water – Chalk-Streams

Nationalisation-lite?

March 13, 2026March 13, 2026Posted in UncategorizedTagged environment, sustainability, uk-sewage, waterLeave a comment

Above: the Hogmsill chalk stream in south London spilling sewage in a light shower in 2007

Repatriation of ownership, public listing, long-term funding, transparency & accountability, independent regulation. It’s not rocket science.

Below is a three-minute summary of how that might work — and why the solution may lie somewhere between privatisation and nationalisation. Read beyond that for the full article.

The Water Industry Debate: A Short Version

Public anger over Britain’s polluted rivers has surged and campaigners are calling for the water industry to be nationalised. After decades of sewage spills and dividends flowing to investors, bringing water back into state control feels like justice.

But nationalisation alone will not necessarily clean our rivers. In the UK, pollution in Scotland and Northern Ireland—where water is publicly owned—are comparable to England and Wales. Across Europe, excellent water systems exist under a variety of ownership models. What the good versions share are long-term investment, governance, and strong regulation.

Britain’s sewage crisis is too deeply embedded to be sorted with a change of clothes. We inherited Victorian sewers that mix rainwater and wastewater, meaning rain regularly overwhelms the system and forces discharges into rivers. Add chronic under-investment (by government and private industry) going back 50+ years, population growth, urban paving, and patterns of heavier rainfall, and the pressure has only increased.

The other part of the failure is financial and regulatory. Water infrastructure requires large capital investment upfront that must be repaid slowly through bills. This should produce a stable, low-risk utility attractive to long-term investors. Instead opaque ownership and weak regulation allowed debt to balloon while infrastructure investment stagnated. Shareholder capital injections have been minimal, with most spending effectively directly funded by customers through their bills. Regulators focused solely on keeping prices low while environmental oversight weakened.

Nationalisation risks recreating the same problems. Two of the institutions that failed most visibly—Ofwat and the Environment Agency—are already public bodies. State ownership does not automatically deliver stronger accountability or better environmental outcomes. The lesson from countries with world-class water systems, such as the Netherlands, is that success depends on transparent governance, specialist institutions, stable long-term funding, and democratic accountability.

Rather than treating nationalisation as the only answer, we should focus on the structural weaknesses that allowed the crisis to develop. Reform could look something like this:

1. Compulsory public listing.

2. A re-patratration of ownership: 75% minimum domestic shareholders.

3. Clarity of corporate ownership / governance.

4. A financial and policy environment that encourages long-term, stable funding from sources that are sensitive to public opinion

5. A simple and easily comprehensible method of assessing and publicising relative environmental performance.

6. Functional specialisation: separating water supply from sewerage and water treatment.

7. Regulatory specialisation: discrete and independent bodies for standards, permitting, monitoring and enforcement.

8. Democratically accountable catchment authorities that are independent of central government.

9. Complete transparency and real-time data.

10. Formalised 3^rd sector and citizen science validation of standards.

Rivers do not care whether the water industry is owned by the state, by pension funds, or by listed companies. They respond only to whether sewage is treated properly, infrastructure is maintained, and the law is enforced. If we keep the debate focused on those outcomes, rather than on ideology, we might build a water system worthy of the landscapes it serves.

Nationalisation-lite – the longer version.

Taking its lead from last year’s hit drama Mr Bates Versus the Post Office, Channel 4’s Dirty Business has dramatised the malpractice of water companies and the incompetence of regulators, bringing public anger to a fever pitch.

From the town square— the X account of Hugh Grant, for example— comes the universal cry to ‘nationalise the water industry’. Nationalisation is, after all, what leading lights amongst the campaigners have been calling for. As Feargal Sharkey said to Toby Perkins MP, Chair of the Environmental Audit Committee, last summer 2025: ‘Right now, the vast majority of this industry, if not the whole industry, actually needs to be taken back into state control’.

Not nearly as prominent a voice as Mr Sharkey, I have nevertheless been campaigning for river health since the early 1990s. I co-authored the 2017 WWF report Flushed Away that helped bring this sewage scandal to a wider audience and stood with WWF’s brilliant Rose O’Neill and Kathy Hughes in a drafty corridor in Westminster, vainly trying to interest passing MPs. I should be delighted that a campaign once thought too esoteric for the public to care about (WWF hesitated over publication) has now hit the headlines. Finally, something might happen.

So, why do I feel uneasy about this war-cry of nationalisation as the answer? Reform UK has expressed support, and I suspect a more left-leaning Labour government might eventually do the same, particularly under pressure from the Greens. The current Labour government has taken state ownership off the table, for now, but you never know.

It’s not as if nationalisation would necessarily be the wrong answer long term, but quite apart from the fact that decisions like this shouldn’t be swayed by TV dramas, it feels in its current catch-cry form like too much of an easy, crowd-pleasing solution and one that won’t necessarily lead to cleaner rivers and seas.

Nationalisation has replicated and could very well again replicate the failings of the privatised system, under a different guise. Unaccountable corporate greed or unaccountable inefficiencies of state: take your pick. I’m more interested in the environmental outcome than thumbing the eye of capitalism: even if, in this case, the thumb may be deserved.

An equality of badness

There is mixed evidence, at least nationally, as to whether state-owned water industries lead to better environmental standards. True, beyond our shores the best countries for quality of wastewater treatment all feature various forms of municipal and state ownership. But here in the UK, where we appear constitutionally unable to run state entities as well as they do on the Continent, the pollution of our rivers and seas is as bad in Northern Ireland and Scotland (where water is state-owned) as it is in England and Wales.

Conversely, there is little evidence that private companies deliver better environmental standards either. This equality of badness may, in large part, boil down to cost. A clean environment is more expensive than a dirty one, no matter who is running the system. Over the last 50 years we have had underinvestment by the state followed by underinvestment by private companies. Is this because a world-class system would cost more than the British public is willing to pay? Has our industrial heritage driven too deep a wedge between people and their own landscape?

It can’t be an accident that the five best European countries for quality of wastewater services are motivated by the need to look after prominent and fragile ecosystems: Denmark, Finland, the Netherlands, Switzerland, and Austria. Of course, England’s population density is much higher— 450 per square kilometre— than all of those other ‘good water’ nations, bar the Netherlands (441). Wales is comparable with Denmark (150 v 140), Scotland (70) is someway between Finland (18) and Denmark (109).

Arguably, none of the above rivals started from such a low base. In the UK, river water quality is actually much better now than it has been for several centuries, especially when it comes to poo. Rivers like the Mersey once clogged with islands of industrial filth. When the SS Alice sank in the Thames in 1878, it was the sewage-infested water that killed people.

Designed to pollute

Worse, in the UK we have inherited a water system that is pretty much designed to pollute: Bazelgette’s combined sewerage was a massive improvement relative to the squalor of the mid 19th century, but time has caught up with it. We have plugged our modern lifestyles and the Augean oceans of poo 70 million people produce onto the nation’s river network via a system of pipes that must be flushed through with rainwater to remain functional. To keep even vaguely on top of this, our sewage systems need to have massive overcapacity and then must also stay ahead of the relentless creep of urban sprawl, paving, house building, car parks, retail parks, and roads that send more and more rainwater down the drain. Not to mention the 13 million extra bottoms relative to when the water industry was privatised and the more intensive rainfall patterns of recent years.

Now you see it, now you don’t. Our ‘combined’ sewage system has a fundamental flaw, mixing rainwater with sewage.

It is clear that privatised or nationalised, our industry needs investment: firstly to become fit for purpose with its existing, flawed (combined rainwater and wastewater) plumbing network and masses more investment than that to become fit for the 21^st century. I wrote about a better system in my last blog: as far as possible we would take our rivers – certainly our most ecologically fragile rivers – off the supply and discharge network altogether. We would take the water in pipework to large, technically advanced treatment works close to the coast, with all the existing sewage works repurposed as stormwater storage tanks, like beads on a chain. This is all a long way off. For now we need to fix the holes in the roof. As we stand, water companies are looking to Ofwat to take the brakes off and provide a bit more investment through increased bills. Ofwat is looking to shareholders to fund their share. One option is unjust (in the historical context); the other is unlikely to happen.

But the fundamental idea of privatisation is not inherently wrong (nor nationalisation, for that matter), and need have nothing to do with the grottier ends of capitalism. Under any form of ownership, sewage infrastructure (if it is to be functional) requires a lot of capital, so much that it must be borrowed and the debt recouped over time through the bills charged to the beneficiaries of that infrastructure. The creditor (whether lending to the state, municipal utility or a private company) will therefore demand a reasonable dividend – they’re not going to invest for free – but they can at least be sure of a very reliable income stream, for people must use the loo in good times and bad.

I don’t see any way round that basic model. Either the government borrows the money and water infrastructure joins the queue behind all the other things the government must borrow money for (welfare, the NHS, education, policing, and defence). Or private companies, or some other institution, must borrow it. Independent funding is a feature of the exemplar publicly owned system I analyse below. A very large part of the protest against the current set-up in the UK is the apparent profiteering. However, a private entity can take various shapes and forms, can even be not-for-profit. Ideally to investors a water utility should look more like an income-yielding bond, rather than a geared-up cash cow.

Clearly, any set-up needs effective regulation, and clearly, our privatised industry didn’t get it. The problem was not so much the principle of privatisation but the way it was allowed through lack of effective regulation, environmental or financial, to metastasise into opaque financial wizardry.

How we got here.

The water industry was privatised in 1989. For a while, some extra investments were made: the shares floated at about £7 billion. Debt was written off and a green dowry added by the UK government to sweeten the deal. The infrastructure was in no great shape, and at the time, society had no real awareness of the degree to which releases of raw sewage were just part of what went on. In the 1980s, ‘Bocky Belly’ was an inevitable side-effect of swimming in the Frome downstream of Dorchester. I’m sure it was the same everywhere. People joked that you couldn’t drown in the Mersey, because you’d die from poisoning first.

Years later, it became clear that water companies really were routinely dumping raw sewage into rivers and seas (I took the photo at the head of the blog in 2007 and if you could smell it you’d gag), though still no one quite knew how much or how often. It was all just ‘flushed away’. In 2012, the much-unsung environmental hero Bob Latimer established through the European Courts(see para 7.) that according to the Urban Wastewater Treatment Directive – to which we were signatories – raw sewage should not be released other than in ‘exceptional weather conditions’: very much contrary to what was happening on his local river, the Whitburn.

A short while later, Fish Legal won a ruling that compelled water companies to comply with Environmental Information Regulations, and on the heels of that, WWF’s Rose O’Neill sent a Freedom of Information request to every water company, asking for details of their raw sewage spills. From memory, only one answered because only one had any idea. At the time, only a handful of sites were monitored at all. However, research by the South East Rivers Trust showed that the outfalls on the River Hogsmill in South London were spilling far more frequently than they had been designed to. And into a fragile chalk stream at that, the site of John Everett Mills famous painting of Ophelia. The spills were not related to exceptional weather.

If only that had been the worst of it. It took dogged campaigners like Phil Hammond and Ash Smith (as portrayed in the Dirty Business drama) to push more persistently and unearth a nationwide scandal of environmental malpractice driven by financial malpractice.

As Flushed Away identified, water company investment had stalled: that’s assuming it had ever really started. I remember we calculated that at the existing levels of investment in 2015 it would have taken 800 years to upgrade the systems. Ofwat – the financial regulator – set the price of water and was determined that it wouldn’t go up. Shareholders added little extra capital over time. Caught between the regulated price and income-hungry shareholders, water companies sweated sewage infrastructure to breaking point and the environment paid the bill. Debt accrued but flowed sideways into the pockets of shareholders, many of them overseas institutions that – one might argue – had little interest in the UK’s environment.

Clearly, Ofwat failed to curb any of this. So long as the price to the consumer remained low, the feeling was – so one must guess – that the greater good was being served? Besides, Ofwat at the time had no environmental remit, only one of cost to the consumer. However, the Environment Agency, whose job it is to police the industry’s environmental standards, must also have been asleep at the wheel. Monitoring of river water quality, of fish and invertebrates, all fell from regular to infrequent to scant in the early 2010s. Prosecutions for pollution were rare. Water companies were left to mark their own homework. From the outside it looked as if the environmental regulator was compromised by the economic implications of applying the law.

No wonder it all went wrong. Now, almost everyone agrees that structural change is needed.

Structural change

The Water Special Measures Act is this government’s attempt to address some of those failings. A lot of store is being set by the potency of other eco-populist catch-cries: bonus bans and criminal liability. I don’t know how effective these will be. Do we really think that water-company chief executives set out to break the law? Sewage infrastructure is not fit for purpose because of a problem decades in the making, now colliding with a level of public awareness far higher than even a few years ago. In AMP8 Ofwat has allowed for an unprecedented level of investment, very largely paid for by increased bills and only time will tell to what extent this starts to address the problem. It is only the start, however.

Looking at where we are and where we go next, the Achilles heel of nationalisation as an alternative is surely that two of the three institutions responsible for this poor situation are public bodies already. If Ofwat and the EA failed in their parts, why should we expect a public water industry to per se do any better?

The fact is we have had nothing like the reasonable investment model that we might have, where shareholders look not for creaming profits but for a modest, steady yield, offset by minimal risk. Instead, as research has shown, we have had net zero investment, debt has ballooned, and the money spent on infrastructure has all come from customer bills. According to a 2024 analysis by David Hall from the University of Greenwich – refuted by Ofwat and the industry – shareholder investment has effectively amounted to zero in real and adjusted terms between 1990 and 2023. At the same time, debt has ballooned from effectively nothing (the companies were debt-free at privatisation) to around £70 billion today. The total spent on infrastructure has been about £190 billion, but where did the money come from? Mostly from bills, according to David Hall, while all the debt has allegedly gone to pay dividends.

The difference between fair and what we got

The difference between a fair model and the model we got must surely be the difference between the dividends owners have paid themselves and a fair dividend yield on the investments made.

Against the £190 billion invested in infrastructure, £70 billion is modestly inline with a fair yield, equating to roughly a 2% pa dividend. However, if the £190 billion mostly came from bills, and a much lower sum was invested – and it appears to be true that there have been few injections of fresh capital over time – that £70 billion of dividend, rather than being a reasonable yield on £190 billion of investment, is a very generous yield on the amount invested at floatation. A fair yield on the £7 billion would have amounted to between £9 and £16 billion. (2.5% – to 3.5% over 35 years).

Meanwhile, according to critics, the companies have been leveraged with debt and bills have been higher than they should have been, in spite of Ofwat’s determination to keep them low.

All of which suggests that the system needs rebuilding. And yet while nationalisation might stem the bleed of debt capital to overseas ‘investors,’ would a nationalised version be any better from an environmental point of view? Let’s not forget the problems privatisation was supposed to address: regional water authorities disinclined to prosecute themselves for polluting waterways, chronic underinvestment (by government), creaking infrastructure, deteriorating water quality (a 1985 River Water Quality survey found a high % of sewage works breaching their limits), and very little appetite by customers to pay more for their water and sewage. The full English one might say, since we are so very good at polluting rivers. Plus ça change.

A paucity of ideas

The replication of these problems, whether under private or public ownership, probably explains the vagaries in the public debate. Beyond the easy catch-cry of nationalisation, there are few ideas, with the exception of those coming from Dieter Helm.

Alistair Carmichael MP, chair of EFRA’s Commons select committee, was tellingly non-specific when quizzed by Toby Perkins MP, chair of the Environmental Audit Committee. EFRA looked at ownership models to inform the Cunliffe report: the government had – at that time – ruled out state ownership. Nevertheless, said Carmichael, there is a fundamental truth that ‘you can have any model of ownership that you choose, but actually, if your industry as a whole has the wrong culture, if you lose focus on the customer service and environmental protection, then you’re always going to end up with bad outcomes.’

Instead of starting with the answer of ‘nationalisation’ and working backwards, we might do better to look at specifically what has gone wrong – a hurried privatisation that didn’t compel proper investment, opaque ownership regulations with no obvious accountability, a total failure of economic and environmental regulation, all built around a system of infrastructure that is conceptually flawed – and try to build a better answer from there. The clear evidence globally is that good environmental outcomes depend on satisfactory levels of investment, adequate regulation, and corporate governance, no matter how the water entity is owned.

Carmichael argued that regulation is what it boils down to, and many will agree with him. The regulator must keep the industry’s ‘feet to the fire,’ however the industry is constituted. Our regulatory system, Carmichael highlighted, is split between too many agencies and was not set up to cope with the labyrinthine financial structures the water companies fragmented into over time.

Hmmm. The single regional regulatory authorities that preceded privatisation had failed too. A 2020 Cambridge University Press study into drinking water standards found that public bodies commit significantly more treatment and contamination event violations and fewer reporting violations relative to private bodies, but also speculated that private bodies may exercise strategic underreporting. Which might lead one to the obvious conclusion that no matter what structure is set up, the regulatory side must be completely and effectively separate from the operational side and must not be captured by economics. Although the system has clearly failed, I have strong doubts that the state would have regulated itself any better.

In the UK, it has taken a third-sector form of inspection and regulation by protestors and NGOs to bring the issue to the fore. Any good system going forward must make room for a formal moderation by citizen scientists of the official marking system and the inclusion of that third-sector moderation in the regulation process.

Nevertheless, this economic capture is probably inevitable, to some degree, both of the state regulator and – surprisingly – the courts. In his book The River Pollution Dilemma in Victorian England: Nuisance Law versus Economic Efficiency, Leslie Rosenthal convincingly argues that in spite of the fact that British rivers have been protected back into the mists of time by Common Law and riparianism (the principle that owners of waterside property may make reasonable use of the water so long as that use does not inhibit the water’s quality and quantity for other users), a balance of convenience skewed towards economic efficiency and the greater common good has long overridden the common law in terms of practical application in the courts. Courts are unwilling, in other words, pedantically to apply the law if it causes economic harm (i.e. the cost of water going up) to a very large number of people, relative to the rights of a few.

It has made virtually no difference over time whether our rivers have been protected by riparianism, the 1876 River Pollution Prevention Act, the Prevention of Pollution Act of 1951, or the Urban Wastewater Treatment Directive. Economic efficiency will prevail, no matter how much a middle-class wild-swimmer or trout-angler (like me) may wish otherwise. Many critics insist that ‘we just need better enforcement,’ and they are not wrong, but the idea that courts alone can drive the levels of investment needed to build a world class system seems far-fetched.

Going Dutch?

So, what are the features of world-class water systems and how can we adapt them to our somewhat unique situation of inherited rust, too many bottoms, too much paving?

The Dutch system is widely regarded as among the best in the world. Drinking water is of a very high quality and is less expensive to the consumer than in the UK. Wastewater is treated to a very high standard too – 70% undergoes sophisticated tertiary treatment.

With the exception of the combined authority that serves Amsterdam (Waternet) the supply and treatment of drinking water is separated from the collection and management of sewer systems, which is in turn separated from the management of wastewater treatment plants. This allows for a high degree of specialisation.

Drinking water is supplied by regional non-profit and publicly owned utilities. Tariffs to the consumer cover costs, investment and maintenance.

Wastewater, on the other hand, is run under the Dutch water authority model, Waterschappen, comprising twenty-one decentralised public bodies (generally defined by geographical catchments) that form the main operational component of the water management system. Responsibilities include flood protection, water levels, water quality, and – critically – wastewater treatment.

Importantly, in terms of what we might learn, these regional boards are democratically accountable and are technically highly specialised and experienced. They are among the oldest democratic bodies in the country, originating in the 12^th century and have acquired expertise over the centuries. They levy their own taxes and also have access to long-term financing through the publicly owned Nederlandse Waterschapsbank (NWB Bank), which provides low-cost loans for public infrastructure. This financial autonomy ensures stable funding for long-term water management projects and supports the sustainable operation of the Dutch water governance system.

The cornerstones of the managerial system are, therefore: functional specialisation, decentralised governance, democratic legitimacy, and financial independence.

Regulation

That’s all very well, but who holds their feet to the fire? In the UK, Alistair Carmichael MP pointed to the ‘littered landscape’ of Ofwat, the Environment Agency, the Office of Environmental Protection, the Drinking Water Inspectorate, as part of the problem in holding the water industry to account. ‘You know, everybody’s got a bit of skin in the game, and then when things start to go wrong, it’s too easy for somebody to say, well, that’s not really our job, it’s theirs.’

Countering the Carmichael viewpoint, the Dutch system is radically decentralised with tiers of overlapping regulatory responsibility. Water boards must answer to the National Inspectorate (ILT), Provincial permitting authorities, the National Water Manager Rijkswaterstaat, scientific oversight (RIVT) , democratic elections, the courts, and effective public scrutiny.

Carmichael’s thoughts presaged those of government, however. In June last year the environment secretary Steve Reed announced that Ofwat would be abolished and a new super regulator would take over from Ofwat, the EA and the drinking water inspectorate. ‘A single, powerful regulator responsible for the entire water sector will stand firmly on the side of customers, investors and the environment and prevent the abuses of the past’.

The Dutch model suggests that overlapping or even split regulation was not the problem. Quite the contrary, it has been a strength. The problem in the UK is buried in the optimism of Steve Reed’s quote. A conflation of the interests of customers, investors and the environment is exactly what Ofwat and the EA got so wrong. The interests of customers, for example, are precariously balanced around the question of cost. A single, super regulator sounds very grand but at the coal-face it’s always a trade-off. Resolving these competing interests is not at all easy in theory, let alone practice. I’d place more faith in discrete and clearly defined areas of regulation with watertight barriers around any possibility of regulatory capture.

For a long time, for example, the thought was that a major barrier to progress in curtailing the over-abstraction of rivers, was the water company licence of right to abstract. What we needed, we all thought, was the ability to remove those licences when it is clear a stream is being damaged, without the need to compensate the water company. We now have that ability, but vanishingly few licences have been revoked. The burden of proof has now moved to slam-dunk, plank-in-the-face evidence of damage, beyond a dry riverbed and dead fish, mind, because a dry riverbed and dead fish might be down to natural causes. The EA has long been caught between protecting the environment and permitting activities that damage it. This is an impossible situation. So long as the EA is saddled with schizophrenic regulatory tasks it will struggle to do its job properly.

A super regulator may well struggle with the same issue of irreconcilable interests. And when it does, money will win, just as it does now.

Nationalisation-lite.

So, if and when the regulators fail to ‘hold feet to the fire,’ – which they will from time to time, even in a perfect world – we come back to the question of governance and accountability. Something that is so clearly transparent in the Netherlands. How directly publicly accountable are the ownership structures in the UK?

Not very much, is the answer. Only three out of nine (South-West Water, United Utilities, and Severn Trent) are publicly listed. The majority of the shares in each of these – 60% to 70% – are held by UK investors, mostly pension funds, insurance companies, and retail investors. These institutions, which will all have active Environmental, Social, and Governance (ESG) departments, should in theory be more sensitive to UK public opinion than the complex and opaque smorgasbord of private equity, foreign sovereign wealth funds, foreign pension funds, and asset management companies that own the other six water companies.

Does this difference in ownership structure translate across to differing levels of environmental performance? Maybe. Severn Trent was the only company with a top-of-the-class rating in 2024. However, Wessex Water appears to be the water company with the best environmental record over time, and yet it is majority-owned by the Malaysian infrastructure conglomerate YTL.

Even so, clarity and accountability could and should make a difference.

It is standard practice globally that companies of particular strategic importance to a nation – airlines, for example, telecommunications, energy – must have a minimum percentage of domestic ownership. Delta, American Airlines, Air Canada, and Qantas must all be owned by a minimum of 51% domestic shareholders. In Canada and Japan, foreign investment is limited to 20% of telecom operators. Both Canada and Australia edict that domestic pension funds must hold majority shareholdings in strategically important companies. The reasons are obvious but include security and economic sovereignty.

Why should water be any different? If all the water companies were by law publicly listed on the UK stock exchange, with a maximum foreign ownership capped at, say, 25%, it would surely lead to more clarity and therefore accountability in their governance. Even better if the financial system and policy environment strongly encouraged investors such as domestic pension funds to own large shares of this national infrastructure. Pension funds have long investment horizons, a need for steady income, and an ability to invest very large sums of money on fair terms. UK pension funds and their active ESG departments should be much more sensitive to public opinion than opaque overseas financial vehicles.

Especially if we could also create a clearer portrayal for customers of ownership associated with relative environmental performance. Why shouldn’t every water bill list who the primary shareholders of that company are? And, why shouldn’t every water bill include the environmental performance rating of that company over the previous one year and five?

The Environment Agency produces a star rating every five years. But few people know about it and it is a bit too esoteric for customers in my view. Customers need a little blue drop or a little brown drop. And they need this printed prominently at the top of the water bill alongside the company logos and a list of who the primary UK-based shareholders are. I can see the likes of Legal & General very much preferring to see their names printed under the blue drops, not the brown.

I have no idea how legally tricky it would be to mandate this public listing, to mandate a minimum % of UK ownership, and enact the policies that would encourage the right kind of investor. But I suspect it would be easier, and less expensive for the government than nationalising the industry and less likely to spook the markets, to use an overworked phrase. A system such as this would achieve a level of nationalisation-lite and powerfully add to our arsenal of regulation the leverage of corporate sensitivity to public opinion, curtailing the financial shenanigans and driving stronger environmental stewardship over time.

Ownership alone will not clean our rivers.

It is tempting, when a system fails so visibly, to reach for the most dramatic solution available. Nationalisation has the virtue of clarity and the emotional satisfaction of redress. After decades in which the public has watched sewage pour into rivers while dividends flowed out to investors, it is easy to see why the call resonates. However, the failures we are dealing with are systemic. They include poorly designed privatisation, unaccountable corporate ownership, and a regulatory regime tasked with divided and irreconcilable priorities, that was under-resourced and in places captured by the very economic constraints it was meant to police. Changing the ownership without fixing those structural weaknesses risks simply recreating the same problems in a different set of clothes.

What ultimately determines environmental outcomes is more practical: sustained investment, transparent governance, and regulators that are genuinely independent and empowered to enforce the law. Countries that succeed at managing water tend to combine these features regardless of whether their systems are public, private, or hybrid.

That is why a better path may well lie somewhere between the slogans. A system that makes ownership transparent, encourages long-term domestic ownership and investment, aligns shareholder incentives with environmental performance, and strengthens independent environmental regulation could deliver many of the benefits people associate with nationalisation without the financial and political upheaval of full state takeover.

Call it nationalisation-lite if you like.

1. Compulsory public listing.

2. A re-patratration of ownership: 75% minimum domestic shareholders.

3. Clarity of corporate ownership / governance.

4. A financial and policy environment that encourages long-term, stable funding from sources that are sensitive to public opinion

5. A simple and easily comprehensible method of assessing and publicising relative environmental performance.

6. Functional specialisation: separating water supply from sewerage and water treatment.

7. Regulatory specialisation: discrete and independent bodies for standards, permitting, monitoring and enforcement.

8. Democratically accountable catchment authorities that are independent of central government.

9. Complete transparency and real-time data.

10. Formalised 3^rd sector and citizen science validation of standards.

Above all, the debate should not become a proxy war over ideology. Rivers do not care whether the water industry is owned by the state, by pension funds, or by listed companies. They respond only to whether sewage is treated properly, infrastructure is maintained, and the law is enforced. If we keep our focus there — on the ecological outcome rather than the ownership model — we might build a water system worthy of the landscapes and people it serves.

The future of chalk streams, if only we’d grasp it

February 17, 2026February 18, 2026Posted in UncategorizedTagged climate-change, environment, nature, sustainability, water1 Comment

Back in the summer we received a letter from Defra and Minister Hardy about the government’s plans for chalk streams, after they abandoned the long-promised chalk streams recovery pack. I wrote about that letter HERE.

Twice recently I’ve been asked to summarise what could be done that would be ecologically effective and cost-effective. As ever, it’s the cost of protecting nature that sets the pace. The answer is no more than I have written about before, because the ideas were always cost-effective. But perhaps if I express it all as a very simple, rounded package that could be started immediately in at least one – if not two – major catchments: London’s Rivers Colne and Lea. It goes like this:

Re-naturalise flows by relocating abstraction

Take the chalk streams off the sewage discharge system and repurpose the small sewage works as stormwater storage

Re-meander the rivers, especially in public spaces, and in so doing boost biodiversity, flood management and carbon sequestration.

In my view this would be a total no-brainer and I can’t understand why we’re banging on about water company bosses doing jail time, when we could actually get on with fixing things.

Recovery of healthy flows

It starts with Chalk Streams First. A very simple and cost-effective way to re-naturalise flows in those very heavily abstracted chalk streams around London and Cambridge. Chalk Streams First relocates abstraction from upper catchment groundwater to lower catchment surface flow and allows the chalk stream first use of the water, all without a significant loss to public water supply. It’s chalk stream cake-ism.

An ongoing process called the National Framework (NF) has identified the deficits to good ecological flow in all of England’s rivers. The water companies, NF regional groups and Ofwat RAPID are developing multi-decadal strategies for water supply, security and environmental protection and restoration, including addressing those deficits to good flows. The smorgasbord of options at their disposal includes reservoirs, pipelines, desalination plants, recycling etc. We should see Chalk Streams First as another major one of these “strategic options”.

Conceptually, CSF, works by greatly reducing groundwater abstraction in the upper reaches of chalk streams. This leads to flow recovery, as the groundwater bounces back up. Generally speaking around 85% of the reduction recovers to the river as surface flow (some is lost as aquifer throughflow and some as evapotranspiration). This re-naturalises the flow in the chalk stream and the extra flow can be taken as surface abstraction much lower down the river system from the reaches where the ecology is less flow dependent. The water is then stored in reservoirs and piped to the places formerly supplied by the groundwater abstraction.

Dorset’s River Piddle is one shining example of what happens when flows are re-naturalised. This exact spot used to dry up regularly when abstraction was at its peak in the 1980s

There is a caveat: the flow recovery is not evenly spread through the year. It is much higher in winter, well over 100%, and commensurately lower in the summer. This leaves you with a summer shortfall, hence the need for a reservoir. In times of extreme drought, the flow recovery would be minimal and public supply threatened.

Ensuring public water supply in droughts

This is where you bring in the concept of a public supply groundwater back-up. Counter intuitively, it is during the drought that you draw on groundwater abstraction to make up the shortfall. Essentially you temporarily mine the aquifer (taking water from aquifer storage in the midst of the drought) and use the chalk streams as the means of delivery from the point of groundwater abstraction to the point of surface water abstraction. The scheme runs for just long enough to get you through the drought.

This actually protects the chalk streams with boosted flows in the drought, though this protection is a bi-product, not the purpose. It leads to slower aquifer recovery in the following winter and perhaps lower than normal flows the following year. In spite of that, the chalk streams flows throughout are still much better than they would be under our existing, chronic abstraction scenarios. A scheme like this already exists: the West Berkshire Groundwater Scheme run by Thames Water. It has been needed only a couple of times in the past 25 years and even then only briefly.

Essentially, Chalk Streams First allows us to re-naturalise flows in chalk streams without a significant loss to public water supply.

Using Chalk Streams First to solve our sewage crisis

Isaac Walton’s beloved River Lea doesn’t really exist upstream of Luton sewage works. Is there a future world where it meanders healthily through Leagrave Park, while the sewage is piped down the valley to much more technically advanced treatment works?

There’s ANOTHER dimension to the Chalk Streams First idea that has been unsung thus far, but which could be THE answer to the 24/7 inflow of nutrient rich and scantily treated sewage water to the upper reaches of our chalk streams from sewage works that are otherwise very expensive to upgrade. The brutal truth at the moment is that many to most of the chalk streams in heavily developed catchments actually need sewage discharges to meet flow targets. The Lea doesn’t really start life until the Luton works outfall. But re-naturalised flows driven by the aquifer would mean our streams are no longer dependent on sewage discharges for flow.

This will give us a solution to the thus far impossible issue of getting cost-effective phosphorus stripping to small-scale sewage works in the upper reaches of rivers. The water industry has actually done a lot to reduce phosphorus discharges, but the laws and incentives have been constructed in such a way as to drive all the investment to very large treatment works. The smaller works get left behind, even though they create the greatest problem in the most ecologically sensitive places.

Chalk Streams First means we could take our chalk streams off the water supply AND discharge circuit altogether. If we no longer need discharges for flow, the small sewage works that currently exist can all be connected and piped down the valley to larger works. Each STW that comes off-line as a treatment works can then be repurposed as storm storage facility, providing a series of buffers in the system.

If flows were re-naturalised we would no longer need sewage discharges to meet flow targets in our chalk stream headwaters and upper reaches. We could take our chalk streams off-line and treat all the water in larger works further down the valleys. Small sewage works could be re-purposed as stormwater storage areas, placing buffers in a daisy chain down the system.

Re-meander the streams, increase biodiversity and store carbon

Finally, you add to the above the comparatively cost effective physical restoration of streams that have been greatly modified over the centuries. Natural chalk stream floodplains are potentially vast carbon sinks, but we’ve dried them out and corralled our chalk streams into canalised straitjackets. I’ve just completed a raft of proposals along these lines for chalk streams in Norfolk and as part of that process reviewed the costs per mile of large-scale re-meandering and floodplain restoration. The numbers – £100 to £350K per mile – seem high, until you compare them to other numbers and reflect on the way in which restoration on this scale adds up to genuine and massive gains in biodiversity, natural flood management and carbon capture. By comparison, it costs well over £2 million to resource a 1-megalitre per day water supply.

Put those three measures together and you have the chalk streams of the future, once we get a government sensible enough to see the potential.

We live in hope.

This lovely image by photographer Charlie Hamilton-James is of a re-meandered chalk stream in Norfolk. There’s no reason why we shouldn’t roll out this sort of stream and floodplain recovery in public spaces and parks in the chalk landscapes all round the Chilterns and London, boosting biodiversity, flood resilience and carbon sequestration.

Full text from the House of Lords debate ref the protection of chalk streams and the Bishop of Norwich’s amendment to the Planning and Infrastructure Bill.

October 29, 2025October 29, 2025Posted in UncategorizedTagged chalk streams, environment, water1 Comment

Extracted from Hansard Report – Planning and Infrastructure Bill – Hansard – UK Parliament

Amendment 93

Moved by

Baroness Grender

93: Clause 52, page 73, line 22, at end insert—

“(6A) Where a strategy area includes a chalk stream, the spatial development strategy must include policies on permissible activities within the area of the stream for the purposes of preventing harm or damage to the stream or its surrounding area.”Member’s explanatory statement

This amendment would ensure spatial development strategies include policies to protect chalk streams.

Baroness Grender

My Lords, Amendment 93, in my name and that of the noble Baroness, Lady Jones of Moulsecoomb, aims to secure the future of England’s chalk streams by enshrining specific protections and standards into our planning regime. As we made clear in Committee, these globally rare ecosystems—there are only 200 in the world—are often referred to as our country’s rainforests in terms of biodiversity and they face genuine risk from piecemeal development and inadequate water management. These are risks that will only intensify without a robust and specific legislative lever.

Relatively recently, I went for a customary walk in a beautiful green space in south-west London, only to discover that the beautiful River Wandle, home to brown trout and kingfishers, had been destroyed by a devastating diesel leak. The Government intend to streamline housebuilding and environmental measures in tandem, but the practical reality is stark.

Chalk streams are uniquely vulnerable. Abstraction of water, chronic pollution and unchecked development have led to tangible declines in many local areas. In 2023, the Liberal Democrats collected data through freedom of information requests, which revealed that one in 10 chalk stream sewage monitors were faulty, with some water companies having much higher rates of broken or uninstalled equipment.

Amendment 93 delivers a targeted solution: a statutory driver for sustainable drainage standards before any development interfaces with public sewers, closing a loophole that currently exists and has allowed cumulative harm to chalk streams. This amendment would ensure that developers are compelled to apply national standards for drainage and water treatment ahead of any permissions, rather than leaving mitigation as an afterthought.

Amendment 94 in the name of the right reverend Prelate the Bishop of Norwich complements this approach, and I thank him for the work he has done on this issue and his environmental expertise, which he has brought to this debate. Amendment 94 tightens oversight and demands full transparency in environmental impact reviews on watercourses at risk, an essential safeguard for communities whose local rivers are too often treated as collateral damage by the planning system’s inertia.

None of us should accept that cleaner, safer waterways are an optional extra and a nice to have. By adopting an amendment on chalk streams and supporting, out of these two amendments, Amendment 94, this House will signal that nature restoration, water quality and sustainable infrastructure are not in competition but can be advanced through co-ordinated and legally binding steps. I urge noble Lords to support these amendments for the sake of our streams and the communities they sustain.

If the right reverend Prelate the Bishop of Norwich moves to a vote, these Benches will support him. It is right that, with something as crucial as our unique chalk streams, we ask our colleagues in the House of Commons to think again and strengthen and protect in law this ecosystem that is almost unique to England. I hope that this House will unite in voting for Amendment 94 and protecting this rare heritage for future generations.

Amendment 94

The Lord Bishop of Norwich

My Lords, I shall speak to Amendment 94, and I thank the noble Earl, Lord Caithness, the noble Viscount, Lord Trenchard, and the noble Baroness, Lady Willis of Summertown, for their support. I am most grateful to follow the noble Baroness, Lady Grender, who has just spoken so powerfully about her amendment, as well as offering her support for this amendment. Amendment 94 would require a spatial development strategy to list chalk streams in the strategy area, outline measures to protect them from environmental harm and impose responsibility on strategic planning authorities to protect and enhance chalk stream environments.

Chalk streams, as we have heard, are a very special type of river. Some 85% of the world’s chalk streams are in England. They are fed primarily by spring water from the chalk aquifer, not rain, which means that they have clear, cold water and very stable flows. These globally rare habitats are found in a broad sweep from Yorkshire and the Lincolnshire Wolds through Norfolk, the Chilterns, Hampshire and Dorset. The Bure, Glaven, Wensum, Test, Itchen and Meon are river names that come to mind flowing, as they do, through the tapestry of English history and in our literature, such as the River Pang-based Wind in the Willows. They are rich in minerals, especially calcium, and this “base rich” environment supports a distinctive and rich ecology.

It is no wonder that this amendment and a similar one in the other place have received such positive support, including in your Lordships’ Committee. What it seeks to do is such an obvious thing, for what we love, we should desire to protect; what we value, we should safeguard; what is of global significance, we should be deeply proud of.

I am grateful that the Minister responded to my letter to her about my amendment. However, her response was far from reassuring in two ways. First, the Government have pointed to local nature recovery strategies as a way of protecting chalk streams. These could, of course, in future be capable of considering, avoiding and otherwise mitigating for direct damage to these habitats, such as occurs from the footprint of a development near a chalk stream. However, to do so, LNRSs will need more bite in the planning system than they currently have. We are still waiting for the regulations designed to do precisely that, placing a duty on local planning authorities to take account of the nature strategy when making planning decisions.

We are still waiting for that to be commenced, and it is now a full two years after these regulations were promised in the Levelling-up and Regeneration Act 2023.

Even once the regulations are passed, LNRSs will not be well placed to map, quantify and avoid or mitigate for the offsite impacts of development such as downstream pollution or the additional water that will be abstracted from chalk streams or their aquifers to serve new homes. These very real threats to our chalk streams, over areas much larger than are covered by strategies, cannot be addressed by LNRSs.

Secondly, the Government have pointed to their plans to limit overabstraction by water companies through amending licences, but their target achievement date is 2030. This could take far, far too long and be far, far too late for many threatened chalk streams. The current abstraction situation is grave. Water companies are not sourcing their water from chalk streams within sustainable limits. The Catchment Based Approach’s chalk streams annual review 2024-2—a mouthful of a title—published last week, reports that a third of chalk streams do not have healthy flow regimes. This CaBA report also highlights additional water bodies where, despite flows being classed as compliant overall, abstraction can cause significant local impacts in parts of the watercourse. For example, in the River Loddon, upstream areas are impacted by abstraction but, because of wastewater discharge downstream of them, flows at the assessment point are classed as compliant. If overabstraction occurs for a sustained period upstream, the whole chalk stream could well dry out.

In light of the growing and urgent challenges facing our chalk streams, we cannot afford to wait for LNRSs to have more planning bite, or for 2030, when the abstraction licence amendments come into effect. We need Amendment 94 so that spatial development strategies are equipped to enable planning authorities to direct development away from areas where development footprints, pollution and overabstraction could sound the death knell for declining chalk streams. I will certainly listen to the Minister’s response with care. However, if this amendment continues to secure wide support, I will look to test the opinion of the House.

Baroness Willis of Summertown

I am pleased to add my name to the important amendment tabled by the right reverend Prelate the Bishop of Norwich, and to Amendment 92 in this group, because, let us be honest, we are not starting from a good place with chalk streams. As mentioned by my noble friend, the current status of these unique and extremely rare habitats in the UK is poor, with more than three-quarters failing to meet good ecological health standards. This is precisely why the chalk streams became such an important issue for debate in the Levelling-up and Regeneration Bill. I remember only too well the same Front Bench colleagues debating long and hard for their protection.

The chalk stream recovery plan, announced by the previous Government, was seen by many, including me, as a good step in the right direction. But here we are again, with chalk streams back in the firing line and, despite the reassurance from the Minister on Report that local nature recovery strategies could propose priorities for their protection, the problem with our planning system is that it requires local authorities only to have regard to our LNRSs, which is not strong enough to protect these vulnerable habitats. We came across this a number of times in the Levelling-up and Regeneration Bill. Those words are etched in my memory.

Also, although the NPPF recognises the importance of irreplaceable habitats, chalk streams, much to my alarm—and, I am sure, to that of many in this House—are not specifically listed as protected habitats. Therefore, they do not have the overarching level of protection in the Bill, through the spatial development strategies, in the same way other protected habitats do. The only hope left, therefore, is the chalk stream nature recovery plan, launched by the previous Government. However, in reply to the question on this asked in Committee by the noble Viscount, Lord Trenchard, who sadly cannot be here today, the Minister stated that even this is now on hold because it is out of step with the ambitious programme of water reforms proposed by the Government. Perhaps the Minister can say for how long it will be on hold, as a result permitting further damage to occur in these unique freshwater habitats.

I say this because time is of the essence here. As an ecologist, I went back to look at the literature. Research on chalk streams has demonstrated that while removing pollution can result in the improvement of water quality within a month to a few years, ecological recovery can take between 10 and 20 years. The more damage we do, the longer it will take for them to recover.

Lastly, surely there must be some no-go habitats in some of our river catchments, and these chalk streams should be one of them. I therefore urge the Minister to agree to this amendment, within which the spatial development strategy would mandate the sort of responsibilities that lead to the protection and enhancement of these unique and rare chalk stream habitats.

Lord Bellingham

My Lords, I support both amendments. I made a speech in Committee in which I laid out very similar arguments to those put by the right reverend Prelate and the noble Baroness, Lady Willis. I will not repeat them now, except to say that the right reverend Prelate referred to a number of chalk streams in my old constituency of North West Norfolk. These incredible assets—these unique and precious assets—are at risk as we speak. I say to the Minister that neither amendment is particularly demanding. They are quite modest in their overall fabric and intent. If the Government are serious about their environmental credentials, and about trying to do something for the countryside, I urge them, please, to accept these amendments.

The Earl of Caithness

My Lords, I have put my name to the right reverend Prelate’s amendment. I am delighted to see him back in the Chamber; we missed him in Committee.

My noble friend Lord Roborough was absolutely right when he said in Committee that all rivers are important. Yes, that is true, but chalk streams are that bit more important. The reason for that is that we have 85% of the world’s chalk streams. We are custodians for that majority, but 83% of those chalk streams do not meet good ecological standards. We have handled the whole situation very badly. I think we have taken a retrograde step with this Government, who have dispensed with the chalk stream recovery pack, which the noble Baroness just referred to.

I have written to the Minister and told her that I will ask her a number of questions. I have given her forewarning, so I expect replies. In what respect did that chalk stream recovery pack fall short? It was nearly ready to go when the Labour Government took over after winning the election. They could have pressed the button; that chalk stream pack focused on some difficult questions that nobody had fully addressed before, so why have they torpedoed it? What do they propose to do that will be better than that pack had proposed?

Let us go down to some specifics of the pack. It had time-bound commitments to reduce groundwater abstraction on numerous chalk streams which, according to the Environment Agency’s own data, are unsustainably extracted: for example, the Darent in Kent, where over half the rainfall that feeds the river is taken away for public water supply. There was a timescale for getting that right. Will the Government stick with that timescale or will there be something longer? Do the Government have plans to move water abstraction further downstream, rather than at the headwaters of these rivers?

The chalk stream pack also had a timebound commitment to address the hundreds of small sewage works in chalk streams that do not remove phosphorus in the treatment process and where there is currently no policy or incentive to drive investment. What are the Government going to do better to give a good timescale to get all those water treatment plants in good order? The pack also addressed run-off from highways and local roads, which I have spoken about before in your Lordships’ House, and how damaging it can be to chalk streams in particular because of the added silt. The CaBA chalk stream strategy recommends revised best practice guidelines for local councils that give more protection to chalk streams. Do the Government have better plans than that? The pack also put forward solutions to reform the farming rules for water, which are currently ineffective. What are the Government going to do to replace that recommendation?

I did not mention this question when I wrote to the Minister, but I will add it now: how do the Government intend to address the physical dysfunctionality of many chalk streams moved, straightened, dredged or dammed over the centuries and put them back to their natural state? In destroying the hard work of some very good, able and committed people who produced the chalk stream pack, the Government have alienated some potential friends in their effort to improve the environment. How are they going to get friends back onside when, after all that work, they have just dismissed it as though it did not matter? What plans do they have to include such people in the future to try to improve the whole river system for chalk streams? It is no good taking just one little area in one district or county council, because chalk streams do not understand those borders; they flow through lot of different councils. The whole thing has to be tackled on a holistic basis, and the only way to do that is by supporting the right reverend Prelate’s amendment.

Lord Roborough

My Lords, I shall speak to the amendments in the names of the noble Baroness, Lady Grender, and the right reverend Prelate the Bishop of Norwich. I am grateful for their excellent, informative introductions. We on these Benches tabled similar amendments in Committee. The amendments share a vital purpose: to ensure that our planning system gives proper recognition and protection to chalk streams, one of our most distinct and rarest natural habitats. These streams help define our landscapes, support unique biodiversity and supply water to many communities. The amendments would require spatial development strategies to identify and protect chalk streams, setting out the responsibilities for planning authorities in their stewardship.

These are sensible, constructive proposals and I am grateful to those who have tabled and supported them. We will support the right reverend Prelate the Bishop of Norwich if he divides on his amendment this evening. Will the Minister say whether she considers chalk streams to be irreplaceable habitats, like ancient woodlands, and therefore deserving of similar policy protection? The case for stronger recognition of chalk streams within our planning system is compelling. They are an irreplaceable part of our natural heritage and a globally important asset, and the way we plan for growth must reflect that.

I hope the Minister has heard the House and will be able to accept these amendments, and explain, as the noble Baroness, Lady Willis, and my noble friend Lord Caithness have asked, why our chalk stream restoration strategy is on hold.

Baroness Taylor of Stevenage

My Lords, I thank the noble Baroness, Lady Grender, and the right reverend Prelate the Bishop of Norwich for Amendments 93 and 94, which propose additional statutory obligations for strategic planning authorities in relation to the identification and safeguarding of chalk streams. With 85% of the world’s chalk streams found in England, these unique water bodies are not just vital ecosystems but are indeed a symbol of our national heritage. The Government are committed to restoring them, which is why we are taking a strategic approach to restoring chalk streams. Working in partnership with water companies, investors and communities, the Government will introduce a new water reform Bill to modernise the entire system so that it is fit for purpose for decades to come. This is essential to restoring chalk streams to better ecological health and addressing the multiple pressures facing these habitats.

Alongside the programme of ambitious reforms, the Government are continuing to deliver vital improvements and investment for chalk streams, including £1.8 million through the water restoration fund and water environment improvement fund for locally led

chalk stream projects. Over the next five years, water companies will spend over £2 billion on chalk stream restoration.

The Government remain firmly committed to the restoration and protection of chalk streams. Plan-makers and decision-makers should recognise these habitats as valued landscapes and areas of high biodiversity. They deliver essential ecosystem services, contribute significantly to natural capital, and should be identified and protected through local plans.

As I emphasised in Committee, local nature recovery strategies provide a tool for identifying and enhancing chalk stream habitats. These strategies map priority areas for nature and are informed by key environmental data, such as the assessments carried out under river basin management plans. Under Section 12D(11) of the Planning and Compulsory Purchase Act 2004, spatial development strategies must already take account of relevant local nature recovery strategies.

In answer to the points made by the right reverend Prelate, local nature recovery strategies are a legal requirement and are prepared by responsible authorities, typically county or combined authorities appointed by the Defra Secretary of State. There are 48 LNRS areas and lead authorities covering the whole of England; there are no gaps, and no overlaps. LNRS responsible authorities work closely with local partnerships, involving all local planning authorities, to identify and map proposed areas for habitat management, enhancement, restoration and creation for biodiversity and the wider natural environment. The West of England Combined Authority published the first LNRS in November 2024. Five more have since followed: North Northamptonshire Council, Cornwall, Isle of Wight, Essex and Leicestershire. The remaining 42 are expected to be published by the end of 2025, or shortly thereafter.

I will also address the right reverend Prelate’s point about the provisions in the LURA. The Act created a duty requiring plan-makers to take account of LNRS. This builds on the existing requirement on all public authorities to have regard to LNRS in complying with their duty to conserve and enhance biodiversity. This duty will be commenced as part of wider planning reforms later this year.

Where a strategic authority considers chalk stream protection to be of strategic importance, Section 12D(1) requires that spatial development strategies include policies on land use and development that address such strategic priorities. Authorities will therefore be able to include such policies where appropriate.

Furthermore, planning policy is clear that decisions should prevent new and existing development contributing to unacceptable levels of water pollution. Where water quality has the potential to be a significant planning concern, an applicant should explain how the proposed development would affect a relevant water body in a river basin management plan and how they propose to mitigate the impacts.

Fixing systemic issues is essential to addressing the multiple pressures facing these habitats, and restoring our chalk streams to better ecological health is part of our overall programme of ambitious reforms for the water sector.

I will respond to the points made by the noble Earl, Lord Caithness. I am more than willing to answer all his points—I will try to do so briefly. It might have been more helpful to have them in writing before today, but I will cover the points he has raised. First, on the time-bound commitments to reduce ground water abstraction, we are tackling one of the biggest threats to chalk streams by reducing harmful abstractions by an estimated 126 million litres daily by 2030, protecting vital water flows to these fragile ecosystems.

Companies covering chalk stream areas, such as Affinity Water and South Staffs Water, have made specific commitments to reduce abstraction from chalk streams. Affinity Water has committed to reducing abstraction by 34% by 2050. Portsmouth Water is building a new reservoir in Hampshire to protect the River Test and the River Itchen—this is the first new reservoir to be built since the 1970s. In June 2025, the Environment Agency updated its national framework for water resources, which set out the importance of chalk streams and how we will include their needs in water resources planning and decision-making.

On time-bound commitments to address hundreds of small sewage works in chalk streams that do not remove phosphorus, under the Environment Act, to achieve the 80% reduction in phosphorus load discharge, the phosphorus improvement driver prioritises action for catchments that meet one or more of the following criteria: catchments with water framework directive regulations—phosphorus standard failures; catchments with identified nutrification issues under the Urban Waste Water Treatment Regulations; and catchments where phosphorus targets set by conservation policy advisers are exceeded. That prioritisation ensures targeting to achieve the best environmental outcomes.

In addressing run-off from highways and local roads, the Defra Secretary of State has committed to including a regional element in the new water regulator. We are considering how road or highway run-off and urban diffuse pollution can be managed at a regional or local level as part of moving to a catchment-based approach.

Lastly, on the reform of farming rules for water—which the noble Lord said in his letter are currently ineffective—the levels of water pollution from agriculture are unacceptable. We are looking at reforming the regulations, including the farming rules for water, as a priority within a suite of broader interventions. We are also working with farmers, environmental groups and other parties to improve the farm pollution regulations to make sure that they are simple and effective. This will allow us to deliver pollution reductions and clean up our waters while supporting farm businesses to grow. I hope that is helpful to the noble Lord.

We need to continue to tackle the biggest impacts on chalk streams, including reducing the risk of harmful abstraction, and we are doing so, as I said, by 126 million litres through the amendment of water company abstraction licences, and rebuilding the water network with a record £104 billion investment to upgrade crumbling pipes and cut sewage spills. In light of all this, I hope noble Lords will not press their amendments.

Baroness Grender

My Lords, I thank the Minister. It is very clear there is a strong feeling within this House that there is a need for something to shift and be enshrined in law. I beg leave to withdraw my amendment in order to hand over and support the right reverend Prelate the Bishop of Norwich if he decides to press his.

Amendment 93 withdrawn.

Amendment 94

Moved by

The Lord Bishop of Norwich

Sharethis specific contribution

94: Clause 52, page 73, line 22, at end insert—

“(6A) A spatial development strategy must—(a) list any chalk streams identified in the strategy area;(b) identify the measures to be taken to protect any identified chalk streams from pollution, abstraction, encroachment and other forms of environmental damage; and(c) impose responsibilities on strategic planning authorities in relation to the protection and enhancement of chalk stream habitats.”Member’s explanatory statement

This amendment would require a spatial development strategy to list chalk streams in the strategy area, outline measures to protect them from environmental harm, and impose responsibility on strategic planning authorities to protect and enhance chalk stream environments.

The Lord Bishop of Norwich

My Lords, I thank all who have contributed to this important debate and the Minister for her response. However, I am not convinced by her arguments; we cannot wait for a water reform Bill and have these arguments again at that stage. Amendment 94 seeks to protect chalk streams, this precious habitat which we are the custodians of. It aims to restore biodiversity and create a planning system that works with nature, not against it. At present, I am afraid, the Bill before us fails to do this for chalk streams. Thus, I seek to test the opinion of the House.

How dry is south-east England?

June 20, 2025June 22, 2025Posted in UncategorizedTagged climate-change, environment, news, sustainability, waterLeave a comment

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 6^th 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.

Sophia’s petition

June 2, 2025February 8, 2026Posted in UncategorizedTagged chalk streams, environment, waterLeave a comment

Last Friday afternoon 30th May Sophia’s petition “please don’t abandon the chalk stream recovery pack” passed 10,000 names. By Monday almost another 1000 names had been added.

This is fantastic news. It means that the government must now respond.

And maybe they have, to a degree. On Monday I met Minister Emma Hardy by a Yorkshire chalk stream. Many thanks to our guide Matt Arnold from the East Yorkshire Rivers Trust.

Though we were standing beside the Boston beck, perhaps one of the least pressured chalk streams in England, Minister Hardy was genuinely keen to know more about the multiple threats to chalk streams and what we should be doing to make things better.

We discussed the extreme levels of abstraction that exist on some chalk streams, especially those near London, and the suffocating nutrient pollution that comes from innumerable small sewage works where there is no phosphorous limit or where, if one exists, it is absurdly lax. We especially focussed on the lack of clarity in catchment level decision-making, something I feel the government could help with by unambiguously signalling the importance of chalk streams.

That signal should have taken the form of the Defra chalk stream recovery pack, of course, but I’m not holding my breath for a change of heart regarding its publication. Though you never know.

I will certainly continue to push, arguing why many of the measures in the pack were low-cost no-brainers: stuff that builds on existing policy with greater clarity and purpose, that would remove blockers in bureaucracy or give clear signals to water resource groups and water companies on where to prioritise abstraction reduction or target better water quality in vulnerable headwaters or that gives support to stakeholders.

My guess is that the treasury has put more or less everything on hold while it tries to prioritise growth through development.

This is worrying. Water efficiency through demand and leak reduction, for example – THE big plays in our national framework for water resources over the next two decades – means nothing for nature, unless accompanied by actual abstraction reduction. Of itself water efficiency simply makes headroom for development. And in the current climate this is almost certainly what it will be used to deliver.

Similarly, if the water industry is left to meet the previous government’s laudable nutrient reduction targets (as set out in the Environmental Improvement Plan) via “highest technical standards” at large works downstream of large population centres where highish standards exist already, then of course this will be the preferred “cost-effective” pathway for all parties.

All parties except fish and insects who might prefer those chemicals are removed upstream of where they live. The point is, you can create a great headline figure for phosphorus removal where it makes little ecological benefit, but why not direct the targets towards their purpose?

Without direction from government or its regulators on how to prioritise either abstraction or phosphorus reduction, economic efficiency of a decidedly anthropogenic kind will decide. River life will receive little benefit from initiatives intended to restore it.

Frustratingly, it’s all about economics – no matter who’s in charge – and so long as water is as cheap as it is, and so long as imaginative and economically-efficient ideas like Chalk Streams First or nutrient treatment wetlands or risk-based buffer strips (all measures a recovery pack might have given prominence to) are starved of oxygen, then nature will pick up the bill.

And thus the can is kicked down the road.

It doesn’t have to be this way. The chalk recovery pack would have been Defra’s first bespoke policy document for chalk streams. This government could yet dig it out, add some oomph to the stuff that got watered down, and defy my cynicism. No one would be happier to be proved wrong.

In the meanwhile, it was a pleasure to meet the Minister and I’m very much hoping we can meet again soon on one of the Flagship project sites, the Chess, for example where Kate Heppell is leading amazing citizen science research, or the Anton, where Simon Cain and Bob Wellard are concocting imaginative re-wilding schemes. And then perhaps the beleaguered Ivel which barely flows, or the Ver whose headwaters this winter have been constantly polluted with raw sewage.

The counter-intuitive (and heretical) idea that could unlock abstraction reduction.

February 8, 2025February 9, 2025Posted in UncategorizedTagged chalk streams, climate-change, environment, groundwater, sustainability, water1 Comment

It took me a while to get my head around the concepts in this post, so bear with me. This is aimed especially at eNGOs and other campaigners for chalk streams, because the more people there are who understand this counter-intuitve idea, the better.

Here it is: you can save many chalk streams from unsustainable abstraction by conceivably using the aquifer in times of low flows and drought.

That is a head-muddler. But this idea could unlock real abstraction reduction, making the bad much better in the foreseeable future. This is far, far preferable in my view than holding out for a perfection (natural aquifers) that will never come.

It starts with my best attempt at explaining what I understand of the complexities of the interactions between groundwater, river flow and groundwater abstraction. Given that I vainly spent a long night in a hut in Iceland trying to explain the very same ideas to two angling friends of mine (they were belligerently uncomprehending in a (successful) effort to annoy me), this will be no easy task.

It is complex … kind of. It’s also quite simple really. Rather as the moon affects the tides, a simple idea leads to a complex set of manifestations.

Idea 1. Chalk streams flow from underground.

If you’re reading this blog you’ll already know that chalk streams derive most of their flow from groundwater. Rain sinks into the ground filling fractures in the underlying chalk and then lower down the slope it seeps out again as springs to create a chalk stream.

Idea 2. The level of the groundwater drives the flow in the river.

This is pretty simple. I used the bucket analogy before. Drill a single hole in the base of a bucket. Fill the bucket with water. As the bucket fills gravity drives water at an increasing velocity out of the hole. Now stop filling and let it empty. The flow diminishes to a trickle. EVERYONE gets this because it’s the same when you pee!

*The rate of flow from springs in a chalk valley is driven by the hydraulic head of the groundwater above the springs. The higher the level, the greater the flow* …

*… In more or less the same way as the water level in the bucket determines the force at which the water is driven through holes in the side of the bucket.*

Idea 3. Groundwater rises in winter and falls in summer.

If you pour water into the bucket faster than water can leave it through the hole(s), the level in the bucket rises. If you stop pouring water in, the level falls as the bucket drains. This is exactly the same with a chalk aquifer. In winter, when it rains a lot, and it’s cold and the ground is wet and nothing is growing, more rain flows into the aquifer than can leave it and so the groundwater level rises. In summer, much less rain – if any – reaches the aquifer and so the groundwater level falls.

*Groundwater rising. This chalk valley is dry most of the time but in February 2021 when recharge vastly exceeded discharge, it had filled to overflowing*.

Idea 4. The higher the groundwater rises up the valley, the more the water pours out of it.

As groundwater level rises, stream flow increases. But not in a linear way as it would with a single hole at the base of a columnar bucket. In fact for every unit of rise in groundwater level, flow will increase by approximately X^{2 to 2.5}. Kind of like having twice as many holes at each level in the bucket as the level below.

There are a number of reasons for this which were debated at a recent groundwater conference. There is a summary of these ideas in Section 2 of John Lawson’s report Flow Recovery Following Abstraction Reduction which we updated following the conference and contributions from the likes of Rob Soley and Alessandro Marsili.

In short, this non-linear response is probably caused by a combination of:

• the shape of the valley – if you imagine the groundwater filling the valley bottom and hillsides, assuming a perfect V- shape valley, for every unit increase the groundwater rises the area of saturated zone exposing springs rises two-and-a-half fold. Chalk valleys are not quite V-shaped but that’s the general idea.

• the fracture density in the chalk – which increases in the valley bottoms and with altitude. At depth chalk is very solid, but in the valley bottoms and higher up the slope and where water has flowed for thousands of years, the fracture density is much greater and the flow pathways are bigger.

• layering within the chalk – chalk accreted in layers under varying climatic / geological conditions and these layers are in turn interrupted by bands of clay and flint. These layers and the varying permeability and transmissivity can influence the way groundwater reaches with the surface.

• as the surface flow pathways lengthen (winterbournes rising higher and higher up the valley) the groundwater pathways shorten.

The fracture density and layering in the chalk, the shape of the valley and the length of flow pathways, all conspire to mean that when chalk valleys fill, flows will rise exponentially.

Idea 5. The impact of a constant groundwater abstraction has a varying impact on varying flows through the year

This is where things gets a bit more discombobulating. All of the above essentially means that as groundwater rises, flows increase exponentially. If that is true, then the reverse is true. For every unit of decrease in groundwater level, flows decrease exponentially.

This means …. drum roll … groundwater abstraction (which lowers groundwater levels) has a greater impact on high flows than low flows! This is a totally skull-tightening idea. Everyone thinks the reverse must be true. But it isn’t.

Groundwater levels and groundwater abstraction

Let’s start with the impact of groundwater abstraction on groundwater levels. In a natural aquifer system, the discharge from the valley must equal the recharge over time. Natural recharge = natural discharge / Time. This stands to reason: if it didn’t the valley would either fill to overflowing or empty (because over time one would exceed the other).

Natural recharge derives from rain and natural discharge from river flow (and some evapotranspiration and flow through the ground). If I add another form of discharge in the form of abstraction, then the former natural discharge MUST go down. If it didn’t, the aquifer would progressively empty until there was no water left (an aside … hydrogeological literature generally describes anything less than draining the aquifer “sustainable”, because the aquifer is being lowered to a new dynamic balance, not mined. This is not the same as ecologically sustainable, however).

Look at it as simple numbers.

Natural recharge (10) = natural discharge (10) / Time.

Natural recharge (10) = abstraction (5) + natural discharge ? / Time.

What’s the new natural discharge? 5, obviously.

Now, as I showed with the bucket, the ONLY way in which the former natural discharge can go down is through a reduction in groundwater levels. If groundwater levels didn’t go down, then because the discharge is driven by the groundwater level the natural discharge would remain the same. As shown above, that is impossible.

Theis, the Isaac Newton of groundwater theory, wrote all this in 1940. The only way that the former natural discharge can go down (and balance the equation) he wrote, is by a reduction in the “thickness of the aquifer”.

Okay, so pause and get your head round all that.

• a single unit of rise or fall in groundwater level has a (very roughly) two-and-a-half fold impact on flows.

• groundwater abstraction lowers groundwater levels.

• ipso facto a single unit of reduction in groundwater level at high groundwater levels has a much greater impact on flows than a single unit of reduction in groundwater level at low groundwater levels.

It still hurts the head, but the discombobulating stuff above means that at high groundwater levels groundwater abstraction reduces flows by quite a lot more than 100% of the amount abstracted. And conversely, at low groundwater levels groundwater abstraction reduces flows by quite a lot less than 100% of the amount abstracted. Albeit over time groundwater abstraction must reduce flows by (essentially) 100% of the amount abstracted (it’s generally less than that for reasons that aren’t that important to the general concept, but basically because not all discharge occurs in the form of flow).

See the chart below to see what the Chalk Streams First modelling indicates % flow recovery would be if abstraction was reduced to zero in the River Ver. It varies through the flow cycle.

The above chart from Page 52 of John Lawson’s report shows that the % flow recovery (green line) at high flows (l/h end of X axis) is well over 100% and at very low flows (r/h end of X axis) is about 30% – 20%.

Idea 6. Groundwater abstraction at low flows is like a credit card.

The obvious question is … if groundwater abstraction at low flows reduces those flows by a lot less than 100% of the amount being abstracted, where the bloody hell is the rest of the water coming from? The answer: if it’s not a direct reduction from flows at the time, it is coming from aquifer storage.

This is easy to understand if you think of a large abstraction next to a small and diminishing stream. In the winter when the stream is gushing, there is more than enough water to satisfy the pumping. In the summer the stream reduces to a trickle or perhaps even dries up. But the pumping continues. At this point the abstraction is clearly not taking water from stream flow because there isn’t any. Another aside … I’ve read hydrogeologists describe this state as abstraction having “no further effect on flows”. This might be literally correct at the time. But it is misleading. The abstraction is effecting future flows.

When a chalk stream dries but abstraction continues it is clear that the abstraction is no longer subtracting water from the river’s flow, but from aquifer storage: this is basically a debt to future flows.

At times of low flow and into droughts, groundwater abstraction increasingly draws on storage, upon which future flows are built. If you unnaturally drain the aquifer, it will clearly take longer to fill when it starts raining again, all before the flows in the river can respond to the rise in groundwater levels.

Therefore groundwater abstraction at low flows is like a credit card: much more a debt against future flows than an impact on present flows. This is a key idea behind the confusing concept of using groundwater abstraction to unlock abstraction reduction .

Idea 7. If you turn off the pumps you get greater flow recovery at high flows than low flows.

Essentially what all this means is that when you cease or lower abstraction you get well over 100% of the amount no longer abstracted at high flows and much less than 100% at low flows. That is what the chart above shows on the River Ver.

And this is the Achilles Heel of the Chalk Streams First idea.

Water resources needs a constant supply of water. Groundwater abstraction gives that. Chalk Streams First says “turn off (or down) the pumps and take the water from river flows much lower down the catchment”. And while you get loads of water back in winter, you get less back in summer. Generally, you must have a storage reservoir to make it work and balance out the varying recovery rates into a constant and reliable supply.

John Lawson – who came up with the Chalk Streams First idea – has long known this. We argue (with empirical evidence) that the flow recovery at low flows is actually much higher than the most pessimistic predictions claim, but nevertheless this variation in response is an issue we have to address. The answer is a reservoir.

BUT … then you get to the prolonged droughts when water companies are under real pressure. In these times, the flow recovery could conceivably drop even lower. What to do? The public must have water. This low flow recovery at very low flows in long droughts threatens the whole idea of reducing abstraction through schemes like Chalk Streams First. Especially now that we have to plan according to 1:500 year contingencies.

Idea 7. In droughts use groundwater abstraction to guarantee public water supply … so long as you’ve turned the abstraction right down to ecologically sustainable levels 95% of the time.

The insurance against the Achilles Heel of low flow recovery in a drought is a groundwater-fed public water supply scheme. There is one in existence already called the West Berkshire Groundwater Scheme (WBGWS). It is a series of wells in the Berkshire chalk that can, in extremis, be turned on and deliver a large amount of aquifer water into the Berkshire chalk streams, from where it flows to the Thames to be captured into the London reservoirs. The scheme is used very, very rarely: no more than once every 25 years. But it’s there. And it guarantees water in a drought.

The West Berkshire Groundwater Scheme wellfield: this scheme is rarely used but guarantees water in extreme droughts. It is a counter-intuitive idea that could unlock abstraction reduction in the Colne, Lea and Ouse chalk streams.

The impacts on the chalk streams are a) one of flow relief in the drought, because the flows get boosted. Albeit – and I have to emphasise this – flow augmentation in not the aim of the scheme, it is a bi-product. And b) at the end of the drought, when the pumps are turned off, the aquifer must recover before flows return to natural levels, so you get lower flows the following year.

But this is crucial: in modelled scenarios, the flows in the year of recovery are still better than they would be if abstraction ran all the time as happens at the moment in streams like the Ver, Misbourne and Beane.

So WBGWS type schemes could unlock Chalk Streams First type abstraction reduction in other settings, such as on the chalk streams of the Colne, Lea and Ouse (even the Darent). As such a scheme would insure against the public supply deficit in droughts created by replacing upper catchment groundwater abstraction with lower catchment surface water abstraction (the Chalk Streams First concept).

BUT …the Environment Agency is very cautious of such schemes

This is understandable because there have been some bad schemes in the past. But flow augmentation to compensate for the collateral damage of abstraction is a different thing altogether.

Some schemes were developed in the past whereby to compensate for abstraction (which had dried the stream) water was pumped from the aquifer into a losing reach of stream and the whole thing was a highway to nowhere.

Other times the concept of augmentation is used to justify continuing, unsustainable abstraction. These schemes have given the whole idea of flow augmentation a bad rap, and one that has stuck like glue.

RevIvel claim that a flow augmentation scheme putting 0.5 ml/d into a dry river bed is not a good type of augmentation scheme, especially if it delays a proper solution to the unsustainable abstraction. This is the kind of scheme is very different from the idea promoted in this blog post.

BUT, I would argue that we need to be more pragmatic and open minded than a presumption against these schemes if we are to achieve the heretofore irreconcilable goals of reliable public water supply and restored chalk streams. Aquifers in the south east are managed one way or another. We need to make sure they are managed mindfully to achieve the specific outcomes we want and in this regard holding out for “natural” when a more flexible approach would unstick hopeful schemes such as Chalk Streams First would surely be counter-productive?

I understand the Environment Agency may be consulting on this topic later in the year. I know from many discussions I have had with chalk stream advocates that the ideas I have outlined above will be surprising and counter-intuitive to most of us, as indeed they are to me.

But it is vital we give the EA the encouragement to take a flexible, if ultra cautious approach, because the gains of doing so could be massive.

Two steps forward, three steps back?

October 11, 2024October 17, 2024Posted in UncategorizedTagged climate-change, environment, groundwater, news, waterLeave a comment

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.

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.

Water policy manager Ali Morse looks at why the Environment Act phosphorus-reduction target could fail to deliver improvements in the chalk stream reaches where it’s most needed.

January 16, 2024January 16, 2024Posted in UncategorizedTagged climate-change, environment, featured, pollution, waterLeave a comment

Today I am posting a guest blog by Ali Morse – water policy director at the Wildlife Trust and chair at Blueprint for Water – on why it is so important to ensure our new, ambitious phosphorus reduction targets are applied to the parts of the landscape where we will see the greatest ecological benefit for the money spent. It’s astonishing to think that although we have been spending millions reducing phosphorus from sewage (66% reduction 1995 to 2020 … and now a new target of 80% reduction 2020 to 2038) we still haven’t found a way to ensure that we reduce phosphorus from the small works in the upper reaches of rivers where the reductions would have the greatest ecological outcome. Essentially, ever since the UWWTD (Urban Wastewater Treatment Directive) was passed to drive these reductions, cost-effectiveness has been measured by population attached to a given works as opposed to for example: % length of river d’stream of the pollution source, or the volume of flow in the receiving waterbody relative to the volume of flow from the pollution. This doesn’t make sense. We create targets to reduce phosphorus because it has a negative ecological impact: the primary outcome should surely be, therefore, to minimise the ecological impact, regardless of the local population size. In practice we reduce phosphorus in such a way that the ecological impact its secondary to accounting methodologies. This means we have rivers like the Frome in Dorset (a SSSI chalk stream) where the phosphorus concentrations go down as you travel downstream and are lowest just above the estuary (see the map below which I drew up when working on the chalk stream strategy, (based on 2016 WFD data)). It cannot be rocket science to find some simple policy drivers that would make the difference. All the river-oriented eNGOs should take a united front on this in my view, change the raw-sewage record for a few turns of the dance floor, and implore government to develop a way to maximise the ecological outcome for their ambitious Environment Act targets.

Here’s Ali’s excellent blog, first paragraph with a link across to the Wildlife Trusts site:

“In November 2021, the Environment Act became law and, with it, the promise of ambitious targets that would turn the tide on nature’s decline. Early last year, new regulations set out the detail of targets on water[i], waste, woodland and other topics that all contribute to the overarching and ambitious ‘apex’ goal, of seeing declines in species abundance halted by 2030.

For our watery habitats, the targets are intended to tackle the key pressures against which there has been stubbornly little progress to date. Nutrient pollution is a key factor that blights the freshwater environment, not just in England but around the globe. Although there are downsides to having targets on specific, potentially siloed topics, the logic of seeking to drive action on THE greatest pressure faced by our rivers, lakes and coastal waters is understandable. In freshwaters, phosphate is the pollutant causing the greatest number of failures against ecological standards. It’s a reason that more than half of England’s rivers, and three quarters of lakes, are assessed as not being in good health.

Of particular concern is the impact of phosphate pollution upon England’s chalk streams …”

CONTINUED HERE