Planning

Planning - Influencing planning processes such as the Thames River Basin Management Plan and Thames Water's plans

Our role in the Thames River Basin Plan process
The EU Water Framework Directive (WFD) came into force in the UK in the year 2000. It is the most important water law that there has ever been in this country. It offers a means of achieving good ecological status or good ecological potential of all of the River Thames system, including its tributaries, lakes over 50 hectares, ground-waters and associated wetlands. The main means of achieving this is through the 'Thames River Basin Management Plan' of the Environment Agency.

TRRT is assisting the implementation of  the Thames River Basin Management Plan in the following ways:

• Policy work – we represent the river trusts movement on the DEFRA National WFD Stakeholder Group and lobby for a national framework that helps the effective implementation of river basin plans
• Planning – we help to deliver the Thames River Basin Plan through membership of the EA Liaison Panel.
• Practical projects – we are helping to set up and deliver a range of partnership projects that demonstrate how to implement the WFD in different localities around the Thames basin
• Promotion – we are raising the awareness of the public about the Thames Basin Plan, through our website, newsletter and activities
• People – we involve people in our practical projects and other activities connected with improving the Thames and its tributary rivers.

TRRT commends the EA Thames Region for following the European Commission's WFD Common Implementation Strategy (CIS) Guidance Document on 'Public participation in relation to the Water Framework Directive'. The process of developing the draft Thames Plan has included the following good practice elements from that CIS guidance document:

• Good information has been supplied to the Liaison Panel members where possible
• The Panel members have been consulted over the options for the shape and contents of the draft plan
• Representatives from the main sectors affected have been actively involved in the draft plan process

More information about the Thames River Basin Management Plan and the WFD can be found on the website of the Environment Agency.

THAMES WATER - DRAFT WATER RESOURCE MANAGEMENT PLAN
The Trust is a not for profit organisation dedicated to restoring the environment of the River Thames and its tributaries and engaging the public in solutions. We are therefore concerned with how Thames Water will protect the environment, while meeting legitimate customer needs for the period 2010 to 2035.

Water supplies in the Thames river basin are already under stress. The past pattern of abstraction for human use has resulted in rivers being depleted and their associated wetlands degraded. Impacts such as the growing population of the region, further built development and climate change will bring additional pressures. Therefore, a precautionary approach to reduce, re-use and restore should be used towards the 77% of Thames Water supplies from our rivers and the 23% from ground-waters.

Overall the Thames Water dWRMP set out a progressive approach to achieving sustainable water use and we look forward to working with them to achieve this. We believe that Government and regulators should be fully supportive of Thames Water's long term resource plan and of the funding required to achieve it.

We are encouraged by:
The amount of work that Thames Water has put into developing this plan. We have noted the increasing value that the company has put on public consultation recently. A significant amount of effort has gone into seeking the views of the public. This investment will surely result in the company's final plans being more accepted. We do appreciate the special events that Thames has organised to engage stakeholders such as ourselves in the planning process.

We support the company's integrated demand management strategy of mains replacement, increasing metering and water efficiency measures. We believe that Government and regulators should be fully supportive of this strategy and of the funding required to achieve it.

We welcome the company's recognition that the environment needs its fair share of water. To address the environmental impacts of abstraction, we fully support the proposal for a major investigation into the flows and ecology of the Lower River Thames freshwater reaches and the Upper Thames estuary. The outputs from that study should be used to inform the review of the abstraction agreement, in readiness for the start of the AMP6 water pricing round in 2013/14. We also welcome the planned reduction in abstraction at the Axford groundwater source of 3.6 Ml/d for sustainability reasons.

We would like to see more in the final plan about:
Actions planned to work with others to get nearer to the DEFRA aspirational target of 130 litres per household per day water consumption. The company's assessment about reaching the target appears to be based on not very strong arguments about reduced household size and increased garden watering due to the impact of climate change. We recognise that water companies do not control all of the factors affecting water consumption. However, the planned fall in average household use of 12 l/h/d, to a level of 150 l/h/d by 2021, will still not compare with the best in Europe. We would like to see more proposals for Thames Water to work with others to reduce average per capita consumption.

We would like to know more about plans to continue the current research and development programme into effluent re-use, particularly in London where treated effluent is discharged to the tideway. Poor water quality in the Thames is still a factor in preventing migratory fish such as Salmon returning to breed.

We would welcome some indication of how this plan will help contribute to better river basin management, in particular how it will link with the actions proposed in the draft Thames River Basin Plan under the Water Framework Directive.

The plan would also benefit from some indication of how biodiversity and fish populations across the Thames basin will benefit from the actions proposed in the company's preferred programme of investment. In particular, how will the plan help to deliver Thames Water's own Biodiversity Action Plan?

We would like to know more about plans for The Upper Thames Major Resource Development (UTMRD) or 'Reservoir – Abingdon 150 Mm3'and how it could help to maintain environmental flows in the River Thames. We agree that this may be a sustainable long-term option to maintain security of supply in both London and South West Oxfordshire. But it should be linked to plans for more sustainable river basin management under the Water Framework Directive.

How will Thames Water react to any proposed reductions in abstraction licences following the current EA review. and any measures affecting the supply which may be contained within the Thames River Basin Plan under the WFD?

We remain concerned about:
Plans for a desalination plant at Beckton in the Thames estuary. The bio-fuels proposed to run this plant could have negative impacts in the river basins where they are grown.