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1. The Canterbury District Committee of CPRE Kent strongly supports the detailed case made by CPRE Kent, but wishes to add its concerns to that objection.

2. Canterbury District Committee has particular interest in the Thanet wastewater proposals because Canterbury is the potential site for a reservoir if excessive unsustainable housing is allowed. Also the CPRE with the local Parish Council and amenity society were major participants in the reservoir Inquiry which heard evidence supporting inland treatment of Thanet's effluent to enable reuse.

3. We are very pleased that Southern Water proposes to improve the treatment of effluent from Margate and Broadstairs by using the Weatherlees facility , but we are surprised and concerned that Southern Water proposes to dispose of the treated effluent to sea, rather than discharging inland which would benefit of the river and hence increase available water resources.

4. We are pleased to see that Southern Water is funding a new conservation post within the Thanet Coast Partnership aimed at promoting the environment and the marine benefits of the Thanet coastline. We believe that support should be carried through to protect and improve the coastline by using inland discharge.

5. Discharging from Foreness point requires new sea discharge pipe work disturbing the shore and sea bed, thus affecting the very marine ecosystems that the new conservation post is designed to protect! Avoiding a new sea outfall would save the cost of this work-

6. It is disappointing that the major investment in works completed between 1985 and 1990 now needs augmenting. The original suggestion of inland treatment and discharge was made at the Broad Oak Inquiry. If that had been followed we believe considerable cost savings could have been made. As customers ultimately pay for this, we trust that the short term answer of sea discharge was not chosen as a quick fix that will cost more in the longer term.

7. We note that one of the four short listed options was in fact for release of treated water into the River Stour .

8. We support this option because it would maintain the flow in the river- not only for environmental benefit but also to support boats on the river, and to maintain channels. Discharging to the River would ensure higher average levels of fresh water in the river, with benefits to the riverine ecology .In addition the additional water would reduce problems with boats going aground when river flows are low. The river downstream of the discharge would have a greater average flow and this would reduce silting of the river.

9. The evidence provided by CPRE Kent shows that the treatment to meet the required standard for inland discharge is not only feasible, but also cost-effective, especially when all the benefits are included in the comparison.

10. Discharge to the river would provide a relatively constant additional flow in the river to reduce the increasing fluctuations in river flow due to climate change.

11. Rising sea level means risk of salty sea water moving up-river thus poisoning the marshes beside the river. A major aspect of the 1979 Broad Oak Reservoir Inquiry was concerned with marsh feeding. Marsh feeding is the process whereby ditches in the area beside the river are fed with water from the river .This serves two purposes for agriculture - one is for 'wet fences' for animals, the other is for irrigating the crops. While 'wet fencing' could use saline water, crop irrigation needs low salinity otherwise adverse effects occur. Providing more fresh water in the river reduces the salinity of the river water. Discharging the treated effluent to the river would reduce saline intrusion, and hence would enable marsh feeding to continue for longer, with corresponding benefits to agriculture. This would also help maintain the ecology of the ditches.

12. The proposed scheme has two pipelines connecting to Weatherlees. If the discharge were to the River, then Southern Water could still install two pipes, but with both being used for flows to Weatherlees they would provide several benefits:
    A Peak flows using two pipes would avoid or significantly reduce storm flow discharges to the sea. Having that capacity could avoid or reduce the size of, storm water tanks at Foreness point.
    B having two pipes would enable one to be closed if a blockage or leak developed in one pipe. As we are dealing with sewage, a blockage is always a possibility .Leakage is less likely, but is still possible.
    C having two pipes means that pumping energy would be less as backpressure would be lower than for a single pipe

13. Storm water discharges are an issue of which Southern Water should have been aware for a long time, and should have been pro-active in managing. As storm events are predicted to increase due to climate change, it is even more important that foul sewage and rain water systems are separated. While it is appreciated that changing the drainage systems in existing houses may be difficult, this does not preclude action to highlight the benefits to consumers of separating drainage systems, not only by way of saving money, but also the wider benefits. In addition much of the problem is due to infiltration into sewers due to leaking pipes and poor manholes. This is an area more within the control of Southern Water and so easier to manage. So far we have no convincing evidence of action by Southern Water to significantly reduce this problem.

14. The Government has been pressing for new houses to be more sustainable, and this includes reducing water use as well as making use of rainwater harvesting systems. In this water-short area, Southern Water should therefore be ensuring that such low water use systems are installed, as well as the use of rainwater and grey water systems. Again evidence for such action seems scant, but calculations of effluent load should include greater use of low water use systems. Additionally rainwater harvesting systems would assist in reducing storm water flows.

15. We are particularly concerned about pumping the treated effluent back to Foreness point because it represents additional, and unnecessary, wasted energy in pumping. In view of everyone's efforts to reduce global warming emissions, pumping should be minimised.

16. We trust that the benefits of anaerobic digestion, generating methane which can be used for electricity generation, will be used, to help counter-act the climate change impacts of the system.

17. Finally the Richborough power station site is currently unused, except for the wind generator. However at least two potential users have been interested in the site to restart electricity generation. The benefit of this is that the waste heat from power generation could be used for low cost desalination, and this is another potential long- term use for the Weatherlees effluent. Desalination becomes much cheaper as salinity decreases, and with the use of waste heat from power generation desalination becomes even cheaper and less energy intensive. As Folkestone and Dover Water Company are already installing 'ordinary' desalination plant for peak demands, it is clear that this is an option that needs to be kept available. Hence the effluent needs to be kept in the Weatherlees area.

18. We therefore trust that the County Council will refuse permission both for the pumping of effluent back to Thanet and for its discharge to sea, and will instead support and require inland discharge of the treated effluent.