SITE: PRESTON CANDOVER, HAMPSHIRE PLANNING INSPECTORATE REFERENCE: RSA/WR/00016 PRE-INQUIRY STATEMENT OF THE UPPER ITCHEN INITIATIVE

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1 IN THE MATTER OF THE WATER RESOURCES ACT 1991 AND CALL IN OF AN APPLICATION BY THE ENVIRONMENT AGENCY TO RENEW ITS ABSTRACTION LICENCE RELATING TO THE CANDOVER SCHEME SITE: PRESTON CANDOVER, HAMPSHIRE PLANNING INSPECTORATE REFERENCE: RSA/WR/00016 PRE-INQUIRY STATEMENT OF THE UPPER ITCHEN INITIATIVE TABLE OF CONTENTS 1 The Upper Itchen Initiative Actions related to the Candover Scheme Basis for objecting to Southern Water s proposal for use of the Candover Augmentation Scheme... 2 APPENDICES Appendix A1 Members of the Upper Itchen Initiative 1

2 1 The Upper Itchen Initiative 1. The Upper Itchen Initiative (UII) is a stakeholder and interest group comprising members from statutory bodies, NGOs, private companies, research organisations and riparian landowners. A list of the membership of the UII is provided in Appendix 1. The UII was formed some 10 years ago to protect the environmental integrity of the Upper Itchen chalk river catchment. The UII s core area of interest is the headwaters of the Itchen comprising the River Alre, the Candover Stream, the Cheriton Stream and the main Itchen river extending to Easton, though through its membership its sphere of interest extends to the middle and lower catchments. 2. The UII meets 3-4 times a year to discuss issues affecting the Upper Itchen. These include, inter alia, issues related to the quality of the aquatic environment, water quality and quantity concerns, updates on work being carried out by UII member organisations, research projects, watercress company updates on measures to improve the quality of discharges to the river, catchment management plans, and measures to broaden public knowledge and understanding of the Upper Itchen. 2 Actions related to the Candover Scheme 3. The UII has been actively engaged over the last year in liaising with its members, the Environment Agency (EA) and Southern Water (SW) on the re-licencing and use of the Candover Augmentation Scheme (CAS). During 2016 it was engaged in discussions with the Environment Agency on the renewal of the CAS licence, and made written representation on the draft proposals. 4. The issue of Southern Water s inclusion of the Candover Augmentation Scheme in its 2014 Water Resources Management Plan (WRMP) came to UII s attention in early Since this date the UII has been fully engaged in discussions with Southern Water, the Environment Agency and on the proposed future use of this scheme. Members of the UII have now been invited to join the Hampshire Water Resources Options Review Group organised by Southern Water. 5. The UII s view is that the licence for the Candover Augmentation Scheme should not be renewed and that the scheme should be decommissioned. In this context the UII is strongly supportive in the short-term of the EA s decision to amend the licence to limit the permitted abstraction to 5 megalitres per day (Ml/d) and the total abstraction to 750 megalitres per year, with the further restriction that the scheme can only be used once in six years. 6. The UII is strongly opposed to the proposal by Southern Water to retain the previous licence and use the CAS in times of severe drought. 3 Basis for objecting to Southern Water s proposal for use of the Candover Augmentation Scheme 7. The following are the objections to Southern Water s proposal for the CAS: i) The first observation is that it is perverse that SW wants to abstract yet more water from an already stressed river basin at a time of water scarcity. It is equally perverse that in order to protect the flow conditions and thus ecology in the lower Itchen the flow conditions and ecology of the Candover stream will be put at risk. ii) It is noted that under s.37 (i) Water Industry Act 1991 SW s remit is to develop and maintain an efficient and economical system of water supply. There is no environmentally sustainable qualification to this phrasing. In this context it has to be taken that the issue of environmental sustainability of water supply abstractions are a matter for other bodies, namely the EA and (NE), whose duties are clearly spelt out in various legislation (the Habitats Directive, the Water Framework Directive, the Environment Act, etc.). In this context the UII believes that it is the EA and NE s responsibility, not SW s, to identify suitable abstraction sites, quantities and timings for water supply. 2

3 iii) The Candover Stream is already adversely impacted by public water supply abstractions at Totford and Lasham. The Totford abstraction (operated by SW) is immediately adjacent to the Candover Stream (< 50 metres) and pumps 4-5 Ml/d. At this proximity the cone of depression will be impacting the natural flow of the stream. Lasham (operated by South East Water) is further away in the upper catchment and will have a less marked impact on the stream. It is understood that the EA plans to review these abstractions in the near future. The EA have expressed concerns over the cumulative impact of the Lasham, Totford and CAS abstractions on the Candover stream. The UII share these concerns, with the cones of depression exhibited by each of these abstractions being additive and adversely impacting on the flows reaching the Candover stream. iv) It needs to be clearly understood that SW s proposal for use of the CAS is HIGH RISK which potentially endangers the ecology of the Candover Stream and the Upper Itchen. The 1976 test of the CAS 1 shows that despite higher than average rainfall during Sept-Nov 1976 the Candover Stream did not return to normal flow patterns until May Had the low rainfall pattern of Sept-Nov 1975 recurred then the period taken for the Candover Stream to return to normal flow patterns would have been extended into the low flow period from June-Oct. v) An additional risk is that SW have paid little or no attention to the consequences of pumping a significant volume of water into the main Itchen river between Itchen Stoke and Itchen Abbas at a time when the river will have been experiencing a drought and flow levels will be low. In discussions with SW on their plan it is apparent that they have not thought seriously about the potential environmental consequences of altering the natural flow pattern by a sudden injection of (cold) water into the Itchen. How will this impact the flora and fauna in the river, will it stimulate behaviour which would normally be associated with later periods in the year when natural flow patterns begin to increase? What are the other potential impacts? vi) SW exhibit an engineering bias in their approach to the use of the CAS. They view the section of the Itchen from the proposed CAS outfall to the abstraction point at Otterbourne as a transportation system (canal), rather than as one of the UK s most valued chalk streams with SSSI status. They continue to display this bias in their whole approach to this issue. This is further exhibited in their costing of the consequences of failing to supply water to businesses and individuals with little apparent attempt to cost the value of the environmental impact of using the CAS, or the ecosystem services provided by the Candover Stream with its natural flow patterns. vii) There are concerns about the efficiency of the supply. SW appears to assume that all the 20 or 25 Ml/day that is pumped from the CAS will arrive at the Otterbourne abstraction point. There is no evidence to show that this will be the case at a time when the CAS water is being added to low flows in the Itchen during a drought period. In addition SW propose that 2 Ml/d can be discharged at the existing minor outfall into the Candover to supplement low flows in the Candover. This wrong on two fronts: (i) it is perverse for SW to be extracting more than they need to release some into the Candover to partially offset the impacts of the abstraction, and (ii) measurements made during the 1976 trial show that of flow ranging between Ml/d diverted into the Candover Stream Ml/d was lost from the gravel bed into groundwater as a result of the lowered groundwater level resulting from the CAS 1 As reported in Southern Water Authority s report Itchen Groundwater Regulation Scheme Final Report on the Candover Pilot Scheme dated June

4 pumping 1. With a flow of 2 Ml/d it is possible that there will be no surface water flow, it will simply be recharging the groundwater. viii) SW makes the case that the Candover Augmentation Scheme was included in their 2014 Water Resources Management Plan (WRMP). The UII considers that there was inadequate local consultation by SW during the preparation of this plan given that the UII, a body specifically established to protect, conserve and enhance the condition of the Upper Itchen, was not consulted. To the UII s knowledge the main riparian landowner was also not consulted on the scheme prior to its inclusion in the 2014 WRMP. The UII believes that this lack of consultation prior to inclusion of the CAS in the 2014 WRMP represents a major failing by SW. ix) Since learning of SW s plan for the Candover Augmentation Scheme the UII has been actively involved in broader discussions on water resources management related to the Itchen. Through these discussions and research it became apparent that there are viable alternative sources to using the CAS. A key viable alternative is the development of the Havant Thicket reservoir which would enable Portsmouth Water (PW) to transfer to Southern Water its licence at Gaters Mill on the lower Itchen. This licence for 35 Ml/day amply covers the amount SW wishes to pump from the CAS. x) The UII has for some while expressed great concern to the EA, SW and PW about the lack of integrated water resources management (IWRM) exhibited in relation to the Itchen and neighbouring catchments. The Itchen is a closed river basin, that is all its sustainably utilizable water resources are allocated, there is no spare water. In this context additional water needs to be brought into the basin if additional resources are required (such as for new housing). For this reason it is difficult to understand, in an IWRM context, why PW continue to abstract water from the water scarce Itchen at Gaters Mill to supply Fareham and Gosport which are well outside the Itchen catchment. As a water supply utility PW is not water scarce, it has a surplus, yet it continues to be permitted to abstract from a highly water scarce SSSI resource. PW have offered to develop a reservoir at Havant Thicket to capture, store and utilize surplus water. Such a resource would allow PW to reorganise its supplies and release its demand of up to 35 Ml/d at Gaters Mill to SW. This proposal was in PW s draft 2014 WRMP but required a request from SW to act Portsmouth Water notes that it would only include further bulk supplies if neighbouring companies were to request them. Therefore the trigger for the alternative plan is dependent on third parties 2. Havant Thicket has been a preferred option for PW for many years, yet SW have chosen not to take advantage of this opportunity. It is a real possibility that SW s proposal to use the CAS is a victim of a failure of two water companies to come together in the interests of proper integrated water resources management. This is not in the best interests of water resources planning, customers or the environment. xi) One of the reasons that the CAS is under consideration by SW is because of the sunk costs already present in the form of 6 boreholes and 13 km of pipeline. It represents a low-cost and (from and engineering perspective) simple option. The UII believe that because of its low-cost and apparent ease of implementation SW have not looked seriously enough at other less environmentally damaging alternatives, such as Havant Thicket. Continuing this theme the UII is greatly concerned that if SW are allowed to use the CAS and construct the additional pipeline from the Candover to the Itchen they may, at a later date, argue that having made the investment they should be allowed to continue using it, even though other sources may have become available. 1 Table 6H, ibid. 2 para 7.3.4, Draft Water Resources Management Plan 2014, March 2013, Portsmouth Water Ltd. 4

5 xii) Finally, river augmentation schemes in the Upper Itchen do not have a good record. The Alre Augmentation Scheme was closed down by the EA when it was found to be adversely impacting supplies to watercress growers and the upper Meon catchment. 8. In conclusion the UII requests that the Inspector rejects Southern Water s case related to Licence Number 11/42/18.16/546 (authorising abstraction by the EA at Preston Candover on the Candover Stream ) ( the Candover licence ) and accepts the Environment Agency s application for a new licence as submitted on 11 August The UII also request that the Inspector invites Portsmouth Water to participate in the Inquiry, given that it is a key player in the discussion. 5

6 Appendix 1 Members of the Upper Itchen Initiative Graham Roberts (Chair) Carrie Hutchins (Secretary) Mark Baring Zam Baring Martin Burton Martin de Retuerto Ali Morse Ben Rushbrook Sam Wright Ben Yexley Samantha Mapes Simon Ffennell Roger Harrison Chris Jeffes Maxime Holden Kerry Sims Jeremy Legge Leah Mathias-Collins Pete Shaw Tim Sykes Bob Wellard Charles Barter Ollie Bedford Nick Measham Steve Rothwell Gail Taylor Suzie Qassim Rose O Neil Independent Consultant and VCT Trustee Vitacress Conservation Trust (VCT) Riparian Owner Wessex Chalk Streams and Rivers Trust Trustee Independent Water Specialist/Consultant Hampshire and Isle of Wight Wildlife Trust Hampshire and Isle of Wight Wildlife Trust Hampshire and Isle of Wight Wildlife Trust Riparian Owner Riparian Owner Alresford Salads Environment Agency Environment Agency Test and Itchen Association Vitacress Salads University of Southampton Environment Agency Piscatorial Society NFU Watercress Association The Watercress Company Salmon and Trout Conservation UK Vitacress Ltd and VCT Trustee University of Southampton WWF 6