Representing Abstractors in Broadland CAMS & North Norfolk CAMS
Newsletter
14th October 2014
Dear member
Changes to existing licences
Many members have been reviewing their licences recently to ensure that they do not fall foul of their licence conditions and to ensure that their licence meets their future needs whilst taking into account the 2020 licence changes. This has resulted in a flurry of applications most of which have met with success at the Environment Agency. Please take some time to find and read your licence and check that you are pumping within your licence conditions.
Cost of water
Every year the cost of the licence increases, repair costs increase and power costs increase. We have had a number of telephone calls recently reporting very high costs of water applied per acre inch to crops in 2014 which was a high water use year. This has resulted in a number of farmers reviewing why their costs are too high and planning on taking the appropriate action. It is very obvious that some systems can deliver water to crops much cheaper than other systems. On the back of this, water efficiency has been included in RDPE LEADER for Broads LAG and Wensum & Coast LAG and applications were submitted to Defra on 5th September. We should know whether these applications have been successful by mid-November. Please take time to check that your licence is on a 2 part tariff and suitable for your needs, monitor power consumption of the pumping systems, review the size of the underground mains to identify areas of turbulence in the pipework as well as fixing all the leaks.
Restoring Sustainable Abstraction
The Environment Agency have considered the follow:
· To identify, investigate and work to solve environmental risks or problems caused by unsustainable licensed water abstraction across England and Wales.
· To consider the level of environmental impact abstractions are causing or could cause.
· They want to work with all abstractors whose abstractions may be having an environmental impact, to find effective solutions.
The changes they are making will restore water levels in rivers, streams, lakes, wetlands and marshes. They will improve wildlife habitats and protect endangered species. They will also provide more opportunities for recreation.
The problem from an agricultural abstraction point of view is “could cause” & “may be”. It appears that some of the issues raised come from computer models rather than actual data. Also, in certain catchments groundwater levels are being linked to river flows due to a hydrological connection between the groundwater and the river. If you are having issues with the RSA programme, please contact Andrew Alston.
In addition there are beginning to be some Water Framework Directive issues that will be corrected in the next round of CAMS (Catchment Abstraction Management Strategy). The issue of biggest concern
is “No deterioration” to groundwater status. We believe that 1700 groundwater licences in Eastern Region will be affected but not those on the North Norfolk Coast (see attached map). The actual piece of legislation that the Environment Agency is trying to implement seems very vague and their solution to implement reductions seems to have a few holes in it. We are concerned that these changes will be implemented before the changes to abstraction licences in 2020 and this may result in a double hit for some abstractors. The problem seems to stem from where groundwater is connected to surface flows even though the surface flow may not have a low flow issue. If this happens then we can see that groundwater licences could be subject to Section 57. In addition, following the consultation last year on EIUC and morphological changes to water courses, we can begin to see where the funding for measures required is going to come from.
The tests that groundwater must pass are:
1. Impact of groundwater abstraction on the groundwater body water balance
2. Impact of groundwater abstraction on groundwater dependent surface water body status
3. Impact of groundwater abstraction on groundwater dependent terrestrial ecosystems (GWDTE)
4. Saline or other poor water quality intrusion related groundwater abstraction
We suspect that BAWAG will need to get some professional help to fully understand the implications of these assessments. Much of the problem stems from a fully licenced scenario which rarely occurs.
Precautionary Principle
In any licence renewals the Environment Agency has to be satisfied that the application is not affecting the environment. In some cases Natural England may say “we cannot conclude that the application will not affect the integrity of the European site and a precautionary approach should be taken”. In this case the applicant must show 100% that the abstraction is not affecting the integrity of the European site. This is almost impossible. Until now the Environment Agency has accepted Natural England’s advice but 2 applications near Catfield Fen in March 2012 are testing the precautionary principle. The Environment Agency have satisfied themselves that the licences are not affecting the European site both alone and in combination with other abstractions in the area but Natural England, Broads Authority, RSPB and the owner of the site will not agree with the Environment Agency’s groundwater model assessment and the implications on the ecology of the site. It is likely that in November the Environment Agency will move to its “minded to” stage. This is a public consultation stage where we are expecting a very large number of environmental NGO responses. The owner of the Fen has vowed to stop all abstraction in Broadland and intensive crop production by invoking the precautionary principle when abstractors renew their licences. When the time is right we will inform members of where to send in their responses to this consultation. We are expecting the consultation to be late November.BAWAG’s committee believe that winning this case is vital and is the whole reason why BAWAG was formed in 1997 in response to the Habitat Directive.
If this case is lost, there will be nothing stopping an environmentalist from crying precautionary principle at any abstraction licence renewal. If the case goes in favor of the abstractor, it is likely that the owner of the Fen will try to have a Judicial Review on the basis that the Environment Agency has not followed the legislation correctly.
NFU Vice President Visit
On 9th October the NFU Vice President Guy Smith visited BAWAG to obtain a better understanding of water related issues. The areas discussed included Precautionary Principle, review of groundwater licences for “No deterioration”, diffuse pollution near SSSI’s and the effect on site integrity, grants for water resources and the collection of survey evidence to protect agriculture. Brian Finnerty (NFU press officer at Newmarket) also attended with a view to writing a human impact story of businesses caught up in abstraction issues. No doubt this story and pictures of our Gumleaf wellingtons will fill the NFU Farmer and Grower magazine.
2014-15 prospects
On the whole prospects for 2014-15 abstraction looks good. There could be an issue on the River Bure where flows were low towards the end of September but recent rainfall should have corrected the flow towards normal flow rates.
Anglian Water
Over the last two years BAWAG and other abstractor groups have been engaging in a series of meetings which look at all water resources in Eastern region. Although agriculture only has 2% of national water rights and rarely abstracts its licenced volume, it can use a very large percentage of available water in an extended dry period. It is felt that by working more closely with Anglian Water that solutions can be found. They are considering moving water into East Anglian from River Trent and pumping cleaned water into the aquifers around Lowestoft which could be available to farmers locally rather than pump it out to sea.
ESWAG
After setting up East Suffolk Water Abstractors Group in 1996, Peter Youngs is in the process of training his replacement, Tim Darby. We wish Peter all the best in retirement.
UKIA
UKIA have a two day visit to Morocco 12-14th November to look at farms that rely on groundwater. If you are interested please contact Melvyn Kay. www.ukia.org
Current Consultations
https://www.gov.uk/government/consultations/draft-flood-risk-management-plans?dm_i=2HBJ,1NQL,25ZBL6,3J5K,1
https://consult.environment-agency.gov.uk/portal/ho/wfd/draft_plans/consult
Andrew Alston
CEO BAWAG
01263 733395
07785 935498