The Branch was again very successfully represented at this year's Michelham, Priory Game & Country Fair. 

The Branch stand, sponsored by Environment Agency, Hardy Greys and Sportfish proved very popular with anglers and potential anglers of all ages, giving our Team of volunteers little respite over the two days.   Casting demonstrations (two per day) were given by Brian Smart of Hardy Greys  Acadamy.  Our team of coaches were hard pressed to satisfy the queues of people wanting to have-a-go at fly casting, together with a number looking for lessons and tips to correct casting faults.  Other visitors were keen to know about S&TA and fishing generally and our band of willing workers were on hand to answer their queries and to give advice on fishing and where to fish.  A number of anglers submitted their names to the waiting list for our very successful Trouting Syndicate - six lakes set in the heart of Sussex - where we also run our Beginners and Improvers courses.

For a slide show of the event click here (courtesy of Paul Cumbers)

The South of England Agricultural Society organised a "Kids Meet the Countryside" event at the Ardingly Showground on 13th July.   Volunteers from the Branch were in attendance to provide casting "Have A Go" on the showground's pond.    With over 2000 school children (mainly Year 6) visiting the event, we estimate that some 700 had a go.   The Environment Agency and the Fly Dressers Guild were also in attendance and collectively we were able to promote the benefits and pleasures of fishing generally.

Our Volunteers were hard pressed to keep up with the demand for "Have a Go" and our Coaches/Helpers had to work flat out.   Well done and thanks to Mark Brown, Mathew Cumber, Bob Hales, Alan Purnell, Brian Raw, Brian Smart & Tom Todd.

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East/West Branch Invitation - Yew Tree Fishery 1 May 2006

Despite the very disappointing attendance, the day was most enjoyable, thanks to the few stalwarts who braved the inclement weather in the morning.

The setting at Yew Tree could not be better and no one failed to catch.    The best fish was caught by Dr  J St Pierre (Sam) - a magnificent 3lb+ Brown trout and the best bag went to Brian Raw (7lb+).    The latter catch could not be more deserved given the effort that Brian had put in to ensure the day was successful.   There were one or two members who understandably had to withdraw because of illness, but others who had promised their attendance and simply did not show, not only missed a great day's fishing but more importantly, let their colleagues down badly.  Consequently, the Branch is somewhat out of pocket and we will have to ensure that for any future events, payment is received up front.

For pictures of the day (kindly taken by Paul Cumbers) click here.

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Sussex Fly Dressers' Guild

                                                               Chairman: John Plowman

                                                      "The Garden House", 246, High Street,

                                                          Uckfield, East Sussex. TN22 1RE

                                                                   Phone: 01825 762975

                                                           Email: beehives@btintemet.com

Dear Tom,

It has fallen to me to organise the Charity Pairs boat fishing competition at Bewl on 8th. October this year.

Below I have added the application form which I would be grateful if you would copy as many as you need.

The price is based on two anglers sharing a boat with a full day ticket each.

Fishing will start at 9.00 am and weigh in is at 5pm. Anglers may continue to fish after weigh in up to the

reservoir closing time. 

In fairness to the Bewl staff I will stick strictly to the closing date for entries. Any late entries will be

welcome provided they book their own boats and make a donation to the charity funds. 

I look forward to meeting you there and hope for good weather.

Yours sincerely,

John Plowman)

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Salmon & Trout Association

Southern Region

presents

‘THE FUTURE OF THE ANGLING ENVIRONMENT’

Open Meeting for all anglers

To be held at

The Felbridge Hotel, London Road, East Grinstead, West Sussex, RH19 2BH

on

Wednesday 29^th March 2006 at 7pm

Speakers:

Charles Jardine

‘Adapting to change in the modern aquatic environment’

Paul Knight

‘Salmon & Trout Association

 – Protecting angling and the environment’

Followed by an

OPEN FORUM

Panellists to include:

Paul Knight, Charles Jardine and Richard Hammond from the Environment Agency

Your chance to question the panellists

ALL WELCOME

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Dear Member,

 It seems hardly possible that another year has passed already.   In many respects, from a fishing angle (pun not intended), it is perhaps a year best forgotten.   Whilst we must not begrudge others the beautifully warm and extended summer,   our sport suffered as a consequence.   Low river flows, depleted reservoirs, rampant weed and algae growth, together with long spells of bright sunshine, made fishing very difficult.   Such conditions are being forecast as the norm by many experts and if their predictions are true, the future of game fishing in our part of the world does start to appear to be unsustainable for future generations.        

 Apart from the weather, the threats mentioned in previous newsletters, remain.    Increasing demands for water continue to threaten our river systems and place pressure on our underground supplies.   Treatment of waste and disposal of rubbish jeopardises water quality, whilst a perceived need to build more and more homes in the South East adds to the overall burden on an already stretched and valuable resource. 

 However, it is not all bad news.   The Branch representations, together with those of other interested bodies, were instrumental in Lloyds Environmental withdrawing their planning application for a hazardous waste landfill and materials recycling plant at South Chailey.   This has been a notable achievement but one which is not yet finalised; Lloyds have declared their intention to re-submit amended plans in the near future.   We have been able to donate funds to The Sussex Ouse Conservation Society for the purchase of equipment to help in their monitoring and analysis of water quality.    We were able to provide some financial assistance to the Bevern Residents Association in their fight against Lloyds’ proposals.   Additionally, we also made a contribution to HQ to help in the publication of the Brown Trout Big Book which will be distributed to all schools, hopefully educating as well as encouraging youngsters into game fishing.

 We were well represented at the Michelham Game & Country Fair in July.   The venue proved to be excellent and our stand attracted a constant stream of visitors, many of whom queued to “Have A Go” at fly casting.    We made a large number of new friends and had a marvellous couple of days.  Branch Membership is still at the 400 mark in round terms.  Over the year we recruited 19 new members but during the same period, lost 45.   Of those, 24 are “lapsed”.    If you have inadvertently forgotten to renew your membership, please do so now.    Remember, the healthier our membership, the better able we are as an Association, to continue to lobby on those issues which matter to Game angling.

 For regular news updates throughout the year visit the Branch website at www.east-sussex-sta.org.uk.

 Branch Organiser

 We welcome Peter Langton as our new Branch Organiser.    Peter is still finding his feet, but is already making a difference.   Peter’s contact details are on this year’s programme

 2006 Programme

 The 2006 programme is enclosed with this letter.   Our first event is the AGM on 3 February 2006, again at the excellent Wellshurst Golf & Country Club near Hellingly. It would be great to see a good attendance. 

 Sussex Ouse Conservation Society

 S.O.C.S. has continued to realise its aims and objectives for the protection and enhancement of the Ouse Catchment over the past year.   The Society has remained financially secure and membership is slightly up on last year.

 The Task Force has continued with a regular programme of debris clearing and stream management and is expanding its areas of operation to other streams in the system.

 The Water Testing Team has continued with its endeavours and sampling on the main river has been extended to Sheffield Mill and Scaynes Hill. Unfortunately our analytical chemist, Peter Symonds, has recently ceased analysing our samples, due to pressure from other commitments. We are extremely grateful for the work that Peter has done for us in the past and wish him well with his new venture. Sample analysis has now been taken on by the S.O.C.S. Director, relying on an antique qualification in A level chemistry and thus on a steep learning curve. So far, he seems to be coping.   Biological monitoring continues with two sampling teams. The results (as for chemical analyses) are published on our website.

 S.O.C.S has also continued with its Schools Education Programme and this year we had a combined exercise with Hamsey and St. Peter’s (Chailey) primary schools which featured Dr. Richard Osmond’s HI-TECH WILD TREK trailer for live video of collected specimens. We are grateful to South East Water who generously sponsored this event.

 Our involvement with Dr. Elizabeth Hill’s study into the effects of hormonal contamination of the Ouse on living organisms is well established. We have been collecting samples of bivalve molluscs for evaluation in the University of Sussex unit.

Our support for Hannah Rei with her degree dissertation on the Bevern Stream paid handsome dividends. Hannah has produced an impressive report detailing the effects of effluents on the ecology of this stream. A copy has been sent to the Environment Agency and we hope it will encourage some action on the problems faced. We are delighted to hear that Hannah won the prize for the best dissertation in her year, an accolade well deserved.

 We exhibited again at the South of England Show together with Dr. Osmond and his trailer, by kind permission of the South of England Agricultural Society, and we have continued to give presentations on our work at the Uckfield Environment Exhibition, Sussex Biodiversity Records Centre Annual Seminar, Plumpton College Open Day Parish Council annual meetings and local village events.  We also provided teas again at the Mount Harry Garden Open day on 15^th May. This is always a most pleasurable exercise and we are extremely grateful to Lord and Lady Renton for regularly inviting us. The next Open Garden Day at Mount Harry is on Sunday 21^st May 2006; well worth a visit.

 The Stakeholder Committee of the Adur and Ouse Catchment Abstraction Management Strategy (CAMS), on which I represented S.O.C.S. and the Branch, published its strategy report in March 2005. It illustrates the problems we face due to scarce water resources in our area and we hope that the strategy will aid the husbanding of this precious commodity.

 The work undertaken by S.O.C.S. has a direct beneficial effect on the quality of your fishing. We value your support and are always pleased to welcome new members. Membership is only £10 per annum and you will receive our quarterly newsletter. It’s not just your money we are after, the more members we have, the more influence we gain. For details of what we do and information about joining us, please visit our website at www.sussex-ouse.org.uk or alternatively give me a call on 01273 400093.

 “Sam” St.Pierre – Director

 Trouting Syndicate

 After a number of false starts, work to improve the access path from the gate to the fishing hut was completed in November.   Subscriptions, however, have been increased to £190 for the season, in order to help fund future improvements.   As a trial we have decided to start our season on 1 March this year, finishing as usual on 31 October.

 Water Resources

 We are facing the same problems upon which I reported in 2004, only worse. As I write this in mid November, we are still subject to a hosepipe ban, which really says it all. A combination of low rainfall and increasing demand has precipitated this situation. Those of you who fish at Cinder Hill will have noticed how the feeder dried up this summer and this has happened in many of the tributaries of the River Ouse. Lack of flow leads to a rise in water temperature, depletion of oxygen and concentration of pollutants, which all take their toll. These factors no doubt contributed to the Argulus (fish louse) infestation experienced at Cinder Hill towards the end of the season.

 Your Branch continues to keep a watchful eye on discharge consents and we robustly lobby for higher standards to protect our fisheries. We are also active in pressing for more sustainable policies regarding the abstraction of water for potable use, irrigation etc. I just hope that we get more rain in 2006.

As there was no one else foolish enough to volunteer, I applied for a seat on the Environment Agency’s Regional Fisheries Ecology & Recreation Advisory Committee (RFERAC), to which I have been duly appointed. So far, it has proved a useful forum for me to voice our concerns. I am told that the Agency does take the views of the committee seriously. I hope this is so, as it will make the effort worthwhile.

 “Sam” St.Pierre – Water Resources Officer

 Acknowledgements

 Thanks go as always to everyone who has continued to give of their time in helping the Branch at various events and functions.  Particular thanks go to Paul Cumbers, Robert Nathan and Graham Mortimore for organising our stand at the Michelham Priory Game & Country Fare.   Together with our sponsors, Caffyns and Sportfish, they made our presence one of the most successful I can remember.  A big thank you to the Branch Committee for their invaluable input and sterling efforts.  Also thanks to all the volunteers who help keep Cinder Hill neat and tidy throughout the season, especially to Brian Raw and to Ron Staplehurst, who has single-handed tidied and improved the fishing hut.

 If you would like to have an input to the running of the Branch, then why not volunteer as a Committee Member?   We are always on the look out for new blood and fresh ideas.  Let’s hear from you at the AGM.

 Best wishes to you and your families for 2006 and tight lines.

 Yours sincerely,

Tom Todd

Chairman

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CINDER HILL 2005 NEWSLETTER

 Dear Fellow Members,

Those of you with the “cormorant’s eye” will note that I live quite close to Cinder Hill, about 10 minutes drive on a bad day.  I am sure this is what John Masters spotted when he asked me to take over his “stocking role”.

We are at the end of my first year of office, which seems to have gone in a flash of silver, turning rapidly red towards the middle of the year.

The weather and fish quality have given me a steep learning curve and I am grateful to all of you for comments, help and guidance.  I stress I am only a humble fisherman and no scientist.

The weather has given us low water, no oxygen, weed and freshwater lice.  Add to this a problem of gravid fish in several deliveries and you can imagine my uncertainties at such an inauspicious start in the job.  However, we have a new fish supplier and there were much better catches and quality towards the end of the season.

The release programme is already set out for next season although this may be brought forward if our season begins early.  I have planned much lower stocking levels for July and August to try and avoid a repetition of previous years’ drought conditions.  This is probably a recipe for full flood all year!  There will also be a slight shift in weights, which I hope will avoid some of the more disappointing catches.  It is worth remembering that the residue of this year’s poor quality fish may still show in some of next year’s catches.  That’s fishing!

I am sure we will all thank John for his sterling efforts over the past eight years, and I continue with thanks to Bill Impey for his regular catch records.  I have not repeated the help rota for release days because our new supplier is more than happy to aid me in the job, thus making the whole thing a very easy and interesting exercise.

My ‘phone number is at the top of this note and please do feel free to call me with ANY comments you may wish to make.  I wish you all a Merry Christmas and a good season for 2006 and I look forward to meeting more of you on the waterside.

Peter Neave

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THE BROWN TROUT BIG BOOK

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Lloyds

ENVIRONMENTAL WASTE MANAGE.MENT LTD

llead Office: Old Flamso, Brickworks South Cliailev Nr Lewes East Sussex BN8 4Q1)

Tel: (0 1273) 401888 Fax: (0 1273) 401999 w\vks,.llo\,dsenvironiiicntal.co.uk info,a 11(~ydsenx,ir(~nmental.co.uk

1 August 2005

Dear Sir/Madam

I am writing to inform you that, following consideration of the officer's report to East Sussex County Planning and Highways Sub Committee on August 3, we have decided to withdraw our planning application for a Materials Recycling Facility and specialist landfill site. 

While we are obviously disappointed with the recommendation made in the report to refuse the application, we continue to believe that the integrated approach we proposed offered a sensible, local solution to the serious problems of waste disposal faced by both local authorities and waste producers in East Sussex.

 Certainly, tougher environmental legislation means the problem of waste disposal still needs to be addressed ‑ we all create waste and we all share a responsibility for dealing with it.

 We will now look closely at the conclusions drawn in the report to the committee. It is our intention to re‑submit a revised planning application in the coming months.

 Having consulted very widely on this project I would like to thank everyone who has taken part in the process. The Lloyds Environmental team will keep these lines of communication open while we review how best to move our proposals forward.

Yours faithfully

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Stewart Glassar

Case Officer

Department of Transport and Environment

County Hall

St. Anne’s Crescent

Lewes BN7 1UE.

 4^th July 2005

 Dear Mr Glassar

 Re Application LW/424/CM(EIM) – Non hazardous and stable non-reactive

Hazardous waste landfill site and materials recovery facility

Old Hamsey Brickworks, South Chailey.

The Sussex Ouse Conservation Society, (S.O.C.S.) has previously written to you in respect of the above facility, we continue to oppose the granting of planning consent for it on the grounds set out below. We have reviewed the further information provided by the developer's consultants (Robert Long Consultancy) in their response to your letter of 21^st March 2005 and remain of the opinion that there still has been no proper evaluation of potential impacts upon the Bevern Stream, a tributary of the Sussex Ouse. Our objections continue to relate primarily to the landfill component of the proposed development. Because of the Society's remit our comments are restricted primarily to how the Bevern Stream may be affected by the development. We would, however, again note our continuing concern about the Environmental Statement in its entirety as, while the response to your letter of 21^st March does clarify certain issues, we still consider it to be a seriously flawed document.  

We wish to draw you attention to the following outstanding issues, which are not, or are inadequately addressed in the Response to Consultations provided by the Robert Long Consultancy, or in the initial Environmental Statement (ES): 

1)  In spite of the additional information provided there remains ambiguity as to exactly what is proposed for the site, and this still includes there being no clear account of what is proposed with respect to the management and treatment of leachate. The Response to Consultations states (pg 22, 5.17) that “the ES is clear that there will be no effluent discharges or run-off from the site into controlled watercourses during the operational period” and again (pg 23, 5.17) “The ES is clear that there will be no effluent discharge from the site into surface watercourses during the operational period”. These assertions are inaccurate because it is stated in the initial ES (Non Technical Summary, pg 5) that leachate will either “be taken off site in tankers to a suitable sewage treatment works, or treated in the on-site liquid waste treatment plant” (which ultimately discharges into the Bevern stream). This anomaly indicates that the Robert Long Consultancy, in drafting their response, appear unaware of what they themselves drafted in the initial ES, or of what is actually proposed with respect to leachate management at the site. Given that leachate generation and management is one of the most significant aspects of landfill operation, a lack of consideration of the impact of its disposal/discharge is a very serious omission. Additionally, we remain concerned that the statement in the initial ES that the leachate could be “treated in the on-site liquid waste treatment plant” does not represent a valid treatment option, as the liquid waste treatment plant could not be constructed in the form for which planning permission has been given, if planning consent was also granted for the landfill. While Robert Long Consultants have (partially) clarified the situation in their Response to Consultations with respect to the exact location of the liquid waste plant relative to the landfill facility, it still appears to us that it cannot, as stated in the existing planning consent, discharge into the old brick pit as this will be the site of the landfill operation.  

2) The primary concern for S.O.C.S. remains that the proposed landfill is in close proximity to the Bevern Stream (and an un-named tributary of it) and may adversely affect it, either by a   direct or indirect discharge of leachate generated by the site, by a failure of on-site leachate management or an accidental spillage, or by a failure of the integrity of the landfill lining. The initial  Environmental Statement briefly acknowledged both the proximity to the Bevern Stream (stated to be 180m at its closest) and the option of discharging treated leachate to it (via the liquid waste treatment plant), but failed to make any assessment of potential impacts upon it. In the Environmental Statement (which runs to several hundred pages) only a few lines were devoted specifically to the Bevern Stream, contrasting with other issues, some of which, e.g. landscape impacts were covered in depth. This rendered the Environmental Statement overall unbalanced as a document. No qualitative or quantitative data relating to water quality in the Bevern Stream, or to its ecological characteristics, were presented. This must be regarded as a highly significant omission given the proximity of the development to the stream, and the stream’s ecological importance. The further information provided by the Robert Long Consultancy in the Response to Consultations provides absolutely no information whatsoever in respect of these issues and this fundamental deficiency in the scope of the ES remains uncorrected. 

The Environmental Statement actually quotes (Appendix 2, 4.20) the advice of the Environment Agency that “The EIA should therefore include an investigation into flood risk issues and potential chemical and biological impacts on the nearby watercourses”. No such investigation of chemical or biological impacts was included in the Environmental Statement. The Robert Long Consultancy’s  Response to Consultations does address, (section 12), at least some of the Agency’s concerns in respect of flood risk and there is some limited information provided with respect to the ponds on site. However, there is again absolutely no consideration of any discharge to, or potential impact on, the Bevern Stream.  This consistent failure to address potential impacts upon it is particularly incongruous given that the Bevern is probably the most important spawning stream for sea trout in the Sussex Ouse catchment; Environment Agency reports (e.g.OUSE01/OU27) state that “The Bevern Stream is a well known sea trout water……The importance of the Bevern Stream lies in its suitability as a salmonids spawning ground, accounting for a large proportion of the Sussex area salmonid population”. There is no indication that those responsible for preparing the Environmental Statement or Response to Consultations were aware of this fact, and there remains no consideration whatsoever of how the sea trout stock (and other fish species) could be affected. 

There is, in fact, no reference to fish of any species (or indeed any fauna or flora) being present in the Bevern Stream. The fish population of the river is actually relatively well documented, including in the Environment Agency reports referred to above, and such data should have been, but was not, drawn upon by those who prepared the Environmental Statement. 

The Bevern Stream must be regarded as one of the most important sea trout spawning grounds, not just in Sussex, but in the whole of lowland South and East England. With  fish passes scheduled for construction on Redbridge and Clappers weirs on the lower Bevern in 2005, to facilitate access to the stream for adult sea trout migrating upstream, there is the prospect of even greater runs of sea trout entering the stream from autumn 2005 onwards, and its importance increasing still further. The sea trout of the Sussex Ouse catchment are exceptionally large fish, and individuals of 5kg or more are regularly observed spawning in the Bevern Stream.   

We again note that the Bevern Stream receives most of its base flow from the Chalk aquifer. While around Bevern Bridge it flows over Weald clay, it does retain partial chalkstream characteristics at this point and its upstream tributaries, particularly the Plumpton Mill Stream are in their upper reaches essentially pure chalkstream habitats. The Roman’s winterbourne, which enters the Bevern just upstream of the proposed development site, is a classic chalk winterbourne. These chalkstream habitats are in their own right important sea trout spawning grounds and any pollution of the main Bevern Stream could affect the upstream migration of adults to, or downstream migration of smolts from them, thus affecting their ecology. Chalkstreams are priority habitats and potential impacts upon them should be identified and evaluated when they could be affected by a proposed development. No such evaluation was made within the Environmental Statement, nor has this omission subsequently been remedied. 

3)  The ecological assessment was presented as Appendix 9 of the Environmental Statement. It was stated (Appendix. 9, 3.1) that the study area included all the land within the application site boundary together with an area of woodland to the east. Restricting the boundary for ecological assessment to the site boundary was entirely inappropriate as this excludes any consideration of ecological impacts on the Bevern Stream, which may receive a direct discharge of treated leachate, or could be polluted following a failure of the landfill liner or accidental release of leachate. Given that the initial Environmental Statement acknowledged (contrary to Robert Longs assertations in their Response to Consultations; see point 1) above) that treated leachate may be discharged, via the liquid waste treatment plant into the Bevern, it is quite extraordinary that there is no consideration given to the ecology of the Bevern Stream, or how this may be impacted by the development. This omission is simply incompatible with proper Environmental Impact Assessment practice. The stretch of the stream around Bevern Bridge is of particular importance for sea trout spawning. Juvenile salmonids are very sensitive to pollution and any potential impact upon them should have been rigorously assessed. It should also have been recognised that any effect on sea trout spawning in the Bevern could, given the stream’s particular importance, have a significant impact on the sea trout stock of the Ouse catchment overall, and on the significant recreational fishery for sea trout dependent on it. The Sussex Ouse consistently has the highest annual rod catch of sea trout for any river entering the several hundred km long stretch of coast between the Itchen in Southampton and Yorkshire Esk at Whitby.

In addition to the sea trout stock, other fish species of particular conservation significance are present in the Bevern Stream, including a large population of bullhead. Twaite shad are being recorded in increasing numbers in the main Sussex Ouse around Barcombe, and there are also well documented spawning populations of sea and river lampreys at Barcombe Mills. Any serious pollution incident arising from the proposed development could potentially impact upon these ecologically valuable populations in the Ouse itself. The extent to which pollution of a tributary of the Ouse can impact upon the fish stocks of the main river is graphically illustrated by an incident in 2001, when small quantities of a pesticide pollutant entered the Ouse at Sheffield Park Bridge via the Pellingford Brook, resulting in an estimated (by the Environment Agency) 80% mortality of the river’s fish stock as far downstream as the tidal reaches. There is a clear indication in the Robert Longs Consultancy’s Response to Consultations that the methodology employed in undertaking the Environmental Assessment is flawed with respect to determining to what distance from the development site potential impacts should be evaluated. It is stated (pg 22; 5.16) that consideration of any impact on the Barcombe Mills Water Treatment Works was omitted as at c.4km from the proposed site it fell outside the “normal” radius of enquiry for receptors. In conducting an environmental assessment proper consideration should be given to how far impacts may extend, rather than relying on arbitrary cut off points.  

4) The Surface and Groundwater Impact assessment (Appendix. 12 of the initial Environmental Statement) provided absolutely no data whatsoever on prevailing chemical water quality in the Bevern stream and made no proper assessment of what impact on chemical water quality a discharge of treated leachate would have. The Response to Consultations similarly provides no information on this. There is also no proper assessment of what the impact of a failure of the liner, or other plant or management failure allowing leachate to escape, would be on the Bevern Stream. There could be potentially serious releases of leachate during both the operational and post-operational phases of the development. There is reference in the Response to Consultations (pg 22, 5.13) that the PPC application will address the impact of long-term migration of leachate, however it would be good practice for this to be addressed in the ES itself, rather than deferring its consideration.  

There remains inadequate information in the Environmental Assessment and Response to Consultations to determine the full range of scenarios during individual development phases which could lead to such a release (in particular because there is still no proper account of leachate management), but given the close proximity to the Bevern stream it is entirely plausible that, should a spillage or other release of leachate occur, it will enter the stream. Depending on the severity of such a pollution incident, its impact could extend downstream to the main Sussex Ouse.  The possibility of a pollution incident is tacitly acknowledged in the Response to Consultations (pg 22, 5.18), in the context of an impact upon the Barcombe Mills Water Treatment Works.  However, there is no attempt to consider what impact any such pollution may have on the ecology of the Bevern Stream itself. 

5)  Rather than establishing existing water quality in the Bevern Stream, as a baseline for impact prediction, and then properly assessing impacts upon its water quality, which would be normal practice in conducting an environmental impact assessment, the Environmental Statement places an over-reliance on the monitoring of water quality once the development is in place.  The Environmental Statement noted (Appendix 12, 2.99&2.1000) that there will be monitoring of the Bevern Stream and its un-named tributary stream to the east of the development, but to simply state that water quality will be “monitored” (with no proper details provided as to what parameters will be monitored) is inadequate and there is no contingency presented for mitigating any impact on the stream should monitoring detect a problem. This inadequacy is not addressed by the Response to Consultations.   

6) The groundwater impact assessment in the initial ES identified, but did not follow through, a potential pathway via which leachate could migrate from the landfill to the Bevern Stream.  The Environmental Statement recognised (Appendix 12, 2.95) that “the confined sand unit to the south and east of the site remains a plausible receptor that could be affected by the landfill development…….The un-named surface stream east of the site may intersect the sand unit and it is considered that any further risk assessment work should concentrate on the sand unit and its relation to the proposed landfill in terms of potential leachate migration into the groundwater within the sand, and then any relationship between the sand unit (e.g. spring discharges) and water flow in the stream”. The Response to Consultations does not provide a detailed risk assessment. The purpose of an Environmental Statement is to provide an evaluation of potential environmental effects and it would have been appropriate for the Environmental Statement to have directly addressed this potential effect, not to defer its consideration to “any further risk assessment work”. The lack of a detailed risk assessment in the Responses to Consultations comprises a further missed opportunity for the developers to assess this issue. It is obvious that any leachate which does reach the small un-named stream may then flow into the Bevern Stream, with potentially serious consequences.                                                                                      

7)  The consideration of alternatives is an important aspect of Environmental Impact Assessment. The Non Technical Summary of the Environmental Statement stated (pg 2) that “The applicant did not consider alternative sites for the proposed development because the site at Old Hamsey is highly suitable for the purpose”. The Response to Consultations does provide a consideration of alternative sites; however, in again concluding that the site is suitable, no consideration as a constraining factor is given to the proximity to, and ecological significance of, the Bevern Stream.  It remains highly questionable whether a location where the receiving watercourse for the discharge of treated leachate  is a very important sea trout spawning stream, of limited flow and capacity to dilute pollutants, can be regarded as “highly suitable” for a landfill development.

8)  The primary role of an Environmental Statement is to provide a planning authority with information on the environmental implications of a project to assist it to make an informed decision. The continuing lack of any consideration of the ecological significance of the Bevern Stream and of potential impacts upon it means that the initial Environmental Statement and the Response to Consultations remain an inadequate basis for making such a decision. 

We trust that the observations set out in our objection will be of assistance to the Council in further evaluating and determining the planning application. If you require any further clarification in respect of any of the issues detailed above please contact me. It remains our opinion that by virtue of failing to determine the baseline environmental characteristics of, and potential impacts upon, the Bevern Stream the ES (and Responses to Consultations, if deemed to be part of the ES) is fundamentally deficient with respect to the requirements of the Environmental Assessment Regulations, and should be treated as such by the Council.  

Yours sincerely, 

J.E.St.Pierre – Director – Sussex Ouse Conservation Society.

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The additional information submitted by LLoyds has not changed their application significantly.   Nor has it alleviated the threat to the Bevern stream in particular and the environment in general, if their application was successful.

Our previous letter of objection (click here) has therefore been re-submitted to the new Councillors.

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20 June 2005

Stewart Glassar                          LW/424/CM

Tel. 01273 481595                      AR/SG

Fax 0 1273 479040

stewart.glassar@eastsussex.gov.uk

 Dear Sir/Madam

 Hamsey Brickworks ‑ Planning Application LW/424/CM

I have received further information from the applicants regarding their proposed development of a non‑hazardous and sable non‑reactive hazardous waste landfill site and materials recovery facility at the above site.

Copies of this additional information will be available for your inspection at this office and at the Directorate of Planning & Environmental Services, Lewes District Council, Southover House, Southover Road, Lewes during normal office hours.

If you wish to comment on the additional information, please do so in writing by 11 July 2005. The views that you express, together with any previous views, will be brought to the attention of the Planning & Highways Sub Committee, which will determine whether or not planning permission should be granted.

For reasons of economy, no acknowledgement will be sent to you on receipt of your representations but anyone making representations will be informed of the final decision in due course.

Yours sincerely

Stewart Glassar

Principal Planner (Development Control)

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Lee Jamieson

Regulatory Specialist

The Environment Agency

Saxon House

Little High Street

Worthing BN11 1DH                                                           Saturday, 21 May 2005

Dear Mr Jamieson,

CONSENT APPLICATION P.12337/S/05 – E. SUSSEX NATIONAL GOLF CLUB 

Thank you for your letter dated 19^th May 2005. We are pleased that the summertime effluent will be used for irrigation purposes, which should indeed have a significant effect in reducing the nutrient burden to the stream at the most critical time.

We would like to express our appreciation for the effort the Agency has undoubtedly made to achieve this result.

Yours sincerely,

 J.E.St.Pierre – Director – Sussex Ouse Conservation Society.

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Salmon & Trout Association

Patron: HRH The Prince of Wales

President: The Duke of Northumberland

Fishmongers' Hall London Bridge London EC4R 9EL

Telephone: 020 7283 5838 Fax: 020 7626 5137

www.salmon‑trout.org

East Sussex Branch:   “Coverside”, Hazeldene Lane, North Chailey, LEWES, East Sussex, BN8 4HH

Telephone: 01825 722712

www.east-sussex-sta.org.uk

The County Planning Officer

West Sussex County Council

County Hall

Tower Street

CHICHESTER

PO19 1RH

West Sussex

                                                                                                                           29 March 2005

Dear Sir,

CORY/FRESHFIELD LANE BRICKWORKS – APPLICATION FOR LANDFILL

I am writing on behalf of my 450 members to lodge our strongest possible objection to the application by Cory/FLB for the creation of a landfill site at Freshfield Lane, Horsted Keynes.

Apart from the inadequate and dangerous access, the threat to health and quality of life, the damage to leisure tourism and the rural economy, our main concern, as one of the main national conservationist organisations, is the threat to our water resources.

The Freshfield Lane Brickworks stands on porous rock on an aquifer, and any landfill operation will inevitably produce leachate into both the aquifer and the near-by Cockhaise and Danehill Streams.    These two streams, as feeders to the Sussex Ouse will threaten the ecology and wildlife of a river system which has now gained Salmonid designation under the terms of the European Union Freshwater Fisheries Directive, demanding much higher standards of water quality.   The Ouse is recognised as an important salmonid fishery, unique in respect of the rapid maturation to unusually heavy weights of its sea trout population.   In addition it is home to indigenous brown trout and bullheads, the latter being a species already recognised internationally as being under threat.    

Already heavy effluent loads within the Ouse catchment make this latest application even more worrying, especially since ultimately, the Ouse provides one of the largest sources of fresh drinking water in Sussex.   Since the recent Environment Agency’s Catchment Area Management System (Cams) review confirms that there are no other sustainable sources available for further abstraction, the need to protect the Ouse from the possibility of further pollution is absolutely critical.

This application appears to be purely opportunistic, particularly since the site is not required for WSCC Waste Local Plan and the need for such a site not proven.    Current EU policy is that landfill should be a last resort and given the pressure to reduce landfill,  increase recycling and protect our environment, I trust that WSCC will refuse this application.

Yours sincerely,

T J Todd

Chairman

cc Peter Jessop, S&TA Regional Representative

Lee Jamieson                                                                               18^th March 2005

Regulatory Specialist

Environment Agency (Southern Region)

Dear Mr Jamieson,

WATER RESOURCES ACT 1991, SHEDULE 10

(AS AMENDED BY THE ENVIRONMENT ACT 1995)

NOTICE OF APPLICATION FOR CONSENT TO DISCHARGE

ZANLIA LTD. – EAST SUSSEX NATIONAL GOLF CLUB  Ref P12337/S/05

On behalf of the East Sussex Branch of the Salmon & Trout Association, I hereby make representations regarding this application. 

• We note that again the Agency refers to highly treated effluent in its Notice statement. Does “highly treated” mean that the effluent will be treated to the highest possible standard of purity, including UV disinfection and nutrient stripping? If not, please will you clarify the bio-chemical parameters that the Agency has in mind.
• We note that the proposed volume is up to 95 cubic metres per day. This is an extremely heavy effluent load for the size of the receiving water (Little Horsted Stream). This stream supports a population of wild brown trout and is a spawning ground for migratory trout. Lack of dilution, particularly in low summer flows demands a high quality of outfall.

• The costs of treating this effluent would be doubtless borne by Zanlia Ltd., a private enterprise. We assume therefore that no quality constraints for financial reasons would be applied either by OFWAT or DEFRA. In our opinion, the Agency should therefore insist on treatment of this effluent to the highest possible standard.
• It should be borne in mind that the ultimate receiving waters (Rivers Uck and Ouse) are now designated as Salmonid under the terms of the EU Freshwater Fisheries Directive, demanding the higher standards of water quality as laid out in this Directive.

The River Ouse is an important salmonid fishery, unique in respect of the rapid maturation to unusually heavy weights of its sea trout population. This species is already endangered from the heavy effluent loads within the catchment. We see this as a golden opportunity for the Agency to demonstrate its commitment to improve the standard of water quality rather than accepting the status quo.

Yours sincerely, 

Dr.J.E.St.Pierre – Water Resources Officer – Salmon & Trout Association – East Sussex.

Our ref:           P.12337/S/05

Your ref: ‑       ‑‑‑‑‑‑‑‑‑‑‑                                                                              ENVIRONMENT

Date:                18th March 2005                                                                   AGENCY

Dr. J.E. St. Pierre

Oakwood House

Barcombe

East Sussex

BN8 5BW

Dear Dr. St. Pierre,

CONSENT APPLICATION P.12337/S/05 ‑ EAST SUSSEX NATIONAL GOLF CLUB

Thank you for your representation on the above discharge consent application. The Environment Agency will take account of your comments in deciding whether or not consent should be granted and, if granted, what conditions should be imposed.

The Agency is required by law to determine the application(s) within four months, unless an extension to that period is agreed with the applicant. When we have determined the application and issued or refused the consent we will write to you again to inform you of the decision.

Please note that Section 10, 5(1) of the Water Resources Act gives the Secretary of State for the Environment powers to call in consent applications for his determination as a result of requests. If you wish to request him to call in the application you should write to the Secretary of State for the Environment, Food and Rural Affairs, Water Quality Division, Floor 3, Ashdown House, 123 Victoria Street, London, SWIE 6DE. The Agency is required to determine the application unless the Secretary of State calls in the application before the determination process is completed.

In the meantime may I take this opportunity to address some of the points raised in your letter.

I and my colleagues continue to consider it appropriate to describe effluent as "highly treated" when it has been treated to a quality substantially better than the old "Royal Commission" standard of 20 ing/1 BOD and 30 ing/1 suspended solid (20/30). In this particular case due to the lack of significant dilution afforded by the receiving watercourse, the existence of nearby downstream on‑line fish ponds and the EU Fishery Designations of the main downstream watercourse, the quality of the treated sewage will need to be of a standard significantly tighter than the Royal Commission 20/30. In fact the proposed consent conditions are as follows ‑ BOD not greater than 10 mg/1, suspended solids not greater than 15 mg/1 and ammoniacal nitrogen not greater than 3 mg/1 during the summer months and not greater than 5 mg/1 during the winter months.

Please note that if a proposed discharge was to undergo UV and/or nutrient stripping the Agency would include the words "UV" and "nutrient stripping (or perhaps the term "tertiary treated") in the description of the effluent.

 As this will be a "private" discharge I can confirm that the considerable capital and running costs of the "top of the range" sewage treatment plant required to meet these stringent conditions will be met solely by the applicant with no contribution from the "public purse".

I trust the above clarifies some of the matters regarding this application.

Yours sincerely,

LEE JAMIESON

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HOUSE OF COMMONS

LONDON SW1A OAA

Thomas J Todd                                                        4 February 2005

Coverside                                                               Our ref: TT0402‑Environment

Hazeldene Lane

North Chailey

LEWES

BN84HH

  Dear Mr Todd,

 You contacted me recently to let me know of your quite proper concern about the proposal submitted by Lloyds Environmental for both a hazardous waste site and materials recycling facility to be created at the Old Hamsey Brickworks in South Chailey.

 You will know from my previous reply that I strongly oppose this application, and I thought I would drop you a line to let you know that Ihave now been able to raise this matter in the House of Commons, and enclose a copy of the media release I issued following that debate. I hope that this will add to the pressure on the County Council to refuse this unwanted application, I have also written to them separately to recommend they do so.

 I hope this is helpful in bringing you up to date with developments.

 Yours sincerely,

 Norman Baker

 Enc.

NORMAN BAKER MP (Liberal Democrat ‑Lewes)

Contact: Tom Fewins ‑ 0207 219 2864

Embargo: Immediate, 3d February 2005

LOCAL MP TAKES CHAILEY DUMP SITE

CONTROVERSY TO THE COMMONS

Chailey's MP Norman Baker has called in the House of Commons for the proposal for a hazardous waste dump at the Old Hamsey Brickworks in South Chailey to be firmly rejected.

 Speaking in a debate on hazardous waste, Mr Baker condemned the proposal from Lloyds Environmental and called upon the Conservative County Council to reject the application. He also criticised the authority for encouraging the applicant to roll together two separate proposals into one application ‑ for the hazardous waste landfill, and for a MRF (materials recycling facility).

 He told the Minister, Ben Bradshaw:

"There are no sites for the disposal of hazardous waste anywhere remotely near to my constituency. No such site to deal with hazardous waste has been identified in the East Sussex, Brighton and Hove waste plan, but a speculative application has arrived for a site in Chailey in my constituency, which is wholly unsuitable. The proposed site is the old Hamsey brickworks, and it is unsuitable because it will lead to the generation of a huge number of lorry movements. Because there are so few sites, and there are none for miles around, a large number of lorry movements from Kent, Surrey and West and East Sussex will all bear down on that site.

The proposal would also place the site on top of a geological fault, of all things. It is close to a stream and it is very close to a residential area, and it would be a nightmare if that were allowed to proceed. However, I am afraid to say that the Conservative county council, which is in charge in my area, has seen fit to ask the applicant, Lloyds Environmental, to combine the application for a landfill site for hazardous waste with a materials recycling facility. They are quite clearly different decisions, but it is being asked that they be considered together. On behalf of my constituents, who have written to me in large numbers, I call on the county council to reject that application. I hope that those comments will be picked up and relayed to the county council.” 

After the debate, Norman added: 

 “I intend to leave no stone unturned in opposing this worrying proposal. The County Council must be left in no doubt just how strongly my constituents understandably feel about this matter."

 ENDS

Inquisitor of the Year 2001

Opposition MP of the Year 2002

Westminster Office: Tel: 0207 219 28641 Fax: 0207 219 0445

Constituency Office: Tel: 01273 480 268 1 Fax: 01273 280 287

Email. bakem@partiamentuk http:/~.normanbaker.o[g.uk

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NEW BRANCH ORGANISER & COMMITTEE MEMBERS ELECTED

We are pleased to announce that at the AGM held on Friday 4 February 2005, Peter Langton was elected as the new Branch Organiser.   The Branch extends its warmest thanks to Peter for taking on this important role and wishes him every success for the future.

Also at the AGM, the following members were elected to the Branch Committee; our thanks to them for volunteering their services:

                                          Frank Reader

                                          Ken Field

                                          Dr Rod Yuill

                                          George Martin

For a full list of the Branch Officers and Committee click here.

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The Salmon & Trout Association 

Patron: HRH The Prince of Wales

President: The Duke of Northumberland

Fishmongers' Hall London Bridge London EC4R 9EL

Telephone: 020 7283 5838 Fax: 020 7626 5137

www.salmon‑trout.org

East Sussex Branch:   “Coverside”, Hazeldene Lane, North Chailey, LEWES, East Sussex, BN8 4HH

Telephone: 01825 722712

www.east-sussex-sta.org.uk

Mr Stewart Glassar

Planning Application Case Officer

Transport & Environment

East Sussex County Council

County Hall

St Anne’s Crescent

LEWES

BN7 1UE                                                                                                                        19 January 2005

LW/424/CM(EIM) LLOYDS ENVIRONMENTAL HAZARDOUS WASTE TIP APPLICATION

I am writing on behalf of my 450 members to object to the planning application submitted by Lloyds Environmental, for the creation of a Hazardous Waste Tip at the Old Hamsey Brickworks, South Chailey.   Our objections are as follows.

1.        The proposed landfill is in close proximity to the Bevern Stream, one of the most important spawning streams for sea trout within the Sussex Ouse Catchment.  The Lloyds scheme may affect it adversely, either by a direct or indirect discharge of leachate generated by the site, through failure either of on-site leachate management, accidental spillage or the integrity of the landfill lining, which incidentally has no long term history as to its effectiveness in dealing with the sorts of hazardous materials listed by Lloyds.

2.       The clay pit proposed for landfill may not be entirely composed of impervious clay but rather a mixture of clay and sand bands.  Such geology would suggest that the ground, even with a lining, makes the risk of pollution of groundwater unacceptable.    This concern is even more acute given Lloyds’ very poor record in regulation compliance.

3.       The site is a naturalised wildlife environment, which is home to a variety of species.   Lloyds’ claim of there being little wildlife is in need of independent verification, particularly if there is even a hint of any protected species.    We are aware for example that the Bevern Stream is home to Bullheads which are recognised internationally as being under threat.   The proximity of a hazardous waste site will heighten that threat.

4.       Lloyds claim that areas of natural beauty outside the boundaries of the site will not be affected.   Clearly, dust and other material will be blown beyond the site boundary and over time will pollute the environment beyond the site.   Coupled with the dust generated by the proposed Materials Recycling Facility and the movement of heavy lorries and plant, the risks to the environment are real and unacceptable. 

5.       The proposed facility will be less than 1 mile form the proposed South Downs National Park boundary at Chiltington and is clearly inappropriate to an area of such natural beauty.   Policy ST13 of the Local Lewes Plan states “ In rural areas, particularly the Sussex Downs Area of Outstanding Natural Beauty……the quietness itself is a recreational asset which will be protected.”.

6.       The Lewes Local Plan, policies ST13 and ST30 require potentially polluting activities to be situated in an appropriate location, have an acceptable impact and no negative effects on health or the natural environment.    Lloyds’ proposals contradict these requirements on every count.

7.       The Lewes Local Plan, policy ST14 also states that “Some development proposals can give rise to unacceptable risk of pollution, such as landfill, disposal of sceptic tank effluent…”.   This is precisely what Lloyds are proposing.

8.        Paragraph 7.27 of the Environmental Impact Assessment suggest that Lloyds are undecided on what facility they wish.   They agree that they have rejected their initial proposal for a hazardous waste landfill as “unattractive in this location” due to “relative proximity of housing” and that “the need for facilities for hazardous waste is uncertain at this time”, yet their list of  proposed materials contains many hazardous items.

9.        The much vaunted Waste Local Plan, compiled at considerable expense to the community, suggests that since there is little hazardous waste produced in East Sussex, a plant to deal with it, is not  necessary.    Lloyds' proposals are contrary to the WLP findings and appear to be nothing more than an opportunistic attempt by them to capitalise on a current national gap in the market.   Their proposals, therefore will benefit neither the local community nor the wider County community.    The only beneficiary will be Lloyds, whilst the surrounding community and environment will be blighted by pollution from noise, dust, leachate and much more additional heavy traffic.    

           For all of the above reasons, I urge you to reject the Lloyds proposals.

           Yours sincerely, 

           T J Todd

           Branch Chairman

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HAZARDOUS WASTE TIP

The deadline for submissions to ESCC regarding the proposed hazardous waste tip is 31st January 2005.   Branch members are urged to write letters of objection to this proposal to either:   

Stewart Glasser

Case Officer

Department of Transport and Environment

County Hall

St Annes's Crescent

LEWES

BN7 1UE

or The Chairman (Cllr R Dyason) or preferably all other members of the Planning Committee at County Hall: addresses can be found at the ESCC website http://eastsussexcc.gov.uk

For further information please also visit the Bevern Residents Association site at www.nodumpinchailey.com

Thank you to our colleagues at SOCS and BRA for the above information.

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CINDER HILL TROUTING SYNDICATE                                                                    

2004 Newsletter

This is the last newsletter from “Him what is in charge of fish stocking”. After 8 years I am handing over the reins and the green wellies to Peter

Neaves who has kindly greed to take on the duties of  “stocking officionado” for 2005.

It is interesting to reflect on the period since 1997, when I first became involved and from my records, I can tell you that, over that time, the annual

cost of fish has increased by about 50% , the membership has been full since 2002 with an increasing waiting list and the number of fish caught or

not caught has shown very little variation, so we must be getting something right.

What has changed is the weights of fish put into our waters, for each year we have gradually moved the weights upward, for example in 1997

we put in 2895 fish of 1 to 2 lb and 114 of over 2 lb, whereas in 2004 the figures were 1800 and 1400 respectively, which I hope has not only

given better sport, but the odd large surprise over 5 lb.   As far as this season was concerned, we have had the usual weather problems at various

times, which has affected both stocking and fishing. We  also had difficulties on the top lake in Aug/Sept with many dead fish including coarse fish,

which led to its closure for a short period while the Environment Agency were called in. However, despite sampling the water and some of the

dead fish, no cause could be found and we can but assume that some short term toxicity entered our water. Most of you will remember a similar

problem on the middle lake some few years ago.

Lastly, my thanks go to those members who have most ably assisted in conveying fish from truck to water this year. I am sure that Peter will be

grateful for similar help in 2005. Also thanks to Bill Impey who continues faithfully to record all catch details each month, which comprise the basis

of all the statistical information we use to monitor progress.

Finally, I can tell you that I shall find it far more enjoyable to fish Cinder Hill without knowing what went in and when. The element of surprise

I think provides far more fun than the knowledge of what is possible------but perhaps some Anglers would not agree with my philosophy!!!!!!!!!!!

  John Masters      

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Dear Member, 

I trust that your individual 2004 season was both productive and enjoyable. 

On the wider front, it does appear that despite some remarkable successes at National level (the buy-out of the NE salmon nets) our rivers and environment in general are under even more threat.    As a Branch we have corresponded with various bodies and local MP on a number of issues concerning landfill, abstraction and pollution.   However, our representations seem to be fairly forlorn given the demands being placed on our natural resources and the necessity to dispose of our waste products, at a price which society wants to pay.  The issues are indeed very complex but thankfully there are a number of undaunted people who are determined to continue in their efforts to make a difference.   If collectively we keep chipping away, some of the short-sighted thinking might just begin to crumble and our river systems might just about survive over exploitation, for the benefit of everyone.

We will endeavour to keep you abreast on these issues on the re-vamped Branch website at www.east-sussex-sta.org.uk.

Branch Organiser

Sadly, and despite the letter sent to all 420+ members in October 2004, no one has offered their services to take up the reins as Branch Organiser.    I cannot believe that in such a large Branch there is no one with the interest, talent, energy, commitment and time to undertake a few hours work per week on behalf of the Branch.   If you are interested and so far have not been made aware of the vacancy, please contact me.   In the meantime the Committee have undertaken to share-out the Organiser’s workload in order to ensure the Branch can continue as a separate entity.    However, the continued absence of an Organiser inevitably will mean that some things will just not get done.   It also means that the remaining Committee members will be sharing an additional workload which may not be sustainable.

2005 Programme

You will see that there are a few departures from what has been our traditional programme.   Over the past few years our presence at the South of England Show has failed to produce the sort of new membership numbers which we would like and the cost of mounting a presence at the Shows is becoming financially non-viable. Additionally, and for much the same reasons, HQ has also withdrawn support for these shows.  Consequently, after much debate, the Branch Committee have reluctantly decided not to attend the Summer and Autumn Shows in 2005.   We are, however, diverting our resource and effort to attending the Michelham Priory Game and Country Fare in the expectation that this event will be more focussed on rural pursuits and therefore more suited to attracting new members.

As always, a big “thank you” to the volunteers who help at our events.  Their contact with the general public, help with coaching and generally, their flying the flag, is much appreciated and beneficial to the Branch.   Where are the rest of you?

Our AGM is on 4 February 2004, again at the excellent Wellshurst Golf & Country Club near Hellingly.  

River Teise

This popular mutual swap between the River Teise Anglers and Owners Association (TAOA), and Cinder Hill Trouting Syndicate, will be available again in 2005.  

Sussex Ouse Conservation Society

“S.O.C.S. has again made good progress with its aims and objectives over the past year.  We are confident that the Society has further developed its profile over the year and is recognised as an established organisation concerned with the protection and enhancement of the natural environment.

We have forged ahead with our education programme this year and developed an information pack for schools. This is used in conjunction with stream dipping to identify “minibeasts” and perform a simple monitoring exercise. We organised outings for Barcombe Primary School on the Bevern and Hamsey Primary School on the Northend Stream. The pupils were very enthusiastic and both schools provided impressive displays for the South of England Agricultural Society’s (SEAS) Education Tent at the South of England Show, which as a whole won third prize for best display in the Farming and Wildlife section. S.O.C.S. also mounted a display in conjunction with the schools and Richard Osmond, who was there with his Hi Tech-Wild Trek trailer showing live exhibits on video, taken from various points in the catchment. Our thanks are due to the SEAS for providing the facility at the show and particularly to their Education Officer, Julia Tingle, who gave us tremendous support.

S.O.C.S. has also been invited to be a partner in a research project at the University of Sussex, run by Dr. Elizabeth Hill. This involves a study into the effects of oestrogens and similar hormones (present in sewage effluents) on the reproductive viability of river fish. This is a four year study and volunteers from S.O.C.S. will be involved in providing samples of fish, sediments, etc. for analysis.

S.O.C.S. and the Ouse Angling Preservation Society, were involved with a similar study on sea trout last year. Dr. Hill asked if sea trout anglers could provide the guts from freshly caught fish for analysis. Our thanks are due to Gordon Vinell, an angler of legendary repute, who provided the necessary material. We understand that the results from the fish studied did not demonstrate a significant problem.

We are always pleased to welcome new members to help us improve and protect our river and its tributaries. Membership is only £10 per annum and includes receipt of our quarterly newsletter. For further information visit our website at www.sussex-ouse.org.uk or phone Sam on 01273 400093.”

“Sam” St.Pierre – Director S.O.C.S.

Trouting Syndicate

The trouting syndicate continues to provide excellent trout fishing at a very reasonable cost and this is reflected in the number of potential members on the waiting list.   However, in order that all members can enjoy their fishing we must have a set of rules.   Regrettably, various reports received during the 2004 season have suggested that some members and their guests may have neglected to either read the rules or may have had some lapses in adhering to them.    The Branch Committee have therefore reviewed and revised the rules and a copy will be issued with the new season’s permit badges, etc.   Please ensure that they are followed.    Members found not adhering to them will be “asked to leave” the syndicate.

The Hunting Bill

The passing of the Hunting Bill gives those of us who enjoy our fishing, little faith that our sport is not under threat from the same group of minority lobbyists.   

Appropriately and following-on from the previous item, on rules, we must ensure that we do not provide the “antis” with any ammunition which could be used to further their cause.    Please ensure that you retrieve and properly dispose of redundant nylon leader.; take it home and cut it into harmless lengths, don't discard it on river or lake bank.   Check all knots on a regular basis to minimise “breaking".   Despatch caught fish swiftly and efficiently or if releasing, do it from the net.   As an Association we sell ourselves as environmentalists; let's ensure that we practice what we preach.  

 Water Resources

“Apart from being your Water Resources Officer, I wear another hat as Director of the Sussex Ouse Conservation Society (S.O.C.S.). My report on the activity of S.O.C.S. this year covers most of the concerns that we all share. There are not only ongoing problems with diffuse and spot pollution in our area. We also face the problem of an ever expanding population using more and more water. This causes an inexorable reduction in flows of our rivers and streams due to increasing abstraction. Lower flows give less dilution to effluents, so the adverse effects on the aquatic environment are compounded. The government is proposing huge expansion of development in the South East but does not seem to recognise that there is just not enough water available to service this, let alone protect the natural environment. The attitude seems to be that we will cope somehow. The S&TA is well aware of existing and potential problems in this realm and is assiduously lobbying for a change of policy. It will require substantial funding to reverse the decline. This would have to be in the form of increased taxes and/or higher charges for water and sewerage services. Such measures are not popular with politicians or most voters. However, we will keep trying.”

“Sam” St.Pierre – Water Resources Officer

Acknowledgements

My thanks go to the volunteers who do their best to help at the various events held throughout the year and to the Branch Committee for their continued commitment to keeping the Branch on the straight and narrow.    Sadly John Sully, John Masters, Keith Carmichael and Alan Freeman have all given notice of their departure as of the AGM.    My thanks to them for all their efforts over the years.    A warm welcome is extended to Peter Neave who primarily has taken over the responsibility of stocking the lakes at Cinder Hill.  Peter also becomes a member of the Committee as a consequence.

 If you would like to have an input to the running of the Branch, then why not volunteer as a Committee Member?   We are always on the look out for new blood and fresh ideas.  Let’s hear from you at the AGM.

 Best wishes to you and your families for 2005  and tight lines.

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OBJECT TO LLOYDS PROPOSALS

It is very important that as many people as possible within the area local to South Chailey, register their objections to Lloyds proposals for landfill of hazardous waste.   Remember it is not only the residents of South Chailey and the immediate environs who will suffer but those in surrounding villages are also likely to experience increased heavy transport on already crowded and hazardous roads.    Also remember, that the ultimate sacrifice is likely to be the health of the Bevern Stream and thereafter, the River Ouse.

For more information on Lloyds proposals click on to the website of the Bevern Residents Association

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The Salmon & Trout Association

Patron: HRH The Prince of Wales

President: The Duke of Northumberland

Fishmongers' Hall London Bridge London EC4R 9EL

Telephone: 020 7283 5838 Fax: 020 7626 5137

www.salmon‑trout.org

East Sussex Branch:   “Coverside”, Hazeldene Lane, North Chailey, LEWES, East Sussex, BN8 4HH

Telephone: 01825 722712

www.east-sussex-sta.org.uk

Peter Jessop

Southern Region Representative

                                                                                               21 October 2004

Dear Peter,

I am sure that you are already aware of proposals, now reaching advanced stages, to develop two sites within Sussex, for waste disposal.

The first at Horsted Keynes, is being proposed by West Sussex County Council for landfill (the old Freshfield Lane Brickworks).  Apart from the site being in the middle of an AONB, the development will introduce heavy traffic in currently quiet country lanes, with all the concomitant noise and pollution that that will bring.  More importantly, from an S&TA viewpoint, there is a real danger of polluting the nearby Danehill and Cockhaise Brooks, both within the River Ouse Catchment Area.

The second also affects the Ouse Catchment Area and is for the development of a Materials Recycling Facility and a Landfill site for disposal of toxic waste, at the old brickworks at South Chailey.   Again, this is likely to increase pollution via heavy traffic and noise, and also pollute another tributary of the Ouse, the Bevern Stream.

On top of these two developments, Southern Water have recently been granted license for the discharge, under particular circumstances, of effluent and untreated sewage into the North End Stream, again a tributary of the Ouse.

My Branch is extremely concerned about the cumulative effect of these disparate developments on the overall health of the Sussex Ouse (which incidentally is also the major source of  abstraction for domestic water supply) and its population of wild trout, sea trout (I understand a unique strain to the Ouse) and bullheads in particular.

In partnership with the Sussex Ouse Conservation Society, the Branch has made a number of representations to the companies/authorities involved, and via our local MP.   Some of that correspondence is on the Branch website at www.east-sussex-sta.org.uk.      Other groups locally are also making their views heard but I gain the impression that the applications will succeed, probably with the blessing of local Government, given the pressures being placed by Central Government to do more on waste disposal.   The EU Water Framework Directive, appears to be having little impact as far as the Ouse is concerned.

The Branch has previously raised these issues with HQ, who have expressed support, but I believe that given the seriousness of the situation, we now need not only HQ support but some practical input form the "experts".

I am therefore writing this rather lengthy document to seek your support in raising the issues outlined, with HQ in the hope we can gain the help of the "big guns" in fighting for the future of the Sussex Ouse.

Yours sincerely,

Tom Todd

Branch Chairman

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WEST SUSSEX WASTE LOCAL PLAN

In the spring of 2003, The Branch lodged an objection to the West Sussex County Council proposals to develop for landfill, the old claypits at Freshfield Lane, Horsted Keynes.    West Sussex County Council have recently advised us that their revised Waste Local Pan is now available on line at www.westsussex.gov.uk/wplan.  In it, they make reference to "deletion of landfill allocations at Freshfield Lane Brickworks, Horsted Keynes (non-inert waste), and Keymer Tileworks, Burgess Hill (inert waste)".

Whilst this appears to be good news, we have also recently been contacted by Cory Environmental to advise that they have submitted a planning application for "the long term working and restoration of the two clay pits at Freshfield Lane Brickworks".  

This proposal would extend the area from which clay can be extracted and restoration by landfilling with non hazardous residual waste i.e waste left after household, commercial and industrial waste has been through a recycling process.

The Branch again intends to voice objections on your behalf, again on the same basis as before, viz.

    - Contrary to designation as Area of Outstanding Natural Beauty

    - Risk of pollution to Danehill and Cockhaise Brooks

    - Concerns about access, noise and traffic pollution

Whilst this proposal affects an area outside our Branch boundaries, the pollution risk to the R. Ouse is unacceptable.

The Branch would welcome any help that members can offer to fight this landfill plan.

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Mr T J Todd

Branch Chairman

The Salmon & Trout Association

Coverside

Hazeldene Lane

North Chailey

Lewes

East Sussex

BN84HH

18 October 2004

Dear Mr Todd,

Materials Recycling Facility and Landfill

I write further to my letter dated 23 August 2004.

We continue to develop our proposals, and arrangements are now at an advanced stage relative to the completion of our Planning Application and Environmental Impact Statement.

I am conscious that you did not attend our public exhibition at Chailey Village Hall on 30 September 2004, in order to express your views and opinions. Given the interest expressed within your letter dated 17 August 2004 1 confirm that 1 would be pleased to meet with you over the next 7 days so that you can add to the consultation process.

 Yours sincerely,

The Salmon & Trout Association

Patron: HRH The Prince of Wales

President: The Duke of Northumberland

Fishmongers' Hall London Bridge London EC4R 9EL

Telephone: 020 7283 5838 Fax: 020 7626 5137

www.salmon‑trout.org

East Sussex Branch:   “Coverside”, Hazeldene Lane, North Chailey, LEWES, East Sussex, BN8 4HH

Telephone: 01825 722712

www.east-sussex-sta.org.uk

Mr T M Billingham

Operations Director

Lloyds Environmental

Old Hamsey Brickworks

South Chailey

LEWES

East Sussex

BN8 4QD

                                                                                               22 October 2004

Dear Mr Billingham

MATERIALS RECYCLING FACILITY AND LANDFILL

Thank you for your letter of 18 October.

I did email you prior to the 30 September to say that I could not personally attend the public exhibition at Chailey Village Hall and asked if you could send me a copy of the proposals.    However, our Water Resources Officer did attend on behalf of the Association.

His feedback confirms our concerns, despite your presentation and assurances, that the proposed MRF and Landfill is an unwelcome and potentially damaging development within the Ouse Catchment Area. 

I can see little point in us meeting therefore, given our very different views, unless of course Lloyds abandon the current proposals in their entirety.

Yours sincerely,

Tom Todd

Branch Chairman   

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The Salmon & Trout Association

Patron: HRH The Prince of Wales

President: The Duke of Northumberland

Fishmongers' Hall London Bridge London EC4R 9EL

Telephone: 020 7283 5838 Fax: 020 7626 5137

www.salmon‑trout.org

East Sussex Branch:   “Coverside”, Hazeldene Lane, North Chailey, LEWES, East Sussex, BN8 4HH

Telephone: 01825 722712

www.east-sussex-sta.org.uk

Dear Member,

You may be aware that our Branch Secretary/Organiser has given notice of his resignation as from the date of our next Annual General Meeting, scheduled for 4 February 2005.

Despite the usual search among the ranks of our Branch Committee, and a notification of the upcoming vacancy on our website, we have so far been unsuccessful in identifying a successor.

I am therefore writing to all of our members seeking a volunteer for this important post.   Ideally we need someone who is able to give of their time for a few hours per week, to undertake the basic administering and organising of Branch affairs and events.    This ranges from maintaining records of branch members, planning, printing and distributing programmes and newsletters, organising events, seeking volunteers, liaising with other organisations and generally helping to ensure the continued health of our Branch.

It is no exaggeration to say that if we are unsuccessful in identifying a new Organiser, the future of our Branch as an entity is very much in doubt.    I am sure, therefore that among our 450 members, there must be someone whose experience and background is ideally suited to our needs.

If you think that you are able to commit to the role, or know of a fellow member who has the attributes and skills we are looking for, then please contact me to discuss the work of the Secretary/Organiser in greater depth.   I do assure you that the task is not as formidable and as onerous as it may sound; we do have fun as well as representing the interests of S&TA at local level.

Yours sincerely,

Tom Todd

Branch Chairman   

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CINDER HILL

1.   Fish Kill.   Regretfully, we had a problem in the top lake at the beginning of September which resulted in the "kill" of a number of fish.   The Environment Agency have been unable to establish the cause despite two separate analyses of the water quality.   We suspect that some toxins have seeped into the feeder stream but given that Hurstwood and Mcarthur's pools have not been affected, we are at a loss to understand the incident.

We have now re-stocked the lakes and the Ashdown & General Landown Company have generously agreed to our extending our season up to and including 14 November.

2.   Rent.   Following negotiations between the Ashdown & General Land Company and the VAT Inspectors, agreement was reached that VAT should not be charged on the rental of the lakes.    That saving has been generously passed onto us by our Landlord and the Syndicate has therefore received something of a windfall.    The Branch Committeee would like to receive ideas from Syndicate members on how the money should be best used.   So far suggestions include, investing the money against the need for raising subscriptions for the future 4 or 5 years; dredging the lakes to give better depth for the fish; replacing the benches which are now beyond repair.

Please let us know of your ideas by contacting the Chairman or the Syndicate organiser via the usual media.

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Lloyds

ENVIRONMENTAL WASTE MANAGEMENT LTD

Head Office: Old Harnsey Brickworks SoutliChailcy NrLewes East Sussex BN8 4QD

Tel:(01273)401888 Fax:(01273)401999 w",w.llovdsenvironniental.co.uk info((~lloydsenvironmental.co.uk

22 September 2004

 Dear Sir/Madam

As you may be aware, Lloyds Environmental Waste Management Ltd is proposing to build a materials recycling centre and small specialist landfill site at its existing industrial site at the Old Hamsey Brickworks, South Chailey.

I am pleased to confirm that, as promised, details of the project will go on show at a public exhibition at Chailey Village Hall, near the Five Bells Public House on the A275, from 4pm ‑ 8pm on Thursday 30 September, when members of the Lloyds team will be in attendance at the exhibition to answer any of your questions.

Crucial to this consultation process are the views and opinions of local people as we envisage this feedback will help us shape the final scheme proposals, prior to the submission of a planning application in mid to late October 2004.

We believe our plans will not only help combat the increasing problem of waste disposal in the south east since the introduction of new European legislation, but will also help local authorities meet tough new Government guidelines on recycling. The issue of waste disposal and recycling is one which the whole community must address, which is why we hope everyone will take the opportunity to contribute to the consultation process.

In order to ensure we meet the submission timetable, the deadline for comments is 7 October 2004. If you would like to speak to a member of the team prior to the exhibition then please don't hesitate to call either myself or Operations Director Tim Billingham on 01273 401888.

I look forward to meeting you on the 30 September and having the opportunity to explain this important environmental project in more detail.

Yours sincerely

Andrew Skinner

Director of Environmental Protection

The Environment Agency

Dear Mr Skinner,

The Sussex Ouse Conservation Society (S.O.C.S.) is comprised of a group of local volunteers concerned with the environmental protection and enhancement of the Sussex River Ouse and its tributaries.

We work closely with our local Sussex Area Environment Agency Office with whom we nurture a good relationship. What we do is published on our website www.sussex-ouse.org.uk 

Southern Water plc is in the process of refurbishing some works and infrastructure of the wastewater processing system in our area. Part of this project concerned the upgrading of Cooksbridge STW, which discharges effluent into the Northend Stream, a tributary of the Sussex Ouse. This stream supports a population of wild brown trout and is an important breeding and nursery area for migratory trout. We were dismayed to discover that the Application for Consent to Discharge from this facility included consents for the discharge of untreated “storm sewage” (when the flow exceeds 7 times the DWF), and for untreated sewage in “extenuating circumstances”, which we understand relates to possible equipment failure. These consents have been granted.

We are aware that CSOs are presently an accepted component of the UK sewerage system, but we do consider that it is an anomalous and unacceptable policy for an environmental protection agency to give consent to such discharges into our rivers and streams and more particularly for those caused by system failure.

We have naturally expressed our concerns to the Sussex Area Office. We have been informed that “…..it is not a requirement of EU legislation, or the Policy of the Agency to control the bacteriological quality of discharges made to watercourses, unless it is an EU designated Bathing Water (and/or Shellfish water)”

We consider this to be an archaic and outdated policy for the 21^st Century, incompatible with current concepts of Health and Safety and protection of the environment.

We are raising these serious concerns with you as the Agency Director of Environmental Protection because a change of policy in this respect is both essential and very overdue.

Yours sincerely,

Dr.J.E.St.Pierre – Director – Sussex Ouse Conservation Society

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Our ref.

Your ref..                                                                                                       ENVIRONMENT

Date:                26 August 2004                                                                       AGENCY

 T J Todd Esq

The Salmon & Sea Trout Association

"Coverside"

Hazeldene Lane

North Chailey

Lewes

East Sussex BN8 4HH 

Dear Mr Todd

RIVER OUSE ABSTRACTION 

Thank you for your letter dated the 9 August 2004. Please accept my apologies for the delay in replying. 

1 understand from your letter that you are party to our recent correspondence with The Sussex Ouse Conservation Society (SOCS) concerning the abstraction of water from the river Ouse by South East Water (SEW). 1 hope our correspondence demonstrates that the Environment Agency shares your organisations aim of ensuring that our rivers and waterways remain healthy for future generations. 

In pursuit of this objective, the complex Ardingly/Ouse abstraction licence has recently been varied and simplified. This process has taken several years of negotiation and has resulted in significant environmental benefit for the river Ouse. Improvements include: an increased Minimum Residual Flow (MRF) at Barcombe of 20 MI/d, a prohibition of abstraction from the River Ouse at Ardingly for refilling the reservoir during periods significant to fish migration, removal of the unnaturally high maintained flow requirement at the River Ouse/Shell Brook confluence and an increase in the continuous compensation release from Ardingly reservoir. 

We continue to meet representatives of the company on a regular basis to discuss water resources issues across their supply area. and ensure a common understanding of the terms of the new licence. In particular, we are working closely with the Company to ensure that " real

time" reductions of flow at Barcombe below 20 MI/d are exceptional and severely time­ restricted within any 24 hour period. 

Notwithstanding the legal interpretation of the licence with regard to the MR‑F i.e. a total flow of 20 MI/d in 24 hours, we and South East Water are fully aware of the spirit of the licence. Both parties are in agreement that instantaneous flows well below 20 MI/d for a number of hours within a 24 hour period are unacceptable. 

As a result of the variation it is also now much easier for the Agency to regulate the licence. In the event of a breach of the licence appropriate enforcement action will be taken in accordance with our Enforcement and Prosecution Policy (available at www.enviromnent‑agency.gov.uk). 

1 trust that 1 have satisfactorily responded to your questions; however, if you wish to discuss this matter further, please contact me at the address given on the previous page.

Yours sincerely

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                                                       Norman Baker MP

                                                (Lib Dem MP for Lewes)

                                                                                                                                                                                                HOUSE OF COMMONS

                                                       LONDON SW1A OAA

Thomas J Todd                                                                                           25 August 2004

Coverside                                                                                                Our ref. TT2508-Lloyds Waste

Hazeldene Lane                                                                                            Treatment

North Chailey

Lewes

BN8 4HH

 Thank you for letting me see a copy of your recent correspondence about the proposed waste site, which I read with interest.

1 do not regard the Lloyds site suitable for intensive industrial activity and have been concerned at the way activity has grown incrementally in recent years, and have made that concern known both to the company itself and to the local press. 

The area is not zoned for a landfill site or for the disposal of toxic waste.  Lloyds will clearly argue with the county council that what we are proposing is merely an extension of the kind of activity already on site. It is my view 'that it is both one step too far and also a gear change rather than a small step. 

As you rightly say, no planning application has yet been submitted though it is clear that Lloyds intend to make one.   I shall be meeting the company shortly to establish the facts and to make them aware of my strong reservations and will consider the best way forward at that point.   I have already however my opposition known through the local media. 

I hope this is helpful.

 Yours sincerely,

Norman Baker

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Mr T J Todd

Branch Chairman

The Salmon & Trout Association

Coverside

Hazeldene Lane

North Chailey

Lewes

East Sussex

BN84HH

 23 August 2004

 Dear Mr Todd,

Materials Recycling Facility and Landfill

Thank you for your letter dated 17 August 2004. 1 apologise for the delay of this response; both Paul Segal and 1 have been absent from the office recently.

We welcome your interest and full participation in the consultation phase of our proposals.

We are still at a relatively early stage of our proposals, however, now that we have publicly announced outline arrangements we will be involving an increasing number of technical consultees over the next few weeks as we build up more detailed proposals. As you would expect, any application that we submit in due course will be accompanied by an Environmental Impact Statement which will provide comprehensive information about the likely environmental effects of the proposals.

Thank you for taking the time to write to us.

Yours sincerely,

T M Billingham

Operations Director

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Lloyds Environmental

Old Hamsey Brickworks

South Chailey

LEWES

East Sussex

BN8 4QD                                                                                           17 August 2004

Dear Sirs,

LANDFILL SITE

We are most concerned to learn from articles in the local press, of your plans to construct a 2.2 acre landfill site and recycling plant at South Chailey.

Apart from the dangers of the reported hazardous waste being leached into the Bevern Stream and thereafter, the River Ouse, the ecological disaster that will ensue seems all too obvious.   This plan, together with your plans for a sewage treatment plant, seems destined to create blight in an area of countryside which is begging for our protection and enhancement, rather than industrialisation and development.

The River Ouse is already under tremendous threat from outfall and abstraction and additional plants such as yours can only add to the not insubstantial pressures being placed on it.    The Ouse and its supply streams, is a natal river for sea trout and sea lamprey and additional discharges, even though accidental, will threaten both these species and the wide diversity of wildlife that the Ouse and its tributaries support.   Additionally, from a human viewpoint, the fact that a large proportion of our drinking water is abstracted from the Ouse, downstream from your site, provides even more anxiety.

Whilst Salmon & Trout Association accepts the need to tackle and properly manage the issue of waste disposal, we believe that all too frequently, economic and political short term expediency, is incorrectly prioritised over the long term necessity to protect and sustain our environment.

We look forward, therefore, to participating in your full consultation exercise as reported in the press, prior to planning application.

Yours sincerely,

T J Todd

Branch Chairman

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ADUR AND OUSE CATCHMENT AREA MANAGEMENT STRATEGY

We have been afforded via SOCS, the opportunity to comment on the Environment Agency consultation Document on future abstraction.   The document itself is very lengthy and extensive, covering detailed examinations of hydrology, discharges, water quality, availability, existing and proposed strategies.    Our comments on the key issues are summarised as tighten the abstraction licensing, stop the discharge of untreated sewage and generally ensure that demands on our river and water supply systems are controlled such that their rich ecology and natural diversity are sustained.    Our Water Resources Officer, Dr Sam StPierre is keeping an eye on our interests and we will let you know progress as events unfold.   

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ABSTRACTION

Our colleagues in the Sussex Ouse Conservation society (SOCS) have alerted us to a possible breach of abstraction license during July 2004 and seeking our support in raising the issue with EA.   The following is a copy of the letter sent on behalf of the Branch.

          Mr P Midgley

          The Environment Agency

          Saxon House

          Little High Street

          Worthing

          BN11 1DH                                                                                        

9 August 2004

Dear Mr Midgley,

RIVER OUSE ABSTRACTION

I am sure you will be aware from the correspondence between my colleagues at The Sussex Ouse Conservation Society (SOCS) and your officers, of the suspicions and concerns regarding a perceived breach of abstraction license at Barcombe Mills on 25^th  June and 29^th July 2004.

Whilst SOCS have received assurances that no breaches were evident and that South East Water have remained within the terms of their license, I believe the detailed correspondence indicates very clearly, the complexity of legislation which all those with an interest in our water resources and environment, is having to contend with.

The Salmon & Trout Association recognises the difficulties involved in trying to balance the needs of society with those of environmental wellbeing, our main interest being to ensure that our rivers and waterways and the life systems that they support, remain healthy so that they can be enjoyed by future generations, a view I believe the Agency supports and encourages.    

However, in view of the incident alluded to above, there is room to surmise that a  universal and sensible application of the “rules” appears to be subject to political expediency, dependent on the “best fit” at any particular time.

I would be very grateful therefore for any assurances that the Agency can give that the current abstraction policies are not only adhered to but are translated and applied in a practical common sense way that is clearly understood by all parties, for their mutual benefit and for the overall benefit of our water resources.

        Yours sincerely,

T J Todd

Branch Chairman

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