rates are allowable at higher flow rates. This anomaly – in terms of the ecological protection of groundwater-dominated streams – has been highlighted in the CaBA strategy. Allowing up to say 30% groundwater abstraction at Q30 flows (indicated in your map as possible in the upper Babingley, for example) will mean that it is impossible to meet a 10% maximum reduction from natural flows at Q95. The only way this circle can be squared is by measuring the flow much further down the chalk stream and probably including discharges in the assessment: for example the chalk reaches of the Ivel are assessed as supporting good status for flows, in spite of the fact that its aquifer is one of the most heavily abstracted in the country: this can only be because flows are assessed further downstream. 

Groundwater abstraction and river flows are temporally related in a much more complex and time-lagged way than surface water abstraction and surface flows, so that allowing abstractions up to a certain % at specified flows only makes sense with surface water abstraction, when the high-flow is a present and abundant resource, flowing past the door, so to speak. 

In short, I would like to see a lot more bespoke work in this plan that captures the distinct properties of chalk streams and how they work and utilises that to the ecological benefit of streams and the range of DO options on the table. This would require a much more fulsome adoption of the Chalk Streams First / flow-recovery principle at a tributary and catchment level and I suspect it might mean a small rethink over the staged parts of the Waterbody Abstraction Tool, so that we don’t have one precluding the other.

8. Has our emerging regional plan been co-created in a fair, open and transparent process involving the right stakeholders and organisations?

Yes, as far as I can tell and apart from my reservations over the jargon and over-reliance on complex tools and methodologies that cannot ever do as good a job of expressing difficult ideas in a simple way as plain English and well expressed arguments.

9. Are there any areas which you feel WRE should be considering which are not currently reflected in our plan? What have we missed?

I would like to see:

• an analysis of the degree and distribution of abstraction pressures in all the chalk streams of the WRE region

• a greater level of detail – catchment and tributary level – of the required deficit reductions

• a prioritisation of ecological importance that is not simply delegated to a number-crunching methodology

• a simple and comprehensible way of correlating the ecological benefits of reducing flow deficits at a catchment and tributary level of detail against the financial and ecological cost of each method of addressing that deficit: this is so we spend resources wisely, do not swap one ecological problem for another and prioritise limited resources to start in the places and at a scale of operation that will yield the maximum gain in the shortest timescale

• flow recovery in the chalk streams should be an integral part of that process.

10. Is there anything else you would like to add?

Thank you for the opportunity to contribute to the emerging plan.