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Today, WCI breaks silence on the phosphates issue facing large areas of Somerset, Hereford, Monmouthshire and recently the River Camel.  Over the past year, the WCI have been working with clients and regulators to understand the issues with excessive phosphates in the Somerset Levels and Moors RAMSAR, the River Lugg and River Wye and recently the River Camel.  We have worked behind the scenes to try to develop appropriate strategies for phosphate mitigation for individual developers and we have promoted collorative dialogue with the Planning Authority and Regulatory Bodies.

However, like most others, WCI has become frustrated with the lack of engagement and progress that is being made.  We are fearful of the impact this lack of engagement and progress is having on the local economy and the lives of the people that will not have homes as a result.  Today, WCI breaks silence and this blog is the first of a series of thought pieces on the issue.  Our thoughts will not claim to have the full picture and will not always be the result of extensive research.  We offer todays thoughts and the thoughts that follow as a contribution to the broader effort in ensuring that our communities and our environment can grow together.

Thoughts for the day…

Wessex Water are constrained by OFWAT funding rules which dictate the capital investment programme defined in AMP cycles.  There is significant investment applied to achieving numerical phosphate limits from major WwTW within the current AMP7.  I personally think it inappropriate to suggest that Wessex Water or other sewerage undertakers solve the problem without acknowledging the cost of doing so.
However, nobody from our Councils appear to have asked Wessex Water what they could deliver beyond current AMP7 with additional funding.  There are a number of small WwTW without phosphate targets (I can share these) which, if improved to comparable levels as other WwTW – ie using established technology to established levels of efficacy – would by, my reckoning, provide for over 250,000 housing units worth of mitigation.  Councils could act as a funding conduit to Wessex Water with a levy raised on developers for this.

Wessex Water are delivering significant improvements through AMP7.  These are acknowledged by NE in the phosphate balance calculator and applied to future development.  NE has quietly ‘banked’ the AMP7 improvements on existing flows through WwTW by stating in initial guidance that these improvements are not sufficient to return the RAMSAR to a required level.
Nobody (eg our Councils) has held NE to account on what the targeted Phosphate level with the RAMSAR is and to what extent AMP7 improvements will achieve this.  The LPAs are tasked with not allowing development to worsen the condition of the RAMSAR. Acknowledging the improvements over AMP7 as these are brought online would allow for current development to be phased through AMP7 in step.  This would give us all a number of years to consider a broader approach for managing the RAMSAR with equal consideration being given to existing occupation and proposed occupation alongside improvements to non-domestic (eg agricultural) phosphate loads.

My personal view is that the problem is caused by the wrongs of the past and that righting this will require improvements to the existing flows – both the untreated WwTW and the myriad private discharges from septic tanks/STP.  This will take political will and time.

I also believe that the current problem is due to a lack of compliance with existing regulations, both agricultural and domestic.  Large improvements will come from ensuring compliance with existing obligations which will require a proper programme of monitoring and enforcement.  This will take political will and time.

Finally, recognition needs to be given to the fact that there is insufficient suitable land available within the RAMSAR catchment to be turned over to Wetlands to offset the phosphate loads implied by the Councils’ housing plans.  Yet, the creation of Wetlands is the stated and implied strategy promoted by NE and the LPAs.  It does not take a year to figure this out but this needs to be acknowledged to ensure reasonable consideration by the LPAs of alternative approaches that are presented to the LPAs.  NE cannot have a unilateral voice in deciding how the problem is resolved and needs to be held to account in tangibly defining the conservation objectives for the RAMSAR.  This will take political will.

Using the two examples above (and others), I believe time can be given to resolve this but we need our appointed regulators and politicians to do their part.

Brad Taylor
Principal Engineer
WCI Water & Wastewater Engineers