In the face of mounting local concerns about ongoing sewage spillages and out of control housing development, Cranleigh Civic Society called a meeting on the 11th of May, at the Elmbridge Road Sewage Works.

We invited representatives, who all attended, from Thames Water (TW), the Environment Agency (EA), Waverley Borough Council (WBC) planning department, Surrey Wildlife Trust, Parish and Borough Councillors, together with members of Cranleigh’s Neighbourhood Plan (NP) to discuss sewage and water quality problems.

Stakeholders meeting at Cranleigh Sewage Works 11 May 2016

At the meeting Thames Water confirmed that they are working on two new filter beds to improve the resilience of the sewage works to cope with current treatment levels.

We are still waiting for answers from Thames Water to some of the questions our members sent in prior to the meeting which we raised on the day.  We will publish these as soon as they are received.

As a result of the meeting the EA, in association with Surrey Wildlife Trust, have agreed to start investigating the flow problems with Cranleigh Waters and to commence a review of Thames Water’s Environmental Permit (sets levels for the quality and amount of effluent) to discharge liquid effluent into the river.

We are now in the process of arranging a river walk with the EA and will be carrying out some monitoring work, which we will let you know about soon, as we will be needing several local volunteers to work with us and Surrey Wildlife Trust.

More Sewage Coming This Way!

It’s a fact that massive increases in housing in Cranleigh will produce far more sewage and place more demand on our local water supply network.  This also has a knock on effect on water quality in local rivers and streams into which the sewage works currently releases 2 Olympic-sized swimming pools of liquid effluent each day.

The EA issue an Environmental Permit to Water Companies to regulate the amount of liquid effluent they release into a watercourse (Thames Water were issued with one for Cranleigh Waters in 2009 and a review is outstanding) and to monitor certain trace elements, like phosphates.  You can read more about this in our article NO MORE SEWAGE IN CRANLEIGH WATERS . The permit does NOT however measure the level of water in the river or stream.

As we have previously highlighted Cranleigh Waters stops flowing completely at times during the year and this lack of flow is not restricted to summer months. This low or absent flow and the accompanying detrimental affect on water quality  is not being taken into account when Waverley Planning Officers recommend applications for approval.

Who’s the Decision Maker for Water Quality?

The EA have made it very clear that Waverley Borough Council are the ultimate decision maker when it comes to approving planning applications that will have a detrimental impact on water quality.

The EA have confirmed that they are simply a REGULATOR when it comes to water quality and the Water Framework Directive (WFD) legislation, they are NOT a statutory consultee.  The difference is that a regulator cannot put in an official objection to a planning application, whereas a statutory consultee can.

The Water Framework Directive established a framework and timeline for action to improve our water quality.  Local Planning Authorities, like Waverley are meant to ensure that there is no increase in pollution and deterioration in the Cranleigh Waters.

This responsibility was clearly outlined by the EA in the Officer’s report on 22 September 2014 which accompanied the Amlets Lane planning application:

The proposed development is located in Water Framework Waterbody GB106039017810 (Cranleigh Waters). This waterbody is currently classified as “bad ecological status” as reported in the 2009 Thames River Basin Management Plan (RBMP). The WFD requires that all waterbodies be of “good ecological status” by 2027, and that there be no deterioration in the ecological status between the six-yearly RBMPs. The development must not impinge upon the host or neighbouring waterbodies ecological status nor prevent the WFD-required “good ecological status” from being attained by 2027.”

We have established that the EA as a regulator are NOT able to object to any planning applications on the grounds of water quality, however, they do and have provide ‘very strongly’ worded advice to Waverley on this subject, which as the experts in this field the planning authority must take into careful consideration.

Waverley are not Listening!

We have lost count of the times that Waverley have said that “The EA has not objected to the application” with regard to WFD and water quality.

They will not listen to us when we tell them that the EA cannot object and that it is Waverley’s responsibility (and risk) to make a decision on WFD grounds, and they will not listen to the EA who have also clearly outlined their role in the planning process.

This document has been circulated by EA: LA Engaging_with_WFD_Resource_Pack

WBC Planning Officers continue to use the absence of an objection by the EA on grounds of WFD to justify their own recommendations for significant applications in Cranleigh for approval, despite the impact on Cranleigh Waters and with the full knowledge that there is an ongoing problem with the river.

Cranleigh Waters dry up October 2015

Was the Inspector on the Berkeley Homes Appeal Wrong?

The role of the EA as a regulator with regard to WFD has recently become far more clear to us, and this places some significant doubt on the Inspector’s decision on the Berkeley Homes site:

68. The inquiry was informed by the Cranleigh Society that allowing the development to proceed could be in contravention of the Water Framework Directive, as the sewage treatment capacity is unlikely to support the anticipated increase in demand. Again, the matter has to be considered in the context of expected growth and additional homes to be provided in Cranleigh. The Environment Agency has not objected to the proposal and it would be for the statutory authorities to take the necessary measures to satisfactorily accommodate the new development.” [our emphasis]

It is not clear whether the Inspector was aware of the regulatory role of the EA with regard to WFD and their subsequent inability to object.  This places some significant doubt on the validity of this statement and subsequent decision by the Inspector.  Unfortunately it has taken some time to unearth all of this information and any further legal redress appears to be out of our reach.

However Waverley Planning Officers continue to refer the Inspector’s decision on the Berkeley Home’s Appeal, despite the fact that the EA have outlined their regulatory role, and despite significant NEW evidence being available.

This evidence was submitted to the Inspector at the time of the Appeal, however she declined to take it into account as it had become available just after the last submission date for evidence.

Waverley cannot assume that faced with this NEW evidence that the Inspector would’ve come to the same conclusion.

Five-year Housing Supply

The pressure for a 5-year housing supply by Government is driving officers to act irresponsibly and ignore pollution concerns and environmental harm in Cranleigh Waters.

Furthermore, Officers are ignoring our significant and well researched concerns about whether these sites in Cranleigh are actually deliverable within the critical 5-year period, which is the MAIN driver for approval.

The major upgrade works to the sewage treatment plant will require Ofwat funding and the next funding round is not until 2020.  If successful in securing these monies, TW then needs a minimum 3-5 years to carry out the work, with a completion date between 2023 and 2025.  That’s a minimum of 7 years’ time.

The upgrade work only covers the equipment and structures required on the sewage works site, it DOES NOT address in any way the flow problems of Cranleigh Waters or deal with the general level of pollution in the water.

We already have reports of dwindling fish stocks by the local Angling Society. And let’s not forget that the Cranleigh Waters runs into the River Wey which is relied upon for drinking water abstraction.

We believe that the significant housing planned for Cranleigh is unsustainable and will cause significant environmental harm.

We will vociferously object to the removal of any Grampian conditions, as recently requested by Cala Homes, which have been placed on the current outline planning permissions which state that no development can take place before a strategy for the sewerage infrastructure has been created and implemented.