Environment, Food and Rural Affairs CommitteeWritten evidence submitted by The Chilterns Conservation Board

1. An initiative of the Chilterns Conservation Board, the Chilterns Chalk Streams Project is a partnership which aims to conserve and enhance all major chalk streams in the Chilterns Areas of Outstanding Natural Beauty (AONB), and to encourage enjoyment and understanding of them. Chalk Streams are a globally rare habitat confined to England and North West Europe and they are a key landscape feature of the Chilterns AONB.

2. The Chilterns Conservation Board welcomes the opportunity to provide evidence to the inquiry on the Water White Paper, which we hope will be of use to the Committee.

Background to the Area

3. Of the nine chalk streams in the Chilterns none currently attain Good ecological status or potential as defined by the Water Framework Directive reporting standards. Indeed four are categorised as “poor” or worse. The major reason, common across all, for this is that of low flows All bar one of these rivers have or are currently being investigated under the Environment Agency’s Restoring Sustainable Abstraction programme. Over-abstraction for public supply has been confirmed as a cause of low flows in six of these rivers.

4. The Thames River Basin Management Plan (which the Chilterns rivers come under) states that no improvement to the status of any of these rivers will occur up to 2021. The reason given for this is that the measures required are too expensive to implement.

5. The Chiltern Hills is a major aquifer, used for public supply by both Veolia Water Central and Thames Water. This aquifer is also the source of water for the area’s chalk streams. Per capital water consumption in the Chilterns area is one of (if not the) highest anywhere in Europe at between 172 and 176 litres per person per day. This is over 20 litres above the national average and 40 litres above Ofwat’s target for UK per capita consumption. The area is designated by the UK Government as an area of water stress.

Comments on the White Paper

6. It is the view of the Board that the proposed timeframe for introduction of a revised abstraction regime will be too late to drive the improvement in condition of the country’s rivers that is necessary to ensure that Water Framework objectives are attained by 2027. This new legislation is urgently required to redress the balance towards abstraction licensing that takes account of environmental sustainability and resource availability. The current measures to reduce over-abstraction are not working and the Paper does not explain fully how existing abstraction reduction measures will be “ramped up”.

7. Changing the abstraction charging scheme to release funding for river restoration measures and including water company solutions for restoring sustainable abstraction are unlikely to deliver desperately needed abstraction reduction to restore flows in the Chilterns rivers. This is because for many rivers in the Chilterns the financial cost of implementing abstraction reduction is estimated to be too great to consider up to and beyond 2021.

8. The Paper advocates a strategy of favouring hydromorphological enhancement over abstraction reduction as a means of improving the ecological potential of a river. This has been adopted by the Environment Agency on at least one river in the Chilterns to date (R. Gade). This strategy does not address the fundamental underlying problem of over-abstraction but instead seeks to “normalises” it, creating smaller, shorter rivers and moving the goal posts to ensure more rivers attain WFD objectives. There are measures that could be taken now to effect a change.

9. There are mixed messages within the Paper with regard to abstraction. On the one hand it recognises the need for more consideration for environmental damage to be taken when dealing with new and existing abstraction licenses. But on the other it outlines proposals to reduce the burdens on business when seeking new licenses, which could see increased abstraction in already water stressed areas.

10. There is little in the Paper to address the issue of per capita demand reduction. What measures there are concentrate on incentivising efficiency rather than enforcing measures through legislation and regulation.

11. While the Paper recognises that water metering is a proven means of reducing water demand, it stops short of advocating their adoption as a means of addressing over-abstraction in water stressed areas. In water stressed areas like the Chilterns compulsory metering should be an option available to water companies to assist with managing demand, leakage detection and to help minimise environmental damage.

12. Whilst there is recognition of the need to improve river water quality and that much of the pollution of water courses is sewage derived (60% of all pollution incidents), the White Paper does not address the issue of Combine Sewerage Overflows (CSO). This is a major oversight. CSO’s have continued for the last 22 years under temporary license. These licenses were originally issued as part of the privatisation process to make acquisition more attractive to potential buyers. However, despite the large investment in the water industry to date, CSO’s remain licensed and commonplace. The unregulated release of partially diluted raw sewage into watercourses without the requirement to warn other river users is an abhorrent practise, which requires urgent attention.

13. The Water White paper is strong on recognising the problems and pressures affecting water resources both from an environmental and supply perspective, acknowledging many of the issues that the Chilterns Conservation Board has been highlighting for many years. However, it is short on robust solutions that will deliver the improvements that are required in the short, medium or long term. It is unlikely that the burden of over abstraction will be reduced on any of the Chilterns rivers to the end of the Water Framework Directive deadline. The only way that these rivers, will attain WFD objectives by 2027 will be by enhancing them hydromorphologically so that these reduced rivers reach the lesser standard of good ecological potential.

January 2012

Prepared 4th July 2012