Challenges & Choices Consultation 2020

Water Challenges and Choices Consultation 2020

Make your voice heard:


Are you currently watching the river you care about deteriorate and wild fish stocks decline? Concerned with how water is used in the England? Is there a fair balance between nature and industry? What changes do you want see to the current system of regulation and enforcement?

This is your chance to have your voice heard on how the pressures impacting our rivers and lakes are managed until 2027. The consultation features 27 questions, however, you may choose to answer only those you feel are most relevant to you or your organisation.

S&TC have submitted a full response to all questions which is shown below for reference.

We feel agriculture represents an area where there's an abundance of opportunity for quick wins and outcomes that are mutually beneficial. Particularly the need for resources to establish an effective regulation baseline. A relatively small investment in this area could reap huge rewards both for nature and for people and our water bills!

See Sections 8, 19 and 20 for our responses concerning Agriculture.

S&TC Challenges and Choices Response 2020

S&TC Response to the Environment Agency’s Water Challenges and Choices Consultation

  1. The way we treat water today will shape all our futures. What changes can you make to improve the water we rely on?

  • Individuals can play their part on rivers locally, by actively getting involved in river restoration and monitoring schemes, as well as reducing domestic water use, and by supporting national campaigns for government policies that protect water and the aquatic environment – but ultimately, change has to come from political commitment to river and water wildlife protection. Water is vital to all our lives- in the future we must put a true value on water as a finite resource which needs conserving in its own right.
  • Government’s present focus is on climate change mitigation, which is quite right for a medium to long term strategy. However, there are a myriad of other environmental issues impacting rivers and water life which need urgent attention now, otherwise there is no chance of closing the gap between the present 14% of rivers achieving GES and the aspirational 75% by 2027. Delivering on these pressures now will also help build resilience in the natural system to better cope with future pressures of climate change.
  • The proposed Office for Environmental Protection must have the same or increased powers as does EU DG Environment at present to protect rivers and water life post- Brexit, and to ensure regulators abide by their statutory responsibilities toward environmental protection. A strong and influential environmental watchdog is fundamental to increase the number of our rivers achieving GES by 2027.
  • More resources for regulators to conduct fit-for-purpose monitoring on all river systems and to regulate effectively enough to create a deterrent for would-be polluters. At present, there is a woeful lack of funding for effective monitoring, which is a fundamental requirement of an effective enforcement policy, and there has to be greater political commitment to challenging polluters.
  • Government must take the lead and work with the public to improve the water environment, for example;

- Individually, we must reduce water consumption and Government must roll out 100% water metering

- Individually, we must report any incidents of water pollution to the Environment Agency ‘Hot Line’. However, Government must ensure adequate resources for enforcement, and that fines are fit for purpose and deliver benefits back to the environment

- We must reduce chemicals entering our waterbodies. Government agencies must assess the risks to aquatic ecology from both chronic, low level chemical exposure and the cumulative, cocktail effect of multiple chemicals entering rivers, and amend discharge permits accordingly.

  1. What more can we do to tackle the impacts of climate change on the water environment and what additional resources (including evidence, targets, tools and additional mechanisms/measures) do we need to do this?

Increasing water temperatures will significantly impact riverine ecology unless we act now to mitigate its effect. We need to accelerate the implementation of action to manage catchments in ways that reduce freshwater pollution, improve water quality and regulate the quantity and timing of flow, so increasing a catchment’s natural resilience to adapting to climate change. We must restore wetlands and, wherever possible, re-naturalise rivers, including tackling morphology issues and managing water flow patterns in ways that promote ecosystem processes.

We need to:

  • take into account the impact of future climate change when calculating whether water abstraction is, or is likely to be, environmentally damaging. The greater the flow down a river, the more chance it has of resisting temperature increase, with the added benefit of increased dilution of contaminants entering the system;
  • better natural water retention in rivers that even out flow regimes and keep water flowing, reducing temperature and diluting pollutants as well as benefits for natural flood defense and biodiversity. This can be achieved by reconnecting rivers with their floodplains wherever that is possible, reversing upland drainage, establishing wetlands - and catchment management plans that include planting native woodland, which evidence shows can retain up to 60 times more water than pasture (Pontbren Project, Wales) and so help to even out flow regimes;
  • where extensive woodland is not possible, establish more shade along riverbanks to help control increases in water temperature so that in-river habitats are protected. This is particularly important in shallow streams such as upland tributaries, which are vital for spawning and juvenile fish habitat that could be particularly vulnerable to temperature increases, as could invertebrate assemblages within the food chain;
  • river restoration projects that encourage pool/riffle sequences to both speed up flows along some river lengths but also create deeper holding pools of cooler water as a refuge for fish and water life
  1. What can we do to address this biodiversity crisis and meet the 25 Year Environment Plan targets for wetlands, freshwater and coastal habitats and wildlife?

As already stated, we must change political commitment, adopting national policies which place a true value on rivers and water life and the services they provide for us, linking environmental resilience to a healthy economy and multiple benefits to human populations. It is not a question of prioritising the economy over the environment or vice versa – the economy needs successful businesses to prosper but humans in every walk of life require a healthy environment in which to exist. Rivers and water quality with high ecological status are an essential part of that healthy environment.

The regulator must be properly resourced to regulate and enforce existing potential polluters. This will require;

  • an increase in resources for EA monitoring that is fit for purpose and effective across all river systems – including data partnerships with 3rd sector organisations. As an example, the present spot sampling of phosphates (P) once a month, and then an average of the 12 samples in a year to arrive at a P standard for discharge permit holders, is totally inadequate, as S&TC’s daily P monitoring on the River Itchen between 2013-2017 has confirmed - potentially damaging P ‘spikes’ can last less than a day and are invariably missed by monthly spot samples. By accepting S&TC’s academically analysed data, the EA would have received accurate evidence on which to base local decisions and saved resources on ineffective monitoring.
  • Post-Brexit Agricultural Policy must include incentives for managers to protect the water environment running through their land, so that subsidies are received in return for public good. This requires sufficient resources to police environmental protection on all English rivers and, conversely, enforcement where adequate protection is not provided, so that a strong deterrent is evident to would-be polluters. Shifts and strategic planning of wider land management use will also be required, given the impacts of agricultural land management on the freshwater environment.
  • As well as increased Government commitment to riverine protection, catchment management is essential to address issues at a local level - from source to sea, including issues such as reversing upland drainage, creating wetlands, reconnecting rivers with floodplains, reversing morphological damage and creating natural coastal defenses which benefit water life as well as acting as natural flood defenses. However, catchment management must be properly resourced so that plans can realistically be delivered – including sufficient Government funding to support local catchment

management partnerships. Delivery of catchment-based measures to reverse riverine degradation is essential to improving the GES of English rivers and should be seen as a natural partner to improved national policy commitment to monitoring and enforcement.

  1. Environmental targets can generate action and provide a strong signal of intent. Could additional statutory targets contribute to improving the water environment? If so, what types of targets should be considered?

  • Specific chalkstream targets:

Chalkstreams are our rainforests or coral reefs. 85% of the world’s chalkstreams are found in England, and as such we have a duty to protect them. Yet, despite this, the S&TC Riverfly Census, which reported in May 2019, confirmed that our chalkstreams are under huge pressure and their current management is failing them. Even the most ‘protected’ in terms of environmental regulations - e.g. the Rivers Itchen and Wensum SAC’s - were shown to be suffering from excess sediment, phosphates and chemical pressures, and declining invertebrate species richness as a result. This situation is unacceptable for such important ecosystems as chalkstreams, for whose protection UK Government and its agencies hold a global responsibility.

The Riverfly Census confirmed that chalkstreams are biologically distinct systems- yet they are managed and classified the same under the Water Framework Directive (WFD) as other rivers. This means a chalkstream at ‘good’ or even ‘high’ according to WFD is not functioning as a healthy chalkstream should. This led S&TC, alongside local EA, to produce bespoke targets for mayfly species richness and Gammarus numbers to better represent a healthy chalkstream system.

Nationally, new chalkstream specific targets should be developed to help protect these incredibly rare and special ecosystems.

  • Another glaring omission is a standard for sediment, which the S&TC Riverfly Census highlighted as a major polluter across English rivers - on its own but also for the nutrients, toxic chemicals and other contaminants that may be bound with it. S&TC commissioned and co-authored a peer-reviewed paper showing that sediment directly kills invertebrates, especially when bound with excess phosphate. A national monitoring standard for sediment and river specific targets are therefore overdue and need addressing as a matter of urgency. The focus on reducing sediment at source via Catchment Sensitive Farming advice alone has not worked. We now need a mechanism to monitor and measure sediment in rivers, along with incentives and stronger, better resourced enforcement to help target further reductions in stressful discharges from land management and drive forward improvements in watercourses.
  • Small waters and headwaters are a valuable component of the freshwater biodiversity resource which largely fall outside of the WFD monitored network and can therefore

be overlooked in terms of funding and delivery, so targets promoting their protection and restoration would be beneficial.

  • However, we also need to achieve the environmental targets we already have – which are seldom being achieved because of lack of political commitment and funding for effective monitoring and enforcement. As already stated, we need properly resourced regulation that acts as a genuine deterrent to would-be polluters, making it uneconomic to contaminate rivers. At present, there is evidence that polluters believe they will get away with their activities or, if they are ever prosecuted, that they see any fine as merely a business cost rather than a serious deterrent to counter future pollution.
  1. What can be done to address the challenge of changing water levels and flows?

  • In order to properly manage our water levels and flows, we must invest in real-time monitoring equipment, so abstractions can be flexible and based on actual available water. In light of climate change and altered flow patterns, extreme weather events and shifting seasons, current water management is not fit for purpose.
  • S&TC believes we need a fundamental review of the national abstraction policy so that it is future proofed to mitigate climate change and population growth. In particular, that policy must have a genuine regard for river protection, rather than a presumption that current abstraction licenses should be supported unless there is irrefutable evidence of environmental damage - which is extremely difficult to prove in the current climate. In many cases, our rivers are currently not being effectively protected from over-abstraction.
  • There should be pressure placed on water companies to find new, sustainable sources of water for potable supply within agreed timelines. This is especially important in aquifer-fed systems, where abstraction from the ground is a relatively cheap and easily accessible source of clean water that requires minimal processing for potable supply, and so there are commercial benefits for companies to increase abstraction from aquifers up to their licence limits. Many companies do not yet abstract to those limits and so, despite the potential for environmental damage, the temptation is to increase current abstraction sources rather than seeking alternative, more environmentally sustainable supplies. For example, this is arguably the case with Southern Water, who appear to have done little over the past decade in researching new sources of water, and now have to rely on increased abstraction from the River Test in times of drought while they wait for a new reservoir and desalination plant to come on-line - still many years away from completion.
  • There are many public benefits to retaining more water in river systems, as well as providingamoreconsistentsourceofpotablesupply. Togetherwiththeconstruction of new reservoirs, which S&TC sees as imperative in water-stressed areas, catchment management plans should also include initiatives to reconnect rivers with their

floodplains, reverse upland drainage, establish wetlands and plant native woodlands to retain water within river systems. These actions would create multiple benefits apart from increased water retention, including evening out river flows, natural flood defence and general biodiversity protection and enhancement.

  • As already stated, many water company sources and other abstraction licenses are not fully utilised, and so water abstraction could be legally increased in relevant catchments, regardless of any (hard to prove) environmental damage caused by doing so. S&TC therefore calls for all unused water abstraction licence capacity to be immediately revoked so that the urgent future-proof planning and assessment of water sources can take place.
  • Agriculture is a significant water abstractor and S&TC believes that there should be fiscal incentives for farmers to construct individual farm reservoirs, and for licenses to be flexible, with real-time in-river flow monitoring, so that they can be refilled at any time above agreed local river flows - the trigger level to be sufficient so as not to cause any environmental damage in supply rivers. This was suggested when the National Flood Group met in 2012 but does not appear to have been followed through.
  • Government must champion water as a scarce resource - for example; support 100% water metering, underpinned by better water labelling and smart pricing, and other initiatives to increase public awareness around water saving approaches.
  1. The abstraction plan, referenced in the changes to water levels and flows narrative, explains our current and future approach for managing water abstraction. What else do we need to do to meet the challenges of climate change and growth while balancing the needs of abstractors and the environment?

  • As the climate continues to change, land use management must adapt to mitigate the impacts of warming temperatures on the water environment. For example, the growing of particularly water-hungry crops in the south and south east, or other water-scarce areas, may no longer be sustainable.
  • The Environment Bill, when adopted, will create the ability to remove or change environmentally damaging licences without the need to pay compensation. This power is extremely welcome but, with changes affecting only licences modified after 2028, S&TC, via the Blueprint for Water Coalition, is advocating an amendment to the Bill to enable action to be taken sooner.
  • And as above, the onus must be on water companies to provide new and sustainable sources of water that take pressure off the environment rather than add to it. For example, as the climate continues to change, land use management will become central to agricultural policy. We may, for instance, have to stop growing particularly water-hungry crops in certain water-stressed areas, such as the south and south east

of England. There also needs be be greater public/commercial education on the need for more responsible demand management

  1. What kind of a water flow environment do we want? Should we maintain statutory minimum water flow and level standards universally across England as we do now, or go further in some places based on environmental risk?

We need to go further. As discussed, we must invest in real-time monitoring equipment, so abstractions can be flexible and based on actual available water. And we need more robust and environmentally sustainable national and local water flow standards:

  • We have to have minimum flows on a catchment basis, taking into account the multiple requirements of specific habitat protection and the fish species likely to be present in individual rivers, the majority of which will have to undertake at least some migration to complete life cycles. We need to update the Environmental Flow Indicator work to incorporate the best science available and invest in new research to fill knowledge gaps - and then action the resulting recommendations!
  • As already discussed, catchment calculations must be based on a new national abstraction policy that has river and water life protection at its core. A national benchmark must be that all rivers should have sufficient flows to allow unhindered migration for fish species from estuaries through to spawning grounds, although this basic tenet would be tailored on a catchment basis (as above) to accommodate the specific species present.
  1. What can be done to address the challenge of chemicals in the water environment?

The best way to counter chemical contamination in rivers is to stop pesticides and other toxins from entering watercourses at source, which can be achieved with stronger regulation and enforcement alongside incentives for land managers to protect river corridors.

With all new chemicals the precautionary approach should be applied, and the burden of proof should be on manufacturers to ‘prove’ no adverse impact- that the chemicals are not toxic, do not persist in the environment or bio-accumulate.

The S&TC Riverfly Census used species level invertebrate data run through the SPEAR calculator to analyse the presence of pesticides and other toxic chemicals in water courses, and the results highlighted chemical signatures from many of our target rivers. One case study in the headwaters of the River Itchen, where S&TC data showed chemical impact on invertebrates, led to the EA investigating the discharge from a Salad Washing Plant and confirming the presence of pesticides, washed off imported salad leaves, in the discharge entering the river.

The S&TC/EA experience on the River Itchen has highlighted the urgent need to review all discharge permits directly into watercourses which have the potential to discharge pesticides and other toxic chemicals into watercourses. S&TC believes no industry should return water in a worse condition than they receive it - therefore no new permits should be granted that allow such discharges directly into any watercourse without the use of technologies to remove such residues.

S&TC strongly believes the Environment Agency has a duty to better understand the impact of low level, continuous exposure to cocktails of chemicals on biota. Managing each chemical in isolation and according to an Environmental Quality Standard (EQS), is no longer acceptable given the high numbers of chemicals being discharged within a single discharge. These chemicals may separately each be below EQS but combined they may be far more damaging to the ecology, or the lower-level chronic, day in day out impact on ecology may be greater than an EQS breach. As a minimum, the EA should adopt the SPEAR metric into its routine monitoring, which will highlight chemical pressures on invertebrate assemblages, which in turn will allow more in-depth, evidence-led and cost-effective research to be undertaken by the EA into potential contamination sources.

The case-study on the Itchen also highlighted that current compliance monitoring for discharge permits - i.e. once a month sampling to produce an annual average - is not fit for purpose in offering environmental protection from seasonal activities, such as the application of pesticides or fertilisers. We believe an urgent review of current compliance monitoring is therefore required.

We also believe;

  • There should be a statutory responsibility for farmers to prevent chemical run-off from their land into rivers. This could be connected to a new Agricultural Subsidy Policy whereby farmers are incentivised to protect the environment, but penalised if they fail to do so.
  • Farmers should have to follow mandatory soil management protocols within an agreed timeframe, including zero tillage where appropriate. Evidence shows that zero tillage minimises soil loss - and any chemicals bound to it - and is a win/win in that it improves yields after an initial short-term dip in production, and also decreases inputs such as fuel costs. There are, therefore, medium to long term benefits for farmers through improved soil management, as well as protecting river corridors from soil and chemicals leaching into watercourses. If zero tillage is not applicable, then contour ploughing and/or control of tramlines must be adopted to minimise run-off into rivers. While not as effective as zero tillage, this type of management will lessen run-off of soil and toxic chemicals entering rivers and will benefit farmers by keeping more soil in fields.
  • Buffer strips should be a mandatory requirement for arable riparian land, together with fencing to keep livestock away from riverbanks. Buffer strips act to filter

contaminants entering watercourses, and minimising livestock access to rivers stops contamination from faeces and any chemicals bound within them.

  • As already stated, there must be properly resourced monitoring, including data partnerships with the 3rd sector, to ensure that toxic chemicals are not impacting watercourses.
  1. Do you support the Environment Agency's proposed strategic approach to managing chemicals as referenced in the Chemicals in the Water Environment challenge document? If not, what changes would you make?

We believe more needs to be done. S&TC’s policy on addressing chemical contamination in rivers is well covered already in this document.

10. What balance do you think is needed between current chemical use, investing in end-of pipe wastewater treatment options and modifying consumer use and behaviour?

  • It is far more cost effective and environmentally-protective to stop chemical inputs at source rather than trying to extract at end of pipe from sewage effluent – see above under 8. However, this takes time, so in the short-term, we need both in order to improve our aquatic habitats now and to help make them more resilient in the future.
  • There must be an increased public education programme to cease using household products containing potentially toxic chemicals that could discharge into rivers via the sewerage system – eg as has happened successfully in Sweden
  • A genuine move to ban toxic chemicals in hygiene and other products which could enter the sewerage system, within timelines – again as has happened in Sweden :

A scientifically based suspicion of risk is enough under Swedish law to act against a chemical, according to Bo Walstrom, senior international advisor at the Swedish Chemicals Inspectorate. To avoid action, an industry must show beyond a reasonable doubt that the suspicion is unfounded and that their product is safe. This is called the reversed burden of proof, and it is combined with the “substitution principle,” codified into Swedish law in 1991. If a safer alternative exists, a company must use it or be subject to penalties.

  • S&TC’s monitoring work on the Upper Itchen system has shown that poorly maintained septic tanks can have a significant impact on rivers and their ecology. At present, there is a lack of regulation of septic tanks and S&TC believes there should be an agency tasked with the responsibility for ensuring proper maintenance and approval of any new developments relying on septic tank systems, so that neither potentially toxic chemicals nor phosphates can enter watercourses from household products via this source.
  1. What can be done to address invasive non-native species?

  • Care must be taken in moving water around the country so as to protect against the spread of invasive species, many of which are very small and easily transported in water – eg aggressive non-native invertebrates and the spawn of larger species such as signal crayfish. Where possible, water retention for potable supply should be local to avoid moving water from one catchment to another
  • Water users should be made aware of the dangers of non-native species and the part they could potentially play in spreading environmental problems to other areas. The Check, Clean, Dry message is a good way of achieving this (see below under 12) but should also be enforced by riparian owners, clubs and other water business operators at facilities and points of activity.
  • The Government and agencies must have mitigation/contingency plans - regularly updated to keep pace with new evidence - for when dangerous non-natives are identified, and to stop them from entering the UK where feasible. The potential danger of Gyrodactylus salaris (Gs) to wild salmonid species is a particularly important issue and a contingency plan for minimising its spread and impact, should it ever arrive in the UK, is vital for the wellbeing of its target species and should be regularly updated in the light of best available science.
  • Experience from Norway suggests that the vast majority of incidents of the spread of Gs was through the movement of fish from an infected source to contaminate another river system, and there is strong evidence that much of the distribution of aquatic non-native species is by human introductions. There should be stronger enforcement of legislation designed to manage non-native introductions - cutting off the source is obviously more effective than putting contingency or mitigation measures in place.

12.   How would you promote Check, Clean, Dry to all recreational users of water, including those who are not in clubs or attend events?

Information must be distributed as widely as possible to water users so that they are made aware of the dangers of non-native species and the part they could potentially play in spreading environmental problems to other areas. Along with succinct explanations as to these dangers, the Check, Clean, Dry message should be spread through:

  • notices on national representative organisations’ websites;
  • notices on local club web sites and facilities that non- members can access;
  • notices at point of activity facilities frequented by members of the public - eg

angling, sailing, boating, water skiing etc;

  • inclusion of relevant statements on national licenses - eg Annual rod and net fishing licenses in England.
  1. Are there any barriers stopping you adopting good biosecurity when you are in or near water?

There are considerable barriers to adopting biosecurity measures, as witnessed by the widespread distribution of non-native fish, invertebrates, plants and animals throughout UK rivers. These barriers include:

  • public ignorance of the potential dangers from non-native species - either from intentional or accidental introductions;
  • the lack of sufficient non-native danger explanations, or the Check, Clean, Dry message, at access points to water-based activities or on club/organisational websites etc
  1. What can be done to address the physical modification of our rivers and coasts?

Physical modifications to rivers have been identified by the EA as the major reason for such a low number achieving GES under WFD, and there has also been a presumption that hard-coastal defences are more effective than natural habitat in defending against marine storm events. S&TC therefore believes there are a number of measures that can be taken to reverse ecologically damaging man-made changes in morphology:

  • Wherever feasible, rivers should be reconnected with their floodplains. As already stated, the benefits are considerable - to fish, invertebrates and especially natural flood defence. In England, many floodplains have been developed for housing and commercial activities, often resulting in properties being flooded in storm events and so reconnection with rivers is no longer feasible. However, the historical attitude of draining water to the sea as quickly as possibly - dredging out main river channels to speed up the process - has to change. Evidence is that rivers with natural meanders and the ability to flood over adjoining land when necessary, offer much better flood defence than those with straightened and deepened channels, quite apart from the benefits to fish and other freshwater biodiversity.
  • Existing work to identify and remove unnecessary/defunct structures, and enforcement to deal with unconsented works, must continue. This work must be adequately funded. Where any new structures are required, their impact upon freshwater ecology can be reduced by legally requiring the installation of fish passage measures (rather than ‘making provision for’ them), as is already the case for European Eel.

So, where possible, rivers should be restored as closely as possible to natural flow regimes - reversing upland drainage, reinstating meanders, replacing dredged gravels etc

A presumption against dredging rivers for flood defence. In particular, we need to initiate natural flood defences by stopping the input of sediment etc at source to prevent the need for dredging. We must have better joined-up approaches to river management, which adopt measures in section 8 above as prevention against having to artificially alter morphology while initiating catchment management plans which reverse historical damage as outlined above.

We must use catchment management initiatives to educate local stakeholders over the need for naturally flowing rivers, rather than perpetuating physical modifications, dredging etc

There is increasing evidence that softer, more natural coastal defences are more effective than hard-wall protection, in that they break up wave actions in marine storm events. Natural coastal defences also have huge biodiversity benefits, providing habitat for fish, mammals and plants, and will become significant carbon storage systems. They will arguably also have socio- economic benefits in terms of attracting ecotourism.

In summary, we need catchment management plans from source to sea that, wherever feasible, restore natural processes within rivers, estuaries and coastal zones. There should be a preference to schemes which utilise nature-based solutions and natural flood management- working with nature, not against it. This requires joined-up and coordinated planning to achieve best-possible results for morphology, natural flood defences and biodiversity.

  1. Giving more space for rivers and coasts to move and adjust naturally will regenerate habitat, improve wildlife and help us adapt to climate change. What can you and others do to support these changes?

While these are laudable aims, there are significant obstacles to overcome in the tightly managed English landscape. Spatial planning must prevent further development on floodplains, and land management (e.g. crop rotations) and land use change (e.g. arable reversion) will need to be considered as we adapt to climate change, helping to restore the functionality of some floodplains. High proportions of rivers are disconnected from their floodplain by embankments and flow control structures, limiting the scope of those floodplains to hold water during high flows and contributing to downstream flooding issues. This loss of connectivity must be reversed wherever feasible.

S&TC therefore believes that:

  • where wetland/reserve creation is not possible, it may be feasible to include riverbank movement within a revised agricultural policy that establishes buffer strips alongside rivers running through farmland. Buffer strips will consolidate banks and so make erosion more natural and slow down the process of river movement, as well as having benefits for water quality by acting as run-off filters.
  • as stated in section 14, soft coastal habitat that protects against storm events, rather than building walled defences, will allow natural movement of channels and sediment etc, as well as arguably providing better protection by breaking up wave action rather trying to stop it against a solid barrier.
  1. What can be done to address plastics pollution in the water environment?

As with other issues within this consultation, the only realistic way to deal with plastic pollution is to stop it entering watercourses in the first place. For this, S&TC believes we must need:

  • support actions to reduce the manufacture and use of single-use plastics, such as The Plastic Pollution Bill (PPB), and measures to reduce plastic littering such as deposit return schemes. Most marine plastic pollution comes via river discharges, including through sewerage systems, so individual actions (via increased public awareness) can make a difference in ceasing to use products containing microplastics or single use plastics.
  • We must also start preparing to deal with the plastic already in the environment. Measures such as water sensitive urban design (WSUD) and increased implementation of SuDS must be flagged for new developments, recognising the role that these measures play in filtration.
  • to influence the improvement of recycling plastic products – both increasing collection points and processing plastics efficiently in UK recycling plants rather than removing the responsibility by shipping plastic waste abroad.
  1. What actions should the Environment Agency take to reduce plastic pollution?

University studies have shown microplastics in all inland rivers surveyed. Microplastics should be added to the list of pollutants regularly monitored in inland waters, requiring agreement of an accurate, repeatable, reportable method for microplastic quantification. The full consequences microplastics are having on organisms and ecosystems are not yet known and requires research.

  1. What can be done to address pollution from abandoned mines?

Some 3% of English river length is impacted by pollution from abandoned mines. While the treatment of coal mine impact is well understood, cleaning up the residue from other mines is more problematic. To address the problem, S&TC believes that:

  • there should be a single agency given the responsibility for addressing pollution from abandoned mines, with sufficient resources for it to carry out its work effectively. The agency should apply best practice from successful clean-up operations in former mining regions of England and Wales, where several rivers are now thriving ecologically, having once been heavily impacted by pollution from mining;
  • there should be more research into treatment methods for metal mines and the recovery of resources from residues to help pay for processing costs;
  • water quality should be monitored and treatment planned on a catchment scale, taking into account that some former mines are protected as sites of special interest
  1. What can be done to address pollution from agriculture and rural areas?

Many of the measures required to address pollution from agriculture have been covered in section 8 above. Although that dealt with chemicals, the measures are similar because they are based on stopping the input of potential pollution into water courses, whether that comes from soil loss leading to sediment, excess nutrients or toxic chemicals - the three most damaging stressors from agriculture identified by the S&TC Riverfly Census. S&TC therefore believes that:

  • measures should be adopted as in 8 above – the carrot and stick approach, especially greater commitment to effective monitoring and regulation, including sufficient funding and commitment to effective enforcement that deters would- be polluters;
  • notice should be taken of the evidence contained in the S&TC Riverfly Census Report as to the impact of chemicals, sediment and phosphate, much of it from agriculture, and their impact on freshwater ecology;
  • an agency should be made responsible for managing septic tanks. We now know that in areas where septic tanks are prevalent but poorly maintained, they can be the source of excess phosphate and toxic chemicals in adjacent watercourses;
  • Ofwat should allow sufficient investment in rural sewage treatment works to prevent overspill of stormwater events directly into rivers - as part of Ofwat’s resilience and environmental responsibilities;
  • regulation (such as Nitrate Vulnerable Areas and Water Protection Zones where appropriate) should be introduced where current initiatives are failing.
  1. How can we support the farming sector to excel at innovative solutions which benefit both productivity and the environment? What should these solutions look like?

As already stated, S&TC believes that win/win solutions for farming and the environment must be encouraged and are more likely to be supported by Government in post-Brexit agricultural policies. A new Environmental Land Management Scheme should identify suitable options that fund farmers to genuinely deliver for nature, Meanwhile:

  • experimental farms such as Game and Wildlife Conservation Trust (GWCT)’s Allerton Project in Leicestershire have shown benefits to farmers from adopting techniques such as zero tillage that increase productivity, cut inputs but also protect the environment. This information should be distributed as widely as possible and included in agricultural college curriculums;
  • we need to reward good practice that protects rivers by paying farming subsidies for innovative practices, but a fallback ‘stick’ measure is still required to punish malpractice by withholding payment from persistent polluters until the offending practice is stopped and the damage rectified;
  • S&TC is finding that farmer clusters are increasingly interested in working with conservation groups to monitor any ecological damage from their operations - eg we are presently working with a farming group on the Wallop Brook, a tributary of the River Test, training them to carry out SmartRivers -species level invertebrate sampling- so that they can identify sources of pollutants and act swiftly to minimise their impact. The EA must embrace this type of high quality, 3rd sector data and include with its own monitoring evidence so that resources are maximised and overlap avoided;
  • there is mounting evidence that many farmers do not have sufficient storage capacity for manure waste, leading to the spreading of slurry etc on fields during inappropriate weather conditions, which is leading to a widespread issue of slurry pollution in rivers due to run-off - especially prevalent in areas with intensive dairy farming. There must be fiscal incentives for farmers to improve manure storage, and greater use of technology that processes waste and so avoids direct spreading on riparian land, so taking away need to spread onto land at inappropriate times. Manure storage and disposal should be integrated into post-Brexit agricultural policies.
  1. What can be done to address pollution from towns, cities and transport?

Urban areas pose distinct problems for rivers for many reasons, including extensive hard areas of tarmac, concrete, garden decking etc that prevent water percolation and increase

run-off into local watercourses. This is especially dangerous in storm events, when combined sewage overflows (CSOs) discharge directly into rivers and can carry pollution with them. S&TC suggests the following solutions:

  • Make SUDS compulsory on all new building projects
  • There should be incentives for retrospective SUDS fitting where feasible
  • Ofwat should allow Investment through the AMP process to ensure urban sewage treatment infrastructure is modern and effective, and connected to CSOs so that storm water is not allowed to enter directly into watercourses.
  • Adopt the initiative from other countries – eg USA – where drain covers have the picture of a fish and a short statement that drains end up in rivers/estuaries and can cause pollution.
  • Explore imposition of phosphate (P) neutral building development. Any additional P to be offset by reductions in P used by agriculture or released via STWs.
  1. How can sustainable drainage systems and green infrastructure be most effectively used to tackle pollution from urban areas? What challenges are there to using them?

As above; Green and blue infrastructure should be integrated through planning policy and be made mandatory in all greenfield development and brownfield redevelopments, recognising the role that these measures play in improving water quality as well as providing multiple benefits around biodiversity, greenspace, air quality and human health & well-being.

  1. What can be done to address pollution from water industry wastewater?

Recent experience has shown that water company treatment of wastewater is not always effective and can cause pollution events in rivers and the coastal zone. S&TC believes that the water industry needs more effective regulation and potential penalties that deter pollution events:

  • There must be sufficient Investment in infrastructure allowed by Ofwat through the AMP process.
  • Water companies must pay for regular, independent monitoring of all their discharges into rivers and coastal zones.
  • Where licence breaches occur, there must be strict enforcement - properly resourced - with potential fines large enough to deter malpractice and re-invested back into the environment affected by the pollution event
  • Catchment management plans should include all water company responsibilities for wastewater discharges - and abstraction for potable supply - including roadmaps for protecting watercourses from the potential environmental impact of accidental spillage and malpractice.

We support mandatory drainage and wastewater management plans to formalise and standardise processing wastewater for the future.

  1. What opportunities exist for water companies to collaborate with other sectors and organisations on measures to improve the water environment?

  • as above, water companies must play a full and inclusive role when setting and delivering catchment management plans, including agreeing local measures to limit environmental damage from sewage discharges, funded by water companies where applicable.
  • Abstraction policies which look to genuinely sustainable sources of water, including new reservoirs, where applicable, in catchment management plans and support for initiatives aimed at natural storage of water within catchments
  • Funding river restoration projects under their social responsibility budgets – but NOT as compensation for non-sustainable abstraction, discharges etc
  • We require more transparency in the production and monitoring of Water Resources Management Plans, with clear timeframes for delivery to ensure stakeholders have the information to drive collaboration at a catchment scale .
  1. How can local partnerships become more inclusive and representative of all of the stakeholders within their catchments?

This is down to local structures and leadership, coupled with sufficient funding to make stakeholder engagement worthwhile. The biggest criticism we hear of ineffective catchment partnerships (there are many effective ones as well!) is that they become talking shops that, however well-meaning and effective at producing plans, know those plans stand little chance of becoming actioned because of a lack of funding. Again, political commitment is vital if catchment management is to be truly effective.

  1. How can local partnerships achieve a better balance of public and private funding to support and sustain their environmental work?

There must be more commitment to Government funding to support local initiatives, because delivery of measures to restore watercourses are inevitably at the catchment level and therefore Government must be a genuine funding partner for actioning catchment plans: S&TC calls for:

  • greater government commitment to environmental protection through post- Brexit funding pots that at least compensate for the loss of EU finance for environmental projects;
  • a change in legislation that allows fines for river pollution to be hypothecated into river restoration projects - this seems an obvious moral method of funding environmental improvement;
  • Local information which encourages everyone likely to benefit from environmental work on local rivers to contribute to restoration initiatives;
  • greater involvement of local authorities in funding river restoration projects which contribute to the public good locally.
  1. How should the step change in protecting and improving the water environment be funded and who should pay? Are there any barriers to doing this?

There are current barriers to funding water environment work but they can be largely overcome with more political commitment to do so. There must be:

  • greater political commitment to enforcement of potential polluters (currently a significant barrier). The agricultural section must, in the third cycle of River Basin Management Plans, pay its ‘fair share’ in order to deliver environmental improvements;
  • greater Government resources provided for monitoring and enforcement (currently a significant barrier);
  • legal requirement for potential polluters to pay for regular independent monitoring of their discharges – taking pressure off the regulator’s budget and forming a deterrent for would-be polluters;
  • replacement of current EU funding streams by new post-Brexit government schemes to fund river restoration and protection initiatives;
  • pollution fines hypothecated into river protection schemes. At present, Ofwat does not have the power to hypothecate pollution fines for environmental restoration, regardless of the damage caused to river systems. We believe that legislation must be changed to allow all environmental fines to be hypothecated back into restoration works - that is morally correct and an obvious source of funds for the work that desperately needs addressing across many English rivers;
  • those individuals/companies benefitting from environmental work should be made to contribute.

Reporting with a purpose

S&TC are a national organisation and we use evidence from local case studies to help instigate policy changes that will benefit UK wild fish populations. But, this is just part of the value - we are making all our Riverfly Census findings available so they can be used to inform local management and drive action.

Each individual river report is based on three years of surveying data. Where possible, we have linked up our findings with other existing literature and data. Using the available information we suggest where local fishing and/or conservation groups can focus their management efforts to achieve the best health outcomes for each of the 12 original Census rivers.

Some of our local reports can be found on the slider below. Alternatively, visit the Riverfly Census page and scroll down to the map.