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Southern Water public consultation

In September, Southern Water (SW) launched a public consultation on its draft Drainage and Wastewater Management Plans (DWMP) and Strategic Environmental Assessment (SEA) Scoping Report.  The consultation runs from Sept. 21 until midnight on Oct. 26.  Details and the online consultation questionnaire are at https://www.southernwater.co.uk/dwmp/have-your-say.  The Faversham Society’s position on the consultation is as follows:

The main issue for Faversham is water quality in Faversham Creek as a result of discharges from the Faversham Wastewater Treatment Works (WTW).  Even under normal operating conditions, treated effluent from the WTW affects water quality along the entire length of the Creek because it is swept upstream on incoming tides, leaves residues as far up as the Tidal Basin, and is not flushed out immediately into the Swale and beyond.  Although the discharges are treated to a relatively low standard, they comply with Environment Agency (EA) discharge consent and so, as far as the EA, OFWAT and Southern Water are concerned, there’s no problem.

Water quality is poor enough, however, that the recreational use of Faversham Creek for swimming, dinghy sailing, rafting, etc., is impossible and will remain so until either regulation is tightened to require effluent from the WTW to be purified to a higher quality (which is determined by the EA, not SW) and/or the Faversham WTW is upgraded so that effluent can be pumped directly into the Swale instead of the Creek.

Under heavy rainfall conditions, storm tanks at the Faversham WTW are designed to store the increased influx of rainwater and wastewater until it can be treated when normal conditions return.  Once the storm tanks are full, however, the resulting overflow – including untreated sewage – is discharged directly into the surrounding environment.

Regarding recreational use, there is very little mention in the SW consultation documents of either public interest or local communities.  Instead, SW is driven by the regulatory texts governing the activities of water companies nationally.  It appears to consider its clients to be the regulatory agencies rather than the private, residential customers who provide most of its income.

Our understanding from previous interactions with SW is that Faversham WTW is approaching the limits of its processing capacity.  Partly as a result, SW recently announced a £2m upgrade of the Faversham WTW infrastructure to reduce the risk of raw sewage discharges and increase processing capacity.  While the new investment is welcome, it will not be sufficient to resolve the problems presented above.

It is not clear either whether the planned upgrade will be sufficient to cope with the increased volume of wastewater that will result from the current expansion of residential housing in and around Faversham.  Rather than increasing the capacity of a facility that is inherently flawed, the Faversham Society urges SW and regulators to think in terms of a more comprehensive upgrade that would see effluent from the WTW discharged via a new pipeline straight into the Swale to a standard that would meet all the relevant European Directives (which still apply).

Over 75% of the world’s chalk streams are found in southeast England.  Many are in poor condition as a result of uncontrolled pollution.  While there are multiple mentions in the SEA of chalk streams as a priority habitat for protection, there is no mention in the DWMP documentation of Faversham chalk streams, notably Thorn Creek and Cooksditch, which both received discharges of raw sewage as a result of the heavy rainfall in August.  We have been unable to locate, on the SW website, the maps that are supposed to be part of the DWMP consultation.  We suspect that the storm tanks at Faversham WTW discharge directly into Thorn Creek and know that, under storm conditions, a SW pumping station near Gordon Square discharges raw sewage into Cooksditch.  As a top priority, both structures must be upgraded to avoid such discharges in future.

There is also very little mention in the SW consultation documents of the impacts of Faversham WTW on shellfish, despite the fact that both Central Swale and East Swale are designated as Shellfish Waters under DEFRA’s Water Framework Directive.  Untreated sewage discharges from Faversham WTW cause inevitable concerns both about the consumption of shellfish caught or farmed in nearby waters and about the safety of swimming at Seasalter beach, favoured by many Faversham residents, let alone in Faversham Creek itself.

Finally, like any other public consultation, it’s important to make sure that this is not just a box-ticking exercise and to make the most of this opportunity to let Southern Water know the views of their customers in the North Kent Catchment.  We hope the information summarised here will be picked up on as well by a wide range of local stakeholders in both the public and private sectors.

October 26, 2021

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