Environment, Food and Rural Affairs CommitteeSupplementary written evidence submitted by Action for the River Kennet (ARK)

Following its session of Oral Evidence on Wednesday 7 March 1012, Action for the River Kennet (ARK) is grateful for the opportunity to submit the following supplementary written evidence:

1. The Drought, the Present State of the River and a proposal to mitigate it

The river above Marlborough is in the worst state in living memory—for this time of year when it should be at its highest. It was in a similar state only in the summer of 1976. Above Marlborough, there have been periods when the river has been completely dry; now there are just disconnected and increasingly polluted puddles. ARK assisted the Environment Agency in locating and where possible helping to move hundreds of suffocating fish. This is particularly serious at this time of year when trout should be spawning, requiring clean clear and well oxygenated flowing water. Below Marlborough the flow is now significantly augmented by sewage effluent. Thousands of young trout have died of suffocation through lack of adequate flow. ARK is submitting to the Environment Agency and Thames Water a proposal to alleviate the effects by an alternative usage of the boreholes in the catchment. See Annex A

2. The 1998 Inquiry, Valuing the Environment, and Time Line

The Inspector ruled in favour of Thames Water’s appeal against its abstraction licence reduction, over-ruling the Environment Agency, in the 1998 Inquiry because an inadequate method of assessing the “value” of the Kennet had been used by the Agency, which set its value at only around £300,000; which was dwarfed by Thames Water’s estimate of the cost to them of finding alternative sources, of over £10 million. (See ENDS Report 278, March 1998). At the time this was a serious blow to the Environment Agency. Attached at Annex B now is the timeline of events since then. The present Government’s new policy of putting a value on the natural environment was set out in the UK’s National Ecosystem Assessment (UK NEA), and in the June White Paper “The Natural Choice: Securing the Value of Nature” (Cm 8082) following the Lawton Review. This policy should help resolve future conflicts over resources more equitably in favour of the environment, particularly when in the context of the Environment Agency’s reports on water “The Case for Change—current and future water availability” supporting the Water White Paper.

3. The Case for Bringing the RSA into the WRMP, and the need for a more urgent timetable for reform of abstraction regime

Chapter 3 of the White Paper acknowledges the weaknesses and delays in the present system for addressing unsustainable abstraction through the RSA process. It states that DEFRA is working with Ofwat and the Environment Agency to identify ways to incorporate company solutions for restoring sustainable abstractions into the price review mechanism. We strongly support this move and would urge Government to address it with urgency, with RSA schemes funded in water companies’ 2014 water resource management plans funded through the next price review. Equally, referring to Chapter 2 of the White Paper we are disappointed that the Department does not intend even to start consulting on proposals for reform before 2013, and legislation is not proposed before the next Parliament (para 2.18). ARK would urge Government to address the long term reform of the abstraction with a greater degree of urgency, commensurate with the pressing need for reform spelt out in the previous chapter and in the supporting Environment Agency and UK NEA reports cited.

4. Hydromorphological Measures

Para 3.37 of the White Paper refers to hydromorphological measures as an option for addressing unsustainable abstraction. Our oral evidence set out why we believe such measures to be of limited value, compared to cutting abstraction, particular in rivers that dry out completely. We referred to photographs illustrating an example of this in the River Kennet at Manton. These photographs are attached as Annex C

5. The Case for Metering

National and international evidence shows clearly the benefits that water metering brings both in reducing consumption and lowering customers’ bills. See the Environment Agency’s 2008 Report “International comparisons of domestic per capita consumption”. This shows how far the UK lags behind other comparable European countries such as Belgium, Germany and Denmark in the introduction of metering and the concomitant reduction in consumption. It also shows (Table 2, page 9) for the UK the significantly lower consumption of water in metered households than in unmetered ones for all water companies. For Thames Water the figures from Ofwat for 2006–7 are 142.7 l/h/d and 156.8 l/h/d respectively. The disinterested written evidence submitted to the Committee by the Chartered Institute of Water and Environmental Management (CIWEM) (WWP 29), and Lord Krebs (WWP 41) both strongly support metering. Given this strength of evidence and independent advice, it is surprising and disappointing to find the White Paper so weak on metering in paragraph 6.14. We urge the Committee to include a strong recommendation on metering in its Report to Government.

6. Clarification of position on 2003 Act “no compensation” Section 27

In our written evidence paragraph 3 (d) said we welcomed DEFRA’s intention to use these powers. We would like to clarify this to explain that, while we recognise that water companies would legitimately need to find the costs of losing abstraction rights if a licence is withdrawn, we believe that this should come from the consumer via water bills (ie as part of the Price Review process). It should not come in the form of “compensation” from the tax-payer via the Government.

Annex A

ACTION FOR THE RIVER KENNET

PROPOSAL FOR MANAGEMENT OF ABSTRACTION TO MINIMISE
THE IMPACT OF THE 2012 DROUGHT

1. Introduction

Regardless of rainfall from mid-March onwards, the drought of 2012 will have a severe impact on the river Kennet. This paper sets out:

Why the flows in the Kennet will be similar to flows in the great drought of 1976, regardless of rainfall.

Why the impact of the drought on the river’s ecology will probably be worse than 1976.

How the impact could be reduced by management of abstraction, without impairment of essential water supplies.

The paper is intended for discussion with Thames Water and the Environment Agency, as part of the process of overall planning for management of drought in 2012. ARK’s aim is to ensure that the needs of the River Kennet are fully taken into account in the plans for managing the drought, not just the needs of abstractors and Thames Water’s customers.

2. Likely Flows in the Kennet in 2012

Figure 1 compares the hydrological features of 2011–12 so far, with the two worst Kennet droughts since flow records started in the 1960s—1975–76 and 1996–97.

The upper part of Figure 1 compares effective rainfall in the droughts (effective rainfall is the amount percolating to the ground water table). Effective rainfall in the Berkshire Downs since October 2011 has been lower even than 1976, according to the data in EA’s West Thames water situation report. However, the slight rise in groundwater levels and river flows in February 2012 suggests that the effective rainfall in January and February has been more than shown by EA’s data. Nevertheless, the dryness of the winter of 2011–12 has been similar to 1975–76.

The second part of Figure 1 shows recorded groundwater levels at Rockley and a prediction of water levels up to autumn 2012. The predicted groundwater levels are based on an assumption that there will be some effective rainfall before mid-April, but minimal effective rainfall and declining groundwater levels thereafter. The groundwater levels are predicted to be similar to 1976 and lower than 1997, when groundwater levels and river flows were boosted by significant rainfall in February.

Abstraction in 2011 was much more than in 1976, although less than licensed:

	Average daily abstraction (Ml/d)
Year	Axford	Ogbourne	Clatford	Marlborough	Ramsbury
1976	2.0	0.3	Not known	Not known	Not known
2011	10.19	2.65	0.80	1.96	0.80
Now licensed	13.7	8.1	1.2	2.5	1.2

Figure 1—Comparison of droughts of 1975–76, 1996–97 and 2011–12

The lower two graphs in Figure 1 show recorded Kennet flows at Marlborough and Knighton, and predicted flows to autumn 2012, assuming abstraction remains similar to 2011 levels. The predicted flows are simply sketched in by eye, based on the rates of flow recession recorded in 1976 and 1997. Regardless of rainfall, the flows are likely to be almost as low as 1976 and significantly lower than 1997.

Assuming abstraction similar to 2011, the flows in the Kennet in the summer of 2012 can be expected to be lower than experienced in the autumn of 2011. The river will probably be dry at the Marlborough gauging station and through the town from about August onwards. By May, the flow at Knighton can be expected to be lower than in autumn 2011, falling to about half the autumn 2011 flow by the end of the summer, although not quite as low as 1976.

3. Likely Impact of Drought in 2012, Compared to 1976

The impact of the drought in 2012 on the ecology of the river is likely to be worse than 1976, because:

Total abstraction above Hungerford has risen from about 4 Ml/d in 1976 to about 17 Ml/d now.

The normal condition of the river is markedly worse than 1976 because of inferior water quality and algal growth.

The decline in ranunculus has caused lower water levels, slower flow velocities and less cover for fish.

The reopening of the Kennet & Avon canal in the early 1990s has caused a major deterioration downstream of Hungerford.

Therefore, every effort should be made to reduce abstraction in 2012, whilst still fulfilling Thames Water’s duty to supply its customers.

4. Alleviation of Drought Impact by Managing Abstraction

The first priority in managing abstraction in 2012 is to reduce the demand for water. ARK fully supports Thames Water’s plans for water saving and proposals for temporary use bans, as announced on 12 March.

However, ARK believes these bans will be more effective locally if they are accompanied by announcements of drought measures to change abstraction for the benefit of the river. The changes proposed are:

(i)Switching off the Marlborough and Clatford boreholes and supplying Marlborough and surrounding villages from Axford. The total abstraction from the upper Kennet would remain the same, but the location of abstraction would be shifted down the river, improving flows at all points upstream of Axford.

(ii)Supplying Swindon as far as possible from Farmoor and Gatehampton, reducing abstraction at Axford and Ogbourne to the minimum possible. This option could only be followed if rainfall in April and May is close to normal and Farmoor reservoir is nearly full, ie in Reservoir Level R_o in the Farmoor Control Diagram, as described in Thames Water’s draft drought plan. It should be noted that Farmoor reservoir is currently in level R_o (ie almost full) and normal rainfall in the summer of 2012 is the most likely scenario. However, even with normal rainfall, flows in the Kennet will drop to close to 1976 levels.

These measures would significantly improve flows in the Kennet. The EA’s CAMS modelling has shown that fully licensed abstraction reduces drought flows approximately as follows:

	Reduction in flow due to abstraction
Marlborough	2.5 Ml/d
Knighton	15 Ml/d

The proposed measures would not reduce the impact of abstraction completely, but could lead to increases in flow of about 2 Ml/d at Marlborough and 10 Ml/d at Knighton. The potential benefit is illustrated in Figure 2.

Figure 2—Impact of proposed drought measures on flows at Marlborough and Knighton

There would be similar benefits to flows in the Og if the Ogbourne abstraction is reduced or cut altogether, with south Swindon supplied from Axford only.

Annex B

TIMELINE FOR ARK AND AXFORD ABSTRACTION LICENCE

1990	Residents form “ARK” to protest about the state of the river
1994	Thames Water apply to vary the terms of the abstraction licence at Axford.
1998	Thames Water appeal against the Environment Agency’s ruling which leads to a Public inquiry into the impacts of abstraction at Axford. ARK gives detailed evidence. Secretary of State rules in favour of Thames Water, but recognises the ecological impacts of the previous licence arrangements, particularly on Ranunculus.The new license includes a flow constraint when flows are less than 90 Ml/d to be applied from January 2000. The license must be reviewed in 2007 and any further evidence of environmental harm could be reviewed as part of any application to renew the variation.
2001–2004	Ecological studies to inform the Low Flow investigations (Atkins)
2004	Environment Agency Catchment Abstraction Management Strategy shows the Kennet to be “over-abstracted”.
2005	Low Flow Investigation is published (Atkins) and concludes that there is a negative environmental impact of abstraction from Axford.
2005	Jenny Covey (EA) attends ARK AGM and states that the EA will contest the variation on the license in 2007, but not the base license itself. ARK argues that the base license should be reduced.
2007	Thames Water apply to renew the variation on the Axford licence.
2007	Fiona Holmes (EA) attends ARK AGM and states that EA and Natural England are aiming to reduce abstraction a Axford to 6Mld with 3Mld to be used locally, and 3Ml/d to go to Swindon with a target date of 2014.
2008	EA grant a temporary extension to the Axford licence with a reduction from 13.7Ml/d to 11.1Mld (average) until 2011. ARK argue this does not go far enough, and EA argue it is part of a process moving towards the target of 6Ml/d.
2010	ARK give evidence at TW public inquiry into water resource management plan, stating that the cost of the Axford alternative should fall within the price review system.
2011	Thames Water apply to renew the temporary variation in the license because no work on the Axford alternative has begun. EA grant the extension.

March 2012

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