RE: Inquiry in the Regulation of the Water Industry Written Evidence.

1. The Amwell Magna Fishery is the oldest fly fishing club in the country still fishing the same stretch of river. We are owners of riparian and fishing rights in a 2.5-mile stretch of the River Lee in the county of Hertfordshire. 

2. The fishery is home not only to the last remaining population of breeding wild brown trout in the River Lee between Hertford and the Thames but it also provides sanctuary for a number of other species scheduled under the terms of the Wildlife and Countryside Act 1981.

Executive Summary.

3. The regulatory system which oversees the environmental and economic impact of the water industry in England has failed.

4. It has failed not only our rivers and lakes but it has also failed the consumer.

5. In 2012 36% of all water bodies in England were recorded as reaching good ecological status. Today that figure stands at just 14% and as reported by the Environment Agency (EA), one of the key drivers of that failure is the water industry.[1]

6. The EA’s recent report “The state of the environment: water resources,” has  highlighted that in 2014 the vast majority of the UK’s chalk streams, 77% did not meet good ecological status. That report continues “When a sample of these streams were tested further, abstraction was found to be the primary contributing factor in around a quarter of cases.”[2]

7. Further it would appear that for the second year running Thames Water (TW) will be subject to an automatic fine for failure to meet their agreed water supply leakage target. An indication that the current system of penalties and enforcement is not encouraging “Responsible behaviour”.[3]

8. Such has been the extent of this regulatory failure that London is now listed as one of the 11 cities in the world most likely to run out of drinking water.[4] TW currently forecast that the company will be faced with a supply deficit from 2019 onwards.[5] Due to a chronic and historical lack of investment in infrastructure rectifying this issue will most likely lead to large increases in household water bills.

9. As of today there are rivers flowing through suburban parks in north London, rivers where children frequently play, contaminated with human waste.[6]

Background.

10. The regulatory system which oversees the environmental and economic impact of the water industry, especially in the South East Region of England has failed.

11. It has failed not only our rivers and lakes but it has also failed the consumer.

12. After almost three decades of regulatory oversight it is nigh impossible to find a single river in the South East Region of England that is not suffering from environmental damage directly brought about by the impact of the water industry.

13. In 2012 36% of all water bodies in England were reported as reaching good ecological status. Today that figure stands at just 14% and as reported by the EA one of the key drivers of that failure is the water industry.

14. The EA’s recent report “The state of the environment: water resources,” highlights that in 2014 the vast majority of the UK’s chalk streams, 77% did not meet good ecological status. That report continues, “When a sample of these streams were tested further, abstraction was found to be the primary contributing factor in around a quarter of cases.”

15. There are estimated to be a total of 220 chalk streams in the world of which 80% occur in the UK. These are unique, globally precious, pristine aquatic environments which as a nation we should be cherishing and protecting with the utmost vigour and zest and yet, directly as a result of the actions of the water industry combined with the accompanying regulatory failure, the vast majority of these rivers fail to achieve good ecological status.

16. In 2017 TW were subject to an automatic fine of £8,550,000, imposed by the Water Services Regulation Authority (Ofwat), for failing to meet agreed leakage targets.

17. During the preceding 12 months TW had lost 26% of their total water supply through network leakage. That is 26% of all of the water the company had abstracted from our rivers and lakes, equating to some 247,105,000,000 billion litres of water lost from the environment. That is water that could and should have remained in our rivers continuing to nurture and sustain those globally precious ecosystems that surround our capital city, our chalk streams.

18. And yet despite the fine imposed by Ofwat it has recently been reported that the company has missed its leakage target for the second year running. An indication that the current system of penalties and enforcement is not encouraging the anticipated “Responsible behaviour”.[7]

19. Added to this situation is the recent announcement that London is now one of the 11 cities in the world most likely to run out of drinking water.[8] TW is currently forecasting that the company will be operating with a deficit of drinking water from 2019 onwards.[9]

20. Contributing to this situation would appear to be the appalling lack of investment in infrastructure, water distribution networks and the prudent planning and delivery of a secure, long-term supply of water for the people of London and the South East. It has become increasingly apparent that the regulator has failed to identify and properly act upon that trend and to have done so in a timely and appropriate manner. The outcome of this impossible situation is most likely that consumers in the South East will imminently be faced with sharp and abrupt increases in water bills to secure the underlying investment needed to develop the region’s future infrastructure.

21. Sewage and other waste misconnections are one of the great overlooked areas of the impact of the water industry that is causing considerable environmental damage to our rivers and waterways. By way of example there is not a single river flowing through north London that is currently not contaminated by raw sewage. These are rivers which flow through suburban parks, flow through residential neighbourhoods and most shockingly of all, rivers where children frequently play, yet in the 21st century, in one of the world’s greatest cities, these rivers are contaminated with human waste.

22. TW’s existing agreement with the EA stipulates that the company may investigate a maximum of 40 of these misconnections per year. That is against a background where as part of their AMP5 investigations TW found that potentially 3.35% of properties  have a sewage and or waste misconnection. [10] That this situation exists is a national scandal.

Recommendations.

1. We would call upon the Secretary of State to establish a steering group, comprised of board level representatives from the EA and Ofwat, all of the water companies operating in the South East Region of England, local communities and environmental groups. And that they should be directed, as a matter of some urgency, to produce and oversee the delivery of a strategy that meets the region’s future water storage and supply needs including any future reservoir requirements.

2. We would recommend that any strategy developed as a result of the above should also include a timetable for the urgent rollback and cession of any unsustainable abstraction current taking place that impacts upon rivers in the South East. Any potential deficiency in supply arising as a result of this measure should be factored into the calculations used in estimating the region’s future water storage and supply needs. Both of these measures should be delivered simultaneously.

3. A joint Board subcommittee should be formed comprised of board members from both the EA and Ofwat with a clear, shared objective of delivering a rapid and permanent end to all environmental impact arising from the actions of the water industry.

Yours sincerely,

Chairman for and on behalf of the

Amwell Magna Fishery.