Thames River Basin Management Plan

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Chilterns Conservation Board response to Draft Thames River Basin District Management Plan consultation.
The Chilterns Conservation Board (CCB) is a statutory body set up under the Countryside and Rights of Way (CRoW) Act 2000, to manage the Chilterns Area of Outstanding Natural Beauty (AONB). Section 87 of the CRoW Act sets out the purposes of a conservation board as:
a) the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty, and
b) the purpose of increasing the understanding and enjoyment by the public of the special qualities of the area of outstanding natural beauty

There are eight chalk rivers within the AONB. They are a key feature of the Chilterns landscape. The Chilterns Conservation Board set up the Chilterns Chalk Streams Project in 1997 in response to low flows, with an aim to protect and enhance the Chilterns chalk streams and to improve public access and enjoyment of them.

The Board welcomes the opportunity to comment on the Draft Thames River basin Management Plan. Out of necessity our comments will be of a strategic nature and specific to particular rivers or areas. Our comments are:

Response of the Chilterns AONB Conservation Board

General comments
1. The Chilterns’ rivers have been identified as suffering from low flows for many years. Rivers such as the Misbourne and Ver were included on the National River Authority’s (forerunner of the Environment Agency) shortlist of rivers most affected by abstraction, as far bank as the 1980’s. The Thames RBD should show a greater degree of priority for improving the status of these rivers by 2015.

2. The Chilterns AONB Management Plan identifies the major pressures on the Chilterns water resources. The pressures are covered comprehensively by the Thames RBD plan. The single overriding problem in the Chilterns AONB is of low river flows and associated environmental degradation. The implementation of the Water Framework Directive through the Thames River Basin Management Plan has the potential make a significant contribution to resolving these problems. The Board supports the plan in its assertion of the need for partnership working to deliver its objectives. This element of partnership needs to be highlighted and, if necessary, supported by dedicated resources. The Chilterns Conservation Board will continue to work with the Environment Agency and other stakeholders to bring about improvement to rivers in the Chilterns.

3. The River Basin Management Plans need to show how they are linked to AONB Management Plans, and their implementation by the Environment Agency and partners will also help to deliver the AONB Management Plan and therefore show "due regard to the AONBs special qualities" as required by the Countryside and Rights of Way Act.

4. In general, the Board strongly supports the objectives of the plan. However, it is of the view that the plan does not set ambitious enough targets for improvement in the first six year period to 2015. As a consequence, the improvement required to achieve good status in all water bodies by 2027, is not realistic.

5. The plan states that the majority of progress towards the ultimate objective of the WFD will be achieved in the period 2021-2027. However, it is also in this period, that the actions to drive improvement are at their most uncertain. It is clear therefore, that firm commitments must be made to actions outlined in scenarios B and C at an early stage and that significant additional investment is allocated, to deliver progress during this critical period.

Assessment of status
5. The assessment process for determining the status of water bodies does not take into account the international importance of the UK’s chalk river resource or their special qualities. As a result they are assessed on a par with other lowland watercourses. This means that chalk rivers may receive a higher rating than they should because they have been assessed against lower standards than appropriate.

6. The assessment of the current condition of Chilterns’ rivers is confused, in some cases, and the confidence in their designated status is low. Where rivers are failing to achieve good status the justifications for failure are insufficiently detailed. In some cases the "one out, all out" principle of the WFD has not been adhered to when assessing river status. For example, the Hughenden stream has been assessed as achieving a status of good ecological potential. This is despite the fact that its rating for invertebrates is poor and for fish, moderate.

7. Where chemical or ecological status has not been assessed, a timetable for the completion of this assessment should be included. Completed assessment of all water bodies’ status is vital in informing on progress towards the plan’s objectives.

8. Where a particular component of ecological or chemical quality is failing to achieve good status, there is no information as to the cause or potential cause

9. It is not clear how the quantitative assessment of groundwaters has been carried out. In addition, groundwater has been assessed at River Basin District level and not at catchment level. Re-assessment at catchment level would enable more focused actions to be developed.

Actions 10. The actions listed for both Thame and Colne catchments are insufficient to bring about the improvement required to reach the plan’s objective by 2027. A more robust series of actions are required to reduce the level of abstraction in the Colne catchment. Increased development pressure in the region is likely to negate many of the savings made through actions highlighted in scenario A.

11. Where low flows are identified as being a barrier to the river not obtaining good ecological status by 2015, in all cases the justification is listed as being "disproportionately expensive " low or uncertain benefits/not worthwhile". It is not clear how this situation will this change in the period 2015-2027 in order for the overall objective of the Plan to be achieved. This is also the case for phosphate levels which are listed as poor or moderate in several cases.

12. The Board welcomes the inclusion of the action "Continue support for Chilterns Chalk Streams Project" in scenario B actions for the Thame catchment. It recommends that this action be added to the Colne catchment list of actions. The Chalk Streams Project has been the driver for significant improvements to all the Chilterns’ rivers over the past 12 years and will continue to do so, given appropriate support from its partners.

Format and content
13. There is a good deal of overlap throughout the report and appendices. This could be greatly reduced providing a more compact document.

14. The language used is often difficult to understand and inconsistent in its message. For example on page 5 of the main document, section 1.2.6, it is stated that, "good ecological status is measured on the scale maximum, good, moderate, poor and bad" and not high, good, moderate, poor and bad.

15. The layout of the document is confusing and lacks organisation. The use of the terms; good overall status, good ecological status and good ecological potential, can also lead to confusion, particularly when good overall status is shortened to ‘good status’.

16. The river summary sheets in Annexe B could be laid out more clearly to show both components (chemical and ecological) of overall status, at the current time and at each of the plan’s milestones.