Adur and Ouse CAMS document - Ouse and Adur …...Glossary 48 List of acronyms, abbreviations and...

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Adur and Ouse Catchment AbstractionManagement Strategy

Final StrategyMarch 2005


The Environment Agency is the leading public body protecting and

improving the environment in England and Wales.

It’s our job to make sure that air, land and water are looked after by

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waters and contaminated land, and improving wildlife habitats.

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© Environment Agency March 2005

All rights reserved. This document may be reproduced with

prior permission of the Environment Agency.

This report is printed using water based inks on Revive, a recycled

paper combining at least 75% de-inked post consumer waste and

25% mill broke.

Front cover photograph by David Dennis, Environmental Images.

Contents

1 Introduction 1

2 Consultation on the Adur and Ouse CAMS 2

3 The CAMS area 3

3.1. Hydrology and hydrogeology 3

3.2. Hydrometry 7

3.3. Abstractions and discharges 7

3.4. Conservation designations 10

3.5. Status of fisheries and ecology in the CAMS area 13

3.6. Water quality 14

3.7. Stakeholder concerns 15

3.8. Links with other plans 15

4 Resource assessment and resource availability status 17

4.1. Introduction 17

4.2. Resource assessment of river assessment points 18

4.3. Resource assessment of groundwater management units 21

4.4. Integration of the surface water and groundwater resource assessments 21

4.5. Water resource management units in the A&O CAMS 23

5 Existing strategies 27

5.1. National Environment Agency strategies and initiatives 27

5.2. Southern Region water resources strategy 27

5.3. Water company water resources plans 28

5.4. Climate change 28

5.5. Opportunities for licence trading in the A&O CAMS area 29

5.6. The Water Act 2003 29

6 Licensing strategy 30

6.1. Introduction 30

6.2. Existing licensing policies relevant to the A&O CAMS 30

6.3. Sustainability appraisal 30

6.4. Licensing policy common to all WRMUs 31

6.5. Promoting water efficiency 32

6.6. Revocation of unused abstraction licences 33

6.7. Licensing strategy for the River Adur - WRMU 1 34

6.8. Licensing strategy for the River Ouse - WRMU 2 36

6.9. Licensing strategy for the Cockhaise Brook - WRMU 3 38

6.10. Licensing strategy for the Brighton Chalk - WRMU 4 40

6.11. Licensing strategy for areas not in a water resource management unit 41

7 Future developments in the A&O CAMS area 42

8 Summary of licensing policy and key actions 44

8.1. Existing licensing policy 44

8.2. A&O licensing strategy 44

8.3. Sustainability issues 44

8.4. Post CAMS appraisal 44

Appendix 1: References/Useful water efficiency contacts 46

Glossary 48

List of acronyms, abbreviations and units 52

Environment Agency The Adur and Ouse Catchment Abstraction Management Strategy

Environment Agency The Adur and Ouse Catchment Abstraction Management Strategy 1

Introduction

1

The Environment Agency is committed to ensuringthat water is managed in a sustainable way thatbenefits users and the environment both now and inthe future. Catchment Abstraction ManagementStrategies (CAMS) set out how water resources aremanaged at a local level. They will make moreinformation on water allocation and abstractionlicensing practice publicly available and allow thebalance between the needs of abstractors, other waterusers and the aquatic environment to be considered inconsultation with the local community and interestedparties.

CAMS are also the mechanisms for managing time-limited licences by determining whether they shouldbe renewed and, if so, on what terms.

Managing Water Abstraction: The CatchmentAbstraction Management Strategy Process is thenational document that supports the development ofCAMS at a local level. It sets out the national policyand the regulatory framework within which CAMSoperate, describes the process of developing CAMSand provides information on the structure andcontent of CAMS documents. This document shouldbe read in conjunction with Managing WaterAbstraction.

The Adur and Ouse (A&O) CAMS sets out our planfor managing water abstraction in the River Adur andRiver Ouse catchments as well as the Brighton Chalkaquifer. This document summarises the availability ofwater resources and the sustainability of currentabstraction. Our policies for managing surface andgroundwater abstraction are described in detail. Thisincludes actions to help maintain and wherenecessary restore a healthy balance betweenabstraction and the needs of the environment. Thedocument also includes our proposed investigationsto help improve our understanding of the interactionbetween abstraction, river flows and ecology.

The A&O CAMS is the second of three CAMS to becompleted in Sussex Area of the Environment Agency.CAMS operate on a six-year cycle and the documentwill be reviewed in 2009 and an updated strategy willbe published in 2011.

A technical document (final version) for the A&OCAMS has been produced which provides detailedtechnical information on which the strategy has beenbased. If you wish to receive a copy of this documenton CD-ROM, please contact:

Tom Nichols – Technical Specialist (Water Resources),The Environment Agency,Sussex Area Office,Saxon House,Little High Street,Worthing,West Sussex,BN11 1DH

Tel: 08708 506506Fax: 01903 215884

Or by e-mail to: [email protected]

Additional copies of the A&O CAMS document andother information about CAMS in Sussex are alsoavailable from the same address.

The CAMS Vision – A shared strategy for the sustainable management of water

resources within a catchment.

Consultation is an integral part of the CAMS process.It is important because it ensures that the CAMS aretransparent and gives everyone the opportunity to getinvolved. For the Environment Agency to managewater resources in a catchment effectively andsustainably, it is important that as much informationas possible is collated on water needs and uses.Comments and suggestions have been gatheredduring the development of this strategy throughvarious activities. These were:

• The wide circulation of an awareness raising leaflet

• Setting up of a CAMS Stakeholder Group

• Presentations to the Sussex Area EnvironmentGroup

• Setting up of a multi-disciplinary CAMS projectteam

• Publication of a formal Consultation Document

The leaflet was distributed in July 2003. Its aim was toraise awareness of the development of the CAMS inthe local area and it also invited anyone with aninterest to send in written comments. We received 19written responses providing information, views andsuggestions for consideration during the earlydevelopment of the CAMS.

A stakeholder group was set up for the A&O CAMS.The role of the group was to represent the keyinterests in the catchment and to help identify issuesof local significance, provide views on proposals andto consider the likely implications of different strategyoptions. The members of the A&O CAMS stakeholdergroup and the interests they represent were asfollows:

Mrs. Vivien Lyth Horsham District Council - Chairperson

Dr. Tony Whitbread Sussex Wildlife Trust

Mr. Trevor Passmore Agriculture

Mr. Paul Holmes Water Companies (South East Water)

Mr. Tony Barnard Fisheries

Mr. Paul Seeley Water Companieslater replaced by (Southern Water)Mr. Mark Potter

Ms. Fenella Collins Country Landlater replaced by & Business AssociationMr. Rupert Ashby

Mr. Peter Currell Sussex Downs Conservation Board

Dr. Sam St. Pierre Sussex Ouse Conservation Society

English Nature were also kept fully informed of allaspects of the process but were unfortunately unableto accept membership of the Stakeholder Group.

It was not possible to include representatives from allinterested organisations on the Stakeholder Group.Contact was therefore established with a number oforganisations inviting their input to the process.Representatives of these groups were sent minutesafter each meeting. These included:

• Inland Waterways Association (IWA)

• NFU (South East Region)

There was also a formal consultation on our proposedlicensing strategy through the A&O CAMSConsultation Document published in July 2004. Wereceived a total of 25 responses, which were analysedand taken into account in developing the finalstrategy.

We greatly value the ideas, suggestion, comments andopinions raised by respondents at all stages indeveloping this strategy.

This document now sets out our final plan formanaging water abstraction in the A&O CAMS area.

Environment Agency The Adur and Ouse Catchment Abstraction Management Strategy2

2

Consultation on the Adur and OuseCAMS


The Adur and Ouse CAMS covers an area of 1073 km2,see Figure 1. It encompasses the catchments of theRiver Ouse and River Adur. It also contains theBrighton Chalk, a major aquifer unit.

The CAMS area is characterised by a concentration ofurban development along the south coast andincludes the city of Brighton and Hove and the portareas of Shoreham and Newhaven. The area has beenattracting tourists for over 200 years. Visitor numbersto Brighton and Hove alone are estimated at 8 millionevery year contributing £382 million to the localeconomy (Brighton and Hove City Council, 2004).

Inland from the coast the area is predominantly ruralwith small and medium sized towns and villagesinterspersed in the attractive countryside. Much ofthe area is included within the Sussex Downs andHigh Weald Areas of Outstanding Natural Beauty(AONBs), which recognises and provides protectionfor the character and landscape value of these areas.Main inland towns include Lewes, Uckfield, HaywardsHeath and Burgess Hill. There is limited industry andmost employment is associated with the servicesector, tourism and recreation and to a lesser extentagriculture.

3.1. Hydrology and hydrogeology

The River Adur and River Ouse support a diverse rangeof habitats and support abstractions for public watersupply (PWS), agriculture and industry.

The River Adur is highly “flashy” responding quickly torainfall events and having low summer flows. Theimpermeable Weald Clay underlies much of thecatchment and plays a large part in determining the

river’s hydrological characteristics. The Adur is also fedby perennial springs emanating from the northernscarp slope of the Brighton Chalk providing a limitedquantity of baseflow to some tributaries of the river.

The River Ouse has the second largest river catchmentin Sussex. It rises on the Tunbridge Wells Sands in theHigh Weald and flows predominantly east and thensouth over before cutting through the Sussex Downsto the English Channel at Newhaven.

The Weald Clay also underlies much of the Ouse catchment. The river has a naturally flashy character

and is prone to winter flooding as experienced inLewes and Uckfield in 2000. It also means that flowsare naturally low during the summer and abstractioncan be unreliable, for example a drought permit wasissued to help maintain abstraction for public watersupply following the dry summer of 2003.

Its largest tributary, the River Uck also has a highlyflashy character and is prone to flooding as are itsother tributaries the Bevern and Clayhill Streams. TheShell Brook and Cockhaise Brook drain TunbridgeWells and Ashdown Sands, both minor aquifers, andfeed into the river’s upper reaches. These streams areless flashy and have a higher baseflow than the othertributaries.

The Ouse has a rich history of navigation and hasbeen managed to support varied uses includingfisheries, flood defence for agricultural interests,industry in the form of mills and iron workings, andmore recently, abstraction for PWS. These haveresulted in a legacy of complex arrangements ofstructures, such as weirs and sluices, to regulate theflow and levels in the river.

3

The CAMS area

The Sussex Coast

Figure 1 - The Adur and Ouse CAMS area


The river system is dominated by a large strategicPWS abstraction operated by South East Water (SEW).Abstraction takes place just above the river’s tidallimit, immediately upstream of Barcombe Mills. Dueto the flashy nature of the river, summer flows areunable to support high levels of abstraction.Therefore the Barcombe abstraction is supported byaugmentation releases from Ardingly reservoir situated on the Shell Brook at the top of thecatchment (see Figure 2).

The river is effectively used as a conduit to movewater from the reservoir to the abstraction point. The reservoir releases fundamentally alter the river’shydrological regime. Summer flows are raised wellabove those that would occur naturally. This hasimportant consequences for water resourceavailability in the river.

One major aquifer, the Brighton Chalk, underliesmuch of the southern part of the CAMS area. It is avery important source of water for PWS and suppliesthe needs of Brighton and Hove and neighbouringtowns on the south coast.

The Ashdown Beds and Tunbridge Wells Sands, whichunderlie the north of the CAMS area, are minoraquifers. They provide important local groundwatersources for abstractions by industry, agriculture and

PWS. They also help to support baseflow to thetributary streams of the River Ouse. Details of thearea’s geology are illustrated in Figure 3.

Although part of the area suffered from significantflooding during the winter of 2000/2001, pressurefrom new development and rising household demandis increasing the need for water. Resources are finelybalanced between meeting the demands of existingabstractions and the need to protect river flows to


Figure 2. Schematic of the Ardingly-Barcombe abstraction system on the River Ouse (courtesy of South East Water).

Figure 3 - Geology of the Adur and Ouse CAMS area


meet environmental and other in-streamrequirements. This is illustrated by Southern RegionEnvironment Agency policy generally presumingagainst further consumptive abstraction and from theChalk aquifer and from rivers during the summer.

3.2. HydrometryWater resources are monitored via a network ofhydrometric stations. River flows, rainfall andgroundwater levels are monitored across the CAMSarea (see Figure 4) and extensive historic recordsexist. These data are used on a routine basis fordrought and flood monitoring, water resourceinvestigations and have also been used to assessresource availability in this CAMS.

Groundwater levels are measured in 60 observationboreholes, predominantly located in the BrightonChalk aquifer. Rainfall is measured in rain gaugeslocated at 45 sites.

The ongoing collection and analysis of hydrometricdata is essential for assessing water resources andsustainability issues. The hydrometric network is

currently under review and subject to improvement.In the A&O CAMS area, spring flow surveys are beingconducted on the Chalk escarpment of the SussexDowns.

3.3. Abstractions anddischarges

Total licensed abstraction in the A&O catchmentsamounts to 231 Ml/d which is about 20% of thearea’s average effective rainfall, see Figure 5.Approximately 98% of licensed groundwaterabstraction is for PWS with the remaining 2% used forindustrial and agricultural purposes. Approximately94% of the licensed surface water abstraction in theCAMS area is for PWS, with around 4.4% foraquaculture (fish farming and watercress beds), 1.5%used for agricultural purposes and only 0.1% forindustry.

The vast majority of water abstracted by SouthernWater Services (SWS) from the Brighton Chalk aquiferis for PWS for the coastal urban area. There are severallarge PWS abstraction points in the unit operated andmanaged under a single group abstraction licence.Actual abstraction is close to licensed volumes andthere is little headroom in most licences for increasedabstraction in the future. Abstraction from the unit hasstrong seasonal trend, increasing sharply in thesummer to meet the additional demands placed onwater supply by tourists.

The River Ouse system is dominated by a large PWSabstraction operated by SEW on the River Ouse, seesection 3.1 for details.

The abstraction licence for the Ardingly-Barcombescheme has recently been varied and was subject to alengthy determination process. The new licenceconditions make the abstraction easier to operate andto enforce. Changes have also been incorporated thathelp secure an improvement in the availability ofwater for PWS, as well as improved environmentalriver flows. These include an increase in the minimalacceptable flow (MAF) that must pass over BarcombeMills weir and restrictions on abstractions from theupper Ouse to secure summer spate flows for fishpassage. There are also changes to the rulesgoverning releases from Ardingly reservoir to create amore natural flow regime in the middle reaches of theOuse.

The variation has been undertaken in full consultationwith local stakeholders and with various EnvironmentAgency functions. An “Ouse Working Group” was setup that included SEW and Environment Agency staffmembers.


Gauging Station Watercourse

Hatterell's Bridge River Adur (western Branch)

Sakeham River Adur (eastern Branch)

Chess Bridge Chess Stream (tributary of the River Adur)

Fulking Fulking Stream (tributary of the River Adur)

Ardingly River Ouse

Shell Brook Shell Brook (tributary of the River Ouse)

Holywell Cockhaise Brook (tributary of the River Ouse)

Gold Bridge River Ouse

Isfield River Uck (tributary of the River Ouse)

Clapper's Bridge Bevern Stream (tributary of the River Ouse)

Old Ship Clayhill Stream (tributary of the River Ouse)

Barcombe Ultrasonic River Ouse

Barcombe Mills River Ouse

Lewes Winterbourne Winterbourne Stream(tributary of the River Ouse)

Table 1 | Main flow gauging Stations in the A&O CAMS Area

Figure 4 - Hydrometric monitoring network sites in the Adur and Ouse CAMS area


Figure 5 - Licensed abstraction in the Adur and Ouse CAMS area


Only a small proportion of the water abstracted in theCAMS area is returned to rivers. Of the estimated 135Ml of treated effluent discharged daily, only around1/3 is to rivers and streams. The remaining 2/3 isdischarged to the English Channel via Long SeaOutfalls at Shoreham, Portobello and Newhaven. Thisrepresents a large loss of water from the CAMS area.See Figure 6 for details.

The Adur catchment is dominated by the discharge atGoddards Green Waste Water Treatment Works(WWTW), operated by SWS, and comprisesapproximately one third of all the water discharged inthe catchment on a daily basis. There are 6 significantdischarges into the River Ouse catchment, 5 of whichare from WWTW. The largest of these is from ScaynesHill WWTW, which accounts for 30% of all thedischarges to the river.

3.4. Conservation designationsThe CAMS area possesses a diverse range of habitatsincluding a wealth of local, national andinternationally designated areas of ecologicalimportance principally related to coastal and chalkgrassland features, see Figure 7.

A large proportion of the rural area is included in thenationally designated High Weald and Sussex DownsAONB and the South Downs EnvironmentallySensitive Area (ESA). The Sussex Downs are includedwithin the area designated as the South DownsNational Park (subject to final confirmation). Planningdecisions already have to take this into account. AnInterim South Downs Management Plan has justrecently been produced (Sussex Downs ConservationBoard March 2004). Much of the remaining rural areais covered by local landscape designations. The areaalso has rich archaeological and built heritage.

The A&O CAMS contains the following internationallyimportant sites:

• Ashdown Forest cSAC and SPA

• Castle Hill cSAC

• Lewes Downs cSAC

These areas of high conservation value are designatedunder the Conservation (Natural Habitats & c.)Regulations, 1994, commonly referred to as the‘Habitats Regulations’, which transposed the EuropeanUnion Habitats and Birds Directives in to British law.

These European sites form a network known as‘Natura 2000’. It includes Special Areas ofConservation (SAC), designated under EC CouncilDirective 92/43 EEC on the Conservation of NaturalHabitats and of Wild Fauna and Flora 1992. It alsoincludes Special Protection Areas (SPA), classifiedunder EC Council Directive 79/409 EEC on the


Goddards Green (Burgess Hill) WWTW (Photograph courtesy of Southern Water Services Ltd)

Devil’s Dyke part of the Beeding Hill to Newtimber Hill SSSI, Sussex Downs AONB

Ardingly Reservoir

Figure 6 - Major discharges in the Adur and Ouse CAMS area


Figure 7 - Conservation designations in the Adur and Ouse CAMS area


Conservation of Wilds Birds. In addition, sitesdesignated under the Convention of Wetlands ofInternational Importance especially as WaterfowlHabitat (known as ‘Ramsar’ sites after the town in Iranwhere the conference was held) are also afforded thesame protection as Natura 2000 sites.

The Habitats Directive requires the assessment of theimpacts of plans and projects on protected areas. Thismeans that the Environment Agency must take fullaccount of the Directive’s requirements whenconsidering new licences and permissions, or beforecarrying out operational work, such as flood defencemaintenance. We must review all existing consents toensure compliance with the Directive and wherenecessary amend or revoke those that are found to becausing damage to habitats or species of Europeanimportance.

We are undertaking an extensive programme toreview existing licences affecting all Natura 2000 sites.This full ‘Review of Consents’, and actions arising willbe completed by 2010.

The sites identified in the CAMS area however, do nothave features that are impacted by water resources

activities. These “dry” Habitats Regulation designatedsites are very important to the local environment, butthere is no direct linkage to the CAMS work. There areno Ramsar sites in the CAMS area.

In addition to the European sites, which are also Sitesof Special Scientific Interest (SSSIs), there are alsomany other SSSIs in the CAMS area. In the lower RiverOuse catchment there are some high quality wetlandhabitats, for example Offham Marshes SSSI and LewesBrooks SSSI. Water Level Management Plans (WLMPs)have been prepared for these sites. WLMPs do nothave to be prepared for any SSSIs in the Adurcatchment.

There are numerous non-statutory Local NatureReserves (LNRs) and Sites of Nature ConservationImportance (SNCIs) in the A&O CAMS area, which areidentified because of their considerable wildlife value.

3.5. Status of fisheries andecology in the CAMS area

The Environment Agency annually collects andanalyses a large amount of ecological data,particularly from electro-fishing surveys and routinemacro-invertebrate sampling. Biological quality ishistorically assessed at 21 sites in the River Adurcatchment and 28 sites in the River Ouse catchment.Such data are used to gauge river water quality as wellas identifying stresses on the river such as low flows.These long-term data have been used to contribute tothe assessment of the sensitivity of rivers toabstraction.

3.5.1. Fisheries

A recent review has resulted in more river stretches inthe CAMS area being designated under EU FreshwaterFisheries Directive. This has given more river stretchesstatutory water quality targets. This will afford theEnvironment Agency greater authority in achievingthese targets for any reaches that fail to meet thestandards of the Directive.

The Rivers Adur and Ouse and their tributaries areused extensively for coarse fishing. Both rivers provideimportant spawning grounds for Sea Trout. Non-migratory salmonids such as Brown Trout aredistributed throughout the middle and upper reachesof the River Ouse and many of its tributaries and occurwidely within the Adur catchment.

There are several stillwater coarse fisheries in both theAdur and Ouse catchments, for example ArdinglyReservoir. There are fewer stillwater game fisheries, the


The High Weald AONB near Horsted Keynes

River Ouse and the Lewes Brooks SSSI


The Environment Agency takes a strategic view on anymodification to structures to aid fish passage. Anysignificant alterations to in-river structures will beadvertised in accordance with planning guidelines.They are also likely to be the subject of anEnvironmental Impact Assessment (EIA) which willtake into account the benefits and costs to theenvironment and other water users of any proposedmodification.

3.5.3. Ecology

The water quality of the River Adur and its maintributaries is variable. The river’s ecology is highlysensitive to changes in flow in the upper headwatersof the western branch above Burgess Hill and on theeastern branch and all of the smaller tributaries. Thisincludes notable Chalk stream habitats at various siteson the scarp slope of the Brighton Chalk aquifer. Theecology in the lower reaches and tidal stretches isgenerally less sensitive to freshwater flows.

The ecology in the Upper Ouse and its tributariesincluding the Cockhaise Brook is also highly sensitiveto changes in flow. This sensitivity declines in themiddle and lower reaches down to the tidal limit.

Riverine ecology is compromised at Ardingly, GoldBridge and Isfield. It is suspected Isfield iscompromised due to water quality problemsassociated with the discharge from WWTWs. This isalso thought to be the case at Gold Bridge, locateddown stream of a large discharge from Scaynes HillWWTW.

Impoundments can also impact on ecological quality.Slow moving water upstream of structures gives riseto an ecology that is less sensitive to changes in riverflows than in more natural parts of the river. Sedimentcan also accumulate behind structures on the RiversAdur and Ouse, which will also affect the ecology.

BAP priority species including Water Vole are presentin the River Adur catchment. There are also plans tocreate favourable habitat for the Water Vole and Otterin the River Ouse.

3.6. Water quality

To assess surface water quality in the A&O CAMS areathere is a network of 50 sampling points coveringapproximately 250 km of classified river. Routinemonitoring shows that surface water quality isgenerally good. Meeting future water qualityobjectives and making water quality improvementsrelies on sufficient flows being available in the riversand streams.

largest being Barcombe Reservoir in the Ousecatchment.

The River Adur and River Ouse support Bullhead(Cottus gobio) and Lamprey (Lampreta sp.), which areAnnex II species under the EU Habitats and SpeciesDirective (92/43/EEC) and are also designatedBiodiversity Action Plan (BAP) species.

3.5.2. Fish Passage

Fish passage in the Ouse is a major issue. Underperiods of prolonged low flows migratory fish such asSea Trout may become trapped in the river’s lowerreaches. Additional “flushing” events may besimulated by enhanced reservoir releases to ensurethat Sea Trout are stimulated to move upstream. Theflow requirements of fish and other fauna and flora arean integral part of the CAMS resource assessmentprocess – see Section 4.

However, the issues relating to fish passage areprimarily concerned with in-river structures preventingfish from moving freely through the river system.

These include Environment Agency owned structuressuch as Clapper’s Bridge weir in the Ouse catchmentand Chess Bridge weir in the Adur catchment.

We are currently leading a project to seek solutions tofish passage issues.

Modifications to Chess Bridge and Clapper’s Bridgeweirs have been made including lowering weir levels.Work at both sites will be completed next year.

During formal consultation on the CAMS a number ofconcerns were raised about the impact of altering in-river structures. These centred on how upstream waterlevels might be affected and the consequences forexisting flora and fauna and opportunities forrecreation.

Bullhead (Cottus gobio)


There are quality concerns associated with the largeGoddards Green WWTW discharge to the Easternbranch of the River Adur, which would naturally havemuch lower summer flows downstream of this point.Upstream of the WWTW, urban drainage has beenidentified as the primary cause of poor water quality.

The issue of groundwater quality protection is alsoimportant because the majority of PWS abstractionsare taken from aquifers. Groundwater in the Chalkaquifer is naturally of very high quality, howeverincreasing nitrate levels are of concern and are beingclosely monitored.

The Environment Agency has a groundwaterprotection policy designed to afford the highestprotection to the recharge areas around Chalk PWSsources. If PWS sources are affected by pollution,alternative sources have to be used either in the shortor long term. Therefore groundwater quality canaffect water resources. We will continue to apply thegroundwater protection policy and to investigatewhere groundwater pollution is suspected. Successfulcampaigns have identified potentially pollutingactivities and advice has been targeted in thesevulnerable areas.

Additional information on water quality in the A&OCAMS area can be found at http://www.environment-agency.gov.uk/subjects/waterquality/.

3.7. Stakeholder concerns

Numerous issues, concerns and suggestions wereraised during the development of this plan about howwater resources in the A&O CAMS area should bemanaged. Many of these were discussed in detail withthe Stakeholder Group, who also made their ownexpert comments at each stage.

We set out our proposed licensing strategy in theA&O CAMS Consultation Document published in July2004.

There was overall support for the strategy includingencouraging the use of winter storage schemes andthe need for further investigations to improve ourunderstanding of environmental flow requirementsand the impact of abstraction. However, a number ofconcerns also remained. These included:

• The impact of abstraction on flows in streams fedfrom the Brighton Chalk aquifer

• The scope and robustness of the ResourceAssessment and Management (RAM) methodologyand its applicability to groundwater resourceassessment

• Time-limiting of abstraction licences and how thiswill affect existing licence holders

• Fish passage and the impact of modifying in-riverstructures

• A number of issues outside the immediate scope ofCAMS were also raised. Most notably about waterquality and included:

• The need for a monitoring programme forendocrine disrupters in the River Adur

• The impact that abstraction could have on summerriver flows and the effect this would have ondilution of effluent

• The impact on water quality from the intermittentdischarging of sewage in the tidal River Ouse

• The impact of nutrients in sewage effluent and theneed for phosphate stripping at WWTWs in theOuse catchment

• Storm sewage releases and their impact on riverecology, including nutrient loading and endocrinedisrupters

• The size of the Goddards Green WWTW dischargeat Burgess Hill compared to the size of the receivingwatercourse

Many respondents felt that that there was a need toincorporate more information about water quality inthis strategy and there is growing demand fromstakeholders to produce a more integrated catchmentmanagement strategy.

We have considered all relevant comments indeveloping our final strategy. Further informationabout fish passage and water quality are detailed inSections 3.5.2 and 3.6 above. Opinions and concernsexpressed about issues not dealt with by CAMS havebeen passed on to relevant Environment Agencyteams and will be used to feed into other initiatives.

3.8. Links with other plans

Developing links with other plans will ensure thatother groups consider water resources issues. CAMShelp both to implement and inform the EnvironmentAgency’s Southern Region and National WaterResources Strategies. CAMS also link to other planssuch as:

Water Level Management PlansCatchment Flood Management PlansWater Quality Improvement PlansFisheries Action PlansBiodiversity Action Plans

Where possible links should be also encouraged withplans produced by external groups such as Regionaland Local Development Plans, AONB ManagementPlans and Water Company Asset Plans.

3.8.1. The Water Framework Directive

The Water Framework Directive (WFD) represents themost substantial piece of water legislation from theEuropean Commission to date. It requires all inlandand coastal waters to reach at least “good ecologicaland good chemical status” by 2015 unless there aregrounds for derogation. There is also a general “nodeterioration” provision to prevent deterioration instatus. The Environment Agency has been named asthe Competent Authority for England and Wales andwill be responsible for delivering the Directive’srequirements.

An important feature of the Directive is theintegration of water quality and water quantity issuesfor both surface and groundwater. This explicit linkingof rivers and aquifers reinforces the holistic approachthat will be taken to water management.

The Directive requires statutory strategic managementplans known as River Basin Management Plans(RBMP’s) to be produced for each of the nine RiverBasin Districts in England and Wales. RBMPs will bedeveloped in consultation with the local communityand will set out how the objectives for all water bodieswithin each river basin are to be achieved.

The integrated approach to catchment managementenvisaged for the WFD will consider a much widerspectrum of pressures and at a smaller scale thanconsidered in CAMS. However, parts of the CAMSprocess will be used to help deliver the WFD. Forexample, the lessons learned from CAMS consultationwill be important in helping the Environment Agencyengage the public in the WFD process.

The first cycle of CAMS will be completed by 2008and will feed into the first set of draft RBMPs to bepublished in the same year. A formal consultation onhow the Environment Agency will approach RiverBasin Planning is underway at the time of publicationof this document. It will look at how our existingwater planning tools, including CAMS, can best beused to help deliver integrated river basin planning.

The latest information about the WFD can be foundat: www.environment-agency.gov.uk/wfd.



Resource assessment and resourceavailability status

4

4.1. Introduction

This chapter summarises the results of the RAMframework used to assess the sustainability ofabstraction in the CAMS area. For more detailedinformation please refer to the A&O CAMS TechnicalDocument CD-ROM.

To manage water resources effectively, we need tounderstand how much water is available and where itis located. This is achieved by undertaking anintegrated resource assessment, covering both surfacewater and groundwater.

Water is used for a number of different purposes, theprincipal categories being general agriculture, sprayirrigation, industrial use, power generation and watersupply. For each different use, the amount of waterthat is returned to the water environment varies. Itmay be close to the point of abstraction or many milesaway or even to a different catchment altogether.Where this local water loss is high, the EnvironmentAgency considers the abstraction to be

consumptive. This may restrict the availability of waterfor these purposes, unless a significant proportion ofthe water abstracted is returned to the water sourceclose to the point of abstraction.

To easily provide information on the availability ofwater resources within a catchment, that may be usedfor consumptive purposes, a classification system hasbeen developed. This “resource availability status”indicates the relative balance between committed andavailable resources, showing whether abstractionlicences are likely to be available and highlightingareas where abstraction needs to be reduced. Thisdoes not replace the need for the licencedetermination process, which is applied to individuallicence applications. More information on thedetermination process is given in Annexe Two ofManaging Water Abstraction.

There are four categories of resource availability status,as shown in Table 2.

Indicative resource Definition Colour coding foravailability status illustration on maps

Water available Water likely to be available at all flows including low Blue flows. Restrictions may apply.

No water available No water available for further licensing at low flows Yellow although water may be available at higher flows with appropriate restrictions.

Over-licensed Current actual abstraction is resulting in no water Orangeavailable at low flows. If existing licences were used to their full allocation they would have the potential to cause unacceptable environmental impact at low flows. Water may be available at high flows with appropriate restrictions.

Over-abstracted Existing abstraction is causing unacceptable Red environmental impact at low flows. Water may still be available at high flows with appropriate restrictions.

Table 2 | Resource availability status categories


The RAM framework involves the development of anunderstanding of the water resources of the CAMSarea and assessment of the surface water andgroundwater resource. These results are integrated todefine the final resource availability status of differentunits within the CAMS area.

Within and between catchments there are variationsin characteristics. In order to measure, manage andregulate effectively, we need to break catchmentsdown into smaller areas, recognising similarities incharacteristics. In the resource assessment for CAMS,in areas where groundwater resources are significant,groundwater management units (GWMUs) aredefined. For surface water, assessment points (APs)are located on the river network. These river APs andGWMUs are the focus of resource assessment andabstraction licensing.

The CAMS area was broken down into the followingriver reaches and associated APs and GWMUs. Theseare illustrated in Figure 8.

• The western branch of the River Adur; assessed atthe Hatterell’s Bridge AP

• The eastern branch of the River Adur; assessed atthe Sakeham AP

• The Upper Ouse assessed at the Ardingly AP

• The Cockhaise Brook, a tributary of the River Ouse;assessed at the Holywell AP

• The Middle Ouse; assessed at the Gold Bridge AP

• The River Uck, a tributary of the River Ouse;assessed at Isfield AP

• The Bevern Stream, a tributary of the River Ouse;assessed at the Clapper’s Bridge AP

• The Lower Ouse; assessed at the BarcombeUltrasonic AP

• The Lower Ouse; assessed at the Barcombe Mills AP

All the river APs are sited at existing gauging stations.

In addition, there is 1 standalone GWMU with noassociated APs:

• The Brighton Chalk aquifer

Further details on how the river reaches, APs andGWMU were defined are provided in the A&O CAMSTechnical Document CD-ROM.

4.2. Resource assessment ofriver assessment points

The surface water resource assessment requires thedefinition of “river flow objectives”. These are basedon the sensitivity of the local ecology to flowvariations (i.e. their vulnerability to abstractionimpacts). It also takes account of other flow needs.These objectives represent the minimum flow that weare aiming to protect. This then affects the amount ofwater that is available for abstraction.

These river flow objectives are developed by firstgiving “environmental weighting” scores to thereaches, which represent the sensitivity of the riverreach to abstraction. Reaches are banded accordingto their sensitivity to abstraction, either Very High(VH), High (H), Moderate (M), Low (L) or Very Low(VL). VH being most sensitive to abstraction and VLbeing the least sensitive. Table 3 shows theenvironmental sensitivity for each river reachidentified in the A&O CAMS area. These results areillustrated in Figure 9.

The river flow objectives are then compared with ascenario flow, which assumes that all licences arebeing fully utilised (i.e. the full licensed quantity isbeing abstracted). This comparison reveals a surplus,balance or deficit. The size of the surplus/deficitcorresponds to a resource availability status for theunit.

Assessment Assessment River Environmental point Point Name weighting

score

1 Hatterell’s Adur (western Moderate (M)Bridge branch)

2 Sakeham Adur (eastern Moderate (M) branch)

3 Barcombe Mills Ouse Moderate (M)

4 Barcombe Ouse Moderate (M) Ultrasonic

5 Clapper’s Bevern Stream High (H)Bridge

6 Isfield Uck High (H)

7 Gold Bridge Ouse Moderate (M)

8 Holywell Cockhaise High (H) Brook

9 Ardingly Ouse High (H)

Table 3 | Environmental weighting results in the A&O CAMS area

Figure 8 - River APs and GWMUs in the Adur and Ouse area


Figure 9 - Water resource availability for assessed river reaches and GWMUs



The surface water resource availability classificationgives an indication of whether new licences will beavailable from the river or whether some recovery ofresources is required. However, there are significantvariations in flow throughout the year. A classificationof “Over Licensed” or “Over Abstracted” generallyindicates that no new licences will be granted.However, this applies only at times of low flow. Duringperiods when flows are higher, there may be somewater available for abstraction. The classification istherefore really a classification of resource availabilityat low flow.

In order to ensure this flow variability is maintainedabstraction licences are sometimes managed by theuse of “hands-off flow” (HOF) conditions. These areconditions on licences that require abstraction tocease (or reduce) when the flow in the river fallsbelow a specified level. Therefore, when river flowsare above this HOF, abstraction can take place butwhen flows are below this, no abstraction (or reducedabstraction) can occur. Low flows will occur morefrequently during the summer months.

In order to maximise abstraction while maintainingthe variability of flow (required for many aquaticspecies), a tiered system of HOFs is applied. Licencesare generally granted with the lowest HOF possible ona first-come-first-served basis. As more licences aregranted, the HOF must be increased to maintainsustainable flows in the river.

For potential applicants for new abstraction licences, itis therefore important to know not only the likelihoodof obtaining a licence, but also the reliability of alicence if granted with a HOF condition. Within theCAMS resource assessment, reliability is expressed as apercentage. This percentage indicates the minimumamount of time over the long term that the scenarioflow exceeds the river flow objective, thereforeallowing abstraction to take place.

The resource assessments for both surface water andgroundwater use a scenario, which assumes that alllicences are being fully utilised; that is, the full-authorised volume is being abstracted. However,many licences are not used fully and therefore inreality the resource availability can be different. If theresult of a resource assessment is “Over Licensed”,data on actual abstraction are then used to establishwhether the status is “Over Abstracted” (actual flowsare lower than river flow objectives). “OverAbstracted” represents abstraction that is alreadyunsustainable whereas “Over Licensed” represents thepotential for damage should the full licensed amountbe abstracted.

4.3. Resource assessment ofgroundwater managementunits

For the groundwater resource assessment, varioustests are applied to each unit to determine theresource availability status. These tests includeexamining the balance between recharge to andabstraction from the unit, the impact of abstractionon summer outflows from the unit and an assessmentof long-term trends including groundwater levels andwater quality.

4.4. Integration of the surfacewater and groundwaterresource assessments

The A&O CAMS has 4 water resource managementunits (WRMUs). These units have been defined toenable the management of water resources at acatchment level and include almost all of the majorabstractions. They have been derived from the riverreaches and associated APs and GWMUs defined toassess water resource availability.

One of the WRMUs, the Brighton Chalk, isgroundwater dominated and has no associated APs.The other WRMUs are a combination of river reachesto form the following:

• The River Adur WRMU; formed of the river reachesto Hatterell’s Bridge and Sakeham APs

• The River Ouse WRMU; formed of the river reachesto Barcombe Mills, Barcombe Ultrasonic, Clapper’sBridge, Isfield Gold Bridge and Ardingly APs

• The Cockhaise Brook WRMU, formed of the riverreach to Holywell AP

A summary of the resource availability in each of theseunits is given in Table 4 and illustrated in Figure 10.Details of the resource availability for each river reachare available in the A&O CAMS Technical DocumentCD-ROM.

WRMU Water resource availability status

River Adur Water Available

River Ouse No Water Available

Cockhaise Brook Over Licensed

Brighton Chalk No Water Available

Table 4 | Summary of water resource availability in the A&O CAMS area

Figure 10 - Integrated Water Resource Availability Status for WRMUs



4.5. Water resourcemanagement units in the A&OCAMS

4.5.1. WRMU 1 - River Adur (Water Available)

The River Adur WRMU, 246 km2, encompasses all ofthe non-tidal River Adur and its tributaries from itsheadwaters at Coolham to the tidal limit at BinesGreen on the western Adur, and from its headwatersat Burgess Hill to the tidal limit at Shermanbury on theeastern Adur. The southern tributaries of the RiverAdur are fed by perennial Chalk springs flowing fromthe scarp face of the Brighton Chalk. The impact ofabstraction from some of the Chalk escarpment hasbeen included in the resource assessment for theeastern branch.

The WRMU is essentially rural in character. With theexception of water for public supply, there is limiteddemand for water resources. The largely impermeablegeology means surface water flows dominate and theriver has a naturally flashy character.

The River Adur was assessed using the RAMmethodology at two APs. The western branch wasassessed at the Hatterell’s Bridge AP and the easternbranch was assessed at the Sakeham AP. Both reacheswere assessed as having Water Available.

The eastern branch has significantly enhancedsummer flows because of the large discharge fromGoddards Green WWTW. The discharge is in excess ofall abstraction from this river reach. River flows belowthe discharge point are raised above those thatwould occur naturally. Above the discharge point andin small headwater tributaries river flows are very smalland during summer months there is unlikely to be

additional water available for abstraction.

The western branch has very limited abstraction.Natural river flows are enough to ensure there is anexcess of water, albeit a very small volume at times oflow river flows (<1 Ml/d), above the minimumrequired by the environment.

There is concern over the impact of abstraction onstreams fed by springs from the scarp slope of theBrighton Chalk aquifer. Some of these abstractionshave been included in the resource assessment, buttheir overall impact on flow at Sakeham is smallcompared to the discharge input from GoddardsGreen WWTW. However their local impact could besignificant and warrants further detailed investigation.

4.5.2. WRMU 2 - River Ouse (No Water Available)

The River Ouse WRMU, 360 km2, encompasses themain River Ouse to its tidal limit at Barcombe Mills. Itincludes the river reaches to Barcombe Mills,Barcombe Ultrasonic, Gold Bridge and Ardingly APs. Italso includes the tributary reaches of the BevernStream to the Clapper’s Bridge AP and the River Uckto the Isfield AP. It is predominantly a rural catchment,but does contain the towns of Haywards Heath andUckfield and many other smaller villages.

Resource availability in the WMRU is complex. Theriver’s hydrological regime is dominated by a largestrategic PWS abstraction operated by SEW.Abstraction takes place just above the river’s tidallimit, immediately upstream of the lowest designatedAP at Barcombe Mills. The abstraction is supported attimes of low river flows by augmentation releasesfrom Ardingly reservoir, situated on the Shell Brook inthe upper reaches of the catchment. The river is usedas a conduit to move water from the reservoir to theabstraction point.

The Adur floodplain and Low Weald looking north from the Chalk escarpment

The River Adur at Hatterell’s Bridge gauging station


The river reaches to Gold Bridge and BarcombeUltrasonic APs are directly affected by the reservoiraugmentation releases. Barcombe Mills AP is affectedby abstraction of the augmentation releases andnatural river flows at Barcombe. Flows at BarcombeMills are used to regulate the abstraction andminimum acceptable flows (MAFs) must bemaintained at this point. The Ardingly AP is alsoaffected by the scheme, as it lies just downstream ofan abstraction point that can be used to directly fillArdingly reservoir. However this abstraction is rarelyused and natural winter flows in the Ardingly Brookand Shell Brook are usually sufficient to fill thereservoir. The Ardingly-Barcombe system is illustratedpreviously in Figure 2.

The 3 other APs situated on the river’s main tributariesat Holywell on the Cockhaise Brook, Isfield on the Uckand Clapper’s Bridge on the Bevern Stream are notdirectly impacted by the scheme. However they allcontribute flows to the River Ouse above BarcombeMills.

The resource assessment revealed that there isnotionally water available at Gold Bridge andBarcombe Ultrasonic APs. Summer flows at these sitesare raised well above those that would occur naturallyas a result of SEW augmentation releases. There is alsowater available at the Isfield AP on the River Uck, dueto the presence of a large WWTW discharge atUckfield. There is also water available on the BevernStream and at Ardingly AP due to limited abstractionin these reaches.

Critically the lowermost AP at Barcombe Mills wasassessed as having No Water Available. Therefore, theassessment at all upstream APs was overridden to NoWater Available in recognition of the need to maintainflows to this river reach. Furthermore, although thereis notionally water available at Gold Bridge andBarcombe Ultrasonic APs, the additional water is aresult of SEW augmentation releases from Ardinglyreservoir in support of their abstraction at Barcombe.It would be a derogation of SEW’s rights if this waterwere licensed for new abstractions.

The situation is complicated further by the fact thatriverine ecology is compromised at Ardingly, GoldBridge and Isfield APs, but river flow is not thought tobe the primary cause (details are available in theTechnical Document CD-ROM).

It was agreed at the Stakeholder Group meeting on 9January 2004 that the result for all APs on the RiverOuse should be No Water Available and that theaugmentation releases from Ardingly reservoir shouldnot be available for new abstraction.

4.5.3. WRMU 3 - Cockhaise Brook (Over Licensed)

The Cockhaise Brook WRMU, 36 km2, is a tributary ofthe River Ouse. It is an attractive rural catchment withconsiderable areas of woodland, much of which fallswithin the boundary of the High Weald AONB.

New Weir - part of the Barcombe Mills complex, River Ouse

Clapper’s Bridge gauging station, Bevern Stream

The River Uck at Uckfield

Abstraction in the catchment is limited with theexception of two comparatively large PWSabstractions, one from the Brook and one fromgroundwater. These abstractions are at present notfully utilised and there is no evidence that currentabstraction is having an adverse impact on riverineecology.

It was assumed that all licensed abstraction, includinggroundwater abstraction, impact upon flows abovethe assessment point at Holywell. Under thisassumption, if abstraction were to increase to fulllicensed limits there is the potential for river flows tobe reduced below the minimum required for theenvironment.

This resulted in the unit being classified as OverLicensed. Consequently the Cockhaise Brook is treatedas a separate WRMU because it has a worse resourceavailability status than the rest of the River Ouse andrequires a separate licensing strategy.

The resource assessment for this unit wasprecautionary. It is possible that additionalgroundwater abstraction may not have an adverseimpact on flows. However, this has yet to be proven.The Environment Agency and SEW are working todevelop a better understanding of groundwater andsurface water interaction. We will refine the resourceassessment depending on the results of these studies.

4.5.4. WRMU 4 - Brighton Chalk (No WaterAvailable)

The Brighton Chalk is the only major aquifer unit inthe A&O CAMS area. It is a very important source forpublic water supply and is almost exclusively exploitedby SWS to supply Brighton and the surrounding area.The recharge area to the main water supply boreholes(117km2) was used to define the boundaries of theunit.

There are limited data on outflows from the unit.With the exception of strong spring flows from thescarp slope (incorporated in the River Ouse and RiverAdur resource availability assessments) surface waterssupported by the main unit are limited to LewesWinterbourne and a number of small springs that feedthe tidal Ouse, some via Lewes Brooks SSSI. Theremainder of the outflows are either south to theEnglish Channel or to tidal reaches of the Rivers Adurand Ouse, which bound the unit to the west and eastrespectively. There are no associated surface waterAPs.

The unit is susceptible to saline ingress. A number ofSWS’s abstractions have to be carefully managed toprevent significant saline intrusion from the sea andfrom the tidal River Adur.

A policy of no further consumptive abstraction fromthe Chalk aquifer has been in place for over a decade.This recognises that a large proportion of recharge tothe aquifer has now been licensed (>50%).

The final assessment was that the unit should beclassified as having No Water Available. There iscurrently no evidence of environmental degradationor long-term decline in water levels or water qualityunder recent actual abstraction rates. However,stakeholders have raised concern about the long-termdecline in spring flows from the Chalk escarpment. Aproject had been put in place by the EnvironmentAgency to investigate these issues. The aquifer isheavily exploited and increased abstraction could leadto saline intrusion and an unacceptable reduction inoutflows.

4.5.5. Areas which are not in water resourcemanagement units

Water availability has not been assessed for some partsof the A&O CAMS area. There are no APs on the tidalAdur or Ouse. The RAM methodology is not


The Cockhaise Brook looking upstream from Holywellgauging station

The Brighton Chalk aquifer (Sussex Downs)

applicable to these reaches. The low-lying coastalfringe to the south of the CAMS where the BrightonChalk is overlain by younger Tertiary strata has alsobeen excluded, as this does not form part of therecharge area to the main aquifer. The minor aquifersof the Ashdown Sands and Tunbridge Wells Sandshave also not been assessed under RAM.

Even in areas that are within defined WRMUs, theresource assessments are limited to defined riverreaches and exclude smaller tributaries. Abstractionfrom these small streams can have significant impacton the local environment and greater restrictions mayneed to be applied in these areas.

In all areas not explicitly assessed under the RAMframework, applications for new or significantly variedabstraction licences will be subject to the normallicence determination process and assessed on a case-by-case basis.

4.5.6. Further data needed before the next CAMS

The preparation of this CAMS and particularly the useof the RAM framework has identified the need formore information to be gathered before the nextCAMS cycle. The RAM framework is regularly updatedand will benefit from the experience gained nationallyduring CAMS preparation. There is a clear recognitionof the need for further investigations in order togauge whether RAM assessments are reflected byenvironmental damage. These investigations arediscussed later.

The A&O CAMS will be reviewed in 2009 and theupdated strategy will be published in 2011.Groundwater modelling would also be useful toobtain a better understanding of the mechanics of theBrighton Chalk aquifer, particularly with regards to theoutflows.


Hamsey Weir, tidal River Ouse


Existing strategies

5

5.1. National EnvironmentAgency strategies and initiatives

There are national Environment Agency initiatives thathave implications for this CAMS. Foremost amongstthese are the National and Regional Water ResourceStrategies, which were issued by the EnvironmentAgency in March 2001.

The Environment Agency has a duty to secure theproper use of water resources in England and Wales.The National Strategy defines the abstraction licensingframework at high level. It looks some 25 years aheadand considers the needs of public water supply,agriculture, commerce and industry, as well as theenvironment. The Regional Strategy and at a locallevel individual CAMS implement and feed back to theNational Strategy.

The periodic review of water company charges alsohas important implications for local water resourcesmanagement. Water companies have to take largeamounts of water from rivers and aquifers to provideenough to supply our everyday use. Whilst fulfillingthis duty, the companies must also protect theenvironment, promote the efficient use of water andmeet legal requirements. Water companies submittheir business plans to Ofwat for consideration in pricesetting. These plans are known as Asset ManagementPlans (AMPs) and cover a five-year period.

We are now in the final stages of implementing AMP3(2000-2005) which include actions identified in theEnvironment Agency’s National EnvironmentProgramme (NEP). This was aimed at identifyingenvironmental concerns caused by water companyoperations and to allow them to seek investmentapproval within the third periodic review to helpovercome concerns on sustainability. Although nosites relating to abstraction impacts were identified inthe A&O CAMS area, a number of improvements toSWS assets to raise water quality were included.

In December 2004, Ofwat published its determinationof the fourth Periodic Review of water companybusiness plans, setting customer price limits for the

AMP4 period, 2005 to 2010. AMP4 includes actionsidentified in the Environment Agency’s updatedNational Environment Programme. AMP4 alsoincludes the implementation of water companyschemes and investigations in the A&O CAMS area, tomaintain and improve the public water supply -demand balance (see sections 5.2, 5.3 and 6.5 and 7).

The Environment Agency also has a national RestoringSustainable Abstraction programme (RSA). Sites whichmay be impacted by abstraction are listed on acatalogue and prioritised to allow furtherinvestigations and if necessary the identification ofsolutions. Some sites recognised in the A&O CAMSmay be included on the RSA catalogue and requirefurther investigation.

5.2. Southern Region waterresources strategy

In March 2001 the Environment Agency published thedocument Water resources for the future – a strategy forSouthern Region. This strategy identifies a preferredapproach to meet the demand for water whilstprotecting the environment in Sussex, Hampshire andKent for the next 25 years. Assumptions were madeabout the potential development of new resources,the realistic potential for savings in forecast water useand the cut backs required to maintain or restoresustainable abstraction in some key areas. Keyprinciples underlying the Regional Strategy include:

• Promoting efficient water use by industry,commerce, agriculture and in the home

• Making the best use of available water resourcesbefore developing new schemes

• Taking account of the potential impact of climatechange

• Requiring water companies to explore theeconomic and environmental benefits of leakagecontrol, metering and water efficiency measures,with all licence applications

• Refusing new abstraction or impoundment licencesto companies with poor leakage or water efficiencystatistics and activity

• Encouraging water company bulk transfers, sharingof resources between areas of surplus and deficitand other increased integration, providing there areno adverse effects

• Future strategic resource developments shouldideally be shared developments benefiting morethan one Water Company.

As PWS is the major abstraction in the SouthernRegion, this is considered in detail, but the strategyalso considers other water users such as agricultureand industry. Total abstraction by local watercompanies has declined over recent years as a result ofleakage control and a reduction in demand from someof the larger water users. However in response to anincrease in house building and changes in houseoccupancy rates the companies expect demand tostart rising again.

Demand Management measures such as meteringand water efficiency measures may offset this rise indemand. In our March 2001 Regional Strategy weassume that a minimum of 60% of households will bemetered by 2025, with an expectation that 75% to80% should be achieved across Sussex. We alsoassume water efficiency saving will be achieved indomestic and commercial water use. Even so, to meetPWS demands over the next 25 years, resource supplyenhancements will be necessary.

5.3. Water company waterresources plans

The water companies, in conjunction with theEnvironment Agency, are required to produce waterresource plans looking at supply and demand over thenext 25 years. These plans are reviewed on an annualbasis. They in turn underpin the existing regionalwater resources strategy and will feed into futurestrategies. As described above, the ‘twin track’approach, which balances the need for new resourceswith demand management and water efficiency, iskey.

Water companies revised their water resources plans indraft and then final form in 2003/4 as a submission tothe Environment Agency and as part of Ofwat’s fourthPeriodic Review of water company business plans. TheEnvironment Agency’s review of these plans issummarised in Maintaining water supply, published inJuly 2004 and individual letters were sent to eachcompany. Companies are now expected to implement

their ‘final’ (2003/4) plans.

In relation to the Adur and Ouse catchments the plansinclude, by 2010:

• Progressing toward year 2030 household meteringlevels of over 80% in Southern Water supplied areasand 68% in South East Water supplied areas. By2010 the metering levels should be over 40% and39% respectively for the two companies

• SEW building a desalination plant at Newhaven

• Full investigation by SEW of a potential newreservoir on the Clayhill tributary to the River Ouse.The investigation will assess the feasibility ofconstructing the reservoir and whether it can beoperational as required by 2016.

5.4. Climate change

Climate change is an important issue facing waterresources management. The latest climate changescenarios from the UK Climate Impacts Programmesuggest that temperatures will rise across England andWales. By the 2050s, in southern England summerswill become drier and winters will be wetter. This hasimportant implications for water availability, as it willchange groundwater and river regimes. For instance,rainfall is becoming both more seasonal and ofincreasing intensity, so this could lead to higher runoffand less water able to percolate into the aquiferswhich supply the bulk of PWS in this area.

It is likely that direct abstractions will become lessreliable in summer, which means that farmers andindustries who rely on these will have to consideradapting in some way if they wish to maintain currentlevels of reliability – this will increase the importanceof using water wisely. The impact on public watersupply is less clear but recent modelling work suggeststhat the deployable output of some systems will bereduced.

For more information on the Environment Agency’songoing work on climate change, please refer toAppendix 1 of the Regional Water Resources Strategy.More details on climate change scenarios are availableat www.ukcip.org.uk/scenarios.


5.5. Opportunities for licencetrading in the A&O CAMS area

One of the objectives of the CAMS process is tofacilitate water rights trading. The term water rightstrading refers to the transferring of licensable waterrights from one party to another, for benefit. Itinvolves a voluntarily movement of a right to abstractwater between abstractors, using the abstractionlicensing process. More detailed information isavailable in Managing Water Abstraction.

A guidance leaflet (Water Rights Trading) waspublished and sent to Licence Holders towards theend of 2002 explaining the scope for water rightstrading within current legislation. Consultation onmore detailed proposals followed in 2003. Afterconsidering the responses to this consultationexercise, further information will be made available toupdate Licence Holders on the Environment Agency’sconclusions for a detailed framework within whichwater rights trading will take place. This informationand guidance will be timed to coincide with theexpected implementation of the sections of the WaterAct 2003 that are most relevant to trading. Furtherinformation on Water Rights Trading is available onour web-site (www.environment-agency.gov.uk/subjects/waterres).

5.6. The Water Act 2003

Following the first major review of the abstractionlicensing system since its inception in 1963, theGovernment set out, in 1999, a new framework formanaging water resources. The CAMS process and themove to time limited licences are key elements of thenew framework, which is completed by revisions tothe statutory framework introduced by the Water Act2003. The Act updates the Water Resources Act 1991in several key areas:

• Deregulation of small abstractions

• New controls on previously exempt abstractions formine and quarry dewatering, trickle and otherforms of irrigation, transfers into canals and internaldrainage districts

• Stronger powers for water resources planning andmanagement

• Changes to the legal status of abstraction licences

• More flexibility to the licensing regulations toimprove thier efficiency and to encourage trading

• Stronger powers on water conservation

For more details on the Act and its implementation,see our web-site, www.environment-agnecy.gov.uk.

The web-site will be updated to provide informationas the Water Act is implemented.



6

Licensing strategy

6.1. Introduction

This section contains details of the abstractionlicensing strategy for the A&O CAMS area. It providesdetails of whether licences are likely to be availableand if so the conditions that are likely to be includedto ensure the protection of low flows and flowvariability. Where recovery of resources is required, theEnvironment Agency’s preferred option(s) to achieve amore sustainable abstraction regime are also outlined.

6.2. Existing licensing policiesrelevant to the A&O CAMS

In general the aquifers and rivers of the region areheavily committed to abstraction. As this has been thecase for many years, licensing policies have evolvedwhich reflect the status of the catchments. Keypolicies operating across Southern Region to protectthe environment when determining licences include:

Use of the “precautionary principle” - Where therehas been uncertainty over the impacts of a proposedabstraction, we have refused licences, or issued themwith time limits, on the grounds of the “precautionaryprinciple”.

Presumption against further consumptive summerabstraction - For most surface water catchmentsthere is also a “presumption against” summerconsumptive abstraction. This reflects the need toprotect the lowest river flows. In some areas HOFconditions are also used to guarantee minimum flows.It is envisaged that updated HOFs generated by theRAM methodology will be used in the future tomanage abstraction in order to protect low flows andflow variability.

Major aquifer licensing policy - There has been a“presumption against” further consumptiveabstraction from the Chalk and Lower Greensandaquifers throughout Southern Region. Thegroundwater drought of the late 1980’s and early1990’s highlighted the vulnerability of these veryimportant water sources. In response a groundwatermanagement policy was introduced by theEnvironment Agency’s predecessor organisation the

National Rivers Authority (NRA) in 1993. Thisembodied the general principle of prohibiting furtherconsumptive abstraction from the region’s majoraquifers.

Encouraging winter storage - Where possible,potential abstractors are encouraged to apply to takewater in the winter and provide reservoir storage forsubsequent re-use during summer months. Thisallows abstractors to use water for consumptivepurposes during summer months when surface waterresources are unavailable.

Recovering resources - A key aspect of the RegionalWater Resource Strategy is the need to recover unusedlicences or portions of licences to correct past overlicensing. This will help secure protection of the waterenvironment, simplify the resources balance andclarify the potential for new licences across all sectorsof abstraction.

6.3. Sustainability appraisal

A sustainability appraisal of options to manageabstraction was carried out for each of the 4 WRMUsin the A&O CAMS area. The process enables theEnvironment Agency to take account of costs andbenefits in the production of CAMS. It allows thesystematic consideration of the government’s fourobjectives of sustainable development, relating toenvironment, economics, society and resource use. Ituses a largely qualitative, proforma-based approach toconsider what the resource availability status for eachwater resource management unit should or could beafter each six-year cycle (Tier 1). This is undertaken forall WRMUs in all CAMS areas.

The process also has a second phase (Tier 2), whichallows the appraisal of options for managing waterresources in order to meet the target resourceavailability status. This is usually undertaken forWRMUs where action is required to improvesustainability and includes, where necessary, theassessment of options to recover resources. Moreinformation on the sustainability appraisal process isprovided in Managing Water Abstraction: TheCatchment Abstraction Management Strategy Process.

The completed forms can be seen in theaccompanying Technical Document CD-ROM.

6.4. Licensing policy commonto all WRMUsAll proposals for new abstraction licences or variationsto existing authorisations will continue to beconsidered under the requirements of the WaterResources Act 1991, the Environment Act 1995 andWater Act 2003. Managing Water Abstractionsummarises how the Environment Agency determineslicence applications and also lists situations where alicence is not required.

Licences that are non-consumptive or aimed atmitigating environmental impacts are likely to beissued irrespective of a WRMUs resource availabilitystatus. However local issues of derogation and/orenvironmental impact will always be assessed andmay override other considerations. Anyone is entitledto apply for a licence even where the CAMS showsabstraction to be unsustainable. Applicants for newimpoundments are dealt with on a case-by-case basis.

In essence in all WRMUs, and particularly those whichare Over Abstracted or Over Licensed, we willproactively seek to increase sustainability by reviewingexisting licences in terms of three tests:

• Need

• Efficient Use

• No damaging environmental impact

All three tests will to a greater or lesser extent beinfluenced by climate change. The three tests will alsobe applied when applications are made for renewal oftime limited licences. There is a presumption thattime-limited licences will be renewed.

6.4.1. Groundwater licences

Most large PWS licences in the CAMS area aregroundwater abstraction from the Chalk. TheAshdown Beds and Tunbridge Wells Sands alsoprovide small but important local sources of water.These abstractions do not have conditions that restricttheir use in dry periods. Calculations to determine thewater availability status of the Chalk aquifer in theCAMS area show the aquifer has No Water Available.Therefore there is little scope for new groundwaterlicences.

• We will continue to presume against issuing furtherconsumptive abstraction licences from the Chalk

There is no policy for abstraction from other minoraquifers. Local investigation will be required to

determine potential environmental impacts andimpacts on other abstractors.

6.4.2. Surface water licences

In accordance with regional policy, in recent yearsthere has been a presumption against issuing licencesfor consumptive abstraction from surface watersduring summer months. Winter storage licences havebeen and will continue to be granted for direct riverabstraction with appropriate flow or level conditionswhere water is available.

This position is supported by recent analysis. A tieredsystem of HOF conditions has been calculated for APsin the River Adur and River Ouse WRMUs based on theRAM methodology. They provide a way to manageabstractions that help to protect low flows and flowvariability.

• We will use RAM generated HOFs, whereappropriate, to control new or significantly variedlicences on main river reaches

Many existing surface water abstractions do not haveany conditions restricting their use in periods of lowflow. We will seek to incorporate existing licences intothe RAM framework as and when these licences comeup for renewal or are subject to a significant variation.This will include the option to impose HOF restrictionsif the abstraction is shown to be causing an adverseimpact to the environment.

Spray irrigation, if not from a reservoir filled in winter,can represent a very significant demand on riverswhen flows are low. Section 57 of the Water ResourcesAct 1991 gives the Environment Agency powers toimpose a temporary restriction on spray irrigators ifthere has been an exceptional shortage of rain. Wewill continue to exercise these powers if required.

6.4.3. Time limiting of licences

Successful applications for new or significantly variedlicences received after 1st October 2001 are normallytime-limited following Environment Agency policy.

For the A&O CAMS area the normal renewal period is12 years and the common end date for this CAMS is2018. This renewal period will decrease depending onwhen any new licences are issued with respect to thecommon end date. Where significant capitalinvestment is made, e.g. major water companydevelopments, longer time periods will be considered.Time limited licences are likely to be renewedprovided they satisfy the three tests described above.


Licence holders will be notified of the need for licencerenewal and will need to re-apply. If a licence isunlikely to be renewed, or it is likely to be significantlyvaried, then the licence holder will be given 6 yearsnotice.

Further details on time limits are available in ManagingWater Abstraction: The Catchment AbstractionManagement Strategy Process.

6.5. Promoting water efficiency

Water efficiency measures can reduce water demandallowing us all to make a difference. Please refer tothe Appendix for more information on how youcan save water, either at home or at work.

Throughout this CAMS area, we will seek to reducewater demand by promoting water efficiency. This willbe achieved through methods, polices and principlesset out in the National and Regional Water ResourcesStrategies. Water companies have a duty under theWater Industry Act 1991, amended by theEnvironment Act 1995, to promote the efficient use ofwater by their customers and ensure that their ownuse of water is efficient. They also have a new dutyunder the Water Act 2003 to ‘further waterconservation’; DEFRA are intending to produceguidance on the implications of this duty and detailswill appear on the Environment Agency’s website indue course.

6.5.1. Water metering

Metering can reduce water consumption by between2% to 14% (with the average being 9%), dependingupon the volumetric charge. The EnvironmentAgency’s Southern Region Water Resources Strategyassumes that in 2025 a water meter will be installed ina minimum of 75% - 80% of Sussex households. Thecurrent take up of meters is about 23% in areassupplied by SWS and 25% in areas supplied by SEW(based on figures for 2002/03 reported in watercompany June returns submitted to Ofwat, 2003).There is still a long way to go to get to the levels thatthe Environment Agency judges necessary to securelong term water supplies and help protect theenvironment. However, the required 2025 meteringlevels are achievable within the opportunities thatwater companies have to meter within currentlegislation. These opportunities are:

• opting for a free meter

• new homes

• changes of home ownership

• unattended sprinkler users

• houses with swimming pools

• compulsory metering, if “water scarcity status” isapplied for by a water company and granted by theSecretary of State

6.5.2. Leakage

All water companies (SEW and SWS) operating in thisCAMS area have reached their Ofwat leakage targets.The National and Regional Water Resources Strategyexpects further economic leakage control progress tobe made through the next 25 years.

6.5.3. Building design

Improved water efficiency should be a key componentof all new housing developments, because on averageonly 3% of all household water consumption isactually for drinking. House builders can help reducewater consumption by installing water efficientdomestic appliances, grey-water recycling schemesand rainwater systems.

The Office of the Deputy Prime Minister (ODPM) hasstated that all new buildings should be designed andequipped in such a way as to enable them to save upto 20% to 30% of per capita consumption. TheBuilding Regulations are currently under review and itis intended to published a revised version in 2005which will include measures to help achieve thesewater savings.

Sustainable urban drainage systems (or SUDS) is thepractice of controlling surface water runoff as close toits origin as possible before it is discharged to awatercourse or the ground. This involves movingaway from traditional drainage systems to softerengineering solutions. The benefits are reduced floodrisk, improved water quality and increasedgroundwater recharge. This water can also becollected and reused for non-potable purposes.

6.5.4. Water audits

All businesses can use their water wisely. By investinga little time and money in implementing a simplewater management plan, an organisation couldreduce its water consumption by up to 80%, releasingmoney to be invested in other parts of the businessand establishing ‘green’ credentials. Water auditsallow the volume of water used during an averageyear to be calculated and suggest ways to reducewater use and therefore costs.


6.6. Revocation of unusedabstraction licencesUnder the Water Act 2003, the Environment Agencywill not have to pay compensation if it revokes alicence that has not been used for 4 years. This sectionof the Act (Section 25/2) will commence on 1 April 2004. However, under Section 25/4, which willalso commence in April 2004, the new provision (4 years rather than 7 years) only applies to thoselicences where the period of non-use started after thecommencement of that section (1 April 2004). For allother abstractions, where the period of non-usestarted before 1 April 2004, the 7 year rule will stillapply.

The revocation of licences will only take place afterprior consultation with the licence holder and in somecases it might be more appropriate to reduce licencequantities.


The western branch has limited abstraction. Naturalriver flows are enough to ensure there is an excess ofwater above the minimum required by theenvironment, albeit only a very small volume at timesof low river flows. There is unlikely to be anyadditional water available for summer abstraction.

Following consultation there was strong support forour proposals to safeguard summer flow in the river.There were concerns that further reducing summer

flow could impact on fish migration and on dilution ofeffluent.

A HOF will be adopted for new and significantly variedlicences that protects summer flows at their currentlevels. Winter storage of water will be encouraged forsubsequent use during the summer.

The Environment Agency is mindful however that usecould be made of the excess water in the easternbranch if it were part of a strategic plan for waterresource development. Any additional abstractionwould be subject to a rigorous environmental impactassessment and cost benefit analysis and would haveto be justifiable in context of managing thesupply/demand balance in Sussex.

There is concern over the impact of abstraction onstreams fed by springs issuing from the scarp slope ofthe Brighton Chalk aquifer. Recent work completed bythe Sussex Area Ecological Appraisal team hashighlighted that abstraction may be the cause ofdepressed ecological quality at a number of Chalkstream sites in Sussex, including the Adur catchment.

We will initiate further work to investigate the linkbetween abstraction, stream flows and aquaticecology and will take appropriate action to ensureabstraction from the Chalk scarp slope is sustainable.


6.7. Licensing strategy for theRiver Adur – WRMU 1

Current water resource availability status – WaterAvailable

Target water resource availability status – WaterAvailable

6.7.1. Resource availability status and results of thesustainability appraisal

This unit has a water resource availability status ofWater Available.

The eastern branch has significantly enhancedsummer flows because of the large discharge from theGoddards Green WWTW. The resource availabilitystatus needs to be carefully understood in that thereare no summer water resources available upstream ofthis discharge point or on small tributary reaches.

River Adur near Shoreham

Figure 11. River Adur WRMU

The Chalk escarpment near Fulking

6.7.2. Guidance on the assessment of newapplications

Applications for abstraction of surface water on thewestern branch and on the eastern branch below thedischarge point at Goddards Green will be consideredusing RAM HOF constraints. Applications for surfacewater above the discharge point are likely to berestricted to the winter months and would requirestorage to allow subsequent use.

Abstractions from underground strata or on tributariesnot included in the RAM assessment, including thosefeeding to tidal reaches will be assessed on a case-by-case basis. No new consumptive abstraction will bepermitted from the northern escarpment of theBrighton Chalk aquifer or the scarp slope streams untilfurther investigation into the relationship betweenabstraction and stream flow have been completed.

• All new and varied licences will be time limited to2018

• HOF conditions based on the RAM methodologywill be considered for all new and significantlyvaried licences.

6.7.3. Renewals and management of existinglicences

There will be a presumption of renewal of licencessubject to the three tests on water efficiency,demonstrable need and no damaging environmentalimpact. Existing licences may be subject to minorchanges including the addition of water efficiencyconditions.

We will seek to incorporate existing licences into theRAM framework. This will include the option toimpose HOF restrictions if the abstraction is shown tobe causing an adverse impact to local riverine ecology.


• RAM based HOF conditions may be added toexisting licences in order to protect environmentalflows

6.7.4. Resource recovery and other changes toexisting licences

We will work with licence holders where abstraction isfound to be having an unacceptable impact on theenvironment and will take appropriate action torestore abstraction to sustainable levels.


6.8. Licensing strategy for theRiver Ouse – WRMU 2

Current water resource availability status – No WaterAvailable

Target water resource availability status – No WaterAvailable


The hydrology of the Ouse catchment is complex.Water resource management in the unit is dominatedby the Ardingly-Barcombe abstraction scheme.Augmentation releases from Ardingly reservoir areused to support abstraction for public water supply atBarcombe. This results in summer river flows beingincreased above those that would occur naturallybetween Ardingly reservoir and Barcombe.

However, the abstraction at Barcombe results in anavailability status of No Water Available at thelowermost AP at Barcombe Mills. Therefore theassessment at all upstream APs is overridden to NoWater Available in recognition of the need to maintainflows at this critical AP.

We will implement a licensing policy that ensures theresource availability status remains at No WaterAvailable and safeguards low flows and flow variability.

In addition, we recognised that the augmentationreleases from Ardingly reservoir should be protectedfrom derogation by new abstraction. HOFs generatedusing the RAM framework will be used to managenew abstractions to ensure the rights of existingabstractors are protected as well as flows required bythe environment.

Local stakeholders have raised concern about springflows from the Chalk escarpment, which feed theupper reaches of the Bevern Stream. Anecdotalevidence has been provided of a decline in river flowsand in ecological quality. However, the EnvironmentAgency has no evidence of ecological damage in themain watercourse due to low flows.

In recognition of these local concerns, we intend toextend recent work conducted by Sussex Area’sEcological Appraisal team on the ecological quality ofSussex’s Chalk rivers and streams to include Chalksprings in the Bevern catchment. We will liase withlocal stakeholders to identify the watercoursesperceived to be at risk and conduct survey work todetermine whether they are being adversely affectedby abstraction. The results of the study will helpinform future licensing policy.


River Ouse at Lewes

Figure 12. River Ouse WRMU

Outflow from Ardingly reservoir, Shell Brook


Applications for abstraction of surface water on themain river will be considered using the RAMmethodology. A HOF constraint will be applied to newconsumptive abstraction licences to ensure flows atBarcombe Mills are maintained and that the rights ofexisting abstractors are not derogated. Given thisrestriction additional water for summer abstraction isvery unlikely to be available, but there are additionalresources for winter abstraction. Winter storage ofwater will be encouraged for subsequent use duringthe summer.

Abstractions from underground strata or on tributariesnot included in the RAM assessment, including thosefeeding to tidal reaches, will be assessed on a case-by-case basis. The Environment Agency will be mindful toensure that any abstraction from groundwater doesnot have an adverse impact on summer flows in themain river or its tributaries.


• There is a “presumption against” further summerconsumptive abstraction

• New consumptive surface water licences will haveHOF conditions to ensure summer flows are notderogated


There will be a presumption of renewal of licencessubject to the three tests described above. Existinglicences may be subject to minor changes includingthe addition of water efficiency conditions. We willseek to incorporate existing licences into the RAMframework. This will include the option to imposeHOF restrictions if the abstraction is shown to becausing an adverse impact on local riverine ecology.



• RAM based HOF conditions may be added toexisting licences in order to protect environmentalflows where appropriate

6.8.4. Resource recovery strategy and otherchanges to existing licences

We will work with licence holders where abstraction isfound to be having an unacceptable impact on theenvironment and will take appropriate action torestore abstraction to sustainable levels.


abstraction has the potential to impact on local riverflows. Therefore if abstraction were to increase to fulllicensed limits river flows could be reduced below theminimum required for the environment.

At present these abstractions are not fully utilised andthere is no evidence that current abstraction is havingan adverse impact on riverine ecology. Therefore theunit has been designated as Over Licensed rather thanOver Abstracted.

However, it is possible that further groundwaterabstraction might not have an impact on local riverflows. We will work with SEW to develop a betterunderstanding of local hydrogeology and the impactof groundwater abstraction on river flows. This willhelp to inform the resource assessment.

As a result of the sustainability appraisal process it isproposed that this WRMU should move to No WaterAvailable. The first step will be to confirm whether theassumption used in the RAM assessment regarding theimpact of groundwater abstraction on river flows isvalid. After these investigations have taken placeoptions to recover resources will be looked at ifnecessary.


There will be a presumption against any abstractionfrom surface water or groundwater that has thepotential to reduce river flows. The current statuseffectively limits any further summer abstraction.However there may be limited capacity for smallsurface water abstractions at high flows or if theabstraction is for a non-consumptive purpose.

Abstractions from groundwater sources will have toshow that they do not have an adverse impact onriver flows and will be judged on a case-by-case basis.



• There is a presumption against further groundwaterabstraction unless it can be shown not to adverselyimpact on summer river flows


There will be a presumption of renewal of licencessubject to the three tests. Existing licences may besubject to minor changes including the addition ofwater efficiency conditions.



6.9. Licensing strategy for theCockhaise Brook – WRMU 3

Current water resource availability status – OverLicensed

Proposed water resource availability status – NoWater Available


The Cockhaise Brook has been assessed as being OverLicensed. This is due to two comparatively large PWSabstractions, one from surface water and oneindirectly from the underlying groundwater,compared to natural river flows.

The interaction between surface and groundwater inthe catchment is complex and is not well understood.A precautionary approach was taken to the resourceassessment and it was assumed that groundwater

Cockhaise Brook looking downstream from Holywell gauging station

Figure 13. Cockhaise Brook WRMU


• Existing abstraction may have HOF conditionsattached if they are shown to be having an adverseimpact on the environment

6.9.4. Resource recovery strategy and otherchanges to existing licences

Several options were assessed to identify the mostsustainable way to move the unit to No WaterAvailable. Our preferred option is to undertakeinvestigations to validate the RAM results and tomaintain current licensing policies until these arecomplete. We will work with South East Water todetermine the impact of groundwater abstraction onriver flows.

If as a result of further work the assumption thatgroundwater abstraction impacts on river flows abovethe Holywell AP is correct, then options to reducelicensed capacities will be assessed. However if ourassumption is shown not to be valid, then theresource availability status may change and additionalgroundwater abstraction may be permitted.



This recognises that a large proportion of recharge tothe aquifer has now been licensed. There is currentlyno evidence of environmental degradation or long-term decline in water levels or water quality. Theaquifer is heavily exploited and increased abstractioncould lead to saline intrusion and reduce outflows tounacceptable levels.

We will ensure the WRMU remains at No WaterAvailable and the policy of no further consumptiveabstraction will be retained.

At consultation we asked whether the policy for themain aquifer should also be extended to all areas ofthe Chalk outcrop in the CAMS area. There wassupport for this proposal and consequently theBrighton Chalk WRMU has been extended to includeall parts of the Chalk previously outside a WRMU.


There will be a general presumption against theissuing of new consumptive abstractions from theaquifer. Exceptions may apply for abstractions thatreturn water close to or at the point of supply,provided they do not impact on groundwater quality,or for abstractions that have a significant benefit tothe environment.


• There will be a presumption against issuing newconsumptive abstraction licences


There will be a presumption of renewal of licencessubject to the three tests. Existing licences may besubject to minor changes including the addition ofwater efficiency conditions. Increases in actualabstraction rates within licensed limits will be closelymonitored to ensure existing outflows andgroundwater quality is not adversely affected.


• Existing licences may be varied in the future if theyare found to have the potential to adversely impactupon outflows or water quality

6.10. Licensing strategy for theBrighton Chalk – WRMU 4

Current water resource availability status – No WaterAvailable

Proposed water resource availability status – NoWater Available

6.10.1. Resource availability status and results ofthe sustainability appraisal

The Brighton Chalk WRMU has been assessed ashaving a water resource availability status of No WaterAvailable. The aquifer is almost exclusively exploitedfor PWS and has a long history of carefulmanagement to maximise yields whilst ensuring salineintrusion is prevented.

A policy of no further consumptive abstraction fromthe Chalk aquifer has been in place for over a decade.

The Brighton Chalk WRMU looking east from SteyningBowl

Figure 14. Brighton Chalk WRMU

6.11. Licensing strategy forareas not in a water resourcemanagement unit

Some parts of the CAMS area do not lie withindefined WRMUs, see Figure 10. These areas includetidal reaches and small tributary streams. Tidal reachesare not included in the RAM assessment as a robustsystem for determining the flow requirements of theseenvironments has yet to be developed. Abstractionsfrom small tributary streams can have a significantimpact on flows and CAMS guidance formulated formain river reaches may not be applicable in somecases.

In this CAMS we also have no specific policy for theminor aquifers of the Tunbridge Wells Sands andAshdown Sands. These aquifers are highly complexdue to faulting and geological variability and there islimited information on outflows and water levels. Theyalso only yield comparatively small volumes of water,but it is noted that these can be locally important.


Our existing regional licensing policy will apply toareas not included within a WRMU. There will be apresumption against further consumptive abstractionof summer surface waters and from Chalkgroundwater. However we will assess any applicationon a case-by-case basis and take full consideration ofthe purpose of the abstraction and any impact on theenvironment.

6.11.2. Renewals and the management of existinglicences

There will be a presumption of renewal of licencessubject to the three tests. Existing licences may besubject to minor changes including the addition ofwater efficiency conditions.


The South East of England is set to see significantdevelopment in coming years. Current RegionalPlanning Guidance for the South East (RPG9) advises onthe proposed levels and pattern of development forthe region. Although the CAMS area will not beimpacted by the substantial planned newdevelopments such as the Thames Gateway, areasincluding Brighton and neighbouring coastal areas,Haywards Heath and Burgess Hill are expected toexpand.

RPG9 is advisory, but under the 2004 Planning andCompulsory Purchase Act it will be replaced by astatutory Regional Spatial Strategy (RSS). The SouthEast Plan is the name given to RSS that will bedeveloped for this area. The purpose of the Plan willbe to provide a spatial framework for local plans andwill integrate regional and sub-regional priorities forhousing, environmental protection and improvement,transport and economic development*.

The draft South East Plan is being consulted uponnow (March 2005). After consultation, a revised Planwill be produced and submitted to Government forapproval later in 2005. The Government will thencarry out further public consultation and hold a publicexamination of the proposals. It is expected that thefinal Plan will receive Government approval in 2006and this will provide a statutory regional frameworkfor development to 2026.

The level of development that will take place in theregion is being consulted upon as part of the Plan andbuilds on the current options developed followingRPG9. These options are*:

• 25,500 additional homes per annum – a lowerfigure than the current planned rate

• 28,000 additional homes per annum –approximately the current planned rate

• 32,000 additional homes per annum – higher thanthe current planned rate

In addition two distribution options are:

• Continuation of Existing Policy – essentially a rollforward of the pattern of development establishedin existing regional planning guidance

• Sharper Focus – a variation which places moreemphasis on a combination of areas requiringregeneration and areas with notable economicpotential

(*Source: The South East Plan: Draft for Public Consultation,January 2005)

Although the exact details of where and how muchdevelopment will take place have yet to be finalised, itis clear that new development will place increaseddemands on water resources. The ability of the SouthEast to accommodate growth is reliant on, amongstother things, the sustainable provision of water.Domestic water consumption is also rising and thiswill place an additional pressure on existing supplies.

The Environment Agency publication Water resourcesfor the future – a strategy for Southern Regionsummarises how supply and demand will be managedin Southern Region over the next 25 years.Assumptions are made about the potentialdevelopment of new resources, the realistic potentialsavings in forecast water use and the cut backsrequired to restore sustainability in certain areas. Thestrategy advocates a twin track approach to meetprojected increases in demand and includes optionsfor increasing supply and managing consumption ofwater.

The Environment Agency and the South East’s WaterCompanies have worked closely together to refinewater supply and demand forecasts in light of thepossible scenarios for growth proposed for the SouthEast. The outcome of this work is reflected in the latestWater Company plans. It has also helped to informthe draft South East Plan and ensure that increases inwater consumption are met in a sustainable andenvironmentally acceptable way. In essence the TwinTack approach will continue to be followed and acombination of demand management measures and


7

Future developments in the A&O CAMS area


strategic water resource development is required tomeet increases in demand.

In the A&O CAMS area Water Companies areinvestigating the following water resource schemes,although to different degrees:

• Reservoirs – investigating and promoting futurereservoir development including in the A&O CAMSarea at Clayhill (SEW)

• Bulk Supplies – continue to investigate the potentialfor shared resources and bulk supplies from onecompany to another to meet demand (SWS, SEWand Mid Kent Water)

• Effluent reuse - particularly the reuse of effluentcurrently discharged to coastal water

Beyond those already included in water companyplans, water conservation options include:

• Further leakage control

• Further Metering – including increasing use of thechange of occupier opportunity (SEW) to install ameter

• Retrofitting schemes - for example, widerimplementation of dual flush toilet retrofit

• Water efficiency campaigns - both in householdand commercial water company customers andwith water abstractors (SWS and SEW)

and,

• New build properties - ensuring that improvementsto the Building Regulations are implemented sothat new build properties are as water-efficient aspossible

More detailed options are discussed in Water resourcesfor the future – a strategy for Southern Region, alongwith others such as rainwater harvesting and greywater recycling which are not selected in theproposed strategy, but could still be introduced.

The latest information about the South East Plan isavailable at www.southeast-ra.gov.uk.


8

Summary of licensing policy and keyactions

8.1. Existing licensing policy

There will be a presumption against furtherconsumptive abstraction from the Chalk aquifer.Further abstraction from Ashdown Sands andTunbridge Wells Sands aquifers will not be permittedunless no adverse environmental impact can be clearlydemonstrated. Each application will be dealt with ona case-by-case basis.

There will continue to be a presumption againstfurther consumptive abstraction in summer monthsfrom surface waters.

We will continue to adopt a precautionary approachto abstraction licensing and refuse applications wherethere is uncertainty over environmental impacts.

8.2. A&O licensing strategySection 6 of this document outlines our policy formanaging new and existing abstraction licences andincludes:

• The RAM methodology will be adopted to manageabstraction licences in the Rivers Adur, Ouse andCockhaise Brook WRMUs

• HOF conditions will be imposed on new andexisting abstraction licences to ensure low flowsand flow variability are protected

• A Water Available resource status will be maintainedfor the River Adur WRMU in light of uncertaintiesover how reducing flows will impact on fishpassage

• We will undertake an investigation into the validityof the RAM result in the Cockhaise Brook WRMU

• We will presume against any further consumptiveabstraction from the Brighton Chalk WRMU

8.3. Sustainability issuesThere is concern about the impact of abstraction fromthe scarp slope of the Brighton Chalk aquifer onstream flows.

We will initiate further work to investigate the linkbetween abstraction, stream flows and aquaticecology and will take appropriate action to ensureabstraction from the Chalk scarp slope is sustainable.

Until this work is completed no further consumptiveabstraction will be allowed from the northernescarpment of the Brighton Chalk aquifer or the scarpslope streams.

8.4. Post CAMS appraisalAn annual update will appear on the CAMS websitehighlighting our progress in implementing thestrategy. The success of the A&O CAMS will beassessed using the following indicators:

• The resource availability status of each WRMUeither remains unchanged or improves

• Regular visits to licence holders to ensure thatlicence conditions are met and comply with currentlegislation and to encourage water efficiency byabstractors

• Routine sampling programmes will continue tomonitor the sensitivity of watercourses toabstraction in each WRMU. This will includemonitoring fisheries, macrophytes andmacroinvertebrates communities

• Progress in implementation or development of theRegional and National Water Resources Strategies

• Successful applications for new or significantlyvaried abstraction licences will be granted usingRAM and appropriate HOF conditions will beimposed to protect low flows and flow variability


• The results of the proposed investigations will befeed into licensing policy

• CAMS will help contribute towards thedevelopment of River Basin Management Plans

• CAMS will help water bodies in the Adur and Ousecatchments achieve good ecological status or goodecological potential required by the WaterFramework Directive


A1

Appendix

References

Brighton and Hove City Council. 2004. A different kindof city – a unique destination - A strategic framework fortourism development for Brighton and Hove [online].Available from: http://www.brighton-hove.gov.uk/downloads/tourism/Tourism_Strategy_2004.pdf(Accessed March 2004)

South East England Regional Assembly. January 2005.The South East Plan, Draft for Public Consultation.http://www.southeast-ra.gov.uk/southeastplan/plan/cons_draft_jan05/executive_summary.pdf(Accessed 02/02/05)

South East Water Plc. 2003. JUNE RETURN2003 BOARD OVERVIEW.

http://www.ofwat.gov.uk/aptrix/ofwat/publish.nsf/AttachmentsByTitle/jr03_mse_overview.doc/$FILE/jr03_mse_overview.doc(Accessed 14/06/04)

Southern Water Services Ltd. 2003. JUNERETURN 2003 BOARD OVERVIEW.

http://www.ofwat.gov.uk/aptrix/ofwat/publish.nsf/Content/jr03_srn_overview_tabled(Accessed 14/06/04)

Sussex Downs Conservation Board (March 2004)Interim South Downs Management Plan.

Useful water efficiency contacts

General/all sectors

Environment Agency

The Environment Agency provides a range of freeguidance on water efficiency, including best practicecase studies for agriculture, business, industry, publicsector and the domestic consumer. Consultwww.environment-agency.gov.uk/savewater ortelephone 01903 832275.

Water companies

For local water efficiency advice, contact your watercompany. Consult www.southeastwater.co.uk orwww.southernwater.co.uk

Water regulations advisor service

WRAS provides advice on the Water Supply (WaterFittings) Regulations which prevents waste, misuse,undue consumption or contamination of wholesomewater. Consult www.wras.co.uk or telephone 01495248454.

Business/commercial

Envirowise

Envirowise is a Government programme offering free,independent advice on practical ways for industrialand commercial small & medium sized enterprise tominimise waste and convert turnover into profit.Envirowise has a specific water section on their sitecalled ‘Waternet’, which includes links to guidancepublished around the world and a benchmarkingtool. Consult www.envirowise.gov.uk/waternet ortelephone the Environment & Energy helpline: 0800585 794.

Public sector

Watermark

Watermark is an initiative from OCG buying solution(part of the Office of Government Commerce in theTreasury) for public sector organisations. It hasproduced benchmarks for a wide range of publicsector buildings, and offers access to a shared savingsscheme for the installation of new, water efficient,devices. Consult www.watermark.gov.uk

Water in the School

Water in the School is a website supported by anumber of water companies aimed at NationalCurriculum Key Stage 2 and 3 pupils and theirteachers. It provides a wealth of information for


pupils on how to make savings. Consultwww.waterintheschool.co.uk

Hospitals

Water UK

Water UK has collaborated with NHS Estates andWatermark to produce Water Efficient Hospitals, aninformation pack to help hospitals use water wiselyand save money by cutting both water and energybills. Consult www.water.org.uk/index.php?cat=3-4701

Agriculture & Horticulture

UK Irrigation Association (UKIA)

The UKIA provides information on irrigation to itsmembers and runs technical workshops. Consultwww.ukia.org

DEFRA Rural Development Service (RDS)

DEFRA’s Rural Development Service provides grantsfor agricultural water resources management schemesunder its Rural Enterprise Scheme. Consultwww.defra.gov.uk/erdp/default.htm or telephone0845 9335577.

Linking Environment & Farming (LEAF)

LEAF promote and develop integrated farmmanagement, this includes whole farm water savings.Consult www.leafuk.org or telephone: 0247 6413911.

AbstractionRemoval of water from a source of supply (surfacewater or groundwater).

Abstraction licenceThe authorisation granted by the EnvironmentAgency under section 38 of the Water Resources Act1991 to permit water abstraction.

Asset Management PlanAsset Management Plans are produced by the watercompanies for Ofwat and set out the investmentprogramme for the water industry. These plans aredrawn up through consultation with the EnvironmentAgency and other bodies to cover a five year periodand have to be agreed by DEFRA and Ofwat.

AquiferA geological formation, group of formations or partof a formation that can store and transmit water insignificant quantities.

Area of Outstanding Natural BeautyAn area of land designated under the National Parksand Access to Countryside Act 1949 in order toconserve natural beauty.

Assessment pointCritical point on a river at which an assessment ofavailable water resources is made.

BaseflowThe component of river flow that is derived fromgroundwater rather than surface runoff.

Biodiversity Action PlanEstablished at a National level in 1995 as part of theGovernment’s commitment to conserving biodiversitymade at the ‘Earth Summit’ held in Rio in 1992. Theplan identified over 100 species and 14 habitats fortargeted action for protection. This national plan hasnow been translated into local actions and the SussexBiodiversity Action Plan (BAP) focuses on habitats andspecies listed in the plan found in the local area.

CatchmentThe area from which precipitation and groundwaterwill collect and contribute to the flow of a specificriver.

Catchment Flood Management PlansHigh level plans developed by the EnvironmentAgency at a catchment scale to facilitate theintegrated management of flood risks to people andthe developed and natural environment in asustainable manner. These plans are being preparedacross Sussex.

ChalkA soft white fine-grained limestone which underliesmuch of the South Downs and forms a major aquifer.

Consumptive Abstraction/UseUse of water which results in a significant proportionof water abstracted not being returned either directlyor indirectly to a source of supply e.g. spray irrigation.

Demand managementThe implementation of policies or measures whichserve to control or influence the consumption orwaste of water.

Deployable outputThe output of a commissioned source or group ofsources or of bulk supply as constrained by:

• environment

• licence, if applicable

• pumping plant and/or well/aquifer properties

• raw water mains and/or aqueducts

• transfer and/or output main

• treatment

• water quality

for specified conditions and demands.

Derogation In legal terms, the taking away of protected rightsunder the Water Resources Act (1991) due to thegranting of a new licence.

Discharge consentA statutory document issued by the EnvironmentAgency, which defines the legal limits and conditionson the discharge of an effluent into controlled waters.


Glossary


Drought A general term for prolonged periods of below-average rainfall resulting in low river flows and/or lowrecharge to groundwater, imposing significant strainon water resources and potentially the environment.

EffluentLiquid waste from industrial, agricultural or sewageplants.

Environmental flow requirementThe amount of water that is required to support theecology of a river.

Fisheries Action PlanA strategic plan for the local management anddelivery of fisheries objectives and duties developed inpartnership with local fisheries interests. The WesternRother Fisheries Action Plan is one of 5 pilot studiesundertaken by the Environment Agency in responseto The Salmon and Freshwater Fisheries Reviewpublished in March 2000.

Gauging stationA site where the flow of a river is measured.

GroundwaterWater that is contained in underground rocks(aquifers).

Groundwater management unitAn area of aquifer delineated to allow the assessmentof groundwater resources.

Groundwater protection policyEnvironment Agency policy relating to groundwaterrecharge areas to control activities having thepotential to pollute underground water.

Habitats DirectiveThe European Directive on the Conservation ofNatural Habitats and of Wild Flora and Fauna - knownas the Habitats Directive - was adopted by theEuropean Commission in 1992. The Directive isimplemented in the UK by the Conservation (NaturalHabitats & c.) Regulations 1994 - commonly knownas the ‘Habitats Regulations’.

Hands-off flowA condition attached to an abstraction licence settinga river flow threshold below which abstraction mustcease.

HeadwatersThe uppermost reaches of a river system.

HydrogeologyBranch of geology concerned with water within theEarth’s crust.

HydrologyThe study of water on and below the earth’s surface.

Hydrometry The measurement of water on or below the earth’ssurface.

Hydrometric networkA system of sites monitoring rainfall, river flow,groundwater levels, river and lake levels and someclimatic parameters. The data is used extensively forwater resources management and planning, waterquality and ecological protection and improvement,flood defence, flood forecasting and flood warning.

ImpoundmentA dam, weir or other work constructed in an inlandwater, whereby flows are obstructed or impeded orwhere water levels are raised above their naturalposition, and any works for diverting flows in aninland water associated with the construction of adam, weir or other work.

Lower GreensandA group of rock formations comprising mainly ofsandstones, siltstones, and sand, silt and clay depositsand include the Hythe Beds, Sandgate Beds andFolkestone Beds.

Macro-invertebrateAn animal without a backbone which is retained in a5mm sieve.

Minimum acceptable flowThe minimum acceptable flow of an inlandwatercourse as defined in Section 21 of the WaterResources Act 1991.

Natural flow regimeThe river flow pattern experienced prior to theinfluence of man, with no abstraction from ordischarge to the catchment.

Natura 2000The collective name given to the pan-Europeannetwork of sites created under the Habitats Directive.This internationally important network includesSpecial Areas of Conservation (SAC) and SpecialProtection Areas (SPA).

Non-consumptive abstractionAbstraction where the water is used is returned to asource close to or at the point of supply, e.g.hydropower generation, fish farming etc.

National Environment Programme The Environment Agency’s programme as approvedby ministers setting out improvements to be made bywater companies between 2000/01 and 2004/05 tohelp meet the needs of European Directives and UKlegislation.

OestrogensNatural and synthetic hormones found in sewage

effluent. These chemicals are linked to the‘feminisation’ of male fish.

OutflowsA term used to describe the movement of water out(losses) from a defined area of an aquifer and includesspring flows, baseflow to surface waters andmovement of underground water past a definedboundary.

Ponded reach/stretchA section of a watercourse upstream of animpoundment or natural restriction characterised byreduced velocity of flow and raised water levels.

Precautionary principleWhere significant environmental damage may occur,but knowledge on the matter is incomplete, decisionsmade should err on the side of caution.

Public water supplyTerm used to describe the supply of water providedby a water undertaker.

RAM frameworkResource Assessment and Management Framework –a technical framework for resource assessment (forthe definition and reporting of CAMS) andsubsequent resource management (includingabstraction licensing).

RamsarA site of international conservation importanceclassified at the ‘Convention on Wetlands ofInternational Importance’ 1971, ratified by the UKGovernment in 1976.

RechargeWater which percolates downward from the surfaceinto groundwater.

Restoring Sustainable Abstraction A programme set up in 1999 to catalogue river andwetland sites suspected of being affected by overabstraction and to establish a future strategy forinvestigations and implementation of solutions.

Review of ConsentsThe procedure by which the Environment Agency asa competent authority will apply the HabitatsRegulations to review all relevant existing consents,licences, permissions and activities which are likely tobe having an effect on a designated European site.

RevocationCancellation of licence and associated rights andbenefits.

River Basin Management PlanStrategic management documents required by theWater Framework Directive detailing how good

ecological status will be achieved for water bodies ineach river catchment. They will be produced inconsultation the local community for each River BasinDistrict in England and Wales by December 2009.

River reachUnit of a river between two Assessment Points,delineated for the purposes of abstraction licensingand resource management.

Scarp slopeA steep sided slope often used locally in reference tothe northern flank of the Chalk downland.

Site of Nature Conservation Importance Sites designated by Local Authorities for planningpurposes as locally important for conservationinterests.

Site of Special Scientific Interest A site given a statutory designation by English Natureor the Countryside Council for Wales because of itsimportance to nature conservation.

Special Area of Conservation Internationally important nature conservation sitedesignated under the EU Habitats Directive(92/43/EEC).

Special Protection Area Internationally important nature conservation sitedesignated under the EU Wild Birds Directive(79/409/EEC).

Spray irrigationAbstracted water sprayed via a boom or rain gun etc.onto grassland, fruit, vegetables etc. Can have a highimpact on water resources and is highly consumptive.

SpringA surface water course that occurs where the watertable intersects the ground surface.

Surface waterThis is a general term used to describe all aboveground water features such as rivers, streams, springs,ponds and lakes.

Sustainable development Development that meets the needs of the presentwithout compromising the ability of futuregenerations to meet their own needs. This involvesmeeting four objectives simultaneously:

• social progress which recognises the needs ofeveryone;

• effective protection of the environment;

• prudent use of natural resources;

• maintenance of high and stable levels of economicgrowth and employment.


Tidal limitThe most upstream point within an estuary or riverwhere water levels are subject to tidal variation.

Time limited licenceAn abstraction licence with specified end date.

Twin track The approach adopted by National and RegionalWater Resources Strategies for the futuremanagement of water resources, balancing the needfor efficient water use whilst bringing forward timelyproposals for resource development whereappropriate.

Water Level Management Plans A written agreement between interested parties,providing the means by which the water levelrequirements for a range of activities in a particulararea can be balanced and integrated.

Water resource management unitAn area that has similar groundwater and or surfacewater characteristics defined for the localmanagement of water resources.

Water resources strategies Strategy for Water Resource planning in England andWales over the next 25 years to ensure sustainableuse and sufficient water for all human uses with animproved water environment. The strategies predictdemand using different social and economicscenarios.

WetlandAn area of low lying land where the water table is ator near the surface for most of the time, leading tocharacteristic habitats.


AMPAsset Management Plan

AONBArea of Outstanding Natural Beauty

A&OAdur and Ouse CAMS

APAssessment Point

BAPBio-diversity Action Plan

CAMSCatchment Abstraction Management Strategy

DEFRADepartment for Environment, Food and Rural Affairs

EU European Union

GWMUGroundwater Management Unit

HOFHands-off Flow

km2

Square kilometres

mmetres

Ml/dMegalitres (million litres) per day

NEPNational Environment Programme

NRANational Rivers Authority

OfwatOffice of Water Services

PWSPublic Water Supply

RAMResource Assessment and Management

RBMPRiver Basin Management Plan

RSARestoring Sustainable Abstraction Programme

SAC Special Area of Conservation

SNCISite of Nature Conservation Importance

SPASpecial Protection Area

SSSIA Site of Special Scientific Interest i.e. an area given aUK statutory designation because of its conservationvalue

SEWSouth East Water

SWSSouthern Water Services

UKCIPUnited Kingdom Climate Impacts Programme

WFDWater Framework Directive

WLMPWater Level Management Plan

WRMUWater Resource Management Unit

WWTWWaste Water Treatment Works


List of acronyms, abbreviations andunits


Notes


CONTACTS:ENVIRONMENT AGENCY HEAD OFFICE

Rio House, Waterside Drive, Aztec West, Almondsbury, Bristol BS32 4UD Tel: 08708 506 506

www.environment-agency.gov.ukwww.environment-agency.wales.gov.uk

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ENVIRONMENT AGENCY REGIONAL OFFICESANGLIANKingfisher HouseGoldhay WayOrton GoldhayPeterborough PE2 5ZR

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THAMESKings Meadow HouseKings Meadow RoadReading RG1 8DQ

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NORTH EAST

Leeds

Warrington

Solihull

MIDLANDSANGLIAN

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WALES

NORTH WEST

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