PARISH COUNCIL

Proof: SSJ03

TOWN AND COUNTRY PLANNING ACT 1990 SECTION 78 (as amended) APPEALS (INQUIRY PROCEDURES) () RULES 2000

APPEALS BY David Wilson Homes Southern

Land North of Marnel Park, Popley, RG24 9RY

PROOF OF EVIDENCE ON WATER RESOURCES

BY DR ROGER WALTERS AND JULIAN CRAWLEY SHERBORNE ST JOHN PARISH COUNCIL

Basingstoke and Deane Borough Council

PLANNING INSPECTORATE Appeal Refs: APP/H1705/A/12/2188125 & APP/H1705/A/12/2188137

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TOWN AND COUNTRY PLANNING ACT 1990 SECTION 78 (as amended) APPEALS (INQUIRY PROCEDURES) (ENGLAND) RULES 2000

APPEALS BY David Wilson Homes Southern Land North of Marnel Park, Popley, Basingstoke RG24 9RY

PROOF OF EVIDENCE ON WATER RESOURCES

C O N T E N T S

SECTIONS PAGE

Summary 3

1. Witness Profiles 4

2. Approach and Rationale 4

3. Water Resources and Rivers 7

4. Water Supply and Development 10

5. The Present Applications 16

6. Overall Conclusions 20

OS Map of local area 21

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PROOF OF EVIDENCE ON WATER RESOURCES

Summary

1. Approach and Rationale Many people have been aware of the impact of growth on residents of Sherborne St John and also on the residents of Popley. This ongoing development in the Popley area has extended over more than 10 years. Concerns were intensified as it was clear the appellant was attempting to resurrect the development of a greenfield site outside the settlement boundary of Basingstoke. Many aspects of these proposals have difficulties and my focus here is on water-related issues that may also have wider implications, and welcome the onset of localism as a route to better planning.

2. Water Resources and Rivers Understanding the geography is important in this present context. is located at the head of the three iconic chalk streams: the Itchen, Loddon and Test. The Loddon forms part of the Thames Basin, and falls under the Thames River Basin Management Plan. Water resources derived from the Hampshire aquifer rely on winter rainfall for replenishment. They are historically resilient but are at risk from increased abstraction due to population growth and new development. Basingstoke is served by 3 sewage treatment works, of which 2 are old secondary treatment works unable to remove phosphate from wastewater and neither is suitable for modernisation. SSJ STW discharges effluent into Vyne Stream and STW discharges effluent into Bow Brook.

3. Water Supply and Development Poor water quality of the Loddon arises from the need for high rates of abstraction for supply from the headwater aquifer. This contributes to limiting the flow of water in a river that is then used for wastewater management. High levels of phosphates in STW effluent and nitrates in groundwater are a cause for concern.

4. Present Applications The supply of potable water to residents is a legal requirement. However, supply implications are a matter relevant to planning and development control. Water supplies and these proposals must be seen in a wider context. The appellant’s view that the site would minimise the risk of polluting a water source is absurd given that the watercourse running through the site is already heavily polluted.

5. Conclusions The wider implications of these appeal proposals have not been fully considered. The state of water resources in the borough was not deemed to be a specific reason for refusal of these applications. However, the parish council believes they are vital and, when added to other considerations, constitute a clear reason for refusal. The impact on water resources and river environment, within a highly sensitive area, is a sufficient reason to avoid this housing proposal at this location. I have shown that these problems cannot be mitigated in an environmentally acceptable manner, and that a refusal of these appeal applications is justified.

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1. Witness Profiles

1.1 I am Dr Roger Owen Walters, a Fellow of the Royal College of Physicians of

London and a Fellow of the Royal College of Paediatrics and Child Health. I have been a resident of Sherborne St John since 1982. I retired as Consultant

Paediatrician at the district hospital in Basingstoke after 28 years of service.

1.2 My background is medical rather than hydrological. I have approached the subject of water with an enquiring and open mind. My perception is of a change in public attitudes to the provision of water resources. People no longer take water for granted, and have the prospect of living in a country facing water resource uncertainty as a result of population growth and climate change.

2. Approach and Rationale

2.1 In the past 30 years I have observed and welcomed a great deal of housing development in Basingstoke and the surrounding small towns and villages. As a resident of Sherborne St John I have positively supported the provision of housing that is essential to maintain a vibrant village community with a school, a post office and shop, a pub, some rural office accommodation, some farming and good facilities for recreation. I have been privileged to be a School Governor for some 25 years and Chair of Governors for 15 years. I enjoy walking and am familiar with the woods, streams and footpaths particularly to the south and east of the village.

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2.3 In the recent period, I had become aware of the growing extent of empty office accommodation in both towns and villages. This is despite the relative economic buoyancy of the area. There is an increasing number of empty retail outlets as well as the demise and closure of country pubs. I had also become aware that many of the dwellings recently completed, in the borough, were occupied by families who had chosen to live in Basingstoke but who had to commute to work by rail or road to London, Southampton and the Thames Valley.

2.4 Concerns around the present applications and appeals were intensified as it became clear that the appellant was attempting to resurrect the development of a further greenfield site outside the settlement boundary of Basingstoke. This was a site that had been specifically excluded from development by the previous Local

Plan Inspector, who had accepted the development of Marnel Park as part of a comprehensive package of proposals associated with the relocation of Everest

School. It is a matter of record that the package remains deficient, both in terms of the completion of the housing and the absence of planned amenities.

2.5 Many people have been aware and concerned at the impact of growth on the residents of Sherborne St John and also on the residents of Popley. This ongoing development in the Popley area has extended over more than 10 years. This came about partly from the relocation of the Everest School, and the re-development of the Park Prewett site following closure of the hospital in 1995. There has also been extensive continued growth along the A33 corridor.

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2.6 Locally, there has been a growing awareness of local planning issues. This was sparked by the actions of BDBC in respect of ‘the Manydown debacle’, which was judged in the High Court to be ‘illogical and illegal’. It became apparent that the safeguards of the ‘Plan-led system’ had been weakened, and might lead to a free for all. As with the earlier Marnel Park development, the proposals, now called

‘Land North of Popley Fields’, would be within the parish of Sherborne St John. It was of such a scale and location that incorporation within the village community was neither desirable of feasible, leading to a likely redrawing of the settlement and electoral ward boundaries.

2.7 It has become apparent that fundamentally important issues such as security of water supply, wastewater management and the associated environmental impacts had become marginalised. These issues were of particular importance to the future of Basingstoke and its environs, to the valley, already the subject of huge development pressures, and that there may be wider implications for other parts of Hampshire.

2.8 It is clear that major strategic issues had been identified in County Structure

Plans up to 2004 and the subsequent preparation of the South East Plan. In the latter, water became is key issue, with Policies NRM1 and NRM2 adopting a twin- track approach to increasing and managing supply. However, even with better domestic efficiency, household growth had led to greater demands on water systems. Water companies were found to be working to a strategy with a bias

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toward resource development. Cumulative effects of growth were not considered, and the engagement of the water companies in these issues was problematic.

2.9 There has also been a failure by development interests to identify the potential problems and an absence of understanding by local authorities of the longer term consequences of a failure to ensure proper infrastructure planning.

This has led to a growing concern about many aspects of the proposed development, with a focus on water-related issues that appear to have wide implications. The onset of localism may herald a new era in better plan making.

3. Water Resources and Rivers

3.1 It is incontrovertible that water is a precious finite resource that is necessary for life. The total amount of water on earth is constant because no new water is created with all water being subject to a continuous cyclical process of evaporation and transpiration, condensation, precipitation and collection. It is estimated that perhaps 97 per cent of the earth’s water is in the oceans and 2 per cent in the ice caps with the remaining 1 per cent in use in an environmental water cycle .

3.2 This finite water resource is already under pressure and will be further stressed in future as a result of climate change and increasing demand from population growth and new lifestyles. Careful strategic planning is critical to ensure sustainable water supply for people, businesses, agriculture and the environment.

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3.3 Basingstoke and Deane is located uniquely at the head of the three iconic

Hampshire chalk streams: the Itchen, Loddon and Test. These are all fed from groundwater springs, where they rise to the surface, above the Hampshire chalk aquifer that spans the area from Basingstoke in the north-east to Cadnam in the south-west. Understanding the geography is important in this present context.

3.4 The , rising 10 km west of Basingstoke, flows west through

Overton, and Whitchurch before turning south to reach the sea at

Southampton Water. The , a significant tributary of the River

Itchen, rises from springs around .

3.5 The River Loddon, rising from springs at West Ham Farm in Basingstoke, flows east under the central part of the town to emerge at Eastrop Park, passing through water meadows where it is joined by small streams from springs and ponds at Black Dam, continuing close to the village of before turning in a northerly direction through Sherfield on Loddon proceeding through the grounds of

Stratfield Saye House and into Berkshire to join the at Wargrave.

3.6 Other important chalk streams that combine to form the River Loddon system include the streams taking their origin from many springs arising to the north of Basingstoke that combine to form the Vyne Stream and the Bow Brook that flow to join the River Loddon at Sherfield on Loddon, the rising just to the east of the town in that flows north to join the River Loddon at

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Hartley Wespall and the rising from springs between and , which is joined by the at , then joins the River

Blackwater near Eversley, before flowing into the River Loddon at Swallowfield.

3.7 The River Loddon System thus forms part of the Thames River Basin District and as such falls under the Thames River Basin Management Plan. All public bodies are under a duty to ‘have regard’ to River Basin Management Plans and the

Environment Agency advice is that planning bodies and authorities need to think about the implications of proposed development and land use change on water, including beyond their local authority boundary.

3.8 The water resources derived from the Hampshire aquifer, which is reliant on winter rainfall for replenishment every year, are historically resilient but are now at risk from:

• increased abstraction associated with population growth, new

development, and rising personal consumption;

• changes to groundwater recharge and river flows caused by climate

change;

• environmental requirements of designated rivers and wetlands.

3.9 Given that much of Hampshire, both north and south, is dependent on this key water resource it is essential that a consistent, collaborative, equitable and strategic approach is taken to its management. Arrangements for the management

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of wastewater in Basingstoke are such that the River Loddon is unlikely to become compliant with the required quality measures in the foreseeable future.

3.10 Basingstoke is served by 3 sewage treatment works. The Basingstoke STW is a tertiary treatment works located on the River Loddon downstream from Old

Basing; the works have been modernised (2011-12) and now has the capability of reducing the high phosphate load in wastewater and of producing dried sludge.

Sherborne St John STW which discharges its effluent into the Vyne Stream just below the village and Sherfield on Loddon STW discharges its effluent into the Bow

Brook; both are old secondary treatment works that are unable to remove phosphate from wastewater and neither is suitable for modernisation.

3.11 Sewage treatment works are also to be found in , ,

Overton and Whitchurch. The latter two STW process sewage and wastewater, and discharge it to surface holding areas. This effectively means that the effluent is discharged indirectly into the aquifer.

4. Water Supply and Development

4.1 Water supply issues and these proposals must be seen in a wider context.

The issues regarding the local availability of water, security of water supply, water quality, the environmental impact of water abstraction, and issues arising from sewage disposal and wastewater management in Basingstoke and North Hampshire is a microcosm of the world picture and are definitely not new.

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4.2 Many of the issues of the sustainability of water and sewerage were first referred to in a paper presented to CIWEM Central Southern Branch Annual

Seminar on ‘South East Housing Development – The Quest for Sustainability’ on 18

October 2000 which includes the Basingstoke Case Study.

4.3 Subsequently the Environment Agency in its guidance makes specific reference (Case Study 2 – Basingstoke) to the problems posed in the development of Basingstoke because of its situation on the headwaters of the River Loddon with the town’s principal sewage treatment works (STW) less than 8 km from its source.

The case study highlights the pressures on Thames Water in fulfilling the sewerage undertaker’s statutory duties in (a) meeting already stringent effluent-treatment standards which are necessary to maintain and improve river quality and (b) providing the necessary infrastructure for an area earmarked for continuing development.

4.4 The River Loddon is a designated Salmonid Fishery under the Freshwater Fish

Directive, designated as a Sensitive Area (Eutrophic) under the Urban Wastewater

Treatment Directive and subject to strict limits on dilution of sewerage effluent from the STW into the River Loddon. Because of the proximity of STW discharge to the source of the river, the available flow of water to enable dilution of sewage would always be limited and this situation is complicated by the high rate of abstraction required at West Ham Pumping Station to maintain water supply to Basingstoke.

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The case study highlights that:

• Wastewater treatment must be recognised as a key consideration in selecting

sites for development.

• Local authorities, water companies and the Environment Agency must work

together to achieve compliance with the WFD which will require both a step

change in water efficiency to reduce the need for the current high level of

water abstraction necessary to improve the flow in the River Loddon as well

as a substantial improvement in the quality of effluent from STWs.

• The considerable cost implications of providing the essential improvements to

infrastructure will need to be addressed in emerging development plans.

4.5 Population forecasts suggest that the population threshold, for which the

River Loddon can provide, even based on the current river water standards that are not being met, will be exceeded in the near future.

4.6 Thames Water faces difficult decisions as to how to deal with Basingstoke’s sewage and waste water, including considering the need (a) to take Sherborne St

John STW and Sherfield on Loddon STW out of use and arranging to pump this wastewater to different catchments further downstream and (b) to make similar arrangements to reduce the load on the Basingstoke STW. The costs of making

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such provision may well be prohibitively high. The technology necessary for further improvement to the recently modernised Basingstoke STW does not at present exist even if the costs could be met.

4.7 The poor water quality of much of the River Loddon basin arises from the need for high rates of water abstraction for supply by South East Water plc from the headwater aquifer of the River Loddon that contributes to limitation of the available flow of water in a river that is then used for sewage treatment and wastewater management with its associated problems downstream.

4.8 Again the Environment Agency in its guidance makes specific reference to

Case Study 4 – The Hampshire Water Strategy, developed with stakeholders through workshops and consultation, with the goal of ‘ensuring the long term future of Hampshire’s remarkable rivers, wetlands and aquifers’, as an excellent example of local authority planners’ initiative in engaging stakeholders on sustainable water management through the planning system. The ‘local authority planners’ referred to are presumably based at .

4.9 The Basingstoke Water Cycle Study, Phase 1, Ecological Appraisal, January

2007 carried out by Halcrow Group includes the statement:

“The Bow Brook which flows West to East some distance to the north of

Basingstoke has not been included in this initial appraisal since it is

considered highly likely to be removed from any potential development

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areas. However, if greenfield sites to the north of Basingstoke were to be

developed the potential for effects within the Bow Brook catchment would

need to be considered in future stages.”

The Basingstoke Water Cycle Study, Phase 2, October 2009 (WCS) was undertaken to address some of the uncertainties about the issue of environmental capacity and wastewater treatment in particular that still remained after the initial Phase 1 study makes further comment on the water quality of the Vyne Stream and the Bow

Brook but did not consider the potential impact of the development of greenfield sites.

4.10 The WCS confirmed that the River Loddon catchment was failing to meet the good status required under the Water Framework Directive and that achieving good status even by 2027 would be significant challenge because of the high level of phosphate pollution could not be achieved by tightening discharges from sewage effluent using the best available technology. Even so there is no acknowledgement that the River Loddon is a salmonid in which the effluent phosphate levels are six times higher than would normally be found in chalk streams.

4.11 Although the WCS acknowledge that the region is water-stressed it states that water resources are not considered to be a critical issue for growth. This conclusion appears to be based on the South East Water plans to achieve a substantial reduction of up to 50 per cent in consumer demand. It would entail

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only a small reduction in leakage and no reduction in abstraction, all of which are uncertain, with if necessary supplementation of Water Resource Zone (WRZ) 4, from which Basingstoke is supplied with water, by transfer from other WRZs.

4.12 The potential size of the supply demand problem is illustrated both by the recent history of a long period of restricted water supply imposed on Basingstoke residents starting during the 2011 drought, and extending to the following summer.

Basingstoke should not be considered in isolation given that and much of southern Hampshire derive water supplies from the same Hampshire aquifer and

Southern Water is forecasting a supply deficit for their part of Hampshire.

4.13 The WCS does not comment on the apparent failure of South East Water and

Thames Water to consult together to discuss the interaction between the abstraction of large volumes daily from the chalk aquifers that feed the River

Loddon with its impact on river flows and pollution resulting from the management of effluent discharge from sewage treatment works situated a few kilometres downstream.

4.14 The classic chalk rivers, such as those found in Hampshire, are characterised by a relatively constant flow of crystal clear pure water emerging from springs in valley floors. The water is alkaline or ‘hard’ with a relatively constant temperature.

4.15 The need to protect the chalk aquifer from pollution in order to maintain the distinctive character of the chalk streams and rivers with their unique fauna and

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flora is self evident, and the important contribution that the chalk aquifers make to the storage of CO 2 needs to be recognised.

4.16 The high levels of phosphates in river water and nitrates in groundwater are a cause for concern. In this respect the recent designation in 2012 of the area surrounding the northern part of the Hampshire aquifer as a Nitrate Vulnerable

Zone (because of rising nitrate levels in groundwater, could reach unsafe levels requiring preventive measures) should be a cause for concern.

4.17 It is clear that much remains to be learnt about the hydrology, the ecology and the impact of climate change on chalk aquifers. The importance of consulting with those responsible for all aspects of the water supply is undeniable. The implications of the disposal of sewage and waste water when considering the need and location of major housing development cannot be underestimated.

5. The Present Applications

5.1 The need for local authorities to take a lead role in overseeing the Hampshire

Water Strategy on behalf of its electorate could not be clearer. They need to work in partnership to ensure the long term future of Hampshire’s remarkable rivers, wetlands and aquifers and the provision of a safe and secure water supply and the management of wastewater and sewage could not be more obvious.

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5.2 The applications, now the subject of these appeals, were the subject of a site assessment by the officers of Basingstoke and Deane Planning Department, which reached the following conclusions:

• ‘There would be adequate water supply to serve the site’. This was

deemed to be a positive feature for the proposed site.

• ‘There would be adequate sewerage infrastructure to serve the site’.

This feature was deemed to be a neutral feature of the proposed site.

• ‘The development of the site would minimise the risk of polluting a

water source’. This was deemed to be a strongly positive feature for

the proposed site.

• ‘The soil is, in principle, sufficiently permeable to allow the infiltration

of surface runoff’. This was deemed to be a negative feature of the

proposed site.

5.3 There is no evidence to suggest planning officers drew to the attention of the

Borough Councillors to the many complex issues referred to above and there is no evidence that their conclusions are based on a significant analysis of the development in the context of the Water Framework Directive. There appears to have been scant regard given to the important roles and responsibility of the local authority in respect of the relevant River Basin Management Plans relating to the

River Loddon, nor regard for the Hampshire Water Strategy.

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5.4 Planning officers appear to have been content to recommend acceptance of the proposals even though comment on the water supply situation was limited. The advice from South East Water that a new water supply pipe would be required and no comment had been received from Thames Water in respect of sewage disposal and wastewater management.

5.5 It is the contention of SSJ Parish Council that:

1. The adequacy of the water supply to this proposed site has not been

demonstrated and that to proceed with this development at this time would

be unwise.

2. It is clear that the assessment of wastewater infrastructure implications for

the proposed site in the local wastewater context is wholly inadequate.

5.6 The planning officers appear to have failed to recognise that the proposed site is a greenfield site to the north of Basingstoke, through the middle of which runs a watercourse, referred to as the Vyne Brook. This drains north and east to join the Vyne Stream at the Vyne and thence flows to the Bow Brook. This watercourse is reputed to be one of the most polluted watercourses in BDBC area.

The conclusion that the development of the site would minimise the risk of polluting a water source is absurd given that the watercourse running through the site is already heavily polluted and the addition of surface wastewater flow from a housing

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development on a site with relatively impermeable soil will only increase the risk of greater downstream pollution.

5.7 SSJ Parish Council has become aware that Thames Water has raised three concerns regarding the site in the form of specific, formal objections to the Local

Plan currently under consideration:

Bell 85645-839-CNS-2.3

Bell 85645-844-6.43-2.3

Bell 85645-846-4-2.3.

5.8 All three of these objections rate the proposed Local Plan as ‘unsound’.

Further investment will be required to recover the current situation; even more will be necessary to balance the adverse effect of further housing. We are advised that the current AMP5 programme (2012-15) has no funding allocation for such remedial investment. No assurance has been given by Thames Water that the sewerage network capacity will be able to support the demand anticipated as a result of this development.

5.9 We know that the supply of potable water is a legal requirement. However, the supply implications are a matter relevant to planning and development control.

There is a need to ensure sustainable water management, and to consider the problems caused by additional housing development. The effects on the health of the river environment are a matter of concern to many in the area.

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5.10 In addition, the Water Framework Directive requires an integrated approach to water management. River Basin Management Plan and Water Cycle Studies are some of the means by which the Directive can be implemented and monitored. The

Environment Agency is a prime agency responsible for providing advice, but must work in conjunction with local authorities.

6. Conclusions

6.1 In my opinion, the wider implications of these appeal proposals have not been fully considered. The state of water resources in the borough was not deemed to be a specific reason for refusal of these applications. However, this is primarily because there has been no effective assessment of the additional pressure in this area due to the growth proposed.

6.2 It is likely in my view that the appeal proposals will result in unacceptable increased demand on water resources, leading to the need for additional abstraction. There will be further environmental deterioration, with no overall improvement. Whilst it is difficult to say if one site or one proposal will be the one that makes a critical impact, I am sure that the present seemingly casual isolationist approach will lead to disaster sooner rather than later. I hope that the site visit will be an opportunity to show the inspector the problems and constraints to major housing development in the location proposed.

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6.3 The impact on water resources and the overall river environment, within a highly sensitive area, is a sufficient reason to avoid major housing development at this location, and in these proposals. This applies both to the sustainable supply of water, the major problems associated with wastewater disposal, the deterioration of the local river environment and the wider implications for Hampshire and the

Loddon Catchment.

6.4 These problems are not surmountable in an environmentally acceptable way.

When taken with a wider range of impacts on the local landscape and environment, a refusal of these appeal applications is fully justified, and I so recommend.

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