Whitewater Valley Preservation Society                                          WQR0018


Written evidence submitted by John Fleming, (committee member, Whitewater Valley Preservation Society)


Whitewater Valley Preservation Society (WVPS) exists to protect the River Whitewater and its valley.  Our mission is to defend the valley from inappropriate development and its resultant impact on the river.  The Society was formed in 1980 and has some 260 members.  Our aim is to fight unacceptable development proposals, which pose a significant threat to the health of the river and the landscape of its valley. Threats to the River Whitewater and its valley are ever more present today.

Our reason for submitting evidence is that since 2009, the river has been designated by the Environment Agency as Failing to meet Good Ecological Status under the Water Framework Directive.  The Society is concerned that such actions as proposed in the answers to your questions are not being supported by the EA, leaving the river still failing.


Question 1

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

The committee should appreciate that to answer this question, it is essential to define the type of water body being assessed.

WVPS is interested in chalk streams, of which 85% of all those in the world are in the United Kingdom.  They should be in pristine condition because of their special qualities.  The Society believes the methodology which we have successfully used during the past four years in the river Whitewater should be chosen by the committee for inclusion in the Environment Bill.

The reasons for adopting the “River Fly Census” are threefold:

The cost of the chosen method is clearly an issue, and if trained laymen carry out the sampling for river fly surveys this will reduce the overall cost.  The total cost of 3 years of surveys at 6 locations, twice yearly, with professional data collection as well as professional analysis cost was approximately £9,000.  Given much larger quantities as well as lay sampling this figure could potentially be reduced.

The organisation responsible for the development of river fly surveys is Salmon & Trout Conservation UK (S&TC) who have supported WVPS in carrying out their surveys, and have been developing the methodology during the past 6 years and have published much data which is readily available in the public domain.

The following describes the process used, the type of output and the measures used as targets, which have evolved from studies of many chalk streams, setting the standard for a water body meeting or exceeding Good Ecological Status.

WVPS commissioned a River Fly Census over three years from S&TC to gauge the health of the river Whitewater, a north flowing salmonoid chalk stream in Hampshire, which the EA lists as failing under the WFD for fish, but which WVPS believes has wider problems.

The basis of the River Fly Census is that “River flies matter:  they and other invertebrates are excellent indicators of water quality, in that they spend most, sometimes all, of their life in water; and they are vital base components of the aquatic food chain. They are leading indicators of ecological distress. Salmon & Trout Conservation UK set aims for their riverfly census which are:  to provide a biological picture of the water quality in a river from which they could gauge the river’s ecological health; highlight any problems the river might be facing; and take a first step towards identifying solutions to those problems.”

S&TC’s approach is to use survey results to tackle problems identified in our rivers.  They have a five-point plan of action involving working with the EA, but also challenging them where necessary, especially over the urgent need to identify and regulate polluters. Where appropriate they use chemical sampling to zero in on the causes of water quality problems;  they are researching how phosphate and sediment harm the early life stages of aquatic invertebrates using blue winged olives as the research species - a once common fly which is now in almost universal decline;  they work with the EA to seek ways to take full account of the impact of phosphate and sediment in particular in the official ecological classification of rivers;  they challenge the government and its agencies to tackle the sources of these and other stresses on River systems;  finally they are keen to extend the range of rivers as well as the life of the survey, all of which requires funding.

The method adopted is to collect invertebrate samples from the 5 selected sites in a river in both spring and autumn.  S&TC UK uses the same three minute kick sweep and one minute hand search sample protocol that the EA employs in its own invertebrate monitoring to aid compatibility where relevant.  In a 3 minute kick sweep sample, the river is typically sampled for 15 seconds at 12 points at the sample site to provide a habitat proportional range of sub-sample habitats. At each of these 12 points the sampler stands up-stream of a submerged net and gently kicks the river bed and sweeps through submerged or marginal vegetation using hands or feet.  The invertebrates wash into the net.  The samples are then taken from the river with the proportion of live animals recorded in situ, fixed in alcohol and sent to the laboratory for analysis by professional freshwater biologists at Aquascience Consultancy Ltd.  They use cutting edge biometric techniques to produce detailed ecological information for each site.  This species level approach is a much more powerful tool than traditional family level analysis to highlight the pollution threats to our rivers.

Comparing the results of the National 2015 Riverfly Census, it is apparent that the Water Framework Directive measure of water quality struggles to capture the often combined impact that nutrients, sediment and organic enrichment are having on the invertebrate life in our rivers.  This seems especially true of chalk streams as well as of some other rivers across the country.

The S&TC analysis is performed at species level providing much higher resolution than family level data, requiring a high level of expertise.

The difference between species and family level analysis is akin to the resolution of a microscope compared to a magnifying glass.  The species level analysis tells us more about the overall health of a river including the subtle early effects of decay.  For example, certain species of river flies such as the mayfly (Ephemera danica) or the large dark olive (Baetis rhodani) are more tolerant of siltation than the blue winged olive (Serratella ignita) or Southern Ireland blue (Baetis niger).  So merely counting the number of olive nymphs will not tell you much about the impact of siltation.  The same is true of other forms of stress.

The S&TC analysis derives 10 measures of the ecological status of each sample site from the site’s species-level community fingerprint.  There are six traditional measures and four biometric measures.

The six “traditional numeric measures” which include species richness (the number of species) and abundance (number) provide variable measures of ecological condition and broad-brush water quality.  These are the Biological Monitoring Working Party (BWMP) score, Average Score Per Taxon (ASPT), species richness (R), Ephemeroptera-Plecoptera-Trichoptera (EPT) richness, Community Conservation Index (CCI) and total invertebrate abundance.  Further information on these is available on request.

The four biometric measures provide a fingerprint of the river’s ecology in terms of the impact of four measures of environmental stress: Nutrient pollution (Total Reactive Phosphorus Index or TRPI); Organic pollution (Saprobic Index or SI) from, for example, slurry; Sedimentation (Pressure Sensitive Index or PSI) from, for example, agricultural runoff; River flow (Lotic Invertebrate Index for flow evaluation or LIFE) from, for example, water abstraction.

Different species of aquatic invertebrates have different tolerances to these four stress metrics.  So, qualifying (and quantifying) the presence, absence and number of a particular species and then comparing with four stress indices creates a biometric fingerprint of the river sample point. These indices correlate closely with chemical analysis results.  For example, the high levels of P (phosphate) detected in chemical sampling on the Upper Itchen correlate with the biometric results from the same site.

Thus, from an analysis of the richness and abundance of various species in the samples, the ecological state of the river can be accurately benchmarked.


Question 3

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

WVPS interprets this reference to water company discharges from those water companies which also have responsibility for sewage networks.  This is Thames Water for the river Whitewater in North East Hampshire has its source in the north Hampshire downs and flows to its junction with the river Blackwater and eventually the river Thames. 

The current situation, whereby permitted sewage discharges under certain circumstances take place without effective control or monitoring, is unacceptable.  Substantial investment is required to improve efficacy of current water treatment plants to improve cleaning of the waste-water before release into rivers.  We should stop being so accepting of the discharges caused by severe rainfall which regularly overwhelms the sewage network and turning a blind eye to the resulting pollution.  No water company self-reports these incidents and that is accepted by the EA: being unreported means un-measured, so they are ignored, even though climate change suggests incidents are likely to be increasing.

All abstracting water companies carry out continuous chemical analysis from their sources, but this is not shared.  That data should be made available to all river basin management plans.  This use of water company data would provide a dramatic increase to the EA test level which over the past 5 years appears to have been only 16 tests a month over 1000 points.  Much more and regular testing is needed.  Otherwise serious or persistent pollution incidents are missed, as in many cases they are only identifiable in the water for a short time, but are nevertheless damaging.

Identifying clearly the sources or potential sources of pollution is the sine qua non.

This is a complex issue and the status quo appears to ignore the fact that in water bodies 97% are affected by nitrates, 40% by metals, 16% by pesticides and 5% by phosphates and that much of that chemical pollution emerges from water companies.  Since WRMPs are closely defined by DEFRA, the EA and others, it is hard to understand why concerns regarding water companies' chemical outputs cannot be tackled more immediately.  What undermines the EA's chemicals strategy is that whatever statements are made, including for example "only protecting ground water where chemical contamination compromises its use as drinking water", the final word states that only if a sustainable cost-benefit solution can be found will anything be done.

WVPS believes that abstracting water companies, such as SE Water in Hampshire, could make a significant contribution by the regular provision of data that they already collect.


Question 4

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?              

We have fines for failure to pick up dog faeces, we should have fines for plastic littering and more environmental taxes for unrecyclable plastics.

Also education.  Water bills should make it very clear and be very prominent in advertising what cannot be put down loos.  Regular analysis and publication of findings in sewage output should be clearly reported on bills when they are sent to customers and also sent to parish and town councils for local publicity.


Question 6

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

Thames Water refuses to provide information on costs such as sleeving sewage pipes in high water table areas to prevent ground water ingress.


Question 8

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

We presume this refers to pollution such as run-off from roads.  On this basis, yes.

On new housing developments and potentially also during planning and building regulation stages for extensions and modifications, Local Authorities have the ability to design out pollution risk or at the very least lessen it.


Question 9

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

WVPS has participated as a member of an Environmental Scrutiny Group in the preparation of two WRMPs for SE Water.

Whilst the company has endeavoured to enable such participation it is a complex and time consuming role for attendees and input from other statutory consultees can over-ride concerns on such issues as environmental improvements.  However participation by SE Water in funding river works is welcome and more would be better!

Demand forecasts in the light of possible climate change impact should be more restrained to avoid unnecessary over-abstraction and consequent damage to the environment.  The move in the latest WRMPs to Regional consideration has yet to prove its efficacy.

Specifically, greater efforts to reduce leakage and cessation of abstraction where harm is identified and agreed are the two issues which tend to have a lower priority than they should, we believe as a result of OFWAT input.


Question 10

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

Domestic water harvesting should be retro-fitted and compulsory at a substantial level of harvesting (not just one single water butt) for all new housing. 

It is time to re-assess the volume of drinking quality water which is delivered to houses but not used for drinking by limiting drinking quality water to that needed. 


Further consideration on water quality.

The most significant factor which affects water quality and river ecology is the lack of reliable quantity of water and flow in the rivers.  For example, ranunculus is a plant which is important to so much ecology in the river, and it is only present where there is sufficient flow.  The overwhelming of the ecology by silt is a further result of lack of flow.  Pollution is of course proportionally greater when flow levels are low – a good flow can dilute the impact of pollutants entering the river.  Therefore areas of the country designated as water-stressed (effectively struggling to meet consumer demand for water) is consistently being further damaged by planning approvals for further house building in water stressed areas.

A planning system which grants planning permission in water-stressed areas requires political support in an environment bill to enable such plans to be rejected on the grounds that this will further damage an already water-stressed and degraded environment.

There should be much better and more extensive insistence of water harvesting for non drinking purposes.  Our local authority requires one single water butt per dwelling as its water saving requirement - this is hopelessly inadequate.  Building regulations should be greatly beefed up to maximise water harvesting.  We need to monitor statistics which identify the potential demand reduction effect of water harvesting in varying percentages of new housing. 

Planning and building regulations should equip local planning authorities to refuse planning permission in water-stressed areas forthwith.  It is significant that the current planning white paper identifies a high percentage of development directed towards areas already identified as under water stress.  If we are not all to waste our time worrying about and trying to rectify causes of damage to our ecology, this legislation needs to take account of water supply issues to protect the environment in areas already identified as water-stressed.

Apart from strict monitoring and license review, the onus must be placed on the water abstracting companies to meet reasonable demands and

In water-stressed areas where abstraction is clearly identified as damaging the environment and water bodies, action to address the harm and to find alternative sources must be more immediate than under the present system



February 2021