At the beginning of October, FORQ wrote to the Environment Agency, seeking to understand;
♦︎ Why the Rib and Quin catchment is so disproportionately abstracted by Affinity Water.
♦︎ Why so much raw sewage is released into our catchment by Thames Water.
♦︎ Why the EA is objecting to further development in Cambridgeshire, but not in Hertfordshire.
We wrote again last month, enquiring as to why we hadn’t received a reply.
The full text of the letter is reproduced below.
As both a concerned resident of North East Hertfordshire and as chair of Friends of the Rib & Quin – a community group founded specifically to raise awareness and concerns for the future of our local chalk streams, I wonder if you can help me.
Over recent years we have investigated much of the publicly available data relating to our catchment, much of it generated or curated by the EA, which highlight a number of areas of concern that I trust areas of particular focus as Water Management Plans are developed.
We have found that abstraction is disproportionate across Hertfordshire, both in terms of catchment and population size. Herts Chalkstreams are abstracted at levels far in excess of the 10% recommended as the maximum percentage of annual recharge in the Chalkstream Recovery Plan. In our particular catchment’s case, our abstraction levels are particularly disproportionate to our population.
We have found that raw sewage spill pollution events in East Hertfordshire represent over 90% of Hertfordshire storm overflow events, with over 50% in Sir Oliver Heald’s constituency alone. We’ve also found that phosphate from Buntingford STW, as an example, has been releasing excessive levels of phosphate for over 30 years, with still no remedy in place.
With these obvious deficiencies in infrastructure and resource to support the existing population of East Hertfordshire, we wonder why the Environment Agency has recommended against further development in Cambridgeshire and yet has made no similar objections to developments in East Hertfordshire at Buntingford, Barkway and Ware.
Your help in understanding these issues, decisions and discrepancies would be of great interest to our members. I greatly appreciate your help in reaching that understanding.
Today, we received the following, somewhat selective and incomplete reply:
Thank you for your email regarding water resources, biodiversity, and development in East Hertfordshire. I sincerely apologise for the delay in our response.
Water is a precious resource that is under pressure across the country. These pressures are being felt most acutely in and around Cambridge and East Anglia, with increasing abstraction posing a real risk to chalk streams, river, and wetland habitats. As you are aware, we objected to some planning applications in the Greater Cambridge Area on the basis that the water supply for these developments will pose a significant risk to our local water environment. Our main concerns in this instance related to Cambridge Water Company’s draft water resources management plan. We are continuing to liaise with the Greater Cambridge Partnership planning authority and Cambridge Water Company to find a solution for people and the environment.
We publish abstraction licensing strategies (ALS) which set out the water availability picture. The Upper Lee Abstraction Licensing Strategy is relevant for the Rib and Quin catchments. This strategy indicates that no new water supply options are available. This situation is replicated in the neighbouring Colne ALS. As a result, any water to support growth needs to be found from within existing resources and improved efficiencies, or from outside of these catchments. To meet our environmental duties, we have been seeking various reductions to existing water company abstraction sources in these areas. There are agreed licence reductions already in place in the Upper Lee and Colne ALS areas, with further changes to be implemented in the Upper Lee by December 2025.
As part of our duty to ensure compliance with the Water Framework Directive (WFD) Regulations, we require water companies to cap their abstraction licences in water bodies where using unutilised headroom could cause a deterioration. Unutilised headroom is the difference in volume of water which companies have been abstracting, compared to what they are licensed to abstract. However, the specific method will vary depending on the type of legal permissions held by the relevant water companies or licence holder. This influences the time frames by which agreed changes need to be put in place and/or how the legislation can be applied in those circumstances. The situation in East Anglia is different to that in Hertfordshire and North London, as Cambridge Water Company must deliver some of these caps by 2024, with additional ones due by 2030. Affinity Water’s situation is different due to the nature of their abstraction licences. In their Water Resource Management Plan (WRMP) 19, they had to investigate which water bodies were at risk of deterioration. The implementation of licence caps to prevent deterioration is detailed within their draft WRMP 24 and due by December 2030. We have sought assurance from Affinity that they can still supply growth, whilst delivering these licence caps.
Buntingford Sewage Treatment Works (STW) is currently being upgraded as part of the Water Industry National Environment Programme (WINEP). The upgrades at Buntingford STW are to increase flow to full treatment, flow monitoring, and add event duration monitors (EDM). This work should be completed by the summer. Storm overflows are a necessary part of the current sewage system, they act as relief valves which prevent the system from overloading during high rainfall events. Every storm overflow is now fitted with EDM, providing accurate information about where and when storm overflow discharges are happening. This is a significant improvement from 2001 when just 7% of storm overflows had monitors fitted. Monitoring storm overflows allows for greater transparency of where there are issues, this allow us to better tackle illegal discharges from storm overflows, investigate those who breach their permitting conditions, and supports the government’s Plan for Water.
In September 2023, as part of the WINEP programme, a 0.25mg/l phosphorus limit was added to the permit conditions at Buntingford STW. This limit is assessed over a rolling 12 month mean. This brings Buntingford STW’s discharge in line with the industry’s technically achievable limit of phosphorus removal from sewage treatment works. Ensuring clean and plentiful water for future generations is one of our key priorities. We are progressing our work to transform regulation of the water industry and have just launched a public consultation to charges applied to water quality permits, which will transform how we regulate the water industry.
I hope that the above is useful in highlighting some of the planned interventions to help maintain water resilience at a local and strategic level. We continue to build our evidence base to inform our position and responses.
One small success then – after over 30 years of phosphate pollution, Buntingford STW will now apparently have a phosphate stripper installed as part of its upgrade. However, it is our belief that these are inadequate answers to reasonable questions. Furthermore it indicates how the Environment Agency is failing to protect our chalkstreams generally and in the Upper Lea and Rib & Quin Catchments specifically. We can also perhaps conclude that the plight of our chalk streams is entirely in the hands of the water companies, who are quite happy to play off one catchment against another, whilst neutering certain local eNGOs with greenwashing funding.
What a sorry mess we are in.
As a side note, when we chased a response to our original letter last month, we copied in local councillors and Sir Oliver Heald, to see if it made a difference. Apparently it did – we received a reply. However Sir Oliver also replied saying he had sent our letter to senior Environment Agency officials. It is unclear whether we will receive a separate response from them.
Friends of the Rib and Quin 