Summary of RevIvel response to AFFINITY WATERS Water Resources Management Plan Consultation February 2023.
Statement from Affinity Water:
Our WRMP aims to address a significant future shortfall in water resources in our supply
Population growth, climate change and the demand for water are putting significant
pressure on the local environment and water resources in Affinity Water’s supply area.
Without action – the area Affinity Water supplies faces a possible shortfall of 449 million
litres a day by 2050. We want to hear what customers and stakeholders think about our
draft plan to help us shape our final plan which we will publish in Autumn 2023.
Every five years, Affinity Water produces a WRMP which addresses these future challenges
and provides a roadmap for a reliable, resilient, sustainable, efficient and affordable water
supply to customers between 2025 and 2075, whilst taking care of the local environment.
The actions include:
reducing customer demand,
driving leakage down further than ever before,
significant investment in new infrastructure for new sources of water
working across the water industry to plan and share resources regionally.
The plan will also make the regions water supplies more resilient to droughts, which are
becoming more frequent due to climate change.
Have we balanced the main factors relating to Environmental Destination in our
RevIvel fully supports the need for prioritisation where abstraction should be reduced, with
a clear focus on head waters and iconic tributaries of chalk streams. According to CaBA
chalk streams should see total abstraction reduced to achieve A10%R (10 % of catchment
recharge). We support the focus on the headwater where abstraction reductions will
provide whole river benefit by increasing biodiversity and enhancing recreational
RevIvel are concerned about the transfer of water from Grafham Water via Sundon TP to
facilitate planned licence reductions in WRSE region (Chilterns chalk streams) in AMP 8.
RevIvel propose that it would be better that this water is used within the Upper Bedford
Ouse catchment where it will be available for future abstraction and reuse as per the John
Lawson solution for the benefit of the River Ivel. The Lawson report proposes significant reduction in abstraction at the headwaters of the Ivel allowing chalk water to flow down the
Ivel, joining the Ouse at Tempsford and later being taken off at Offord for Grafham Water.
Then according to Anglia Water /Affinity Water agreements, water is then transferred south
to Sundon TP and onto the North Herts area. This would follow the principles of Chalk
Streams First and the recycling of water back into the Upper Ouse catchment would benefit
the Ivel and Ouse and WRE overall. The Great Ouse Act (1961, amended 1971) was passed
in the 1960s to facilitate water transfer into the N Herts area, knowing that this area would
be subject to water stress in the future. We believe that Affinity is not using their allocation
from Grafham Water as originally intended. Can water from Grafham Water be better
utilised within the Upper Bedford Ouse catchment rather than being exported from the
There is a current desk-based feasibility study on the Upper Ivel to evaluate the likely
recover of downstream flows along the Ivel and beyond if borehole abstraction of chalk
water at Baldock/ Letchworth is significantly reduced. If this desk study (due in 2023) shows
the John Lawson solution to be workable then RevIvel propose a full or partial
implementation in AMP 8. Switching off the borehole pumps may be considered a PILOT
scheme and would benefit the Upper Bedford Ouse in the 2025-2029 timeframe. This would
demonstrate that Affinity and Anglian Water are committed to the Chalk Streams First
principle and prepared to follow up a favourable report with action rather than just further
rhetoric. Using the Ivel as pilot scheme would also provide both water companies with a
very positive PR win.
Environmental destination delivery should be delivered separately from demand
management and leakage management and should be accelerated. Failure to meet demand
or leakage targets should not be used as an excuse for the scaling down or slowing down of
environmental targets. The proposed timeline would see the death of many Chalk streams
and the further loss of genetically unique flora and fauna.
Does the adaptive plan support your main concerns.
Revivel support the concept of adaptive planning.
Some agile thinking and willingness to deviate when opportunities arise should be
considered. An example of this would be rapid adopting of the John Lawson proposal
following the outcome of the Ivel feasibility study.
RevIvel support the focus on water efficiency and leak reduction.
Environmental destination plans should not be linked in any way to the industry’s ability to
manage leaks or reduce per capita consumption.
We support metering in water stressed areas and are supportive of a tiered approach to
water tariffs above 110 litre / person/ day.
Which measures you consider are most likely to support management of demand
and should be considered for inclusion in our draft plan.
‘SOS ‘campaign is laudable but has failed to deliver the demand reductions needed in the
short and long term. More needs to be done.
Smart water meters in water stressed areas are key and should be installed ASAP.
Affinity Water should fully exploit the data available from the smart meters to communicate
with their customer base and encourage more responsible use.
National Housing Planning policy needs to focus on embedding water consumption targets
for new houses. Local government need to enforce/ regulate adoption.
Industry should be encouraged to manufacture water efficient toilets/ showers, baths etc.
Water Companies should be part of this process.
OFWAT should consider implementation of a tiered approach to domestic water tariffs
where usage above the sustainable 110 litres / capita / day is penalise
Your thoughts in relation to the SROs that we have identified.
The rainfall is greatest in the west and north of the country whilst the population growth is
primarily in south and east. Transfers across the country are essential and will lower the
burden on already water stressed areas.
RevIvel fully support the investment in new water sources provided that they do not cause
environmental degradation to the water bodies in question and that all possible measures
are taken to minimise the spread of harmful or invasive species.
We encourage adoption of all Strategic resource Options (SROs). We welcome the scheme
such as GUC and Minworth SRO which can elevate pressure on groundwater supplies and
will support urgently needed reduction in chalk stream abstraction in AMP8-9.
RevIvel are aware that in AMP 8 water will be brought in from WRE region to allow
reductions in chalk abstraction in the Chess and Misbourne catchments. We believe the
reductions in abstraction at the headwaters of both these rivers should be dealt with at a
local level by rolling the abstraction licences further downstream and later by using water
made available from the proposed new sources (ie Grand union Canal GUC / Abingdon
reservoir) being brought on-line.
Water transfers from Anglian Water to Affinity Water already exists as detailed in The Ouse
Act (1961, amended 1971). RevIvel understand Affinity has in the past used only a fraction
of their allocation preferring to abstract pure chalk water from the aquifer under North
RevIvel request more clarity on how much water is available to Affinity Water from Grafham
Water in the WRE region. Affinity Water should seek to maximise their take-up of their
allocation from the reservoir and use it to reduce abstraction for the benefit of North
Hertfordshire chalk streams (Ivel, Hiz, etc) which are in the Upper Bedfordshire Ouse
Are there other factors that we should take into account in our best plan?
For too long demand management has unilaterally driven policy and actions. Affinity Water
need to give more weight to environmental consideration. Sustainability needs to be
implemented rather than being frequently used jargon. Application of Chalk Stream First
(CSF) principles go a long way to addressing items in the Environmental and Social Benefit
objectives such as improving biodiversity and other environmental benefits in the
headwaters of chalk streams.
Starting now, Affinity Water need to demonstrate their commitment to CSF principle by
practical application across their whole supply area. If the current feasibility study on the
Ivel has a positive outcome, then Affinity Water rapidly adopt implement the study findings
and allow chalk water to flow down the Ivel in AMP 8.
Regenerative Farming techniques over chalk catchments are fully supported by RevIvel and
we hope this can be embedded in national ELMs strategies by DEFRA. We congratulate
Affinity Water for taking a lead in this area.