River Till Briefing for Danny Kruger MP

 

Briefing Note On The River Till For Danny Kruger MP

Executive Summary

The River Till, a rare chalk stream winterbourne in Wiltshire, is being damaged by treated sewage effluent and stormwater discharges from Wessex Water’s Shrewton Water Recycling Centre. Even clean water being discharged to the dry bed of the winterbourne in summer does irreparable damage to the entire ephemeral section of river below the point where the effluent is discharged.   This effluent discharge, permitted under outdated regulations, is causing eutrophication, harming the river’s ecosystem, and posing health risks to those using the river recreationally, often children, due to high bacteria levels.   Wessex Water’s preferred proposed solution to pipe the effluent further south, seems to have been selected on purely financial grounds and does not address the root problem. It seems likely
that it will worsen the situation for the River Till, its inhabitants and those who live alongside it.

Background

1.     The River Till is a 14km long chalk stream winterbourne in south-west Wiltshire. There are around 3,700 named rivers in England of all types. There are only 250-260 chalk streams in the world and 224 (86-89%) of these are in England. Of these chalk streams, it is estimated that only about 50 have winterbourne sections (20-30%). The River Till is a Site of Special Scientific Interest (SSSI) in its own right, from Orcheston to Stapleford. It is also part of the Hampshire Avon SSSI and the Avon Special Area of Conservation . The River Till is amongst the rarest of the rare.

2.     The winterbourne section, the bit that is fed by ephemeral springs that dry up in summer, runs from Tilshead in the north and ends 10km south near Asserton/Berwick St James at apermanent spring at Grid Reference: SU 0775 3964 The winterbourne section represents over 70% of the whole length of the river.

3.     Wessex Water’s Shrewton Water Recycling Centre (Shrewton WRC) discharges treated sewage effluent and stormwater into the River Till at Grid Reference SU 0742 4262 at the northern edge of the parish of Winterbourne Stoke, some 8.5km north of the confluence and 4.5km north of the permanent springs; well within the ephemeral section of the river.

4.     Wessex Water currently discharges into the River Till under Permit No: SW/04000080/007. The Environmental Permitting (England and Wales) Regulations 2016 .

5.    Much of the rationale for these permits is based on the work of the Royal Commission on Sewage Disposal 1898-1915); in particular the Fifth Report . Whilst this was revolutionary in its day, many aspects of it are now scientifically untenable, but the Environment Agency continues to reference it.  

6.     In October 2023, as part of a 5-year business plan (2025-2030), Wessex Water published Annex WSX17.  On page 230, Wessex Water makes the following admission: "The discharge from Shrewton WRC is having a localised impact on the invertebrate communities of the River Till in its sensitive and valuable ephemeral reaches.  The organic loadings from the discharge have caused a significant shift in the invertebrate community away from one that is able to support the notable winterbourne specialist species in the reach immediately below the works.  This is either due to infiltration resulting in discharge of high levels of untreated effluent, or due to treated effluent being discharged into a dry river for much of the year therefore receiving no dilution and turning what should be an ephemeral reach into a perennial ponded reach made up of 100% effluent for long periods of time.”

(1)  Accessed 3rd September 2026: https://designatedsites.naturalengland.org.uk/PDFsForWeb/Citation/2000431.pdf 1
Accessed 3rd September 2026: https://designatedsites.naturalengland.org.uk/PDFsForWeb/Citation/2000183.pdf
Accessed 3rd September 2026: https://sac.jncc.gov.uk/site/UK0013016 3
Accessed 3rd September 2026: https://webapps.bgs.ac.uk/memoirs/docs/B06082.html
Accessed 3rd September 2026: https://nsip-documents.planninginspectorate.gov.uk/published-documents/
TR010025-000405-6-3_ES-Appendix_8.12B_RiverTill_FishSurvey.pdf
Accessed 3rd September: https://irp.cdn-website.com/7dfe45d9/files/uploaded/
Wiltshire%20Botany%204%202001-273a1bbe.pdf
Accessed 3rd September 2026: https://environment.data.gov.uk/public-register/water-discharges/registration/
SW-040080-007?__pageState=result-water-discharge-consents
Accessed 3rd September 2026: https://babel.hathitrust.org/cgi/pt?id=uiug.30112083818812&seq=7
Accessed 3rd September 2026: https://corporate.wessexwater.co.uk/media/iavpfwdz/wsx17-annexes-wastewater- 9
networks-plus-strategy-and-investment.pdf
6
7
8
The Problem
7. Even clean water being discharged into a dry river bed destroys the fundamental nature of a
winterbourne by introducing water at a time of year none should be present. Wessex Water
freely admit this, as shown in para 6 above.
8. However, the water leaving the Shrewton WRC is not pure. It is a mixture of treated sewage
effluent and, sometimes, stormwater. Such emissions introduce a range of pollutants into the
River Till. These, together with legacy residues of nitrogenous fertiliser and animal waste, are
turning the River Till below the outfall eutrophic; it is dying. In the past 20 years, rafts of Water
Crowfoot and Watercress and the life they supported have disappeared to be replaced with
algal mats and sewage ‘fungi’ as far south as Berwick St James. Other animals and plants are
also disappearing. Although phosphorous (as phosphate) levels are low, in part possibly
caused by Wessex Water’s use of iron to remove it during the sewage treatment process, the
residual iron can have a similar effect in triggering the availability of nitrogen from nitrate by
algae. Sunlight and warmth can have a similar impact.
9. The Royal Commission assumed that discharges would be diluted by clean river water; a
situation that is not happening here for much of the year. Wessex Water and the Environment
Agency (EA) claim that discharging into a dry river bed is permissible, but that flies in the face
of EA’s own rules that explicitly require (or strongly prefer) water courses with year-round flow.
10. The Royal Commission set standards using the science of the day. It recognised that how
these were applied needed to be very flexible, particularly when it came to dilution rates. They
realised that the nature of the water course and the nature of the contaminants being released
into it might increase the dilution rate needed to eliminate ‘nuisance’ by one or even two
orders of magnitude. The nature of the River Till as a winterbourne has been understood
since time immemorial. The 1086 Domesday Book, recorded the winterbourne nature of the
River Till in the names of the villages astride it. Shrewton, Winterbourne Stoke, Asserton and
Berwick St James were all simply called Winterbourne, reflecting their location on what was
then called the River Winterbourne. Surprising then, that neither Wessex Water, nor the
Environment Agency (nor their predecessors), failed to account for this in the design,
construction, permitting and operation of the Shrewton WRC.
11. What did the Royal Commission mean by ‘nuisance”? They regarded it as a pragmatic,
sensory sense of something that ordinary people would object to; a smell, a visual intrusion,
anything suggesting something wasn’t right. This concept still exists in common law
(Manchester Ship Canal Co v United Utilities) and in statutory nuisance actions (Environmental
Protection Act 1990, s.79). However, the legality of discharging effluent to a dry river bed, or
when insufficiently diluted, to prevent ‘nuisance” does not appear to have been tested in a
single landmark appellate ruling. Perhaps now is the time to press for this.
12. We have tested water in the River Till at either end of Winterbourne Stoke. Water ceased
flowing into the village in early June 2026, so all of the testing since June has been on the river
as it flowed southwards out of the village. Springs within the village are now shutting down
and it is likely that the river will have disappeared from the village entirely by early October.
Nitrogen levels have remained high. At the start of June, an independent, UKAS accredited
laboratory tested water samples that showed high levels of Escherichia coli and other faecal
coliform in the river. These are indicators of human, or animal, faecal contamination and may
indicate even more pathogenic micro-organisms are present. At the bacterial levels found, the
River Till, had it been a registered bathing site, would have had to be closed immediately on
health grounds. It isn’t, but generations of children still like to paddle in fords along the river.
The levels of bacteria found would likely cause gastrointestinal disease if river water was
swallowed, but also the levels were such that it could cause disease by contaminating cuts
and grazes putting people at unnecessary risk. This, as with much of the foregoing, is another
clear and objective demonstration of ‘nuisance’.
Wessex Water’s Misguided Plan
13. In Annex WSX17 to Wessex Water’s Business Plan, the company illustrates its intentions for
improving the situation. The company recognised that the current situation is untenable (by
admitting it is damaging the ecosystem) and plans to pipe the effluent from the Shrewton
WRC southwards. One option is to pipe it to the south of Berwick St James which is below
the perennial springs. However, Wessex Water’s preferred option, on cost grounds, is to run
the pipe south from the current outfall to a point on the River Till that is just north of the A303.
This is over 2km north of the site of the perennial springs. It doesn’t solve the problem and
merely moves it further away from the Shrewton Treatment Centre; a case of out of sight, out
of mind.
14. As it stands, villagers in Winterbourne Stoke would have more concentrated effluent from
treated sewage and stormwater flowing through their gardens and stagnating there when the
ephemeral section of the river through the village dries up, as it does quite regularly, it would
still create an artificial flow in the river when it should be dry and would still damages a 2km
stretch of a rare winterbourne section. It would cause particular damage to the unique area of
interface between the ephemeral zone and the permanent zone of the river. Moreover, this
point of interface has been identified as being high quality terrestrial habitat for Great Crested
Newts (GCN); other sites between the current sewage outfall and the permanent springs are
known to house breeding colonies of GCN and provide further high quality habitat. Wessex
Water’s plan may worsen the situation for GCN in some places.
The Solution
15. In addition to providing better ways of treating sewage on a day-to-day basis, Wessex Water
need to devise a way of minimising the number and volume of stormwater overflows. It needs
to pipe all of this and treated effluent somewhere it ceases to be a ‘nuisance’ by virtue of
dilution at a level suitable for a sensitive chalk stream winterbourne. This could be achieved
by piping the water to a point south of the permanent springs and because even here the flow
rates are likely to regularly fall below even Victorian standards for dilution, it may have to be
piped further south to the confluence of the River Till and the River Wylye. Alternatively,
effluent from the Shrewton WRC might be piped northwards to the centre of the catchment
and be disposed of to groundwater, thereby using groundwater dilution to minimise surface
impacts.