Background
Affinity Water's Water Resource Management Plan (WRMP) aims to address a significant future shortfall in water resources in their supply area.
Population growth, climate change and the demand for water are putting significant pressure on the local environment and water resources in Affinity Water's supply area.
Without action – the area Affinity Water supplies faces a possible shortfall of 449 million litres a day by 2050. Affinity Water sought to hear what customers and stakeholders thought about their draft plan to help them shape their final plan which they aim to publish in Autumn 2023.
Every five years, Affinity Water produces a WRMP which addresses these future challenges and provides a roadmap for a reliable, resilient, sustainable, efficient and affordable water supply to customers between 2025 and 2075, whilst taking care of the local environment.
The actions include reducing customer demand, driving leakage down further than ever before, smart metering and significant investment in new infrastructure for new sources of water - working across the water industry to plan and share resources regionally. The plan will also make the region's water supplies more resilient to droughts, which are becoming more frequent due to climate change.
The consultation took the form of 8 questions. Please find below the questions and East Herts Green Party's answers.
East Herts Green Party Response
Prepared by Nicholas Cox - February 2023
Q1. Please tell us how well you think we have balanced the main factors relating to our environmental destination in our draft plan. Should we be doing anything differently?
If your mission is to provide sustainable, high-quality water and work together with your community then you have failed dismally because you are destroying our chalk streams and appear to have accumulated a £3 billion liability through lack of investment and you are telling your “community” that we have to pay for your mistakes through higher bills. Why aren't you lobbying and campaigning for property developers to fund part of the cost? Given the international importance of our chalk streams, before Brexit the EU would have part funded restoration projects, why aren't you asking the UK government to match-fund what you would have claimed from the EU?
What else should you be doing differently? In addition to the measures mentioned below, Affinity should have a duty to produce a dWRMP that is written in plain English so that members of the public can understand it. It is ludicrous that your company pretends this document can be properly consulted upon when readers require an MSc in Water Resource Management to understand the language you use, let alone comment on your plans in a meaningful way. You should spend some of the many millions you earn in employing science communicators to rewrite your document so that it can be read, understood and consulted upon properly by members of the public.
Q2. Please tell us if there are any other factors that we should take into account in our best value plan. Which do you think are most important?
You claim that “Best value planning” looks to balance the economic, social and environmental cost of a solution or programme of work while still balancing supply and demand. This is woolly thinking. How precisely do you claim to have balanced the economic, social and environmental costs? How do you attribute an “environmental cost” to a globally important chalk stream? Where are your calculations to demonstrate this?
It would be better to use terms with defined definitions:
“Best available techniques” (BAT) means the available techniques which are the best for preventing or minimising impacts on the environment.
“Best Available Technique Not Entailing Excessive Cost” (BATNEEC), a modification of BAT, was introduced in 1984 with Directive 84/360/EEC and superseded in 1996, by Directive 96/61/EC, which applied the framework concept to, amongst others, the integrated control of water pollution.
Q3. Please tell us how well the adaptive approach addresses your main concerns. Is there a different approach we could use?
It is self-evident that you have not been planning for the future. If you were, then you would not be destroying our precious chalk streams and face an unfunded bill of £3 billion to resolve the problem!
The approach that we would like to see is using a not-for-profit model to maintain a basic resource for both residents and for nature. We want to see Affinity nationalised. While you operate to provide profit for share-holders, it is clear Affinity has little real interest or motivation in properly tackling the issues we face with water shortages in our area.
Q4. Please tell us which measures you consider are most likely to support management of demand and so should be considered for inclusion in our draft plan. Which of the identified options should we prioritise?
Firstly we want to see you stripped of responsibility for our water and your service nationalised. Until that can occur, fixing leaks is obviously the top priority and your target of a 50% leak reduction “beyond 2040” is nowhere near ambitious enough. You need a 50% leak reduction by 2030 and a 90% leak reduction by 2040. Your plan doesn’t mention transformational help for existing residential customers to reduce their consumption to the levels required. You have previously provided water flow regulators and low water shower heads free of charge. This needs to be upgraded and broadened into a permanent campaign, not a one off, and needs to be extended way beyond simply giving each home a water butt. Affinity should be spending its own money on installing large-scale grey-water harvesting systems at all new developments in East Herts to cut fresh water use and retrofitting them at existing sites that use large amounts of water.
Q5. Please tell us your thoughts in relation to the SROs that we have identified.
The six Strategic Resource Options need to be developed and progressed in parallel because time is of the essence and the problem is getting worse.
The uncontentious schemes should commence straight away.
For example, the total closure of Friar's Wash and Redbourn pumping stations and a significant abstraction reduction at Kensworth pumping station offset by transferring more water from Grafham Water reservoir.
Care needs to be taken when transporting water over long distances. Has the risk of importing invasive species been adequately studied?
The water from chalk streams is slightly alkaline with a pH range of 7.4-8.0, high in minerals (esp calcium) and low in nutrients (phosphorus 0.01-0.03mg/l and nitrogen 0.2mg/l) and high in dissolved oxygen. Softer water from other regions might have a lower pH, will this adversely affect local species? Softer water could have a corrosive effect on our chalk beds particularly over the longer term. Have all the necessary environmental impact studies been carried out and peer reviewed? This is critical or your supposed solution could wreak havoc with our precious, delicate chalkstream ecosystems.
Nor is there mention that The New River is still in use today, transferring around 220 million litres of water per day out of our region for London's use. The pumping stations upstream of Hoddesdon should be permanently shut down and offset by building a water recycling facility at the Rye House sewage works and feeding the recycled water, with levels of phosphates at levels suited to natural rivers, into the New River, perhaps using the Essex Road pumping station for this purpose.
Q6. How should we prioritise demand management? Are there other assumptions or risks (in addition to relying on government policy) that we should consider?
The demand management strategy will fail because a) it doesn’t take into account the insane house building targets set by East Herts District Council and Hertfordshire County Council - some 18,000 new houses are planned in East Herts alone, which will require at least 6.2 million litres / day of water (assuming 2.3 people per household using the current average of 150 l/p/d) – with a further 80,000 homes across the county by 2035 and b) the limit to water use stated in Building Regulations at 110 l/p/d, enforced through the East Herts District plan, is completely UNENFORCABLE at the moment.
It is no more than wishful thinking without proper enforcement, and based around developers willingness to install minor adjustments to taps and shower heads etc which have next to no impact. There is nothing to prevent home-owners using as much water as they want. In an affluent area like Hertfordshire, putting a 110l/p/d limit on usage is pure fantasy.
Affinity Water needs to take this issue seriously, and lobby the government to tighten Building Regulations, as well as actively work with developers to install large-scale grey-water harvesting systems on every new development. In the US, energy companies have spent large amounts of their own money as executives realised that spending money on helping residents use less energy would mean they didn’t need to construct another power station. Exactly the same situation applies with water here – Affinity should be spending its own money on installing large-scale grey-water harvesting systems at all new developments in East Herts to cut fresh water use and on retrofitting these systems at existing sites where users have a heavy water demand that can be met with grey water.
Q7. In choosing the 100Mm3 SESRO option we are balancing the impact on local communities against the risk that we won’t have enough water if we need to adapt to a higher environmental destination or can’t achieve the demand reductions. Please tell us how well we are approaching the balance between the environmental destination and the impacts on the host communities and environment. Is there anything we should do differently?
We support all measures taken to reduce abstraction from chalk streams and their aquifers and are in favour of the abstraction reductions planned for rivers including the Ver in Affinity Water’s dWRMP and look forward to the environmental improvements at the Ver, the Beane and the other chalk streams in this area.
However, 100Mm3 is a massive underestimate if you are serious about restoring our chalk streams. 150Mm3 should be the minimum target, with a strategy for going higher should the need arise.
The definition of sustainable abstraction should be to ensure that chalk stream flows are reduced by no more than 10% from natural at the most water-stressed times of the year with a commitment to meet this target on all chalk streams within the region by 2040.
You plan to reduce abstraction by 228 Million litres a year - actually not a lot given that you are currently abstracting about 13 million litres every day from boreholes at Baldock and Letchworth alone. That is 4,745,000,000, or 4.745 billon, litres per year.
Your abstractions have gradually risen to around 50% of average recharge, putting it amongst the most heavily abstracted chalk rivers in the whole World.
The Lawson Report calculates that to meet the 10% recharge limit, abstraction must be reduced by 81%. There is a simple solution, which is to back off pumping the boreholes, let the springs flow, let the river run, let the biodiversity recover, and abstract that same water further downstream.
Q8. Overall, do you think that our draft plan represents the best value plan for Affinity Water customers, communities and the environment? Please tell us what you think and the reasons for your answer.
No. We have about 10% of the Earth’s chalk streams in Hertfordshire. Over-abstraction of water from the chalk aquifer has resulted in our chalk streams being reduced to dangerously low flows; the source of the River Rib has moved downstream to Buntingford, while the Ash is reduced to just 11% of long-term average flows. The draft plan fails acknowledge the urgency of the problem and is not “best value” for the environment. You should be spending money cutting leakage, installing grey-water harvesting systems, working to get the building rules changed so that homes have a proper and enforceable limit to water use, and ending extraction from our chalk streams.
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