Request
Pursuant to the Environmental Information Regulations 2004, please provide copies of all recorded information held by the Council from 1st January 2022 to the present date regarding the technical methodology, boundary redrawing, and subsequent exclusion of the Nallbourne and Little Stour catchment from the Stodmarsh Nutrient Neutrality catchment map. This includes but is not limited to Land off the Hill Littlebourne CA/23/00484 and multiple other sites allocated for urban expansion in the Draft Canterbury District Local Plan (2042/43)
This request specifically requires the disclosure of:
- All internal and external correspondence (including emails, letters, Microsoft Teams chat logs, and meeting minutes) between Council planning officers, executive leadership (including the Chief Executive), and Natural England regional or national officers concerning the decision to alter the Stodmarsh catchment boundaries to exclude Littlebourne.
- All technical notes, hydrological models, reports, or advice submitted by Water Environment Limited or consultant Guy Laister concerning surface water routing, wastewater networks, or package treatment plant (PTP) models in the Littlebourne, Lampen Stream, or Wingham River sub-catchments.
- The specific scientific datasets, maps, and independent legal advice relied upon by the Council to justify excluding Littlebourne on the basis of surface water pathways while omitting the wastewater/foul sewer pathways routing to local Wastewater Treatment Works (such as Dambridge WwTW).
- All minutes, briefing notes, and agendas relating to the decision by council leadership to restrict, redact, or veto elected member questions regarding potential conflicts of interest within the Stodmarsh Nutrient Mitigation Strategy governance group.
Please note that under the EIR, there is a strong presumption in favor of disclosure for information relating to emissions and environmental decisions. If any part of this request is refused, please provide a detailed schedule of exemptions relied upon, alongside a public interest test calculation for each item withheld.
Response
Under Section 1(1)(a) of the Freedom of Information Act, we have established that this information is not held. This is because Dover District Council were not involved in the exclusion of the Nailbourne and Little Stour Catchment which falls mostly within Canterbury District.
Internal Review Documents
Internal Review Request:
I am writing to lodge a formal corporate governance complaint regarding material, documented contradictions concerning Dover District Council’s (DDC) involvement in the Stodmarsh Nutrient Neutrality catchment mapping modifications. Specifically, this complaint asserts that despite recent catchment boundary adjustments and the adoption of localised surface-water modelling, DDC retains ultimate, non-delegable statutory liability for any environmental degradation, unmitigated nutrient loading, or compounding harm caused to the Stodmarsh designated protected site where such impacts originate from wastewater and sewage generated within the Dover district and routed through regional infrastructure toward the protected site.
On 2 September 2026, Corporate Governance Services responded to an Environmental Information Regulations (EIR) / Freedom of Information (FOI) request to Dover District Council. The request sought all correspondence concerning the exclusion of the Nailbourne and Little Stour operational catchment from the nutrient neutrality catchment area. The Council denied direct involvement in these boundary adjustments.
Incontrovertible evidence proves this position is incorrect. I have attached the report: Stodmarsh Water Quality Modelling, Dover District Council, Project Reference: P0006031, September 2022, which was actively commissioned by Dover District Council.
While boundary changes may offer short-term relief to local developers by bypassing Natural England’s nutrient offset guidance, it does not absolve the Council of its strict statutory and international obligations.
The technical and legal basis of this corporate governance complaint rests on five key areas:
1. Procurement and Data Ownership Contradiction
The attached project document (Project Reference: P0006031) confirms that DDC directly commissioned, funded, or partnered in the production of the foundational water quality modelling used by the cross-boundary Nutrient Neutrality Executive Working Group to alter catchment boundaries. Disclaiming involvement in a technical study the Council actively commissioned represents a severe breach of corporate transparency and public data accountability.
2. Incompatibility of Surface Water Modelling with Ramsar Resolution Obligations
While the technical data within the 2022 DDC-commissioned modelling study may be accurate on its own terms, its scope is restricted strictly to surface water. This restricted scope is legally non-compliant and directly violates Ramsar Resolution VII.18 (River Basin Management), which dictates that wetlands cannot be managed in isolation from the broader hydrological basin, and Resolution VIII.40 (Groundwater Protection), which mandates the evaluation of the whole water cycle.
Furthermore, the Council’s subsequent non-disclosure and denial of involvement violates Ramsar Resolution VIII.40, Paragraph 11, which explicitly stresses: "that the analysis of these issues and the solution of conflicts require a completely transparent environment, scientific rigour and, above all, participation of all actors involved in the management and use of water resources;"
As a signatory to the Ramsar Convention, the Council has a strict duty to manage all water sustainably, protect "shared species," and maintain absolute public transparency. Attempting to decouple this catchment based on an incomplete, surface-water-only model while withholding information breaches these international commitments.
3. Dambridge WwTW Hydraulic Overload and Cumulative Flood Risks
The Dambridge Drainage and Wastewater Management Plan (DWMP) - submitted separately via Email Part 2 due to corporate firewall file-size constraints - forecasts a high risk of flooding by 2050 due to hydraulic overload. Processed sewage emissions from Dover (facing a 91% growth forecast) route directly to the Dambridge Wastewater Treatment Works (WwTW). This facility sits just 3.9 miles south of the Stodmarsh wetland and discharges into the Wingham River / Little Stour system. The area around Wingham is highly vulnerable to groundwater emergence during periods of high water table. When combined with increased surface water flooding driven by climate change and urban creep, tidal flow vulnerabilities, and the planned expansion at the neighbouring Newnham Valley WwTW, the cumulative flood risk is severe. Even minor, small-scale flooding or operational bypass events at Dambridge present significant, compounding legal and environmental flood risks to the Stodmarsh protected site.
4. Non-compliance with National Planning Policy Framework August 2026
The August 2026 update to the National Planning Policy Framework (NPPF) explicitly reinforces that all strategic supporting infrastructure, specifically including Drainage and Wastewater Management Plans (DWMPs) and Water Resources Management Plans (WRMPs), must be managed robustly so as not to cause degradation, unmitigated nutrient loading, or structural damage to protected environmental sites. There are further national and statutory requirements to improve ecological status of chalk streams. Please find attached DEFRA’s analysis of the Wingham and Little Stour water body poor ecological status and DEFRA’s wider map of the Stour catchment of which this is part.
5. Specific Risks highlighted by Southern Water Stour River Basin BRAVA
The Southern Water Stour River Basin DWMP Baseline Risk and Vulnerability Assessment (BRAVA) for Dambridge WwTW shows very significant operational pollution risk in 2020, very significant risk of non compliance with dry permit flows by 2050, very significant risk of poor ecological status in 2020 and significant risk of not meeting nutrient neutrality in 2050. any modelling or boundary adjustments that attempt to decouple this catchment from nutrient neutrality obligations under Ramsar Resolution VII.18 (River Basin Management) and VIII.40 risk of uncontrolled development and failure to manage groundwater and cross boundary cooperation create risk of severe trans-boundary legal and environmental liabilities for DDC. Natural England’s role is purely advisory, the fact that they have agreed to the boundary change does not affect or alter Dover Council ultimate liabilities.
Internal Review Response:
I am able to confirm that Dover District Council did commission the technical study referred to however it was not for the purpose that is being suggested. We did not claim to have no involvement in this technical study and I apologise if this was implied. However, the study was commissioned for other purposes not referred to in your FOI request and therefore it was believed it did not relate to the request.
The FOI you submitted specifically referred to the Nailbourne and Little Stour Catchment and development within the Canterbury District. Dover District Council had no involvement in this decision and therefore have no records of this in relation to the Nailbourne and Little Stour catchment decision.
The report was commissioned for the purposes of having the Wingham and Little Stour catchment removed from the Natural England Guidance, but this is not what the FOI asked for.