Principle External Relations Officer

Andy Turton,

Principle External Relations Officer

Environment Agency

Kings Meadow House,

Kings Meadow Road,

Reading, RG1 8DQ

14 May 2009

Dear Andy Turton,

I am responding to theWater for life and livelihoods consultation on the Draft River Basin Management Plan of the Thames River Basin District.The proposition seems be that consumers pay more for less water and that the environment continues to be suffer. You are offering Hertfordshire higher bills and low environmental benefits.

The Chalk Rivers of Hertfordshire

The Chalk Rivers of Hertfordshire are uniquely pure and sustain many rare species. They form an important amenity for the people of Hertfordshire in a heavily populated county. Sadly these rivers are polluted, over-abstracted and face the threat of over-development.

Modesty of Objectives

I find the objective for improvement of progress towards achieving good ecological status and good ecological potential for the rivers of the Upper Lee valley unacceptable. The objective of no improvement on the 19km river length of good status for 2015 for this important river habitatis no objective at all. Many other catchment areas in the ThamesRiver Basin (such as the Wey, the Medway and the Loddon) are expected to achieve significant improvements in the length of the river which achieves good ecological and good ecological potential status[1]. This lack of ambition is completely unacceptable.

Poverty of Response

The measures designed to achieve progress towards the goal of improving the rivers include relocating pumping stations at Fulling Mill and Whitehall (to reduce abstraction pressures on the rivers Mimram and Beane respectively) and reducing household consumption. I am concerned that neither of these solutionsrepresent a long term solution. Ifear that if the whole of the UpperLeeValleyis over-licensed or over-abstracted, reducing abstractions in one area although providing much needed alleviation to one area, will eventually cause a worsening of the situation elsewhere. Furthermore the Draft River Basin Management Plan of the Thames River Basin District[2] says the population of the Thames River Basin is forecast to grow by 0.7%; yet the East of England Regional Spatial Strategy plans an increase in housing in Hertfordshire of 42% over the next 20 years[3]; clearly thefigure mentioned in the Draft River Basin Management Plan is inaccurate as concerns this county.

It is clear that the Draft River Basin Management Plan of the Thames River Basin Districthas no over-all long term strategy for the rivers and the people of the UpperLeeValleyand I find this unacceptable.

Progress

Currently water for Stevenage is abstracted from the surrounding rivers and then sewage from this town flows to the Rye Meads sewage treatment works south of Hertford, and then out into the lower Lee resulting in a net export of water from the catchment area. I support the River Beane Restoration Association’s recommendation that consideration be given to some local recycle of this used water back into the local rivers. A degree of sewage treatment could occur in the local area and the treated water returned to the River Beane system to bolster flows. I suggest that the Rye Meads Water Cycle Strategy should consider local treatment options. I note that there is a precedent in that the upper River Lee flow at Luton is totally sustained in summer months by treated water from the East Hyde sewage treatment works.

It seems to me that in order to bring all water bodies up to good ecological status or good ecological potentialadditional water supplies must be created through the formation of a long term strategy for Hertfordshire which will take into account the needs of both the people and the environment. Although I welcome the investment into Abingdon reservoir and the strategic water transfers Three Valleys Water company intends[4], I believe the situation requires more.

Costs

The Draft River Basin Management Plan of the Thames River Basin Districtmentions plans for free household water meters[5] yet does not explain where the money to pay for these will come from.

I am concerned that the seasonal tariffs referred to in the Draft River Basin Management Plan of the Thames River Basin District consultation document[6] will mean large increases in water bills for many of my constituents, and that coupled with the requirements upon them to reduce their overall consumption will mean they will end up paying more for less.

Community Identity

I would like to draw your attention to the work the Chilterns Conservation Board, together with the five town and parish councils of Amersham, Chipperfield, Little Missenden, Sacombe and Welwyn, have done to highlight the important part that rivers play in the identity of local communities. Their importance can be summed up by Welwyn Parish Council’s response when the local water company suggested rivers were a low priority:

In this Parish… a flowing river (the River Mimram) is a key element of our lives and is part of our sense of “place”, even appearing on our coat of arms.[7]

The chalk rivers of Hertfordshire play a central role in the life and livelihoods of the people of North East Hertfordshire and much more must be done to protect this precious natural resource.

I would welcome your assurance that you will take a full account of my views.

Yours sincerely,

Oliver Heald MP

[1]Water for life and livelihoods consultation on the Draft River Basin Management Plan of the Thames River Basin District (December 2008 Corrected – February 2009), page 36, 6.6 Loddon catchment: “Currently 30 km of river length (11% of waterbodies) in this catchment are achieving good ecological status/potential. We are proposing that by 2015 this will improve to 79 km, but with additional local input this could increase.” I note that this is an improvement of 263%.

[2]Water for life and livelihoods consultation on the Draft River Basin Management Plan of the Thames River Basin District (December 2008 Corrected – February 2009), page 7: “The population is forecast to grow by 0.7% between 2002 and 2015, more than the average for all River Basin Districts.”

[3]East of England Plan: The Revision to the Regional Spatial Strategy for the East of England (May 2008), page 31: Minimum Dwelling Provision still to build by 2021 is 65,720.

[4] Three Valleys Water: Draft Water Resources management Plan; Summary of our Plan (April 2008), page 37

[5]Water for life and livelihoods consultation on the Draft River Basin Management Plan of the Thames River Basin District (December 2008 Corrected – February 2009), page 45

[6]Water for life and livelihoods consultation on the Draft River Basin Management Plan of the Thames River Basin District (December 2008 Corrected – February 2009), page 45

[7] Three Valleys Water Revised Draft Water Resources Management Plan: Statement of Response (January 2009) Summary of Representations, page 38section 4.27: "The apparent low value placed on river levels is a distortion, which has been arrived at because of the water company's many urban customers who never see a river from one day to the next. In this Parish, by contrast, a flowing river (the River Mimram) is a key element of our lives and is part of our sense of "place", even appearing on our coat of arms."