Special Edition

Ken Burgin, the Trust's Vice Chairman, has prepared this important article for ENews.

Please find the time to read it and react accordingly. If you would like to discuss further with Ken, he can be contacted at ken.burgin@pikelock.com or telephone 01453 827414.

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The Cotswold CAMS (Catchment Area Management Strategy) is up for its final consultation phase. Its outcome could be critical to the availability of water for the eastern part of the Thames & Severn Canal and therefore to the Cotswold Canals Project as a whole.

Please take time to consider the issues below and send in your comments to: cams.thameswest@environment-agency.gov.uk before the end of April.
The consultation document can be viewed at:
http://publications.environment-agency.gov.uk/pdf/GETH0107BLUG-e-e.pdf?lang=_e

The main issue that needs to be communicated to the EA is that the Cotswold Canals restoration is important locally, regionally and nationally so their strategies for managing water need to take it fully into account.

There are several ways they could do this and several ways they could interpret their own regulations so that much of the water required by the canal is exempt or regarded as non-consumptive (for example, any water leaking from the canal into the ground should be viewed as non-consumptive as it ends up back in the groundwater upstream of the extraction point and therefore ends up back in the rivers – policy G6). If the EA regard all water required by the canal as consumptive and chose not to exercise any of the other exemptions, this CAMS will be critical and contains elements which are of great concern.

These include

1. A presumption that new licenses will be issued on a first come first served basis and that existing licensees have priority over new applications. Having declared that water is a precious resource, it seems daft to let it be used purely on the basis of when an application is made for however an inappropriate use. Surely priorities must come into play – what is the water to be used for, howmany jobs will it support, what impact will it have on the wider community etc?

2. The Thames override affects all of the Thames catchment area. This basically states that any water that is available the Cotswold area cannot be used because London needs it. Without this, it is probable that licensable water would be available for the Cotswold Canals near Ingelsham. Notice that this override and the problems it causes does not stop the Government encouraging massive increases in the number of houses being built in the South East. Consultees are invited to disagree on page 19. The consequence of the EA regarding the supply of the canal as consumptive within a "No Water Available" CAMS strategy is likely to have the following implications:

1. Water would have to be stored in very large quantities in reservoirs which can only be filled in winter. The gravel pits in the Cotswold Water Park are generally linked by porous ground and could only be used if they were to be clay lined. To operate the canal in the way most other canals are used would require a significant number or large gravel pits to be converted which may have unforeseen implications on the wider groundwater environment.
The alternative proposal of building a large reservoir north of Swindon at a cost of tens of millions of pounds made by one consulting company is considered prohibitively expensive and is likely to get bogged down in planning issues.

2. As an alternative to the above, the canal could be constructed to minimise water use. This would mean making the canal bed completely watertight (probably using concrete at a considerable cost), preventing as much trees and vegetation growth as possible and back pumping all lockage. Some reservoir storage would be needed to offset evaporation but this is only about 10% of the capacity needed for normal canal use. This would create a rather sterile canal and water quality issues may arise.

If the EA can accept that canal leakage is non-consumptive and can be supplied by abstraction where water has been identified as being available locally, lockage is back pumped and evaporation/transpiration is offset by reservoir storage, it should be possible to restore the canal in an environmentally attractive and reasonably economic way without adversely affecting the flows in any of the local rivers.
This CAMS, once adopted will not come up for review for another 6 years and since it is the first revision, is likely to inform all future ones.

Therefore please make the time to communicate your view to the EA in your own words even if this is simply to say that you support the Cotswold Canals project and want to see it get the water it needs.

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As I said at the beginning this is a vitally important subject that Ken is raising so please follow it up if you possibly can.
Thank you.