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