Alison Davis                            WQR0039

Written evidence from Alison Davis


Parkwood Trout Farm


Water Quality in U.K. Rivers and Chalk Streams.




My husband and I run the last remaining trout farm in Kent, and, sadly, the Angling Trust have recently advised that we have now been forced to become the most defensive Fishery in the country.


Our farm is a small rural family business, originally started in the 1970’s by my father-in-law, Colin Davis.

A large part of our business involves raising brown trout for stocking into rivers throughout the South East of England, which is an important part of the ecological balance and biodiversity in our waterways.


We have up to 40,000 brown & rainbow trout in our waters, spread over 10 stock pools and 2 fishing lakes, all fed by the small Goddington Chalk Stream at the base of the North Downs.

These trout are highly sensitive to pollution in the water environment & it is imperative that they are raised in clean, unpolluted water, as they are all ultimately for human consumption.


The Goddington Chalk Stream is also a tributary water of the River Len, which then flows on to the Moat & Great Water at Leeds Castle Estate. Waters here host an annual triathlon event each summer, with hundreds of swimmers in the waters, so good water quality in this area is extremely important.


The reason I feel compelled to comment here is that the last 5 years have been the most challenging of our farm’s 40-plus years history, due solely to the extreme & constant pressure from multiple ill-informed planning applications in the surrounding local area.


Sewage Pollution & the Planning System.


As there is no access to mains drainage in this rural area, these planning applications all involved the use of biological sewage treatment plants. All proposing to discharge directly into the Goddington Chalk Stream itself, without any understanding of just how small this chalk stream is, how low the flow is, or how damaging the resultant discharges would be to our fish stocks immediately downstream.

(The stream is actually only 3 inches deep in this area and does not have sufficient water flow to be able to disperse sewage output here at all.)


The planning system should be more robust, as at present, it is not fit for purpose in relation to chalk stream watercourses & sewage disposal.


1).   There should be an agreed high level of comprehension from architects and developers in relation to when or if it is safe to be able to use chalk streams for disposing of human sewage at all, as currently there is no understanding of the importance of the water environment or consideration of safe water flows whatsoever.


2).    Containment systems for sewage should be re-introduced as a condition of planning permission for houses close to small chalk streams, to protect the integrity of these important watercourses from further damage into the future. A safety zone should be identified around the course of each stream.


3).   There is also a severe lack of informed expertise to assist local planning officers to make an informed decision on whether it is appropriate to grant planning permission for household sewage treatment plants or not.

At present, it falls to affected bodies such as ourselves, the Angling Trust or the CPRE and the Local Wildlife Trusts to advise officers of the risk & this vitally important part of the planning process is typically totally overlooked.


The water environment is highly complex & widely misunderstood & it is unrealistic to expect planning officers to have this specialist knowledge.

They should be supported by a robust approach from the Environment Agency (with additional funding, as necessary), with clear guidelines prohibiting the use of small chalk streams for sewage disposal at all and giving strict protocol for proof of a minimum required safeannual water flow in larger water bodies.


4.)    The planning process should also take into consideration any treatment plants already discharging into the water body in the surrounding area, as these discharges are cumulative. At present, this is totally lacking & overlooked.


Sewage management plans need to identify all existing biological treatment plants discharging in the area, to identify the true extent of sewage discharges into the water and implement a strict code of practice for their safe continued operation.

Each plant should be inspected & certified by the Environment Agency annually, to ensure that their discharges are within agreed limits. At present, the onus of responsibility is on the individual householder, so discharges are left unchecked.

These plants also have a limited lifespan & are less effective at treating the waste water over time. These changes in efficiency leads to increased pollution in output.

The Environment Bill should allocate additional funding to the Environment Agency to enable the Agency to play their vital role in reducing sewer discharges.


5).   These regulations should apply to all new planning applications near chalk streams, not just those of over 10 dwellings, as I believe is the case at present.


This is important, as the most damaging of all the cases we had to oppose was for only 2 large houses, crucially located immediately upstream from our first stock pond and alongside the Goddington Chalk Stream itself.

The resultant construction runoff, diffuse pollution and sewage output would have polluted our entire farm network & totally destroyed our aquatics business, which is the only remaining one of its’ kind in Kent.

This is hardly ‘sustainable development’ by any definition, as is apparently the stated aim in the 21st century.


6).  There should be an introduction of a total exclusion zone upstream from aquatics businesses such as our own, preventing any new biological sewage treatment discharges into the supplying watercourse for up to 1 mile upstream. Any developments beyond this zone should include remedial reed beds for additional protection to the watercourse.


7).   The Environment Agency should also be instructed to introduce regulations to prevent owners of swimming pools discharging chlorinated swimming pool waters into the natural environment & nearby chalk streams & water bodies. The chlorine bleach is highly toxic to all aquatic life & would totally destroy the entire ecosystem of any chalk stream used in this way.

At present, the Environment Agency will only respond after a pollution event has occurred, which is, of course, totally ineffective & too late to protect the environment at all.

What a woefully inadequate state of affairs.


8).   The Environment Agency need additional funding to be able to regain their role as an effective environmental body. Recent budget cuts have diminished their ability to protect the water environment in many respects, which is resulting in the current significant pollution problems in our waters. This is set to continue & increase into the future unless radical action is taken.




Indicators for River Water Quality.


The Environment Bill needs to recognise the vital role that various fly life play in the health of our rivers and streams, and in the ecosystems of our natural environment as a whole.

Most of these insects have a larval stage that is water sited and this is the vital part of the life cycle that is relevant here.


The Wildlife Trusts have advised that there has been a sudden, significant crash in populations of multiple varieties of fly life in the U.K. in recent years.


This crash in numbers is directly related to increased levels of pollution now found in our rivers and streams, as their larval stages of development are adversely affected by sewage pollution in the water environment, leading to massive population crashes.


Fly life is essential in a healthy freshwater ecosystem, as it is the food base needed to support a healthy environmental food chain for all fish and freshwater invertebrates. Biodiversity relies on this fundamental beginning.


Again, I believe that the Environment Agency are no longer able to fund adequate assessments of these ecosystems, due to extreme budget cuts & will only become involved after pollution incidents have occurred, which is, of course, far too late.

A preventative approach is vital to adopt going forward in order to make any progress at all.


Biodiversity will continue to decline without significant change.


These vital indicators need to be identified & used as targets in relation to the Environment Bill and further funding made available for the Environment Agency to be able to firstly assess the current situation & then have the power to be able to improve the water quality in our freshwater habitats in order to begin the reverse of this decline.


I hope that our direct experiences of the shortcomings of the planning system and the associated decline in the health of our chalk streams & rivers is helpful to the Committee & will enable the inquiry to pinpoint the areas needed for immediate action and improvement in order to attempt to achieve the environmental targets in place.


February 2021