River Misbourne campaign

Chiltern Society campaigns for funding for remedial work to help improve the flow of the River Misbourne

[To] Ms Dawn Instone
Water Supply and Regulation Division
DEFRA
Area 2C, Ergon House
Horseferry Road
London SW1P 2AL

Dear Ms Instone.

3 Valley Water Draft Water Resources Management Plan

I refer to the above plan issued in April 2008, and the response form at the end of the consultation document. The Society’s views are as follows:

Question 1:
Reduced carbon emissions and water savings through efficiency measures

We wish to register our disbelief in the sustainability of the statutory prediction of a 20% increase in the number of dwellings in the area, resulting in part from an expected 12% increase in population, coupled with a 5% reduction in water availability as a result of climate change. We realise that these are ‘given’ to the company by government and will challenge them elsewhere with the appropriate department, as they seem to us unsustainable predictions for the long term.

It is regretted (and ridiculous) that water companies are not statutory consultees in plans for major developments and we believe it is important that they seek to become involved at a very early stage, when they can advise on both in-house water efficiency and sustainable drainage systems (SUDS). Development of multiple units provides an excellent opportunity for implementation of SUDS. Our opinions on these questions are -

(a) We note that Defra’s Future Water speaks glibly of the 80 l/p/d house and this can be the ultimate aim but for a Company whose customers repeatedly top the national per capita consumption table this does seem unattainable; we need to remember that it is not houses that use water but unpredictable people. We support your water efficiency strategy with its eight strands and would suggest that if smart metering can include access to an in-house readout customers will be much more inclined to curb their usage.

(b) However, in addition to your demand management programme and in view of the long lead time in developing new major resources we believe that the Company should constantly bear in mind the need for such in the longer term and work with other companies in the stressed south-east in planning the development of alternative major resources such as the Abingdon reservoir.

Question 2:
Levels of service: hosepipe bans, Drought Permits and Orders

hosepipe restrictions once in 10 years,
drought orders once in 20
stand pipes never

This is a formula that has seen us through three major droughts within the last 20 years and is worth supporting. There has been, and no doubt will always be, a threat of three or more consecutive dry winters which could bring water companies to their knees but the threat must diminish as climatic volatility increases and the establishment of decadal, 1890s style, droughts recedes. To plan for the latter contingency would be wasteful and expensive

(a) We consider that the present balance is about right

Question 3:
Impact on the environment

We cannot agree with the implication that maintenance of river levels is relatively unimportant and question whether 524 opinions from a customer base of 3.2 million, many living to the north and west of London, can be regarded as statistically significant. Many of the urban population will have little or no knowledge of the rivers of the Chilterns, despite many visiting the area for relaxation, so it is a pointless exercise to ask their views on this subject. The 6,500 members of our Society would probably hold the opposing view, if questioned, and are certainly in no doubt that protection of our globally rare and threatened Chalk streams is a priority concern and the view that we have a special responsibility to protect these streams is shared by the UK Biodiversity Steering Group and the European Habitats Directive.

We are puzzled by the Environment Agency’s request not to plan for changes in abstraction regimes when the outcome of their own CAMS points to the need for reductions across most parts of the Company’s operating area and when WFD projections threaten more radical cuts. We think that you are right to make reasonable provisions for these factors in your headroom calculations.

It is undesirable and contradictory that you show the rivers water levels as the penultimate value in the diagram on page 16 of the stakeholder consultation, yet strongly support the aquifer of the Chiltern Hills on pages 13 and 18 of the ‘Summary of our Plan’ document.

The chalk streams of the Misbourne, Chess, Bulbourne, Gade and Ver and the natural habitat they support are very precious to the people who live in the Chilterns and they need more nurturing to survive than the company is allocating to the task. For the purpose of this letter alone, I wish to draw your attention to the plight of one river in particular, the River Misbourne, and I enclose a report written by one of our members who has been studying this subject for the last 10 years.

(b) Our conclusion is that the Company should be pro-active in its approach to maintenance of a healthy riverine environment, as indeed it has been hitherto.

In our view, it is essential that some action be taken by 3 Valleys and the Environment Agency to mend the Misbourne which has been broken by centuries of human activity, and we wish to see some value specifically included in this plan for such action within the next 5 years and for funding to be made available to the company through Ofwat and the National Environment Programme mechanism.

Question 4:
Protection of our water sources from pollution

(a) We agree that the polluter should pay

If you have any questions on our response to this consultation exercise, which we consider is a valuable opportunity for community participation; we will be pleased to assist you.

Yours sincerely

John Taylor
Chairman

Please click ›here‹ to view a report, Saving The Misbourne by John Norris, a Chiltern Society member who has been studying the River Misbourne for 10 years.

Click ›here‹ for a PDF (3MB) of our proposal to the Environment Agency to repair the Misbourne's leaking river bed. Note, clicking this link will start your PDF viewing software (it it's installed correctly) and load the proposal in a new window. If you want to download it, Windows users: right mouse click. Mac users: hold the control key and click.

 
The River Misbourne near Gerrards Cross, with a good flow, as it reappears from under the M25, with Chiltern Railways' viaduct on the skyline. If only it was like this at all times along its entire length.

Thanks to 'timo_w2s' at Flickr.com for the picture.