Response from the Environment Agency 28th April 2020
Response from the Environment Agency to FeCRA’s questions. 28th April 2020
Thank you for your further questions and request for clarity on information I have previously provided. There is a lot of information included within this reply so I remain very happy to discuss this with you.
I have put your questions into bold text and answered them in the blue text.
Page 2 “The Water Industry National Environment Programme3 estimates that water company abstraction volumes need to be cut by over 700 million litres per day (Ml/d) to address environmental problems”.
The first thing that needs clarification is whether the reduction of 700 ML is to current rates of abstraction or to licensed figures
The Water Industry National Environment Programme (WINEP) includes both current rates and licensed figures. As I mentioned in my email of 25 March it depends on the issue we are seeking to address. Schemes to improve river flows will use current rates of abstraction (we call these recent actual levels, which can be up to the fully licensed level). Schemes to prevent deterioration in Water Framework Directive (WFD) ecological status will use fully licensed quantities.
Exactly where these reductions are needed, not just the Cam Catchment?
I have attached the publicly available copy of the WINEP, which is also available on www.gov.uk. Searching the WINEP there are 302 sustainability changes (Column Y) that should see reductions in licensed quantities. These stretch across the country and I have included these in the attached spreadsheet (WINEP Sustainability Changes) to show where they are.
The WINEP uses codes to identify different types of measure and the different drivers which are being addressed. An investigation measure is first required to confirm the issues before options appraisal is carried out leading to an action to prevent deterioration or improve status. Within the spreadsheet these codes (in column Q) include:
ND INV – a no deterioration investigation (if proven would lead onto an ND in the next WINEP)
ND – action to prevent deterioration
INV – investigation into WFD status (if proven would lead onto an IMP in the next WINEP)
IMP – action to improve status / achieve Good Ecological Status (GES)
What is the reduction in abstraction needed to mitigate any environmental damage being caused to the River Cam / Granta?
Due to the size of the chalk aquifer our groundwater computer model extends across a broad area taking in the River Cam / Granta, as well as surrounding rivers and across to the west. We refer to this as the Cam & Bedford Ouse. For this area the model suggests a reduction in groundwater abstraction, for all sectors, in the order of 55% of fully licensed rates, though we must consider this in context and also be clear on what is meant by ‘any environmental damage’.
A reduction of this scale would have a clear effect on public water supplies in the Cambridge and Bedford area with challenges for public health. It would also impact on industry and agriculture as well as fail to address the issues from high personal consumption, pipe leakage etc. Alternative sources of water would need to be in place and ready to take over this supply, which is where Water Resources East (WRE) comes in.
The main area of our work on sustainability of water resources at a catchment scale comes through the Water Framework Directive River Basin Management Plan process. The first River Basin Management Plan (RBMP) was published in 2009 and the current plan in 2015. A third cycle plan is scheduled to be published in 2021.
Work on RBMPs takes place with two core objectives:
1. To get all water bodies to Good Ecological Status (GES)
2. To prevent deterioration in water body status.
There are surface water bodies (river catchments) and groundwater bodies (aquifers).
RBMPs look at both water quality and water quantity. For water quantity issues, we assess whether flows in rivers, or a range of tests for groundwater bodies, are supporting GES. Where it is not we appraise what options are available to get them to supporting GES. Water quantity options can include, reduction in abstraction quantities, river support schemes and river restoration.
An important factor for any scheme seeking to achieve GES is they have to pass a cost benefit test, which is carried out at a wider catchment scale and looks at all the measures that are required, both water quality and water quantity. Examples of these may include measures to improve the quality of water coming out of Water Recycling Centres, removal of barriers to fish migration and land management changes to reduce run off of water from fields into rivers. Where measures are found to be cost beneficial, then they are written into the RBMP to become legally binding objectives and are translated into the WINEP.
Page 2 “The Water Industry National Environment Programme estimates that water company abstraction volumes need to be cut by over 700 million litres per day (Ml/d) to address environmental problems”.
Can you please tell us how much of reduction applies to the River Cam?
In my email of 25 March I said planned reduction to water company abstraction licences in the River Cam & Granta catchments equates to approximately 4.2 million litres by 2025. After reviewing our information the reduction on the Cam and Granta is closer to 4.45 million litres. There is also an additional 1.07 million litres potential reduction subject to flow conditions in the Upper Cam.
Which category does the Cam Catchment fall into; improve river flow, or prevent deterioration? Or possibly neither?
The Cam Catchment includes schemes to improve river flows and to prevent deterioration, so falls into both categories.
Flows in the Cam and Granta were failing to support GES and there is also a risk of deterioration from utilisation of historically unused licensed quantities. There are measures in the WINEP aimed at moving the flows back to supporting GES (for example, Cambridge Water Company measures in the Granta and Affinity Water measures on the main Cam). There are also wider measures that seek to prevent deterioration in the flows, for example, licence capping of groundwater licences to reflect historically used quantities and applying conditions on surface water abstractions that cease abstraction at low flows.
If the Cam is not in the more critical category, can you explain why and give a couple of examples of rivers that have been awarded that category backed up by evidence. (% time spent below normal, notably low and critically low over the last 12 months compared to the Cam)?
Whilst preventing deterioration is a key aspect of the Water Framework Directive, we consider improvements to river flow and preventing deterioration to both be important issues so there is no ‘more critical category’. Schemes on the Cam and in other rivers and water bodies are identified according to the issues we are seeking to address. The Cam is not in competition with other rivers or areas of the country.
Was Ofwat aware of the need to cut abstraction volumes?
Yes. The WINEP was shared with Ofwat. The water companies take the requirements from the WINEP and use them to develop their 5 yearly business plans, which are then submitted to Ofwat for funding approval. The WINEP includes details on the type of action required, where it is and the reasons, or drivers, as to why the action is required.
If so where exactly are they being cut?
Abstraction reductions are planned in the River Cam and River Granta as follows.
Upper Cam Affinity Water sustainability reductions from fully licensed rates to prevent deterioration (by 2025 in cubic metres)
Licence number Reduction Quantity Reduction %
6/33/27/*G/0082 2,470,000m3 37%
6/33/27/*G/0011 735,000m3 44%
6/33/27/*G/0012 174,798m3 35%
6/33/27/*G/0013 124,000m3 10%
Total reduction from fully licensed rates = 3,503,798m3 (31.5%)
Upper Cam Affinity Water sustainability reductions from historic abstraction rates to get flows to supporting Good Ecological Status (by 2025 in cubic metres)
In addition to the reductions above (to prevent deterioration) Affinity Water also has a reduction from historic abstraction from 6/33/27/*G/0082 of 1,073,000 m3. This quantity of water is to be made available for river support and represents a higher quantity of river support than Affinity presently has to make available. The increased quantity for river support results from an increase in the target flow at Great Chesterford. Please note, that the river support is only required when flows are low, so in wet years, river support may not be required. Even in drier years, it may be that the full quantity of river support isn’t required, so the figure above is the maximum quantity.
River Granta – Cambridge Water sustainability reductions from fully licensed rates to prevent deterioration (by 2025 in cubic metres)
6/33/28/*G/0052, 6/33/28/*G/0051 & 6/33/28/*G/0012 – reduction from full licensed rates across 3 licences = 945,000m3 (40%). This represents unused licensed headroom.
River Granta – Cambridge Water sustainability reductions from historic abstraction rates to get flows to supporting Good Ecological Status (by 2025 in cubic metres)
The measures required to get flows back to supporting Good Ecological Status involve:
1. Increased use of the Environment Agency’s Granta river support scheme
2. Introduction of phased conditions on three of Cambridge Water’s abstraction licences, which constrain the daily quantities that can be taken as the flows decline. As these conditions are dependent on the flows, during higher flows the company may not experience any reduction in its daily rates.
Cherry Hinton Brook sustainability reduction from fully licensed rates to prevent deterioration (by 2025 in cubic metres)
6/33/34/*G/0024 – 197,100m3 (3.5%)
Hobson’s Brook sustainability reduction from fully licensed rates to prevent deterioration(from 2020 in cubic metres)
6/33/28/*G/0007 – 700,800m3 (21%) (Please note this is a maximum amount and will not be required every year depending on flow conditions at Nine Wells). The company also has an investigation obligation in WINEP for the 2020-25 asset management plan period to look at the deterioration risks of abstraction historically unused licence headroom from 6/33/28/*G/0007.
Taking the figures for the Cam and Granta together, the total reduction in licensed quantities for the two companies are:
Affinity – 3,503,798 cubic metres, which is 3.5 million litres
Cambridge 950,000 cubic metres, which is 0.95 million litres
Total of 4,448,798 cubic metres, which is 4.45 million litres
As set out above, there would be a maximum additional reduction (dependent on flows) of:
Affinity – 1,073,000 m3, which is 1.07 million litres
And if not in the Cam Catchment, why not? Where in the country is there a greater risk to the rivers?
As explained, reductions are planned in the Cam Catchment.
Can you disclose whether your area submission that fed into the draft WINEP and subsequently approved by Ofwat, included cuts in abstraction necessary to address environmental problems?
They included cuts in abstraction required to get flows in the rivers back to supporting GES where they were cost beneficial through the 2015 Anglian River basin Management Plan.
How were they calculated?
For river systems, the assessment of whether flows are supporting GES looks at whether flows in the river are meeting a target in surface water rivers we use called the Environmental Flow Indicator (EFI) which is the amount of flow calculated to support the ecology in a particular water body. This indicator works out how much of the natural flow in a river is required to support the ecology. Critically, it does allow for a proportion of the natural flows to be allocated to other uses, for example abstraction. Therefore, our work is not about returning flows in the rivers to their natural state, but recognises that there is scope for some of the natural water to be abstracted, whilst maintaining the ecology – we wouldn’t view this as environmental damage.
The assessments look at what the effects of actual abstraction over a recent period are on flows. Where this assessment shows that the resultant flows are below the EFI, then the flow in the river is classified as not supporting GES. We cross reference this with our ecological monitoring data to verify that there is evidence that the ecology is suffering. There are some instances where flows can be failing the EFI, but the actual ecological monitoring data shows that the ecology is healthy. In these instances, we would overrule the EFI, which is an indicator, and say that presently, flows are supporting GES. For all other failures, where they are backed up by the biological monitoring, the rivers are assessed as set out above.
The second duty under WFD – preventing deterioration – means that even if it is found to be disproportionately costly to get waterbodies back to supporting GES, we still have to prevent them from getting any worse. The prevention of deterioration is not subject to a cost benefit assessment. Water companies have been required to investigate the risk of deterioration from abstracting historically unused quantities over the 2020-2025 planning period.
All groundwater abstraction is contributing to a general lowering of groundwater levels across the aquifer. This diffuse problem is the more challenging to resolve as it would require significant reductions in overall groundwater abstraction. The financial costs of which make it almost impossible to pass cost benefit testing.
The results of this for the 2015 RBMP were that the measures needed to get entire aquifer system back to supporting good ecological status were disproportionately expensive. The plan did approve some measures to improve the status of the rivers that were failing to meet their ecological flow needs and this was due to pressure on flows. The River Cam and River Granta were two of these rivers.
How are they being delivered?
The actions from the RBMP are translated into the WINEP for delivery by water companies around the country. For the Cam catchment this means a range of actions for the water companies to address low flows or to prevent deterioration are required. During the 5 year programme cycle Environment Agency officers keep regular contact with water companies, at local Area/Water Company boundary/national levels to monitor progress and ensure delivery.
The effects of historic licensing and abstraction are significant and there is no quick fix for this issue. Cost benefit testing limits the range of options we have available to us to address the environmental issues we face. We also need to consider what we mean by sustainable water use. Returning the River Cam’s or Granta’s flow to natural conditions or to somewhere between natural and present levels will require significant reductions in abstraction for both public water and also other sectors including agriculture. Replacing this water is not a simple, cheap or quick solution and would likely result in the need for new reservoir storage, the treatment and movement of surface water from other parts of the country, which have their own environmental impact, as well as changes in personal consumption, pipe leakage, as well as growth and development .
The Government has recently introduced a new level of water resources planning through the regional water plans. As you know for this region, we have Water Resources East(WRE), which I was pleased to hear from you that FeCRA are now a partner. The project is looking at how to maintain water supplies in the face of challenges like housing growth, climate change and providing greater resilience in supply networks. We are asking WRE to consider the implications of more significant reductions in groundwater abstraction than are presently in their plans as part of the environmental ambition. This should allow a more informed debate about the measures that would be required to achieve these reductions and what the costs, financial and environmental would be.
We respond to requests under the Freedom of Information Act 2000 and Environmental Information Regulations 2004. Please refer to the Open Government Licence available here: http://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/ which explains the permitted use of the information we have provided.