Category: Uncategorized

Note: this blog is critical of the way WFD assessments have been applied on the upper River Ivel. It’s no secret that I think this WFD assessment process needs to be improved. Too many headwater chalk streams are effectively unprotected by what should be a powerful statutory driver. The criticism is meant with the best of intentions, however, and I hope it will be taken in that spirit.

Although I have driven across its aquifer countless times on my way from London to Norfolk, until recently I wasn’t that familiar with the River Ivel, or the several chalk streams around it that form the Ivel’s headwaters: the Hiz and Oughton, Purwell, Pix Brook and Cat Ditch. I stopped there once, in 2005, to take a few photographs for my anthology on chalk streams and managed to get the snap below of a small, wild trout near the springs of the Oughton. So I knew that these were chalk streams and that they held trout. And I also knew that they were, like many East Anglian streams, easy to pass over, unknown and perhaps unloved.

But not universally unknown and unloved. Not at all. More recently, whilst putting together the CaBA chalk stream strategy I corresponded with a band of people who cared deeply about their local stream (or rather, the lack of it) and who had for years been railing against its condition as a river action group called RevIvel.

The River Ivel, they claimed, was now a shadow of the river that it should be. It was being abstracted, to the point that it barely flowed. And yet the Environment Agency seemed relatively deaf to their concerns, while Affinity Water claimed that this wasn’t true, that the groundwater abstraction, such as it is, does not reduce natural flows in the River Ivel.

Last November Revivel invited me to sit in on their virtual AGM. I listened with growing dismay and sympathy, to a familiar tale of hair-pulling frustration as the group recounted the minutiae of their efforts to get their case taken seriously. I didn’t say much and I can’t remember exactly what I did say, but I guess it would have along the lines of advocating what I try to do when tilting a lance at those windmills of bureaucracy: get seriously forensic, arm yourself with data (they’d done a lot of this already) and tirelessly pick apart the inconsistencies that have allowed a priority river habitat to not actually exist as a river.

All okay advice. But I also suggested they pick up the phone to conservationist and technical consultant, John Lawson, and ask him to do an independent analysis of the abstraction in the catchment, because with that they would have a much stronger case. That was the really useful bit.

Until now the ‘science’ of analysing the impact of groundwater abstraction on chalk stream flows has been rather one sided, to say the least. Water companies have claimed over the years (not quite so much any more, I’m happy to say) that groundwater abstraction doesn’t reduce surface flows, and that the passage of water underground and its interaction with surface streams is of such unknowable complexity that only expert hydrogeologists can understand it.

Common sense might suggest that if a catchment can be seen as some kind of basin with a boundary, an inflow of water and an outflow (which it can, in fact), then if you add another form of outflow the former outflow will reduce, about as surely as an apple hitting the ground when it falls off a tree. But I and many others have succumbed to cognitive surrender when arguing with experts about this: defeated by befuddling terminology, incomprehensible maths and the problematic fact that we can’t see underground. Although it must be a tempting tactic to impose cognitive surrender on the layperson in the street who is wondering where his or her river has gone, it is surely also a self-defeating one. They might not have beaten your argument, but they’re still angry and suspicious. And they don’t go away.

The CaBA strategy was all about building bridges across this divide, because we’ll only really restore our chalk streams if we all honestly acknowledge what’s wrong with them and work together – river lovers and water companies, regulators and NGOs – to fix them. Recommendation 5, in the CaBA Chalk stream strategy advocates the evolution of a collaborative approach towards knowledge-sharing when it comes to assessing and managing the impact of abstraction on stream flows. Water companies and the EA should share what they know and their data, while stakeholders should be allowed to contribute to the debate at a technical level, instead of just railing outside the door with pitchforks.

This is where it is jolly useful to have a John Lawson on the team.

John has now completed his survey and analysis of the River Ivel, and although it does make for some uncomfortable reading (I think the case of the Ivel may be about the best (best as in worst!) example of how a muddle in the Water Framework Directive assessment can have disastrous knock-on impacts), I think it also marks the first and thus a very important step in this attempt to democratise knowledge and move forward together.

John’s survey has revealed that in terms of groundwater abstraction as a % of the natural recharge of the aquifer (A%R), the upper Ivel is among the most heavily abstracted chalk streams in the country, with 50% of the rain that reaches the aquifer taken by groundwater abstraction. Only a few other chalk streams, like the Darent, or upper Lea, are in that territory. It is hard to imagine this isn’t having a major impact on flows.

In other work, John has already demonstrated the close, mathematical relationship between groundwater levels and stream flows, with a highly predictive formula that equates stream flows to the height of the groundwater above the stream bed at the point of assessment, and the v-shape of a river valley: because as groundwater levels rise, not only do the springs flow faster and faster (because of increasing groundwater head), but also, because of the shape of a valley, a proportionately greater and greater surface area is exposed to the saturated zone of the aquifer.

The Lawson formula therefore is Q = aH^2.5. (I have looked and looked but I cannot find any version of this formula in groundwater literature, although it is linked to an important part of Theis’ foundational groundwater paper of 1940, where he wrote that a new ‘development’ (an abstraction) from an aquifer must reduce former outflow and that the only way this can happen is by a ‘reduction in the thickness of the aquifer’. Note that in America, where much of the hydrogeological science comes from, many aquifers are not V shaped.)

I like to write equations in prose because then I understand them. In English therefore, the Lawson formula shows that (in a chalk valley): “flow equals the height of the groundwater level above a given point in the stream, multiplied by a constant (which accounts for the properties of the chalk), multiplied by 0.5 (to account for rising head / gravity) and squared (to account for the v-shape of the valley).

John’s formula fits every chalk stream he has looked at, including the Kennet, Tarrant, Test, Misbourne, Ver and now the Ivel. It is quite compelling therefore.

The question then becomes: has groundwater abstraction on this scale lowered groundwater levels in the Ivel catchment?

John’s lumped parameter model simulates changes in groundwater levels and flows. It gives a very good fit between recorded and modelled output on all those rivers mentioned above, now including the Ivel and it suggests that groundwater levels are between 4 to 6 meters lower than before groundwater abstraction began. Interestingly, the Environment Agency figures back this up.

As does historical research carried out by RevIvel and incorporated into John’s report. Data from the Royal Commission into Metropolitan Water Supplies in 1893 (which recorded the depth of water in wells in the valley) suggest that groundwater levels at that time were about 3 to 6m higher than recent groundwater levels.

The existence of 19th century functioning water mills at Blackhorse Mill and Norton Mill, the commercial water cress beds at Baldock and a trout hatchery and fisheries at Norton suggest that the Ivel Springs and Nortonbury Springs would once have flowed perennially – which they don’t now.

Meanwhile long-term rainfall records cannot account for these changes: winter rainfall has – if anything – increased, albeit the catchment may well be less absorbent than once it was.

All this adds up to a large reduction from natural flows according to John’s way of assessing the link between abstraction, groundwater levels and flow: the current abstraction of 13 Ml/d, accounts for an average flow loss over the full year of 11 Ml/d (85% of the amount abstracted), albeit the loss of flow as a % of the abstraction is much greater at high flows than low: over 100% at high flows, more like 45% at low flows. Read the Lawson formula carefully and you’ll see why in the part that represents the shape of the valley.

I have to say, for the sake of fairness, that Affinity Water (AW) has a different way of looking at this. Based on data collected during switch-off tests, AW argues that the cessation of abstraction appears to have only a very small impact on flows. They have concluded that the presence of semi-permeable layers in the chalk impedes the connection between the deeper, confined aquifer (the part under the semi-permeable layer from which AW abstracts water) and the unconfined aquifer (the uppermost layer of aquifer which is directly in contact with the stream).

John argues that the switch-off tests were not nearly long enough and only ever happened one at a time: so it would be impossible to discern any difference in flow because the tests could not have made any difference to regional groundwater levels away from the cones of depression around boreholes. Abstraction would have to cease altogether for about 18 months and we would need a good recharge of rain to rebalance groundwater levels in the aquifer.

Incredibly, at the that heart of this is a diversion of opinion over what actually causes flows to diminish as a result of groundwater abstraction. John, as explained, argues that groundwater levels across the whole valley are the fundamental driver, and that the cones of depression around boreholes cause only localised, smaller-scale impacts, separating the stream-bed from the water table, for example or lowering / inverting the groundwater gradient at the stream edge within the radius of the cone.

AW and, as far as we can tell, much of the expert community, sees the cones of depression as the fundamental mechanism that reduces flows: thus AW has argued that when these cones of depression have filled in – as they quite quickly will during switch-off tests – that dynamic-equilibrium (the balance of the water table between inflows and outflows) in the aquifer is re-established.

Dynamic-equilibrium is when outflows balance inflows over time. It can be a ‘natural’ dynamic equilibrium, or an ‘unnatural’ one. Add abstraction to a virgin aquifer and the equilibrium will be upset for a while (meaning outflows exceed inflows), until groundwater levels reduce, and thus the former natural outflows reduces and then you are back to a state of equilibrium, albeit an ‘unnatural’ one (see my previous post on the bucket aquifer and you will understand this, if you don’t already).

Cease abstraction at a given pump and – as John would argue – of course the cone of depression will fill in. When it has, that is conspicuously not the same as ‘natural’ dynamic equilibrium. What is happening to the water no longer abstracted? It’s not yet discernible in flows because it hasn’t yet lifted groundwater levels: it’s still filling up space in the aquifer.

So, we have some fundamental disagreements.

Happily, we’ve agreed to convene a workshop under the CaBA banner and to invite independent experts to look at the evidence and our arguments and see whether we can find common ground. I see this workshop as the first part of delivering on the Recommendation 5 in the chalk strategy.

**

Meanwhile, the poor River Ivel continues to hardly flow at all and the only measure of relief on the horizon is a tiny 0.5 Ml/d augmentation, which as RevIvel argue, is the wrong mitigation and not nearly enough even if it were the right one (augmentation is actually part of our proposal for a more sustainable future, but only as an emergency measure for resilience of water supply during extreme droughts).

AW has written “Evidence suggests that abstraction is not likely to have a significant impact on flows in the Ivel. As a result it is considered that the ecology is not impacted by abstraction and therefore any reduction or cessation of abstraction is unlikely to improve the ecological status of the Ivel.”

Whatever way you interpret the Ivel evidence, the idea that groundwater abstraction on that scale is having no impact on flows, or ecology, seems too incredible.

The trouble is, the Water Framework Directive assessment of the Ivel, is as unhelpful as AW’s statement above.

The Ivel is classified as a heavily modified waterbody (HMWB). No real reason to disagree with that, on the face of it. There are many relic mills. On the other hand there are mills on most chalk streams not deemed to be heavily modified. In fact the HMWB designation isn’t supposed to describe the degree to which a waterbody is modified by relic structures like mills. It exists to account for waterbodies whose modification provides an essential and current socio-economic benefit (like a runway at Heathrow airport, for example) so that the waterbody so deemed only has to achieve good ecological potential, not status (a lower bar) and does not have to achieve good status in those elements or supporting elements affected by the relevant modification.

You can see the sense of it, but there are collateral impacts of this HMWB designation on many chalk streams in eastern England, streams which are part of larger, lowland waterbodies where modifications are essential (sea-gates for example, or navigational locks), lowering the bar for their chalk stream headwaters, where there is no reason to diminish expectations for proper restoration to good status.

I have encountered this before on my local stream the Nar, where in 2011 the EA classified the lower man-made watercourse, “not heavily modified” even though its perched trapezoid channel very clearly had a current, vital socio-economic benefit (keeping water off thousands of acres of Fenland farmland) and the upper natural watercourse as heavily modified, even though all its modifications had become redundant by the end of the 19th century. Thus the EA had – based on some fish scores carried out in unrepresentative parts of the channel – set in train a designation which suggested that the very homogenous lower river didn’t need to be improved, and the natural but much degraded upper river, didn’t need to be improved either.

So, the HMWB status is the first problem.

The second, deriving from that, is the bewildering assessment of ‘good’ anyway.

In 2016 the assessment was more convincingly representative of the Ivel as we know it, at least in that the waterbody failed because it was assessed as ‘poor’ for macrophytes (unsurprising given the lack of flow) and as ‘does not support good’ for flow.

By 2019 it was back to good again. On other hand in 2019 the macrophytes were not assessed at all. In fact macrophytes have only ever been assessed on the upper Ivel in 2014 and 2016, as “moderate” then “poor”, both of which are failures of a WFD key element, leading therefore to an overall fail.

It is worth mentioning here that Ivel is not assessed for fish. Not at all. Never has been. Why not? Fish are also a key element within WFD.

I can’t explain why, in the two screengrabs above, the cycle 1 box including 2013 and 2014 the overall status is recorded as moderate and in the cycle 2 box including 2013 and 2014 the overall status is recorded as good. In 2016, however, the status is poor, because the macrophytes score is poor.

However, when you look into the reasons for not achieving good status (known as RNAG), for macrophytes, you won’t find that flow, or lack thereof, is blamed at all. The RNAG for macrophytes is ascribed to the “agriculture and rural land management” sector, specifically poor soil management and structures.

Good status, so the assessment explains, was prevented by the heavily modified waterbody use and thus “action to get biological element to good would have significant adverse impact on use”.

Hmmm.

RevIvel could ask the EA exactly what it is on the upper Ivel, within the agriculture and land-use sector, that is heavily modified with an essential and current socio-economic benefit and then what it is about that use which would be significant and adversely impacted should any actions take place to bring the macrophyte status up to “good”.

I don’t think the EA would be able to provide convincing answers to those questions, because I’m not sure there are any. Sure, agricultural run-off might well be sending sediment into the stream, and sure the historic mills, where they impound the flow, will be exacerbating the impact of that sediment. But there are many chalk streams with runoff issues and old mills: make that 100% of chalk streams in fact. And they aren’t all at poor status for macrophytes. The real reason macrophytes are so poor in the upper Ivel is because it is hardly flowing and often dry.

And yet, and yet … the flow or hydrological regime’s status as “does not support good” (for some baffling reason flow is only a supporting element in the WFD assessment structure) was investigated, apparently in 2015. The investigation concluded that the flow supported good status after all and the level of confidence of that assessment is recorded as “certain there is not a problem”.

In his report John pointed out this rather counter-intuitive assessment of a chalk stream whose abstraction amounted to over 50% of the recharge. The EA explained that in 2015 the boundaries of the catchment were enlarged to include the Pix Brook tributary and the Letchworth water recycling centre (sewage works) discharge. The flow assessment point was moved to the new boundary, downstream of the sewage works and “this explains the change in flow compliance at the assessment point which is at the very bottom of the catchment from ‘does not support good’ for Cycle 1 up to 2014, to ‘supports good’ for Cycle 2 in 2015. The change took place as part of a national exercise to reduce the number of very small catchments – in this case between Astwick and Henlow”.

So, in fact the WFD assessment neither reflects conditions in the upper river, nor protects the stream from over abstraction, because according to the WFD assessment, the flow is just fine.

Right now that assessment is plain wrong. It is the perfect example of the way in which WFD flow assessment points, waterbody boundaries and an inconsistent application of WFD process, fails to protect many chalk streams.

All this has been highlighted in the CaBA Chalk stream strategy. Not only do we need a better driver for protection and restoration, we need to apply the existing one so that it actually works.

I have to say, I don’t feel this is entirely the Environment Agency’s fault: the WFD timetable was designed without a realistic consideration of the scale of the problem or what it would take to fix it: putting our much abused rivers into truly good ecological condition is a multi-decadal undertaking. With overly ambitious timetables the EA was set an impossible task and it was almost inevitable that the WFD assessment process would become skewed by the need to tell a sunnier story than was really the case. The one time the EA decided to take it on the chin, when water-sampling technology advanced to the point that various ‘forever’ chemicals entered the fray and caused mass WFD failures, it became another stick to beat them with. So, I understand why fudges like this one on the Ivel take place: the EA is forced to consider, at every turn, what the cost of a rigorous application of the WFD assessment process would actually be, how it would reflect on them (and the press they would get for ‘failing’, when actually they would be doing their jobs better), how it would play with the water industry and Ofwat and the government.

I don’t think things will get any easier now we have a cost of living crisis.

BUT … if we want to actually restore chalk streams as opposed to just talk about it, we have to be honest about the scale of the problem. Then we have to agree to solve it, even if it will take a long time. That’s what the CaBA strategy is all about.

The upper Ivel is the almost the worst example I have seen of a chalk stream that has fallen between the floorboards of the various so-called protection and restoration drivers. Let’s use its example to inspire a much more coherent way of working in the future.

Above: the River Piddle in Dorset. One of lowland England’s freshwater miracles.

I’ve been hearing a lot of concern lately that the campaign to bring the ecological plight of chalk streams to the attention of the government, the water resources industry and the general public, is in danger of detracting from equally pressing ecological restoration of other habitats. Chalk streams are getting all the attention, is a complaint I am hearing.

Personally, while I may have a special affection for chalk streams, I am passionate about all watery habitats. They all matter.

But chalk streams are globally rare. Most are in England and all of these flow through the most highly developed landscape. Any pressure exerted by mankind on the natural world of rivers is felt most acutely on chalk streams. They are abstracted and polluted. They are corralled by roads, towns and farmland. Their physical form has been greatly altered over the centuries. And yet chalk streams are such gentle streams, they are totally imprisoned by what we have done and continue to do them.

That is the chalk stream’s curse and our responsibility. A responsibility of global importance. We can restore chalk streams and because of this same gentle nature, they will respond. Through chalk streams we can show what can be done and how it is eminently possible to live busy lives alongside a living and healthy natural world.

I passionately believe that if we can raise the plight of our chalk streams in the public consciousness and if we can use chalk streams to show the government and its regulators that when once we took nature for grated, now we see that it is both fragile and profoundly important, then that success will help all habitats.

In a cupboard in the High Wycombe public library is a mid 19th century sanitary inspector’s report into the slums which straddled the River Wye – a chalk stream – to the west of the town. Read that report and you will understand the miracle and privilege of clean water coming from a tap in your house and a loo that doesn’t give you cholera. To have these things is amazing, so amazing and so fundamentally valuable to people, that for a while we lost sight of, or didn’t care about, where that water came from and what impact the use of it had on the natural world.

That has changed. Why? Because the natural world which has picked up the bill for that miracle is also profoundly important to us, to our mental health and physical well being. If nothing else, the last few years will surely have shown that? And also because it is profoundly important of itself. How bloody amazing is it that we now have wild trout spawning and thriving in a south London river?

The fact is, this is not a binary choice: healthy people versus healthy rivers. To think as much – as aspects of our financial regulation of water have assumed in the past – is delusional. The two go hand in hand, or should do in the better world we will build as we start to value and pay for nature’s restoration and protection.

That’s why chalk streams. If we can restore chalk streams we can restore anything. Their restoration won’t detract one iota from the restoration of other habitats, but make it all the more possible.

The Great Stour in Kent (above), along with a number of other iconic chalk streams like the River Nar in Norfolk or the Great Eau in Lincolnshire, is classified in the least sensitive to abstraction band ASB1, even though the original 2005 groupings of river types by sensitivity to abstraction placed all chalk streams in the most sensitive group ASB3.

In December 2020 I wrote a post pointing out the anomalies that exist in the banding of chalk streams according to their sensitivity to water abstraction. I had discovered, for example, that my local chalk stream, the River Nar, was in the least sensitive band ASB1, along with the Great Eau, Lincolnshire’s most iconic chalk stream, while numerous other classic streams, like the Ver and Chess were in the middle band ASB2.

In fact, when I looked at the banding of all the chalk streams, frequently I couldn’t make much sense out of what seemed inconsistent assignments. Neighbouring and very similar streams like the Cerne and Sydling were – inexplicably – in different bands. Even allowing for the fact that a mixed geology chalk stream, or a very highly modified chalk stream in an intensely developed setting, or the lower reaches of a very big chalk stream, could all arguably be placed in ASB2, there seemed to be many inconsistencies: Wylye tributaries the Swan, Heytesbury Stream and Chitterne are all ASB3 but its SAC tributary the Till is ASB2, for example. Why?

The abstraction sensitivity banding is designed to provide a level of protection against the pressures of abstraction by assigning to a stream a “sensitivity to abstraction” associated with a maximum allowable % reduction from natural flow. Thus at very low flows, for example, the most sensitive of streams in ASB3 are deemed to tolerate a 10% reduction from natural flows, while for the least sensitive in ASB1 that reduction can be 20%. At higher flows these reductions can be greater: 24% at Q30 for ASB3 and 30% for ASB1.

The ASB banding is an evolution of the flow standards for river types developed by the UK Technical Advisory Group (Acreman at al 2005 and UK TAG 2008) and is based on an assessment of three components: a physical score which takes into account including gradient, catchment size, rainfall, and base-flow; a LIFE (lotic index for flow evaluation) score for the expected macroinvertebrate community; and a fish-guild based score for the expected fish community. In the Acreman / UKTAG banding chalk streams and especially headwater chalk streams were deemed to be amongst the most sensitive river types, so one would expect most chalk streams to now find themselves in ASB3.

Indeed, the key word here taken from EA literature is “expected”. This word suggests to me that the banding should be set according to the river’s potential or type, not necessarily its current condition. First of all, let’s look at the score of a classic chalk stream in excellent condition, the Alre:

WFD no.	Name	Phys	LIFE	Fish	ASB
GB107042022610	Alre	31	23	33	3

The Alre is one of the three tributaries that come together to make the Itchen. The others, the Candover and Cheriton score more or less exactly the same, so this gives a good idea of a classic chalk stream score for rivers in good condition.

Now let’s take an anomaly I highlighted above, the fact that the Sydling is ASB3 and its neighbour the Cerne is ASB2. Their scores are:

WFD no.	Name	Phys	LIFE	Fish	ASB
GB108044009700	Sydling Water	33	23	32	3
GB108044009710	Cerne	32	23	21	2

The Sydling’s score is more or less the same as the Alre’s and the difference between it and the Cerne is, clearly, the (expected) fish community. But the Cerne is a headwater, pure chalk tributary just like the Sydling. It is dominated by trout. Salmon might occasionally spawn in the Cerne, although they can’t ascend the Sydling. Of course there will be eels, bullheads and minnows too. The two streams should – to anyone who knows them – score exactly the same for expected fish community, albeit the Sydling might score better according to its actual fish community because it is in better condition than the Cerne: the valley is dominated by organic farms, and there is only one small village on the Sydling, whereas the Cerne valley is more developed, and the stream more heavily impacted by abstraction and sewage discharges.

But as said, the scoring is supposed to be according to type not condition.

Now, let’s look at some chalk streams that should be just like the Alre and Sydling but aren’t, not least because of how much they are abstracted: the classic chalk stream tributaries of the Colne.

WFD no.	Name	Phys	LIFE	Fish	ASB
GB106039029830	Misbourne	11	23	21	2
GB106039029870	Chess	11	23	32	2
GB106039029890	Bulbourne	11	23	32	2
GB106039029900	Gade (upper)	12	23	32	2
GB106039029920	Ver	12	23	31	2

Apart from the lower score for the Misbourne (why?) the expected fish community scores are the same as for the Sydling and Alre. The expected LIFE scores are the same too. That’s good: it implies that expected is indeed the operative word, given that the actual fish and invertebrate communities of the Chilterns streams will not as good as the Wessex streams.

But the physical score which – note – is based on gradient, baseflow index, catchment size and rainfall, is drastically different. This makes no sense: these are not exactly mutable qualities and I doubt there are very many differences at all between these physical parameters of the River Chess and any number of Wessex chalk streams whose physical scores are around 32/33. You could possibly argue that these Chilterns chalk streams are more heavily modified than those in Wessex, but then how come the River Wye, the most heavily modified and urbanised of all the Chilterns chalk streams scores as follows:

WFD no.	Name	Phys	LIFE	Fish	ASB
GB106039023880	Wye (High Wycombe fire station to Thames)	21	23	33	3
GB106039023890	Wye (Source to High Wycombe fire station)	31	23	33	3

To me this suggests a basic inconsistency of application. Maybe different area teams interpreted the scoring system in different ways, or maybe the assessment has been done in a rather mechanical way by personnel who aren’t that familiar with the streams they are assessing and within parameters that just don’t fit the physical reality.

For example, the scores for chalk streams local to me in Norfolk suggests the same inconsistency complicated by unhelpful WFD waterbody boundaries.

WFD no.	Name	Phys	LIFE	Fish	ASB
GB105033047791	Nar upstream of Abbey Farm	22	13	12	1
GB105033047792	Nar downstream of Abbey Farm	11	13	12	1
GB105033047620	Babingley River	22	13	12	1
GB105033053480	Heacham River	22	13	12	1

In these East Anglian rivers it is common for the waterbody to include chalk headwaters and reclaimed fenland drain. Often the waterbody boundaries don’t always fall in a place that allows these changing characteristics to be properly assessed and fitted to the waterbody in question. But really there should no difference at all between the expected invertebrate and fish communities of the East Anglian rivers Nar, Heacham and Babingley and the Wessex rivers Alre, Sydling or upper Test.

The second recommendation of the Water Quantity section of the CaBA chalk stream restoration strategy launched in October last year was for a review of this abstraction sensitivity banding:

CaBA CSRG recommends a review of the Abstraction Sensitivity Banding. All chalk streams should be banded ASB3, unless there is evidence to support a lower band. ASB3 may not be appropriate on the lower reaches of very big chalk catchments or highly modified systems, for example the lower Colne or Lea, the lower Wey, Gade, Stort etc.

In the table below I have indicated the chalk streams which should – unarguably, in my view – be reassigned into ASB3: coloured blue these are classic chalk streams, whose morphology and expected or actual fish and invertebrate communities are exactly the same as all the other chalk streams already in ASB3. In some cases it might make sense to split the waterbody in order to do this with logical consistency . In my view, the stand-out anomalies are:

Frome headwaters and Wraxall Brook

River Cerne

River Piddle (middle reaches)

North Winterbourne (trib of Stour)

River Wylye

River Till

River Bourne (Wilts)

River Ebble

Sweatford’s Water

Allen River

River Dever

River Test (middle reaches)

Wallop Brook

River Dun

River Itchen (upper and middle reaches)

River Meon

River Loddon (headwaters)

River Whitewater

River Ver

River Gade (upper reaches)

River Bulbourne

River Chess

River Misbourne

River Beane

River Quin

River Ash (upper reaches)

River Stort

Great Stour (middle reaches)

Nailbourne and Little Stour

River Dour (headwaters)

River Nar (upper river)

River Babingley

Heacham River

River Burn

River Stiffkey & Binham Stream

River Glaven

River Bure (upper reaches)

River Wensum (upper and middle reaches)

Great Eau (upper reaches) & Burwell Beck

River Lud

West Beck incl Elmswell beck and Little Driffield Beck

Gypsey Race

River Dever

If I haven’t included a given chalk stream that is currently ASB1 or 2 in the list above that doesn’t mean it shouldn’t be moved to ASB3. It just means it’s not as stand-out obvious as the streams in the list above are.

North of London, for example, the lower-lying topography creates shorter chalk streams that segue into different kinds of lowland stream, all lumped into one waterbody. To protect the chalk stream reaches of many streams like this it’s probably going to be necessary to split the waterbodies between the chalk upper reaches (which could then be classed ASB3) and the lower reaches. Across the piece, the lower reaches of larger chalk streams, or very heavily urbanised streams could reasonably be assigned ASB2. Re-assessing them all will, of course, require good local knowledge, applied consistently across all chalk regions.

In my view though, the EA could make a good start by moving those stand-out streams listed above en bloc into ASB3 whilst committing to a review of the rest.

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 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.

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”.

2. 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!

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.

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. 

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 500^th 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.

(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.

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.