Submitting updates to the chalk stream map

Following on from my last post, people may also be interested to know that Natural England has reinstated the facility to make suggested updates to the chalk stream map. This will be especially interesting, I suspect, in places where the scarp slope of the chalk gives rise to numerous chalk rills and chalk fen habitats that might have been missed in our survey to date.

This facility can be accessed by going to the discovering priority habitats webpage and then clicking on the Citizen data portal tab. Then click on ‘Contribute data’ and then the button labelled ‘Mapping river/stream types’.

Revised guidance on proposing refinements to the chalk rivers map can be found there, along with a registration form for accessing the data portal and adding sites.

Natural England’s official chalk stream map

Natural England’s chalk stream map is now up and running and viewable by clicking HERE:

You’ll get to a page that looks like the screenshot below. Click on the bit that reads Chalk Rivers (England).

You may need to zoom in, but when you do you’ll see the chalk streams appear, as in the screenshot below:

Thank you to the team at Natural England / Defra especially Chris, Fraser and Grant for all their hard work on this.

More good news from the Environment Agency

I’m very happy to report that the Environment Agency’s water resources team has taken an active interest in the recommendations made by the CaBA chalk stream restoration strategy.

A few weeks ago I reported that the team had published a paper on various ways chalk stream flows can be assessed, including variations on or additions to the official EFI which – in my view – would get around some of its shortcomings (for example assessing flow at the perennial head rather than at the catchment boundary downstream of major sewage discharge points). That report concluded: “that substantial abstraction reductions will be required before chalk stream flows are sustainable, and the majority of these reductions will need to come from public water supply”. Indeed.

Now I have just been notified that the additional funding supplied by changes to abstraction licence fees will be dedicated to addressing low-flow issues in chalk stream in the following ways:

  1. Launch of the water resources chalk partnership fund

A £1 million water resources chalk partnership fund. Funding will be made available annually to partnership projects that deliver a flow benefit in chalk catchments where there are known abstraction issues (for more information on which catchments those might be I encourage you to look at the CaBA Abstraction as a % of Recharge report – not an official EA report, but an independent assessment of abstraction pressures).

This is a substantial sum and great news. The EA has said that it hopes the money will support their “efforts to address the water resources actions identified in the CaBA chalk stream restoration strategy”.

Projects can include habitat restoration, monitoring and engagement “to help us to achieve quick improvements and also longer-term change in chalk streams. Although the fund will be focussed on resolving water resources issues, we will seek to support multi-benefit projects and combine this with other funding sources where possible. Our catchment coordinators will work with partners to identify and develop project ideas. Further details about the fund objectives, potential projects, and local allocations are in the attached briefing note”.

  1. Plans to recruit new water resources chalk posts to operational teams

The EA is also finalising plans to recruit to about 30 new posts across operational teams nationally and locally “to work on water resources issues impacting chalk streams”.

National posts will develop and deliver a national water resources chalk programme for the Environment Agency, creating a network of local water resources chalk leads and provide a link to policy development. Posts in local area teams will be focussed on planning and coordination; technical work to develop the evidence base and engagement.

The EA will be undertaking recruitment over the spring and summer.

This latter recruitment drive is not insignificant. In putting together the CaBA report I got the distinct impression that one of the things holding back progress with abstraction reform was not a lack of dedication, just a lack of people-power. It all comes down to detail and processing, in the end.

And the evidence base alluded to above is key, because in some places – the River Ivel springs to mind, even if it doesn’t spring to the surface – the current assessments of abstraction impacts do not appear to reflect reality (hence the need to review the ways we assess abstraction impacts and flow, as above).

This is all GOOD STUFF and I’m so pleased the EA is responding to the CaBA strategy (in which the water resources team played a key role I might add) positively and proactively.

What I would really like to see now is all parties – lead by the EA, but with the water companies and the NGOs in close collaboration – making a big push to establish a flagship flow-recovery project with g’water abstraction taken back to under 10% of recharge on a regional scale. The Chilterns / Colne is the place to do it, with the ‘Supply 2040’ pipeline the means (only make it Supply 2030!), the Grand Union Canal xfer and 100M Ml/d from Birmingham (very quickly available at only £2 million per megalitre) the insurance policy, and all the flow recovery a water resources bonus: it would be 80% over the full year or I’ll eat a hat, but with the Birmingham water making up the shortfall the actual % (over which we could debate for ever and a day), becomes less critical.

Come on EA / Rapid / Ofwat: make it happen!

Two allies in the drive to restore chalk streams: the drainage board and imaginative landowners.

A nice feature in the Spring 2022 ADA newsletter on the latest phase of the River Nar catchment restoration, highlighting two of the best assets we have benefitted from in the delivery of our catchment restoration strategy: a drainage board (Norfolk Rivers Internal Drainage Board) ready and able to provide all sorts of technical and delivery support (a potential role for the EA here on other chalk streams?) and bold, imaginative land-owners – in this case Holkham, West Acre and Narford estates – keen to embrace the art of the possible.

Click HERE to read the article.

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?

Yes.

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?

Yes.

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.

Response to WRE emerging plan consultation.

(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.

EA report on assessing sustainable abstraction in chalk streams

I’m delighted to report that the Environment Agency has responded to several of the recommendations in the CaBA chalk stream strategy with the publication of a new report titled “Hydrological approaches to assessing sustainable abstraction in chalk streams“. This is a timely report given we are in the midst of the national framework water resources consultation as it will contribute to an informed and democratic dialogue between all stakeholders.

Our CaBA strategy made the observations that a) the public-facing assessments of abstraction in chalk streams were simply binary and did not communicate the scale or spatial distribution of the impacts and b) that the methodologies for assessment were somewhat complex and not easily available to citizen scientists and chalk stream advocates. We argued that knowledge-sharing and an open approach were vital to a fully informed debate in a time when some big decisions were being made with regard to water resources planning.

On behalf of the CaBA group and with the support of Defra we commissioned an independent survey of abstraction as a % of recharge (A%R), which we summarised in the strategy and published fully a few weeks ago. That methodology is one of five summarised in the new EA report. In addition the EA has unpacked the Environmental Flow Indicator (EFI) assessment methodology and the National Framework “scenarios”. Most interestingly the EA has also added details on a groundwater balance test (very similar to abstraction as a % of recharge) and also an approach that looks at the EFI flow at the perennial head of the chalk stream, called point x (which we have argued would be achieved most of the time by A10%R). Both of these address one of the weaknesses of assessing EFI flow at assessment points further down the valley where sewage discharges can mask the impacts of abstraction higher up the catchment: the upper Lea (pictured top left!) is a very good example of where this occurs.

The report doesn’t say what % of reduction in the groundwater balance / level is acceptable (is it close to our suggestion of A10%R?) but it’s worth noting that the reductions in abstraction signalled by both the groundwater balance test and A%R are actually smaller than those signalled by EFI, for example. Of course the A%R report surveyed only 55 catchments, but in addition I suspect the figures are lower because EF includes surface-water abstractions which generally occur much further down the catchments, and are controllable through protective measures such as “hands-off” flows (unlike groundwater abstraction), and so arguably are of a lesser order of ecological impact.

My personal opinion, but shared also by John Lawson who wrote the A%R report, is that pragmatism and practicality need to inform the debate: in fact I have said that to achieve anything of real significance we need water companies to be more idealistic and conservation NGOs and stakeholders to be more pragmatic. We’ll make the ecology of our streams better one quotidian action at a time. In which case, as well as setting out long-term ambitions (no more than 10% abstraction on all chalk streams) we must have an eye on what we can deliver and when and ideally what we can deliver in short order, so that we can make progress and allow success to beget success.

Starting with the ambitions enshrined in the A10%R concept and applying that on a regional scale across multiple pressured catchments (for example the Colne and Lea) would be a fine place to start and would demonstrate the art of the possible. If we can fix those chalk streams, we can fix all chalk streams!

I once made a film about searching for a wild trout in London: I found one in the very lower reaches of the Chess, inside the M25, if not actually greater London. If I looked again now, I know I’d find them in the Wandle. Nature is there, waiting for us to to give it a chance.

This new EA report is a great contribution to the actions we will need to take to make that happen.

The priority habitat map of English chalk streams

Another of the key recommendations in the CaBA Chalk stream restoration strategy was for a definitive working map of all the English chalk streams. This was something Natural England had started to work on some time ago subsequent to the publication of a list I had prepared for WWF and their State of England’s chalk streams report in 2011: this in itself being based on a NE priority habitat map from around 2006 or so. I had added a number of smaller streams which I knew of, especially some of the headwater and scarp-face streams. When I read about the forthcoming NE update I got in touch with Chris Mainstone who had been leading on this and offered to help. In addition, we received via the CaBA consultation process a number of really useful maps and river names and general pointers which have been added to the map.

I’m delighted to say that all that work has come to fruition in the online publication of the latest NE priority habitat chalk stream map.

The data display page on the priority habitats website has now been updated.

Click on ‘Display river/stream’ types. The top-level display for chalkstreams shows both high and low certainty sections – if you click on the arrow to the right of the chalkstream entry on the map legend you can toggle the high and low certainty components on and off.

The explanation of the work (including intentions for future local refinements) can be found under the about priority habitats tab – scroll down to ‘Mapping types’.

We will be working on a facility whereby additions and deletions can be made via local partnership leads in order to refine the map yet further over time.

I should add that in addition to Chris, both Fraser Elliott at Natural England and Grant McMellin at the Environment Agency deserve huge credit for the many hours of work they have put into this.

The map will be updated to the CaBA Chalk stream hub as soon as possible.

Chalk stream teaser: the photo gallery above features 16 chalk streams, one from every English county that has a chalk stream: Yorkshire, Lincolnshire, Norfolk, Suffolk, Cambridgeshire, Hertfordshire, Buckinghamshire, Berkshire, Oxfordshire, Wiltshire, Hampshire, Dorset, Sussex, Kent, Greater London and the Isle of Wight too. I’ll send a signed copy of my chalk stream anthology (Medlar Press 2006) to anyone (the first if there’s more than one!) who can name all the featured chalk streams in the order in which they appear. (Many thanks to Carol Walker, Bogbumper/wikimedia-commons and Chris Hamer whose pictures of streams in the Isle of Wight, Suffolk and Sussex I had to pinch off the internet)

1st Feb 2022 … after a week no one has even started on my mapping teaser (and I just realised I had posted two from one county!), so it must be far too tricky. Okay. I’ll name the counties top to bottom, left to right and so now name the streams: Hants, Oxon, Bucks, Cambs, Suffolk, Berks, Norfolk, Herts, Greater London, Yorks, Lincs, Kent, Wilts, Dorset, Sussex, Isle of Wight.

A%R – abstraction as a % of recharge in chalk streams

A key recommendation in the CaBA Chalk stream restoration strategy was for an independent review of abstraction as a % of catchment recharge. The basic findings of that report were published in the CaBA restoration strategy but now we have the full report and not before time …

You can read the report HERE

With the regional plans out for consultation, it is vital that we now make the case for a) prioritising chalk streams in absolute terms and b) for careful strategising and planning of abstraction reductions on the chalk streams, so that we see ecological gains in the places they are needed most urgently.

We all know that we have been leaning heavily and are dependent on groundwater in the chalk for a large chunk of public water supply across southern and eastern England. We know that the impact this has on the ecology of chalk streams is unacceptable and yet we also know that we cannot replace water resources overnight. It has taken too long to get to this point but at least we now have a chance – via the regional plans – to make significant reductions to chalk aquifer abstractions.

However, the scale of the flow deficits identified in the regional plans is enormous: so enormous that some form of prioritisation and expediency will surely be necessary, at least in terms of what comes first, if not in absolute returns.

That’s one place where this A%R report can play a very useful role in the public debate. Until now we stakeholders have had no real insights into the scale or spatial distribution of over-abstraction in chalk streams, even if we have felt sure our streams were over-abstracted. The public-facing WFD assessment gives a binary status of does or does not support good (flow being – absurdly – only a supporting element in the WFD assessment process).

John Lawson’s report is first and foremost an exercise in democratising that knowledge. Quantifying groundwater abstraction as a % of the total effective recharge of the chalk aquifer in a given catchment – or even across a region of catchments – is a very simple and accessible way of assessing the relative impact of that abstraction on flows. It is not infallible: we empirically know what the abstraction is, but effective rainfall estimates are subject to uncertainty and inconsistency. However, so are all the other forms of assessing impact while these are a) not available to the public and b) more complex.

A%R, therefore, is about bringing stakeholders, into the discussion armed with knowledge.

The A%R modelling in this report uses modelling of abstraction impacts on the River Ver to derive a correlation between A10%R (where groundwater abstraction uses no more than 10% of effective recharge) and the Environment Agency’s target for flows in an ASB3 (abstraction sensitivity band 3 being the most sensitive) chalk stream. It has been pointed out that this correlation may not hold for other chalk streams and that is true: it will vary from stream to stream according to variations on hydrogeology and land-use. On the other hand, the modelling was also accurate on the River Kennet and is proving a good fit in preliminary surveys of streams like the Beane and Mimram.

CaBA chalk stream hub

One of the key recommendations in the CaBA Chalk stream restoration strategy was the publication of an online resource and data hub for chalk streams. I, for one, strongly felt that a large part of what has held back progress in the rehabilitation of our chalk streams has been a lack of knowledge and data – hence my own website chalk stream.org. Those who care about these rivers have been disenfranchised from the information needed to make arguments, to even join the debate. The relationship between groundwater abstraction and flows, for example, has been kept beyond the reach of the ordinary stakeholder because the figures just aren’t available, and the modelling is complex and inaccessible.

I could make the same point with regard to water quality. In fact, it was the publication of the WWF report Flushed Way in 2017 – brainchild of Rose O’Neill and Kathy Hughes – which brought the sewage scandal to light and compelled the collation of data which can now be used to quantify the issue and catalyse change.

Knowledge is the power to make change and we need knowledge on all sides of the table.

I’m delighted to say that the CaBA chalk stream data hub is now up and running. It is by no means yet a complete set of the data and information that will eventually become available: I hope we will be building it for a long time to come.

The hub can be found HERE

Take a look, for example, at the fascinating, interactive water quality dashboard.

I will post notifications on this blog as and when more data is published.