Guest blog – How nature dies – part 2 by Alistair Gammell

Alistair Gammell worked for RSPB for 40 years and was closely involved in the drafting of the Birds and Habitats Directives and for growing RSPB’s international work. He was RSPB’s first International Director and retired from RSPB in 2009.  He then worked successfully to establish large-scale fully-protected marine reserves in the seas around the British Indian Ocean Territory and Pitcairn Island.  He is a passionate nature conservationist and fly fisherman (

Oughton Head. © Copyright Humphrey Bolton and licensed for reuse under this Creative Commons Licence.

When last December I wrote my guest blog “How nature dies”, I predicted that although Affinity Water had recently withdrawn their damaging application which threatened the River Oughton and Oughton Head Common in Hertfordshire, they would be back.  Well, less than a year later they are back, with the same proposition to build a denitrification plant and to restart groundwater pumping from the aquifer that gives life to the River Oughton and Oughton Head Common.

To recap, the Oughton River is a chalk stream in Hertfordshire. Chalk streams are a globally rare habitat, with 85% of the world’s chalk streams being in England.

Oughton Head Common is a Local Nature Reserve formed by the springs close to the source of the River Oughton.  It is one of the premier wetland sites in Hertfordshire and is the largest base rich marsh on chalk in the county.  Many of its features are priority habitat types in the Hertfordshire Biodiversity Action Plan (BAP).

The common, springs, river and associated woods used to be listed as a Site of Special Scientific Interest (SSSI) because of their wildlife richness and diversity, but this listing was withdrawn in 1970 because of the deterioration of the site due to drying out of the peat marsh and lack of water flow from the springs, both caused by water abstraction by Affinity Water and its predecessors.  However, this remains a local wildlife site and is in close proximity to the planning proposal’s site boundary.

The applicant, Affinity Water, clearly accept that both the River Oughton and Oughton Head Common are of significant importance. Their publicity film accompanying the planning application opens by saying that “Chalk streams are the UK’s rain forests or coral reefs.  In their natural healthy state, they are home to abundant precious wildlife, including grayling, brown trout, mayflies, kingfishers, otters and water voles. The River Oughton is an important chalk stream near Hitchin, in North Hertfordshire. It flows north-east between Oughton Head Common and Oughton Head Nature Reserve, a well-used and much-loved place within the local community.  Oughton Head also marks the natural spring that feeds the river with water rising from an underground layer of water-bearing rock called the aquifer.” (

Affinity water has also publicly accepted that groundwater pumping is an unsustainable practice and pledged to stop it.  In September 2020 Affinity Water’s Director of corporate affairs, Jake Rigg said: “Chalk streams are a precious part of our local and national heritage and a priceless natural resource. This is the decade where we will either protect and enhance the environment for every generation or fall further behind. We recognise this is not a new issue, but it is clear that we need to act with urgency. This is why on World Rivers Day in September, we announced that we stopped taking water from boreholes at the top of the Chess Valley and committed to end unsustainable abstraction from chalk groundwater sources in our supply area.”(

On the new planning application Affinity Water answers the question on the planning form which asks “Whether there is a reasonable likelihood of designated sites, important habitats or other biodiversity features on land adjacent or near the proposed development being adversely affected or conserved or enhanced”?  with a “no”!  The yawning gap between what they have said publicly (see the two paragraphs above) and their actions in filling out the planning form is a chasm – Low flows in chalk streams, drying out of marshes?  Nothing to do with us!

Planning applicants need to file an EIA and the accompanying EIA notes deep in the text that the adjacent LWS has the potential to be indirectly impacted via changes to hydrology, but having briefly noted it, suggests nothing further since that might suggest that the development should not go ahead and who would want to do that?

Affinity Water’s has employed a planning advocate, Dalcour Mclaren, to make the planning case for their proposal.  The resulting 24 page document tries to make the case using planning law and documents as to why this application should be given planning permission, but somehow missed those paragraphs in planning law which try to protect biodiversity or rivers, no doubt since that might suggest that the development should not go ahead and who would want to do that?

Specifically, Dalcour Mclaren somehow completely managed to miss the provisions of planning guidance paragraph 180(c) “development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists”.  Now that’s a surprise!

This important planning provision is designed to protect biodiversity, the words “such as” in the guidance are clearly there to indicate that ancient woodlands is only illustrative and that other habitats of importance/irreplaceability should be included too. So is the River Oughton an irreplaceable habitat?  Well, the applicant itself describes the River Oughton as an important chalk stream and describes chalk streams in general as the “UK’s rain forests or coral reefs”.  So clearly Affinity Water consider chalk streams as of the highest importance and under considerable threat too, and in this they are right.  Furthermore, a list of “Priority Habitats” exists drawn up as a result of work undertaken by Natural England under the provisions of Section 41 of the Natural Environment and Rural Communities (NERC) Act 2006.  This list includes chalk streams, and thus includes the River Oughton.

And there are the requirements of the Water Framework Directive.  Planning policy requires that applicants identify whether their application might have implications under the Directive, ie in this case might affect the River Oughton.  Affinity water admits in its EIA that what is proposed has the potential to impact the River Oughton and the Oughton Head Marsh, which it also accepts are habitats of immense value, but despite this, it has not undertaken any study (which should be required under planning guidance for the Water Framework Directive) to reassure itself, the public or the planning authority that what it is proposing will not damage these areas or meet the requirements of the Water Framework Directive.

How can Affinity Water possibly reconcile its words “Chalk streams are a precious part of our local and national heritage and a priceless natural resource. This is the decade where we will either protect and enhance the environment for every generation or fall further behind. We recognise this is not a new issue, but it is clear that we need to act with urgency”…..“ (We are) committed to end unsustainable abstraction from chalk groundwater sources in our supply area”, with their corporate actions, which include in this case a proposal to recommence pumping at a site that they stopped pumping 8 years ago; saying that there were no designated sites, important habitats or other biodiversity features near to their proposed site; failing to undertake any study of how their proposal might affect the river or marsh; etc etc?

At the recently concluded earth summit there was much discussion of the potential gap between the words and actions of governments and industry. 

Remember Affinity Water’s words “This is the decade where we will either protect and enhance the environment for every generation or fall further behind”.  In this application Affinity Water illustrates the yawning gap between their talk and their actions and it is in this yawning gap that nature dies.


9 Replies to “Guest blog – How nature dies – part 2 by Alistair Gammell”

  1. Quite clearly this is a planning application that should be refused. Yet will it given that the company acknowledgement of this the very habitat at risk may blind those judging it. Weasel words indeed.

  2. As you point out, we are all too familiar with ‘commitments’ that run directly counter to the actions of governments and corporations – as for example the backing of new coal mines whilst committing to phasing out coal and moving to ‘net-zero’ ghg emissions.

    It is immensely frustrating, if unsurprising, that this development has reared its head again. Hopefully, Affinity’s own words about the importance of chalk streams can help to make a successful case against them receiving planning permission. Is there anything readers of this blog can do to help block this application?

      1. Unfortunately, it appears that it is too late to comment via the portal which states the consultation period for this application is now closed. Perhaps still worth writing to NHDC though.

        I wish you luck and hope that the planning authority will see the contradiction between what Affinity says about the importance of chalk stream and what it is proposing to do and refuse the application accordingly.

  3. Again a proposal on the basis demand has to be met rather than examined then reduced – of course the former tends to be more in the line with making money, the latter with living within our means and the planet’s. I wonder how much water is being used by people Karcher power washing their drives and patios which seems to be the new golf given the weekends spent doing it. There’s some exciting new technology that might mean the water used in showers can be recycled so that you’re reusing the same water (with gritty bits extracted of course) from the start of your shower and it will also need far less energy to reheat to the required temperature.

    Great stuff and there’s so much else that could reduce our consumption, but pissing in the wind if on the whole you have a society that doesn’t know and/or doesn’t care, for example, that using high pressure water to clear weeds and dirt off the drive is helping to kill rivers at source, and not turning the tap off when you’re brushing your teeth doesn’t help either. Water is a material resource just like timber, aluminium or food – reduce, reuse, recycle should be the order of play, but yet again that basic awareness is missing in action.

    Great guest blog, the 20th century father of angling Richard Walker grew up by the Oughton. I wonder how much it’s already changed since he was a wee boy catching tiddlers there, and how much further could the bar drop before ‘enough is enough’ is finally called.

    1. Things have got worse, since the SSSI denotification is an official admission of the degradation of these habitats. In fact they got so bad that a river augmentation scheme was put in place about 30 years ago because allowing the river to run dry was pretty obviously a catastrophe. But the flow remains much reduced on what it naturally would be. Can I suggest you write to the CEO of Affinity Water suggesting that they undertake a study involving suitable conservation NGOs of what would be needed to bring the Oughton River and the Oughton common marsh back into good status under the Water Framework Directive and then implement those actions as an essential companion to their groundwater pumping actions. Thanks

      1. Will do! I worked on a farm in Suffolk that had an abstraction licence to irrigate hop plants from the already low and eutrophic river Gipping. Some water was piped in to the polytunnels for the young cuttings. At the same time any rain that fell on the expansive area of polythene just pooled where the tunnels met the ground with the result that the farm yard was ankle deep in mud which was an utter pain. A very basic system to collect rainwater falling on the polytunnels and redirect it to help supply water to their plants would have been a boon in more ways than one. I’ve seen similar issues at festivals. The opportunities for reducing waste/consumption are enormous, they’re all around us, the lack of awareness/action in exploiting them infuriating.

  4. Not sure if this helps but a couple of weeks ago I attended a final planning meeting that refused permission for Egdon Resources to drill for oil in the Lincolnshire Wolds.
    The relevance is that part of the consideration for refusal was down to the possibility of it affecting an important local chalk stream.

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