Select Committee on Environment, Food and Rural Affairs Written Evidence

Memorandum submitted by the Friends of the Lake District



  The submission of the Friends of the Lake District, based on involvement in water supply issues over a number of decades, applies the local context as examples to the consideration of national issues.

  The submission concentrates on how the current water resources might be better utilised to provide a greater security of supply largely based good and early resource planning, and on better catchment management practices that, in turn, offer enhanced benefits for other areas of the government's rural policies, particularly in respect to designated landscapes.

  The submission emphasises the need to promote better water use management and conservation and in building on the recommendations of the Environment Committee's 1996 Report "Water Conservation and Supply."


  1.  The Friends of the Lake District (FLD) was established in 1934 to campaign for the Lake District to be designated as a National Park. Since 1934 we have been active in landscape and amenity issues throughout the whole of the area now known as Cumbria. We have some 6,800 members and work both locally and nationally.

  2.  FLD are a member of the Council for National Parks and act as the Cumbria Association for the Campaign to Protect Rural England. We work with a number of kindred bodies.

  3.  The FLD have a long history of involvement with water resource issues and, along with our members, have campaigned for sustainable water use in order to minimise the impact of water abstraction on the landscape. Over our history we have successfully resisted some new reservoir sites in the Lake District and Cumbria, but have also seen new reservoirs constructed, new sources developed, and existing abstractions varied. Much of this submission is based on local, north-west, examples but we believe the underlying issues are of national interest.


  4.  FLD has taken part in a number of Inquiries involving Drought Orders and Permits. United Utilities (UU), and its predecessor North West Water (NWW) has sought drought powers for their major sources in 1976, 1984, 1995, 1996 and 2003. In some years it was necessary for them to seek either the renewal of these powers (as the droughts were prolonged) or their extension to further relax abstraction conditions, such that had the rains not arrived when they did, lowering of natural lake levels would have been necessary (paragraph 5 below). These would have caused significant visual impact by further exposing lake shores to drawdown effects within the Lake District National Park. The repeated frequency and the variable time of the year (the 2003 drought power application was in December) has given us cause for concern with respect to the adequacy of water resources to meet changing supply and demand stresses.

  5.  Exacerbation of supply pressures through climate change and the generalised forecast of wetter, windier winters and warmer summers is likely to add to the stresses of well-integrated regional supply systems such as that of United Utilities in NW England. Furthermore, this integration results when Drought Powers are sought for use of the Lake District as the inevitable choice to obtain additional water from the two non-damned lakes, Ullswater and Windermere, which have an existing abstraction infrastructure. Abstraction Licences restrict how much water and when this water may be taken in "normal" circumstances. The availability of the installed pumping capacity when coupled with a relaxation of the licence conditions provides a convenient supplementary source of supply.

  6.  We have (April 2004) reported to our members our attendance at the December 2003 Inquiries. We said:

  "For the third time since 1995, the long, dry summer of 2003 produced low reservoir levels at Haweswater and Thirlmere. The detrimental effect on the landscape of scoured, bare shorelines was more than obvious as the ruins of Mardale again began to appear to public view."

  "In December the regional water supply company, United Utilities, applied for applying for Drought Permits and a Drought Order to take more water than normally permitted from Windermere and Ullswater to relieve the situation at Thirlmere and Haweswater. FLD did not object because there would be only limited landscape. The main impact being the small, temporary weir at Pooley Bridge."

  "Equally we felt that the need to re-fill Thirlmere—by reduced rates of abstraction from this source—and Haweswater—through water transfer from Ullswater—would reduce the landscape impact of the exposed shorelines. Without any major winter rain this landscape impact could continue or worsen in 2004."

  We continued:

  "Although we did not object to the Drought Permits and Order, neither did we feel able to give them our wholehearted support. This was due to both our concerns about the recent frequency of United Utilities seeking to abstract more water in drought conditions and, in this case, the lateness in the year when the application was made."


  7.  United Utilities, inherited, via NWW, the assets of Manchester Corporation in the Lake District. The company currently has a Drought Plan that is based on seeking drought powers on average once every thirty years. The recent frequency of applications for powers—three times since 1995[1]—is not in the spirit of the decision granting Manchester Corporation the permission to abstract water from Windermere and Ullswater—the Ullswater and Windermere Order—in 1966. The Order came after Lord Birkett had persuaded the House of Lords not to allow Manchester to turn Ullswater into a reservoir, and FLD had successfully campaigned against the construction of a reservoir in the Winster Valley. The Order allowed Manchester Corporation to abstract water from Gale Bay, Ullswater and from Windermere under certain flow conditions in the rivers emerging from those two lakes.

  8.  The Government, in respect of the 1966 Order, said that "The Minister would readily include in the Order provisions debarring Manchester from applying for power to increase the amount (of water) to be taken, either permanently or temporarily in time of drought, and debarring himself and his successors from entertaining any such application." However, on a point of law, this course was not open to him.

  9.  Indeed, in 1984, following an application for a Drought Order, the Minister noted that such emergency action "is not intended as a permanent or a regular practice".


  10.  The frequency of drought powers being sought, and the threat posed by climate change to aggravate the situation further, is a cause for concern. It is important that the Inquiry consider the potential of the current water resource and supply system and how it might be managed to take full account of water conservation and demand management rather than the current methods of operation. We are disappointed to note that the advice offered by the Secretary of State to the Director General, Ofwat, (see paragraphs our 13 and 14 below) for the current Water Price Review (AMP4) does not, with one minor but important exception, appear to allow water supply companies to begin any effective planning for climate change.

  11.  What is needed is a fundamental review for water resource planning for the sustainable management, in our case, of the Lake District resources. Such a review should look at how the region's water resources might be better managed to safeguard the landscape and national policies leading to the designation of the Lake District National Park. During the recent (Dec 2003) drought inquiry our representative, Dr Walsh, called for a new Drought Plan to be drawn up that ideally avoids or at least reduces the frequency with which Drought Orders are being sought for Windermere and Ullswater. We currently await the response of United Utilities and the Environment Agency. Such water demands relate also to statutory duties to designated landscapes (paragraph 18 below)

  12.  The recent requirement for UU to seek drought powers for the major sources in NW England as often as every 6 years on average suggests that current resources are not sufficiently robust to cope with the present variability in climate. If climate becomes more variable with extremes occurring more frequently in the future then the pressure on water resources will be much more pronounced and we would expect to see even more frequent applications for drought powers and inevitably the threat of exacerbated drawdown of the lakes will become an undesirable reality.

  13.  We note that the next round of the customer price review, currently being undertaken by the Director of Water Services (Ofwat), has just been the subject of Ministerial Guidance from DEFRA. We understand that this round of price reviews (Asset Management Programme 4 or AMP 4) will not consider any schemes directly related to climate change. FLD UNDERSTAND THE PRESSURES FOR A MAJOR UPWARD PRICE REVIEW FOR AMP 4 BUT REGRET THE LACK OF MEDIUM TO LONG-TERM CONSIDERATIONS AND ALLOW THE OPPORTUNITY TO START TO BUILD IN CLIMATE CHANGE PROVISION TO SUITABLE SCHEMES DURING THE FIVE-YEAR AMP 4 PROGRAMME.

  14.  The Secretary of State's Ministerial Guidance to the Director of Water Services (Ofwat) contains two paragraphs (6.15.1, 6.15.2) of relevance to this Inquiry in respect of bids made by United Utilities and Northumbria Water to allow AMP4 expenditure on developing a more sustainable approach to whole catchment management. Such an approach could give positive benefits for water yield and quality, along with benefits for landscape, biodiversity and public access, thus contributing to other Government policy targets. This holistic approach could produce benefits in preparing for potential climate change stresses on the water resource. WE RECOMMEND THAT YOU CONSIDER THE BENEFITS OF A WHOLE CATCHMENT APPROACH TO SUSTAINABLE LAND AND WATER RESOURCE MANAGEMENT.

  15.  FLD note that in areas of high rainfall there are times when excess water is allowed to escape to the sea. We recognise that there is a need for landscape and biodiversity issues to ensure that certain flow levels in rivers are maintained. We are not convinced that the Environment Agency licensing system nor the capital infrastructure of the water companies is sufficiently flexible to capture, treat and store water when it is available in abundance. WE RECOMMEND THAT GOVERNMENT PLANNING FOR AMP5 CONSIDER HOW BEST WE CAN UTILISE SUPPLY SOURCES WHEN THEY ARE ABUNDANT AND WITHOUT COMPROMISING LANDSCAPE, BIODIVERSITY AND PUBLIC AMENITY. FLD would expect that any enhanced storage capacity would be nearer the point of use than in high quality landscapes.

  16.  Additional storage is, however, a very complex topic and requires detailed analysis that might be more readily justified when weather patterns due to climate change start to become more clearly established. Such an approach may take decades, however, that does not stop at least an experimental consideration of a more sustainable approach starting early in the timescale.


  17.  FLD has concerns about the high levels of leakage from supply pipes and the inflexible attitude of the water industry and the Director General of Water Services in considering leakage as only a short-term economic matter. We regretfully note that the Ministerial Guidance to Ofwat (as above—paragraph 4.1.7) uses the term "economic levels of leakage" and therefore fails to address the wider issues of government policy in respect of sustainability. We reported to our members (April 2004):

  "There are other related issues that need to be addressed including reducing consumption and addressing the problem of leakage from the water supply system. Over the last decade United Utilities has made real progress in reducing leakages from the supply system. However, the dry year of 2003 saw a slight deterioration in that position. We still believe that there is still too much water lost from the system. Whilst some of this is a problem at the consumer's end, there is still much that could be done to prevent leakages."

  "We have raised this matter at the national level with the Government's regulatory body, the Office of the Director General for Water Services (OFWAT). OFWAT has consulted us on some of the issues of the current review of water pricing that will affect all our bills from 2005. We have asked OFWAT to consider how they define leakage to ensure that includes issues related to landscape, amenity and conservation topics and is not simply based on economics. English Nature has voiced similar concerns on this matter."

  We recommend that the inquiry press for higher targets for the control of leakage from the water supply system and that a more holistic consideration of landscape and biodiversity issues alongside future water supply stress take precedence over the concept of "economic levels of leakage".

  18.  FLD will be concerned that should water supply companies look to the uplands of England and Wales for additional storage that this would be because of their relatively higher rainfall and the favourable cost of new storage schemes. The uplands of these areas are often fine areas of landscapes designated as National Parks and Areas of Outstanding Natural Beauty (AONBs). Parliament has placed a duty on government departments and utility companies to have regard to the purposes of designation of these areas (National Parks: s62 Environment Act, 1995; AONBs: s85 CRoW Act, 2000). We recommend that the protection of these landscapes, and their biodiversity, should be paramount in the consideration of the development of any new water storage capacity necessary arising from climate change or pressures arising from additional demand.

  19.  The issue of significant new house building proposals by Government will create additional water demands. The additional pressures that such development will add to potential stresses arising through climate change will no doubt feature strongly as an issue to be considered by this Inquiry. The planning for new developments should incorporate water saving devices and minimal water usage. The water savings achieved through supply metering (UKWIR Study with the Environment Agency 04/WR/01/16, 2004) appear to be very encouraging. Equally, the use of fiscal measures by Government to favour the purchase of low water consumption domestic and commercial appliances could be considered. In any case there remains a compelling need to favour water demand management policies throughout government policy.

  20.  FLD note that over the last few years and with the increasing application of EU directives on water quality (eg affecting such matters as colour, heavy metal content, cryptosporidium) there has been a tendency for upland water resources to be concentrated on the larger reservoirs and larger water treatment works leading to, in perhaps 10-20 cases in the north-west, the abandonment of small reservoirs and stream sources. In some case the abandonment can lead to enhanced stream and river flows and potentially a richer biodiversity. In other cases the decommissioning of the small supply reservoirs and sources, as not readily economically reusable, may result in the loss of potential future resources. We recommend you consider that Ofwat undertake an assessment of abandoned sources to appraise if they might offer some future contribution to the supply system.

  21.  The changes, over the last few decades, towards fewer, larger supply sources and greater integration of supply networks, whilst beneficial to consumers, has further contributed to greater energy pumping costs for moving the water around such systems. We suspect the energy consumption of the current networks is huge, costly and, ironically, a potentially significant contribution to carbon dioxide and climate change. We recommend that you consider that an assessment is made of the sustainability of water supply systems.

  22.  FLD note that water customers have nationally agreed standards of supply (eg no restrictions on garden hoses greater than 1 in 20 year). We wonder, at times of increasing water resource stress, if such standards are too lax in respect for the sustainability of water resources. We recommend that you consider if real benefit might be achieved through a review of supply standards to customers.

  23.  In November 1996 the HoC Environment Committee produced the `First Report: Water Conservation and Supply'. This was a well-considered and widely welcomed Report and it is relevant to the focus of this Inquiry. We commend that the conclusions and recommendations, in particular those related to issues of demand management, in the 1996 report are worthy of being revisited by this inquiry.

  24.  The FLD are willing to expand on the matters we have raised should you require our further assistance.

Friends of the Lake District

April 2004

1   Drought powers have been sought for increased abstractions from Ullswater and Windermere in five years of the last 30 years (in some years powers were sought on two occasions). This is on average once every six years. Back

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