Response to WRSE emerging plan consultation

I have submitted a response to the WRSE emerging plan consultation, posted below for those interested in protecting chalk streams. This is my personal take, but in short I have emphasised the need for:

1. Prioritisation of chalk streams: because I have concerns that we may never afford the upper end of the reductions. Chalk streams need special consideration, no matter what.

2. Certainty: there is much uncertainty in both water-efficiency savings and the large infrastructure schemes. While these things must be strived for, schemes which offer certainty should be top billing in my opinion. 

3. Timeliness: chalk streams have been suffering for 50+ years. We can’t just wait another 30 for the big infrastructure schemes, which will all be subject to enquiries and some of which may never happen. Severn to Thames, the Grand Union Canal and Chalk Streams First can all be delivered in a short time-scale at relatively low cost and can be used to save our chalk streams.

4. More water: we simply need more water per head in our overstretched south east. Schemes like the Grand Union Canal and Severn to Thames transfers achieve this. And if abstraction reduction is deemed a net loss, then Chalk Streams First type flow recovery can actually add a lot of water resource resilience, as the reduction from public supply is only a fraction of the abstraction reduction.

I’ve also emphasised that to make intelligent choices about approach and prioritisation, we need way more detail on the impacts of abstraction and the proposed locations of abstraction reductions, down to tributary level.

I encourage anyone passionate about chalk streams to take the time to make an online submission to WRE. You can make a response online HERE

WRSE emerging plan consultation response

Charles Rangeley-Wilson

Organisation: this is a personal submission but is informed by my roles as:

chair of the CaBA chalk stream restoration group

spokesperson for the Chalk Streams First coalition

vice-chair of environmental advisory group WRSE

Section 1.

1. Abstraction reduction to protect the environment is likely to be the single biggest driver of investment in water resources over the next 25 years. Do you agree with our approach to establishing the appropriate level of abstraction reduction required across the South East England?

The broad parameters of the ‘approach’ seem very sound. I agree with the plan’s articulation of the need to:

• determine the appropriate locations and sizes of abstraction reductions (p6);

• its recognition of the fact that the impact of abstraction varies between catchments (p8); 

• and stated need to agree an appropriate pace and prioritisation of abstraction reductions in order to balance the needs of the environment with the cost and with resilience of supply (p9).

But there is currently not enough detail to see how this will play out in practice. Nor is there quite yet enough information to determine what constitutes ‘appropriate’.

Providing this should be a key part of the next phase of the plan.

In order to assess ‘appropriate’ levels of abstraction reduction we need a much more detailed map and description of the scale and distribution of abstraction pressures and / or of the proposed abstraction reductions under the different scenarios. 

The plan acknowledges that the impact of abstraction varies between catchments, but we need more detail on that variation too.

And difficult though this will be, we also need to qualify our rivers, streams and wetlands into some kind of hierarchical order of ecological importance. Some of the questions in the consultation are, of course, designed to start that process, but without the information above, it is difficult to make really informed statements at this stage.

And ultimately, without an informed, democratic discussion armed with all this information we risk trading environmental damage in places of great ecological value for the alleviation of environmental damage in places of lower ecological value, or we risk making large investments that may ineffectively mitigate ecological damage or conversely, we risk making no investment or not enough investment where we could very easily have successfully mitigated ecological damage.

Focussing on chalk streams

The plan states (page 4.) that we currently use 6000 Ml/d and that over half of this comes from underground sources, the rest from rivers and springs. 

The ways in which abstraction impacts the environment and the ways in which we can mitigate that impact differ depending on the source of the water and type of environment and especially between whether the source is ground- or surface-water.

Chalk rivers need flow but have suffered acutely from the abstraction of groundwater (see p24 of the CaBA chalk stream restoration strategy), especially following the growth of groundwater abstraction from the chalk in the post-war years. 

The Water Act of 1945 attempted to control burgeoning, ad hoc expansion of abstraction and included clauses relating to environmental flow protection, based on flow gauging and hands-off flows. But using gauged-flows to manage the impact of groundwater abstraction is ineffective at protecting natural flows in chalk-streams, where the flow cycle is annual and where groundwater abstraction at all times, including at times of year when flows are high, has a significant impact on flows throughout the year and when flows are low. As is pointed out on p25 of the CaBA chalk stream restoration strategy, the wording of the Act did not allow for this distinction and yet environmental flow protection has been based on the same ideas ever since. 

For example the idea of abstracting more water at high flows and less at low flows simply doesn’t protect flows in groundwater dominated streams. Whilst winterbournes need protecting in an entirely different way, as they naturally don’t flow some of the time. Excessive abstraction turns ephemeral reaches into grassy ditches but current flow assessments do not protect these valuable parts of the stream.

It is very important to take this point on board and duly revise our methods for assessing flows and mitigating the impact of abstraction in chalk-streams, so that when we do make abstraction reductions they actually deliver the improvements we are looking for.

Sustainability reductions made in the chalk streams to date have, it is often stated by regulators and the industry, yielded disappointing results. But if so, this is arguably down to this failure to properly consider the way groundwater abstraction reduces flow: by lowering groundwater levels across the whole catchment, and not just by local interception or capture of flow in the radius of the zone of draw-down as is currently espoused by the water companies.

Thus, sustainability reductions have often been: 

• too small a proportion of the overall groundwater abstraction in a given catchment

• wholly or partially off-set by increases from other groundwater sources in the same catchment

• of too short a time duration (including 12-month shut-downs) to allow groundwater levels to fully recover before assessments are made

• have not been made on a catchment, or even regional spatial scale, so that continuing heavy abstraction in other parts of the aquifer minimises the impact of the reduction or at the least makes discerning results very difficult.

In addition, when each megaliter of licensed groundwater would have a replacement capital cost of about £2-3 million and the primary statutory duty on water companies is to provide a secure public water-supply, it is not quite in the water company’s interests to make these reductions in such a way as to prove their efficacy.

A sustainability reduction made in 1993 at Friar’s Wash on the River Ver, on the other hand, was:

• a significant reduction in absolute terms;

• a significant net reduction to the g’water abstraction in the whole catchment;

and there are long sets of empirical data from the pre-abstraction period, during abstraction and following the abstraction reduction. 

This graph shows flow recovery as a % of the 14.4 Ml/d abstraction reduction made at Friar’s Wash on the River Ver in 1993. Oct 1982 to Sept 1992 = a 10 year period before abstraction-reduction / October 2007 to Sept 2017 a 10 year period following abstraction-reduction. These ten year periods were selected because effective rainfall was exactly the same for both.

These show that flow recovery over the full year is 12.1 Ml/d: most of the abstraction reduction of 14.4 Ml/d. In other words, when the scale of the reduction is a considerable proportion of the abstraction and when it is a genuine net reduction across the whole catchment, approximately 80% of the abstraction reductions manifest as increased surface flows.

In the interests of protecting the environment from the impact of abstraction we need greater transparency of information and we must triangulate decision-making between the industry, regulators and stakeholder interest groups. This hasn’t really happened thus far and although this national framework planning is consultative, the relative lack of detail that could inform the debate above is currently a shortfall.

A%R survey

In the interests of opening up the discussion on chalk streams, the CaBA CSRG commissioned an independent survey into groundwater abstraction as a % of aquifer recharge, which is a simple way to form a baseline analysis of abstraction pressure at a level of detail the current draft of the WRSE plan hasn’t yet provided. From that A%R survey useful insights can be drawn which illustrate the way this detail will aid a more inclusive decision-making processes to the benefit of all.

For example on p17 of the Appendices of the CaBA chalk stream restoration strategy, an analysis of the abstraction reductions needed on the River Colne catchment (as identified by the A10%R target) shows how a prioritisation exercise would indicate deficits of 54.9 Ml/d on all of the most ecologically valuable and iconic chalk stream tributaries, set against a total of 274 Ml/d for the whole system. 

This turns a very large deficit, the mitigation of which would be dependent on large infrastructure costs and a long-term delivery timescale, into a much smaller deficit which could be delivered in the short term, with comparatively much less investment in infrastructure.

If one also then factored in the potential for the flow recovery indicated by the Friar’s Wash data to realign abstraction pressure from groundwater abstraction in the headwaters to surface water abstraction in the lower catchment, across the full year, the 54.9 Ml/d abstraction reduction becomes a net loss to public supply of only 11 Ml/d.

11 Ml/d is a very different number from 274 Ml/d.

It is true that flow recovery is less in summer (less than 50%) and much less in a severe drought (less than 20%) and these drought conditions may well govern the amount of deployable output upon which we can fully rely. Nevertheless, in terms of environmental protection the flow recovery all year round is just as important, while the flow recovery outside the bounds of the 1:100 year drought, can still be used to fill storage reservoirs and supply the public with water. 

Short-term, easy and certain solutions should take precedent

A final point in relation to determining the correct approach and appropriate levels of abstraction reductions so as to create significant, tangible improvements to the environment is the need for timely solutions wherever these are at all possible. 

Many of the strategic schemes will require significant investment in infrastructure, will take a long time to deliver and will be subject to all sorts of public enquiries: note how the 75 Ml/d desalination scheme in Hampshire has been ruled out following local protests.

Equally uncertain, but in a different way, are the savings we will be able to achieve through changes in public behaviour and water use and through building regulations, labelling of goods etc.

These uncertainties mean we must – as a founding principle of out approach – bank obvious, no-regrets gains wherever and whenever we can.

The fundamental need for more water

Whichever way you look at it, the south east region is stretched in terms of the supply of water per capita. Any scheme which brings more water into the region will offer significant and certain improvements to the overall resilience of supply.

While I agree with the 4 principle underpinning the safeguarding of supplies for the future, namely: – 

• efficient use of water and minimal wastage;

• new water sources that provide sustainable and resilient supply;

• a network that can move water around the region;

• catchment and nature-based solutions; 

I feel these are idealistic / optimistic without specifically adding new water sources from outside the region and networks that can bring that water into our region. 

Therefore, I am disappointed that the adoption of 1:500 year planning has greatly reduced the availability of water from other regions. This is effectively allowing other regions to say that although they have more than enough to spare for 499 years in 500, they cannot in fact spare it, in case they need some in that 500th year. 

In a 1:500 year drought everywhere is stretched: that really shouldn’t preclude sharing resources when they are not stretched.

This and the apparent limitation on the degree to which flow recovery in the chalk streams can be factored as a reliable deployable output except under the most pessimistic 1:100 or 1:500 scenarios suggests to me that – in the interests of environmental protection – we need to adopt our planning approach so as to partition water-resource solutions that are also environmentally beneficial all of the time from water-resource resilience challenges that are definitively rare, so to ensure that the latter doesn’t rule out the former.

Of the inter-regional water transfer schemes, the potential to use the Grand Union Canal to transfer up to 400 Ml/d of highly treated effluent from Birmingham to the northern part of the WRSE region, from where it could be used to offset a large number of sustainability reductions in the chalk streams, has not been given nearly enough of a billing in this current draft. This is a scheme with a definable and certain boost to supply via infrastructure that was helpfully built by our forbears more than a century ago. 

2. We’d like to hear your views on how we prioritise where abstraction is reduced. 

Please score the following criteria from 1 to 7 – with 1 being the least important and 7 being the most important.

The instruction above is a bit ambiguous: should I score each criteria out of 7? Or order the 7 options 1 to 7? Therefore I have done both.

Prioritise upper catchments, because headwater ecologies are the most vulnerable and the benefits to flow should improve the whole catchment. 

6/7 or 6

Prioritise catchments where the impacts on flows are the most severe.

6/7 or 5

Prioritise catchments where there is the highest degree of certainty that abstraction reduction will restore flows and deliver environmental improvement.

5/7 (lower score because the science of certainty is poorly resolved at the moment) or 3

Prioritise catchments where people have the most unrestricted access to rivers and streams.

2/7 or 2

Prioritise catchments where nature will benefit most, even if public access is restricted.

5/7 or 4

Focus abstraction reductions on a smaller number of catchments but fully address the issues they face.

7/7 or 7

Focus on a wider range of catchments and partially address their abstraction issues

1/7 or 1.

3. Are there any other factors that you think should be considered as we prioritise where abstraction could be reduced in the future?

I feel that there is a very good case for a prioritisation of chalk streams because they are globally rare , iconic ecosystems, are potentially amongst the most biodiverse of British rivers, are home to rare and specially adapted flora and fauna and are under pressure because many of the rivers around London and in the busiest parts of the south east are chalk streams. All the chalk streams of the Colne and Lea, as well as the Darent, Cray, the upper Ivel and Hiz are under acute pressure from groundwater abstraction and have become – in their beleaguered states – emblematic of our careless exploitation of the environment. Turning this narrative around is really important and would be good for all rivers, not just chalk streams.

4. We have assessed the future water needs of the other sectors that don’t rely on the public water supply provided by water companies. Do you agree with our assessment? 

5. We’ve described our adaptive planning approach and the scenarios we’ve included in our adaptive planning pathways. Do you agree that we have planned for the right scenarios in each of the pathways, with a wide enough range for each of our key challenges, through our adaptive planning approach? 

6. Do you support our approach to treat each pathway as equally likely and not choose a core pathway beyond 2040? 

7. Do you have any other comments on our approach to addressing the challenges that are facing South East England?

Just to emphasise the need to bring more water into the south east region as being the most certain and probably cost-effective way of improving the resilience of water resources in this overstretched region.

Section 2

8. Reducing the demand for water through leakage and water efficiency activity contributes to more than half of the total amount of water needed in the first 15 years of the emerging plan. The balance then shifts to include a greater reliance on supply-side solutions, particularly in the more challenging future scenarios. Water companies are committed to delivering these reductions, but they are reliant on customers making sustained reductions in their water use over the long-term. Do you think our plan strikes the right balance between demand and supply solutions and the risks associated with delivery of such solutions?

Yes, I think it is right to focus hard on these efficiency measures, but there is considerable uncertainty as to the level of savings possible, the level of public appetite for efficiency, our ability to change behaviour. So, as stated, I would like to see these efforts running parallel to schemes that can deliver certain gains, with relatively small investment within a short time-scale, namely Chalk Streams First type abstraction realignment schemes, and the Grand Union Canal and Severn to Thames transfers.

9. The plan assumes that the Government will introduce new policies that will support more efficient use of water across society – through labelling of water-using products by 2024, introducing a minimum standard for all water using products by 2040 and tightening the water efficiency requirements within the Building Regulations for new homes by 2060. Do you support these interventions and the timing of their introduction?

Yes. But the biggest impact would be made by metering and block tariffs. Not invisible meters under the pavement, but meters by the kitchen sink that you can see every day, whirring round and round next to a price meter, just like when you fill your car with petrol.

10. Do you think it is appropriate for Temporary Use Bans and Non-Essential Use Bans, that reduce demand for water further during droughts, to be used as options in this regional plan?


11. Do you agree with the mix of options that provide new water supplies for the region within our plan – reservoirs, desalination, water recycling, new transfers, improved abstraction from groundwater storage and ASR schemes? Do you think that some options should feature more or less in our plan to secure future water supplies? 

As stated inter-regional transfers should feature more prominently and we should fight hard against the daft collateral implications of this new 1:500 planning. 

I am disappointed to not see Chalk Streams First flow recovery as a specific water-resource option within the plan.

12. Do you support the use of new, potentially long pipelines to move water around the region?


13. We have identified where water companies might investigate a number of new, more innovative nature-based solutions to improve the region’s water catchments. Whilst these options can provide multiple benefits, the fact they are still relatively new can make it more difficult to be certain of the benefits that will be delivered and the return on investment. Do you agree that we should promote new, more innovative nature-based solutions in our plan to develop a better understanding of their future value and role in delivering water supplies and wider environmental improvements?

Yes. Especially if Chalk Streams First qualifies as a nature-based solution.

14. Do you support our approach to stop using the majority of Drought Orders and Permits – only continuing to use a limited number during droughts until we achieve one in 500-year drought resilience, and stopping their use after 2040, unless we experience a drought more severe than a one in 500-year event?

Yes. But personally I would endorse the use of schemes such as the West Berkshire Groundwater Scheme to fill in that 1:100 or 1:500 hole and thus allow the deployable output of flow recovery to be factored into water resources according to the more average pattern of recharge and flow.

15. Overall, do you agree that the emerging plan, which presents the most cost-efficient adaptive planning solution, should be used as the basis to further develop our draft best value regional plan?

Yes. All the above caveats and comments notwithstanding.

16. Finally, do you have any other comments about our emerging regional plan? If so, please give more details below.

Thank you for the opportunity to contribute.

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