Colne Valley Fisheries Consultative                            WQR0011

Written evidence submitted by Colne Valley Fisheries Consultative

  1.                The Colne Valley Fisheries Consultative is based in the Colne Valley, Hertfordshire and represents fishery and conservation interests in the waterscapes of the River Colne, Mimmshall Brook, Upper Colne, Ellen Brook, R Ver, R Bulbourne, R Gade, R Chess, R Misbourne, Shires Ditch, Alder Bourne, Pymmes Brook, R Brent or Crane, Frays River, R Pinn, Bigley Ditch, Poyle Channel, Colne Brook, Wraysbury River, Bonehead Ditch, Duke of Northumberland’s River, Longford River,  R Ash and the many lakes which hold water in the lands surrounding the rivers. 
  2.                The rivers to the west of the catchment are all important chalk streams draining the Chilterns. The same chalk aquifer provides much of the water for consumption to Affinity Water, the supply company, and to Thames Water which has responsibility for waste water and sewage.
  3.                The Grand Union Canal runs into and out of the rivers Bulbourne, Gade and Colne and the whole system is a tributary of the River Thames.
  4.                Membership of the Consultative is open and presently it represents about forty angling clubs with local water holdings with a combined individual membership in the regions of 50,000.  Many Londoners use the Colne Valley as their local wild place for angling, walking, sailing, boating, running and cycling with good communication links to and from the city.
  5.                The Consultative works in partnership with many stakeholders; the individual river groups, Herts & Middlesex Wildlife Trust, London Wildlife Trust, Colne Valley Regional Park, The Environment Agency, TW and AW, Angling Trust, Fish Legal, Wild Trout Trust and many others.  On its website it provides a reporting app for pollutions, non native invasive species and riverfly monitoring.  The Pollution app has now been developed for Angling Trust and will shorty go live and national as a service to the protection of fisheries across the country.  


What are the best indicators for river water quality that could be used as targets being developed under the Environment Bill?

  1. Regular volunteer river fly monitoring supported by the Environment Agency and the Natural History Museum for necessary finance for training and equipment (EA) and archiving of records (NHM) in a national database accessible to all.  You have a detailed and extensive submission on this topic from my colleague Rod Cutler.


How could drainage and sewage management plans, introduced by the Environment Bill, play a role in reduced sewer discharges?

  1. Locally water companies have been trying to finance the investment in STWs and sewage systems to remove the problem of raw sewage discharges and have published those plans in the WRMPs over a number of cycles but consistently their investment plans have been thwarted at the consultation stage by Ofwat, whose only concern appears to be the price of water to the consumer.
  2. In a period of increasingly rapid climate change and likely consequent water shortages the consumer price is necessarily going to become a major contributor to reducing demand for water and Watercos need to be able to invest in their assets now in order to limit ecological damage and maximise revenue retention to finance water acquisition plans which will inevitably include water transfers from areas of plenty to areas of unsatisfied demand and over abstraction.
  3. Drainage and sewage management plans should be an important key to permitting future housing development and investment is needed in modern sewage systems with adequate capacity for the projected population growth over the next century, to reduce the leakage from the system as well as make systems more resistant to ingress into the system of groundwater.  Poor and underinvested sewage systems both pollute the environment and to destroy it by drawing groundwater into the system and denying it to the environment and our rivers. It’s a double whammy without adequate investment and planning and Ofwat’s policy appears to fly in the face of governments stated policy of greening the environment.

How adequate are the monitoring and reporting requirements around water company discharges? How can technology improve and assist with transparency and enforcement?

  1. Monitoring and reporting of water company discharges were significantly damaged and weakened by the policy adopted under the Government of David Cameron, which destroyed the regional structure of the Environment Agency, removed regional oversight of the EA by RFERACs, lost a whole tier of senior, experienced and progressive management within the EA, destroyed the career path from local area officer, through a regional post to potentially being the head of a national department and introduced the policy of self monitoring for water companies and others under the Permitting scheme. 
  2. Companies regularly under report or conflate events into a single event so that they appear to be doing better than is the fact.
  3. The Permitting scheme would be a joke in a third world country but in the UK it is simply an insult to the intelligence of Parliament and the public. Check out the self monitoring terms offered to HS2 by the EA Permit (HS2 Tunnelling Permit EPR-QB3092NR) allowing discharges of waste water into the Rover Colne from the mining of a tunnel though the chalk aquifer which is the Chiltern Hills.  Such a risky procedure that the Government has given Affinity Water a guarantee against them losing asset values as a consequence of damage to an aquifer which is complex and only now beginning to be understood yet which will be drilling through twice for the HS2 Chiltern Tunnel.
  4. I have included our concerns here about the sloppy and unqualified wording used in such permits and the dangers to the environment such poor use of language can cause.
  5. { HS2 Tunnelling Permit EPR-QB3092NR Concerns
  6. Concerns:-
  7. 3.2.2. (b) where a non-hazardous pollutant is not controlled by an emission limit, to limit the input of such non-hazardous pollutants to groundwater so as to ensure that inputs do not cause pollution of groundwater. Surely any pollutant released into a water course causes a pollution? Hence this is a meaningless sentence, is it not?  The potential polluter is left to judge for themselves with no external monitoring of the site or process.
  8. 4.3.1 (a) any malfunction, breakdown or failure of equipment or techniques, accident, or emission of a substance not controlled by an emission limit which has caused, is causing or may cause significant pollution; and (“significant pollution” means a category 1 or category 2 incident indicated by the Common Incident Classification Scheme (CICS))
  9. 4.3.1 Any other significant adverse environmental effects……shall be notified to the EA as soon as reasonably practicable following detection.  There is no definition of “significant adverse environmental effects” or “reasonably practicable”. The potential polluter is again left as judge and jury to determine future action.
  10. 4.3.4 Where the operator proposes to make a change in the nature of the activity by increasing the concentration of, or the addition of, or allowing the introduction of, a substance to the activity to an extent that the operator considers could have a significant adverse environmental effect on the receiving waters, and the change is not permitted by emission limits specified within schedule 3 table S3.1 or the subject of an application for approval under the EP Regulations etc etc   The potential polluter is again left as judge and jury to determine future action.


  1. Schedule 1
  2. Table S1.2 Operating techniques
  3. Documentation OT1 – Method Statement Date received 05/01/2021
        1. PERMIT DATED                                    08/01/2021
  4. Does three days allow sufficient time to study the MS, raise and answer any concerns the MS presents, or were there no concerns about the MS as presented by the applicant?
  5. Schedule 3
  6. Suspended solids are at 180000mg per minute / 10800000mg per hour
  7. 10.8 Kilos per hour                                                                                                                259.2 kilos per day                                                                                                                         1814.4 kilos a week, every week while mining goes on,                                                             94348.8 kilos a year into our rivers. 
  8. That is 94 tonnes of waste matter dumped in a river each year and permitted by the Environment Agency.
  9. Local landowners are sometimes permitted to release 10mg/l for short periods
  10. It is unimaginable how much damage that will do and the EA has permitted it. It is frankly beyond belief that some called the Environment Agency can be so blind, or is it being bullied by the government which seems hel bent on securing something for the north.  Good luck with that then, because the south nmight just rise up in revolt ant the destruction we are now seeing
  11. All this waste at a pH 6 to 9 – the receiving water will never have a pH of 9 or 6 naturally and this input at pH 9 will have a significant impact on invert life.  The river runs at around 7.4, so the permit allows the killing of sensitive invertebrates
  12. Discharge consents for our local STW’s are below for comparison


  1. Maple Lodge
  1. Blackbirds
  1. Chesham
  1. Ammonia 
  1. 1 mg/l 
  1. 1.40 mg/l 
  1. 2 mg/l 
  1. Suspended Solids 
  1. 15 mg/l
  1. 10 mg/l
  1. 20 mg/l
  1. Bio-logical oxygen demand
  1. 15 mg/l
  1. 7 mg/l 
  1. 7 mg/l
  1. Chemical oxygen demand
  1. 125 mg/l
  1. 125 mg/l 
  1. n/a
  1. Phosphorous 
  1. 1 mg/l
  1. 1 mg/l
  1. 2 mg/l
  1. }
  2. If this was your water supply and your river would you be happy with this Permit being issued, and subject to self-monitoring and reporting from a series of companies which have shown no concern whatever for the environment while driving HS2 through AONBs, SSSIs and local beauty spots?
  3. Now I see the EA has resorted to Citizens Juries to assist in policy development, using people with limited knowledge to do the job of the previously well qualified and experienced members of RFERACs.  It is great to see progress being made in the face of government inaction and previously destructive policies. 
  4. As an example of the failure of permitting and self reporting Natural Resources Wales has recently (202101) issued a warning to the owners of a landfill site after it identified non-compliance issues around its environmental permit in the wake of a fire at the site last year.  When did we start to trust the fox having a seat in the chicken coop?

What is the impact of plastic pollution and other materials on drainage and water quality in rivers and what should be done to mitigate it?

  1. We see it but have no measure of its consequences at the present time. Obviously it is not good for the environment, but to assess true damage probably requires an extensive research project to be undertaken and long term funding.

How can consumers be persuaded to change their behaviour to minimise pollution?

  1. Consult social scientists on consumer motivation for change and listen to specialists. Based on their advice and a good understanding of the target audience profile commission a campaign to change public perceptions of need and value.  It is a social science issue and advertising/promotions/campaigning could and would change those opinions positively. 

What is the required investment level needed to minimise storm overflows vs the scope for sustainable drainage and nature-based solutions?

  1. We are not qualified to answer this question. The answer will be dependent on the local water company and the situation and standard of the existing sewage system under the present AMP.


How effective are the planning policy and standards around sustainable drainage systems to reduce urban diffuse pollution in England?

  1. No detailed knowledge but we are unaware of planning being an issue in improving the sewage system.
  2. The Building Regulations need to be updated to include SUDS as a basic requirement in any future development.  One has to ask why has this not been done before, other than to protect the profits of developers and to keep house prices down.

Should local authorities and highways agencies be given a duty to prevent pollution to watercourses without prior treatment?

  1. Road run off direct to water courses is a prime source of micro-plastics from tyre degradation entering the aquatic environment. Requiring LAs and HAs to cleanse run off before it goes into water courses would be a massive step in reducing the most damaging of micro plastics in the wider environment. 
  2. BTW there is little point in providing a reference that the great majority of responders will and cannot access. The cost for an NGO to access ENDS is more than £1500 a year. 5 ENDS Report, 2020. Regulators ignoring horrific and poisonous road run off say EA insiders. I am sure it would make very interesting reading but our opinion is based on the M25 and M1 both running through our catchment and both depositing huge amounts of road run off into our rivers.  It was brought to my attention when discussing chemicals in river courses with an analyst who had worked on a river in Canada where all the salmon were dying, for no apparent reason until he tested the run off and found the micro-plastics and rubber from tyre degradation contained a toxic poison, which was killing the fish and the lumber lorries ran that road while felling and cutting was in progress at the same time as the salmon ran the river.

How effective is Ofwat’s remit and regulation of water companies? Does it facilitate sufficient investment in improvements to water quality, including sustainable drainage systems and nature-based solutions such as constructed wetlands?

  1. Ofwat has been a constant source of concern to conservation and river stakeholders as well as to the water companies in always demanding reductions to investment plans for assets, to protect consumers from paying a realistic and higher price for water.  The price our rivers and wetlands is paying is beyond imagination when you analyse the chemical load in most rivers which run through urban areas.  The main river Colne can carry a load of forty or fifty separate chemicals, many in very small amounts but also many of which are highly toxic.  We are presently working with scientists to get a useable list and to find the sources of the ongoing pollutions.

Is adequate investment being made in adapting water treatment systems to future climate change?

  1. No because even though our local water companies keep putting asset improvement into their planning cycle Ofwat keeps insisting such plans are reduced or removed to protect consumers from price increases.  Consumers of the environment need protecting from Ofwat!

How could the designation of inland bathing waters by water companies affect the costs of achieving the associated water quality standards?

  1. There are fewer than 120 wild swimming clubs in England, Wales and Scotland, the largest claims a membership of 25,000 (it’s free to join) and many of these are actually sea swimming clubs.  Is the demand for freshwater swimming such as to impose costs on water companies to facilitate wild open freshwater swimming when investment has been delayed for at least the last three AMP cycles for most water companies in necessary asset improvements to improve the wider environment? 


  1. Submission By Colne Valley Fisheries Consultative                                                   Michael Heylin OBE                                                                                                    Secretary                                         


January 2021