A letter from Minister Emma Hardy

I met with Minster Emma Hardy on a Yorkshire chalk stream earlier in June to discuss what this government might do to help chalk streams. The meeting was mentioned in parliament as excerpted below and I have also received a letter from the Minister setting out the government’s ambition for chalk streams, also below.

I’m obviously as disappointed as anyone that government has dropped the Defra chalk stream recovery pack. I’m still not sure why it has chosen to when the fate of our fragile and unique chalk streams is so obviously important to such a broad range of people and to so many people … including Sir David Attenborough.

Encouragingly, however, Minister Hardy has written “chalk streams will continue to be fundamental to our mission to reform the water system”.

The proof of the pudding, as they say …

I have heard good things about what may in the pipeline (following the Cunliffe and Corry reviews) in terms of revitalised and empowered catchment management, and the easing of the treacle-wading bureaucracy that is a sheet anchor to river restoration efforts. Both much needed. So, it may well be – fingers very crossed – that the progress we make through this term will move things forward for chalk streams.

Nevertheless, the CaBA chalk group continues to feel that the gist of its recommendations – greater protection for chalk streams, prioritised abstraction reduction and phosphate reduction targeted to where it will most benefit ecology (not some obtuse economic algorithm) are all very much in the gift of Defra and Ofwat, and are total no-brainers if we want to restore our chalk streams and deliver on the collegiate, universally supported work of the past 5-years.

Dear Minister Hardy, can we have both?

The Parliamentary Under-Secretary of State for Environment, Food and Rural Affairs (Emma Hardy): Chalk streams are not only a beautiful and iconic part of our precious natural landscape; they are symbols of our national heritage. The protection and restoration of our cherished chalk streams is a core ambition in our overall programme of reform to the water sector.

Luke Murphy: I am grateful to the Minister for her response. In Hampshire, we are blessed with several rare and irreplaceable chalk streams, including the River Loddon, the River Itchen and the River Test. The Minister will be aware of the campaigns to secure greater protection for these irreplaceable habitats, including during the passage of the Planning and Infrastructure Bill, and I pay tribute to the Hampshire & Isle of Wight Wildlife Trust, Greener Basingstoke, and Natural Basingstoke for all their work. Can the Minister confirm that this Government are committed to the protection of chalk streams, and set out what further steps they will take to restore these precious habitats?

Emma Hardy: My hon. Friend is quite right: chalk streams are a source of beauty and national pride. Just a few weeks ago, I had the privilege of visiting a chalk stream restoration project with Charles Rangeley-Wilson, who is a passionate campaigner for chalk streams. Under this Labour Government, water companies will spend more than £2 billion to deliver over 1,000 actions for chalk stream restoration, and will reduce their abstraction from chalk streams by 126 million litres per day.

Mr Gagan Mohindra (South West Hertfordshire) (Con): The River Chess in Rickmansworth is one of the chalk streams that goes through my constituency. The volunteers at the Rickmansworth Waterways Trust are keeping our canal heritage alive, despite funding for the Canal & River Trust being cut. I believe the cut is short-sighted, because these waterways tackle water shortages, boost biodiversity and protect 2,500 miles of national assets for a modest cost. Will the Minister rethink the funding cuts and back the Fund Britain’s Waterways campaign, so that local champions like David Montague and his team at Batchworth lock are not left to sink or swim on their own?

Emma Hardy: The hon. Gentleman is quite right to say how important volunteers are in supporting our natural environment up and down the country. He will be aware that the decision to reduce the funding for the Canal & River Trust was taken by the previous Government, and that was extended under this Government. There will be a tapering off of some of the funding, but we continue to support water projects up and down the country. As I have already mentioned, the changes that we are introducing for water companies will help to protect not only our beautiful chalk streams, but all our rivers, lakes and seas.

How dry is south-east England?

I enjoy Simon Cooper’s chalk stream focussed newsletters, for a variety of reasons, not least that they are well written, sardonic and interesting. No matter what he writes – unarguable truth or arrant nonsense – there’s never a dull moment.

On the 6th June Simon asked “where do all the water company fines go?”. Good question! The Conservative gov’t introduced the idea that these fines ought to go to improving the environment damaged by water company malpractice. But the sums aren’t ring-fenced. So, of the £242-million levied on the industry in 2022/23, only £11-million found its way into the Water Restoration Fund. We need to ask this question repeatedly: “who is trousering the fines?”

This week Simon is on the water company case again, lampooning Southern Water’s Tim McMahon. McMahon had claimed that the south-east of England was “drier than Istanbul”. Simon called this “Southern Water Fantasy Maths”. 

“McMaths,” he wrote “who probably hones his calculating skills watching endless repeats of the numbers game on quiz show Countdown had to perform two feats of contorted logic to arrive at this implausible claim. Firstly, he had to include the population of London in his calculations. The last time I looked our capital was most definitely not in the south-eastern portion of England but hey-ho Tim perhaps you are lining yourself up for a Nobel Prize double to include geography. Secondly, Tim has used the historic average for Istanbul rainfall but compares it to one of the driest periods on record for South-East England.”

In fact Tim had said to the BBC: “If you look at the south-east of England, it’s drier than Sydney, Istanbul, Dallas, Marrakesh. We have got a very densely populated area and we need to start investing to cater for that. We need to reduce customer usage. Otherwise we will have to put other investments in place, which will not be good for customers and might not be the best thing for our environment.”

If I were to pick that statement apart, it would not be to make a petty objection to the “drier than …” statement.

The point is kind of obviously rhetorical, not literal. Tim is also clearly referring to the geographical reality, not the regional concept. London is undeniably in south-east England. It is a region in itself, however, so it is not technically in the region described as “the South-East”.

To match the pedantry I looked up the “centre of England” and found it – deemed so by Ordnance Survey – to be a village in Leicestershire called Fenny Drayton, definitely above and to the left of London.

As for the rainfall, across the south-east of England it is generally a bit less than 650mm a year. Sydney’s average rainfall is 1150mm, Istanbul’s 820mm, Dallas’ 880mm, and Marrakesh’s average is 250mm.

So, McMahon was wrong about Marrakesh.

To his wider point, however: south-east England is undeniably dry. Why object to someone saying that blindingly obvious truth? 

And I’m glad Tim has pulled London into his justification, because it is around London that our chalk streams are most damaged by abstraction. That’s because there are too many tea-pots, basins, showers, loos, baths and gardens relative to how much rain falls in the Thames basin.

The Misbourne is regularly dry. As are the upper Beane and Darent. Abstraction in the upper Lea is 90% of average recharge. The poor-old Lea doesn’t really become a river until the Luton sewage works discharge. 

That’s why we do need investment, a national grid for water, pipelines, reservoirs and de-salination. The lot.

The part of Tim’s statement that is of concern is the idea that if we don’t trim usage we may have to put other investments in place, which might be bad for customers.

That’s the bit to focus on.

Demand reduction per head of itself solves only one problem: demand increase through development. On it’s own trimming customer usage just allows the government to build more houses.

To see chalk streams flowing naturally again, we need to reduce the amount of water we take out of chalk aquifers. And we can’t do that without investment.

The abandoned chalk stream recovery pack?

As far as I have been told Defra has abandoned publication of the promised chalk stream recovery pack. A great shame for beleaguered chalk streams like the Ivel (above), the Lea, the Ver, the Darent, the Misbourne, the Cam, the Granta and dozens of other globally unique but over-abstracted and polluted rivers. Is the door open for a change of mind? I truly hope so.

That dogged river warrior Feargal Sharkey – who will no doubt be leading the river of people through London this weekend – repeatedly asked the last government after the fate of the chalk stream recovery pack that had been promised by then Minister Rebecca Pow. 

Twenty-one times he asked on Twitter what had happened to the document – Defra’s response to the recommendations in the CaBA chalk stream strategy – that the minister had said on the 15th June 2023 would be published by the end of that year.

It wasn’t. (Not the minister’s fault, btw … see below)

But since the general election Feargal has stopped asking. Which is a great shame, because his tireless needling does resonate in government. And the pack is worth publishing.

I have to admit, it used to bother me that he once asked so often, because elsewhere Feargal has written that the CaBA chalk stream work is a waste of time. I felt it was a taunt, much that I also wanted him to keep chasing. I don’t agree with him. Our chalk stream work is not a waste of time. But here was Defra proving him at least partly right, and utterly failing to fulfil a promise. 

Feargal’s tweets and the lack of anything material suggested that the pack was a total fiction. 

But I knew it wasn’t a fiction … because I was helping Defra to write it. 

And by December, the date by which it had been promised, it was all but ready to rock. Feargal kept on asking and I kept on waiting for Defra to prove him wrong and publish the damn thing. But the promised chalk stream recovery pack has gone round and round in circles ever since, every component repeatedly sliding back to the bottom of the negotiation tree as staff are cycled from one place to the next.  

Following months of groundhog day delays, it has now been shelved. Defra told me there is now “no mandate”. 

I suspect their reluctance to publish might partly be because myself and the brilliant Ali Morse – water policy director at the Wildlife Trust and vice-chair of the CaBA chalk stream group – worked so hard to make the pack amount to something: we were nettlesome and pushy, for sure. But I like to think always in a positive way. 

There may also, of course, be an element of the new administration wanting no part of the old: after all the pack was promised by the Conservative minister Rebecca Pow. But I prefer to think not.

Anticipating a Labour victory in an upcoming election I went to see the Cambridge Labour MP Daniel Zeichner in December ’23, when the chalk stream recovery pack was all but ready, but was failing to find a publishing runway or clearance from the Defra conning tower. 

I must have had some notion that Defra officials might filibuster the thing for as long as they could. I had met Daniel at a chalk stream conference in Cambridge and I had a hunch that he would be an important figure in a new administration. I wanted to emphasise how important it was that our collective approach to chalk stream conservation should transcend party politics if we were to stand any chance of making progress. 

Nothing he said made me doubt his commitment to that truth. Apart from anything else, he knew Feargal would hold them to account. I hoped, even believed, that a Labour government would be as supportive of our work to improve chalk streams as the Conservatives had been. 

And much as it runs against the grain of the popular view, some Conservatives politicians, certainly Rebecca Pow, and the likes of Sir Charles Walker and Sir Oliver Heald (all gone from Parliament) were very supportive. As were MPs in other parties, of course: Sarah Green MP, for example. And members of the House of Lords, notably Viscount Trenchard and all those who spoke in favour of including chalk streams in the Levelling up and Regeneration Act. Chalk streams have cross-party support.

The delay in publishing the chalk stream recovery pack actually had nothing to do with the Minister, Rebecca Pow. She was committed and passionate about making a difference, and appeared as frustrated as I was at the procrastination. My reading is that Defra was focussed on one thing: ending the media onslaught about raw sewage discharges. And their policy-making – in spite of good words about chalk streams in the Plan for Water – appeared to be focussed on this single BIG issue.  

If my hunch is true then, ironically, the ferocity of the raw sewage campaign was undermining the possibility of progress in all the other areas where rivers are equally, if not more pressured. The raw sewage scandal gets easy media attention and of course that is what government then responds to.

Techie, nerdy stuff like perfectly legal discharges of phosphorus, which arguably do more damage in many vulnerable, headwater settings, are then ignored.

But we should not ignore the full range of ills that beset our streams.

Our chalk stream restoration strategy and Defra’s unpublished chalk stream recovery pack, were based on the interconnectedness of pressures on rivers. It’s so important to build this understanding into advocacy and ultimately into policy, because otherwise you get skewed action or unchallenged inaction and you waste money.

For example, the impact of sewage and other components of poor water quality are inextricably bound up with abstraction and the quality of the physical state of the river. In the case of abstraction, most obviously because abstraction reduces flows and thus drives up the concentration of nasties in the water. As well as water temperature which turbo-charges the activity of those nasties. 

More subtly these pressures are bound up because in many places (especially headwaters of chalk streams like the Lea and Lark) we abstract so much that our river flows become – in summer – entirely supported by sewage discharges! 

Alternative abstraction and water treatment arrangements could feasibly and cost-effectively provide the same amount of water to public supply and allow naturalised flows which would immeasurably improve water quality. 

But this will only ever be possible if people think around the policies in a three-dimensional way and do not get swayed by single-issue protest into chasing half-baked policy responses.

As Ali and I tried in vain to persuade Defra to create a policy and economic driver that would address phosphorus impacts from small works in upper catchments we were told that what would be happening (instead?) is legislation to enforce the highest technical standards on designated rivers. In other words, only the places that were already good would get any better.

Now the new government appears to have ditched the troublingly joined-up chalk stream recovery pack and vowed to jail water company bosses who break the law, a populist policy, but not necessarily an effective one.

Steve Reed has announced a review of the water industry but the terms of reference do not look auspicious. There’s no sign of the nationalisation that some so hope for, but instead talk of ‘trade-offs balancing affordability with service and clean water’: which is exactly what we’ve had since forever. Only, without the clean water.

The environment always picks up the bill.

So, we have “a march clean water” but we should also march for “more water” and “better habitat”.

In the time I have dealt with Defra over a chalk stream strategy instigated by Defra – or at least their minister – I must have interfaced with at least half-a-dozen individuals who were handed the chalk stream brief. They have all been very bright, committed and well intentioned. They have all learned quickly about the pressures and the whys and wherefores of the policy recommendations in the CaBA strategy. Then just as they are getting their feet under the desk, they have been moved on and another fresh face has appeared on the Teams screen. This makes progress quite challenging.

The last new face I met had been shoved to the fore to tell us the recovery pack had been shelved, but that instead the government would focus on chalk streams in national parks and areas of outstanding natural beauty. In other words, as far as I could tell the new Labour government wanted to double down on the concept of privileging the privileged and abandon the chalk streams whose condition is most abject, in the suburbs and orbit of London, in the intensely farmed landscapes of East Anglia, and in ordinary towns like Dover, Driffield, Bridlington, Dorchester, Luton, Fakenham, King’s Lynn, Bury St Edmunds, which are the focus of so much concern. 

I hope everyone who reads this will think that is as misdirected as I do.

Knowing that I wasn’t speaking to the general and was therefore wasting my breath, I nevertheless pointed out that a central plank of the chalk stream strategy, signed up to by all parties, including the Environment Agency, Natural England, Defra and Ofwat and the water industry, was the urgent need for the protection of ALL chalk streams to match those few already well protected. 

The abandoned but oven-ready recovery pack addressed that protection through a range of commitments including time-bound goals for abstraction and phosphorus reduction bringing all chalk streams to good or high status by certain key dates. It also included undertakings to consider chalk streams irreplaceable habitats in planning law, to consider better practical measures to reduce run-off in improved farming rules for water, to include special consideration for chalk streams in national highways and local road network technical guidance, and in restrictions relating to septic tanks. 

Okay, so over time much of it became watered down by undertakings to review rather than to act. Frustrating but that’s the way these things work. And as statements of intent and clear support from government, it was still very much worthwhile.

Besides, when the pack wasn’t published before the election this became a golden opportunity for a new government, committed to the restoration of our rivers – as this one claims to be – to inject a bit more oomph and send it to the printers. 

I haven’t entirely given up hope however, because as I say, I’m not entirely convinced this decision – in as much as it is a decision, as opposed a slow and relatively silent abandonment – comes from the new government so much as the permanent department. In a recent debate on chalk streams Minister Emma Hardy was asked by Sarah Green MP when Defra would publish the chalk stream recovery pack. The minister didn’t entirely sound as if she’d been briefed about it. 

If only the minister had known it was ready to go, is a total no-brainer, could be made more impactful in a jiffy and would go down very well with all those people marching through London on Sunday.

And maybe two steps forward again?

I’m pleased to say that I heard yesterday from Paul Jennings – chair of the River Chess Association – that the Environment Agency had contacted him to say they will not go ahead with the resumption of the Alma Road abstraction: not for now anyway (see previous post).

Paul’s official statement reads: “The Environment Agency has announced that work on the resumption of abstraction at Alma Road, Chesham has been halted. Affinity Water has been asked to stop work. The Chiltern Society, River Chess Association and Chiltern Chalk Stream have been told that the EA want to engage with local stakeholders to present their evidence. The River Chess Association feels there will be little data to support the resumption of abstraction. It believes the focus should be on tangible flood risk identified by volunteers over the past 5 years not theoretical models.”

Respect to the EA for being gracious enough to listen to the public unease at their poorly explained and apparently not well justified plans, to act quickly and halt their work.

We’ll see now the real case for the proposal, but as I suggested in the previous blog post, manipulating groundwater levels to mitigate fluvial flooding is a very convoluted approach and unlikely to work, in my view. Fluvial flooding is all about channel conveyance capacity. The best way to use a chalk aquifer to mitigate flooding would be to address run-off in the upper catchment and make changes to ditches, drainage and land-management (encourage zero till, for example) so as to increase aquifer recharge rates and slow in-channel flow rates. The aquifer itself will then act as a buffer. Do that in combination with easing conveyance pinch-points in the channel, of which there will be many in a town like Chesham.

I also questioned whether repurposing a public utility groundwater abstraction licence towards so-called flood mitigation could possibly be within the conditions of the licence.

And finally I asked if deliberately increasing one form of environmental damage – abstraction – to off set another – flooding – might be in breach of water framework directive rules.

I hope all these issues are addressed when the EA engages with stakeholders.

Two steps forward, three steps back?

Why, oh why has the Environment Agency asked Affinity Water to turn abstraction pumps back on in the River Chess catchment?

In the late 20-teens John Lawson came to me with a great idea that could end over-abstraction in many chalk streams, especially those near London. He explained how in the next ten years or so Affinity Water would be building a pipeline to connect their southern region (south of the Thames) where they have more than enough water, with their northern, where they do not. This pipeline, said John, would enable the wholesale reduction of groundwater abstraction in the chalk stream tributaries of the Colne: iconic streams like the Ver and Chess that have been far too heavily abstracted for over half-a-century. And maybe the chalk streams of the Lea too.

If you turn the groundwater pumps off, a lot of the water you “leave in the ground” so to speak, comes back as flow in the stream. With a pipeline you could abstract the water at the lower end of the catchment instead, store it in reservoirs (of which there are several in the London area) and take the water back to the places it came from, to be used as public water supply. The difference being that this way, the rivers actually get to flow. We called John’s brilliantly simple idea “Chalk Streams First” because it gives the river first use of its water. With the support of a coalition of eNGOs we started trying to interest the water companies, the Environment Agency and Ofwat-Rapid (Regulators Alliance for Progressing Infrastructure Development).

Rapid was interested from the start. Paul Hickey, who directs Rapid, is passionate about ensuring we actually deliver on our environmental ambition. The Environment Agency was interested too. Even Affinity Water took to the idea, especially once the Environment Agency indicated that it might allow some variations on the theme and flexibility with licence relocation favoured by Affinity’s very clever technical guru, Doug Hunt.

The introduction of the Grand Union Canal transfer scheme promised to underwrite any losses to public supply (ie. disparity between what you no longer abstract at the top end and what you get back at the lower end of the streams) and thus Affinity Water started to build abstraction relocation into their business plan. They will address the Colne chalk streams to start with, but in due course all the chalk streams of the Lea could also be included. The first shots, the prequel shots in fact, were fired in 2020 when Affinity Water voluntarily shut down their Alma Road abstraction on the River Chess.

Through these same years the CaBA chalk stream strategy has gained momentum, with support from Defra, the water industry and all stakeholders. The Colne version of Chalk Streams First promised to become a national flagship for how to realign abstraction, put the environment first, but still take account of public supply. Literally everyone liked the idea. Who in their right mind wouldn’t?

So why, in the name of all that is Holy, has the Environment Agency asked Affinity Water to resume abstracting from Alma Road at a rate of up to 7 million litres per day, without much in the way of explanation (at first) or consultation (thus far)? The decision itself seems bizarre. The way it has been handled given how the plight of our chalk streams has touched the national consciousness and has been debated in Parliament, is clumsy, to put it politely.

In the interests of fairness, I ought to say that the Environment Agency has now explained that this request was made of Affinity Water in order to conduct a five-year modelling exercise to study the relationship between abstraction, groundwater levels and fluvial flood risk in the Chess catchment. Note the words I have placed in italics.

The River Chess has historically suffered from excessive abstraction which has reduced flows in the river and sometimes caused it to dry up altogether in its upper reaches. As with other Chilterns streams groundwater abstraction climbed massively through the 20th century, in the Chess from a minimal 2.5 Ml/d in the 1920s to a peak of over 20 Ml/d between 2008 and 2018, almost 38% of the average aquifer recharge, placing it amongst the highest impacted chalk streams in the country (in the more impacted, such as the Ivel and Darent, abstraction exceeds 50% of recharge).

The cessation of the Chartridge and Alma Road abstractions has reduced the overall catchment abstraction to more like 25% of aquifer recharge: still far too high, but enough to show noticeable benefits.

The River Chess Association report that otters, water voles, brown trout, water crowfoot, mayfly and rare invertebrates such as the winterbourne stonefly have all returned to Chesham. In fact nothing monitors improving river health more effectively than invertebrates. The Association has been recording river-dwelling invertebrates in Chesham since 2009. In recent years species previously unseen in Chesham have been recorded, including mayfly (Ephemera Danica), caseless caddis (Rhyacophilidae ), turkey brown (Paraleptophlebia submarginata), and the nationally rare winterbourne stonefly (Nemoura lacustris).  

Personally, I remember taking photographs in Chesham of a dry river in May 2017 and of a flowing river full of ranunculus in August 2022. The Chess stood for hope.

The River Chess a mere puddle in 2017
The same reach in 2022

So why toss that all away? The stated explanation seems feeble. When asked by the River Chess Association what reasoning and data were behind the decision, the Environment Agency replied:

“The Environment Agency used their current understanding of the relationship between groundwater abstractions, groundwater levels, and river flows in the Chess catchment. This included information from two reports … which concluded that there is a relationship between groundwater abstraction and river flows. Based on the conclusions from both reports, a potential increase in fluvial flood risk [arising from a reduction of abstraction – my clarification not EAs] could not be ruled out. Implementing temporary adaptive abstraction, as set out in the operating agreement, minimises the potential impacts of abstraction reductions on fluvial flood risk until these impacts are better understood and managed.”

This states the obvious – that there is a relationship between abstraction, groundwater levels and flows – and presents it as an explanation. Of course there is a relationship! That’s why we want the abstraction to be reduced, to increase flows in the river and thus river health. In as much as it is an explanation it seems to be saying that the resumption of abstraction will be used to assess if abstraction can be used to reduce flows in the river, and via this reduce the risk of flooding.

Taken at face value this is very strange reasoning. The idea appears to be to use abstraction to reduce flows in the river. Despite what the EA state about adaptive abstraction* in the operating agreement I wonder a) if repurposing an abstraction licence from its use for public water supply to a different use of so-called flood-risk mitigation is within the remit of the licence and b) whether it is entirely legal under WFD legislation to deliberately reduce the flows in the river in order to theoretically reduce flood risk.

(*adaptive abstraction essentially comprises the variation of pumping rates across time, but I’ve only ever heard of the idea as a means to reduce ecological damage, which is the unfortunate by-product of the public water use, the reason why the licence exists. The EA’s idea here is actually putting the abstraction to a entirely different use than intended by the existing licence)

But these queries aside, this plan is not even a good way to reduce fluvial flood risk. Of course flooding is related to flows (and flows to groundwater levels), but in a chalk stream fluvial flooding is much more likely to be influenced by things such as impoundments, culverts, drainage, ditching and land use in the upper catchment. The EA would be far, far better off looking at these issues in order to mitigate fluvial flooding.

And that aside, using groundwater abstraction as a temporary measure to reduce fluvial flooding is like blowing the other way in order to slow down a tanker. The impact of groundwater abstraction accumulates over time and its impact on flows is geared via its impact on groundwater levels. By the time you realise you might have to reduce groundwater levels to reduce flows it is too late. You could only reasonably make this idea work if you run the abstraction all the time and reduce flows all the time, which is exactly what groundwater abstraction does.

Besides, where are they going to put all the water? Pump it downstream?

To me this feels like a nonsense explanation.

As anyone with a Twitter account knows, the sewage works at Chesham spills groundwater ingress sewage all the time when groundwater levels are high. In other words the groundwater spills through cracks in the pipes and overwhelms the sewage works. It is almost certain that the increase in groundwater levels that has followed the reduction in abstraction has increased the groundwater sewage spills (that and some very wet winters).

Is this really about modelling something we know all about already (the relationship between abstraction, groundwater levels and flows, which it is perfectly possible to accurately model), or is it a designed to see if the groundwater ingress flooding can be reduced by resuming abstraction?

You decide. Maybe I’m being too cynical. But if my suspicions are correct the EA would be trying to play tunes on the theme of ecological damage, resuming one form of damage to reduce another and I’m not sure that’s such a great idea. Or maybe Defra is exploring ways to meet its own stormwater reduction plan targets for chalk streams? These pesky groundwater ingress discharges are going to be a hard nut to crack.

If the issue really is fluvial flooding, where is the risk occurring exactly? And why not consult the Chess Association, and the Chilterns Society / chalk streams project to explore how the flood risk could be addressed without pumping all the groundwater away? I will be happy to publish any reply or further explanation from the EA.