Phosphorus, Chickens and the River Wye

S&TC’s agricultural policy is simple; incentivise farmers to invest in their infrastructure and spread the word about modern soil management, but always be prepared to use the current legislation to regulate persistent offenders...

Paul Knight, S&TC Fisheries Consultant

George Monbiot writing in the Guardian recently highlighted the dreadful state of Welsh rivers.  He focussed on the Wye, where intensive chicken farming discharges phosphate (P) at far greater levels than the safe carrying capacity of the river, leading to awful water quality and subsequent impact on its wildlife.  The NFU hang on the coattails of Natural Resources Wales, who state that P has improved in the river over recent years, but rather than crow that excess nutrient is no longer a problem, it is important to understand the way P acts in a river, and why no-one should be complacent about the state of the Wye or its sister Welsh rivers.

The easiest way to explain P’s impact on a river is to think of a cliff gently sloping down until it reaches an edge, which then drops vertically into the sea – let’s give the cliff-edge a value of 30 and the top of the gentle slope as 100.  P at 40 has broadly the same impact on water quality as it does at 100 – too much nutrient leading to excess algae growth, discoloured water and the ‘dirty’ riverbed to which George Monbiot  alludes, but once it drops back to 30, the improvement is dramatic, and the symptoms fall away, you might say, over the cliff edge and into the sea.

This rather simplistic explanation has an important message, cutting P back from 100 to, say, 50, is a huge improvement, to which government agencies and the likes of the NFU will crow about the great job being done.  However, in terms of water quality improvement that actually supports more resilient and healthy life in the river, it is virtually useless.  More work needs to be done to reach 30 at the cliff edge, and then the river really starts a rapid improvement.

So why is excess P a problem to water life, apart from making the river environment murky and the bed gravels covered in algae?  S&TC’s Riverfly Census showed that P, along with sediment and toxic chemicals, are the biggest river polluters across the UK, and that agriculture is their main source. Our further research proved that high P levels, particularly in conjunction with sediment, kills water insects, the vital basis of a river’s food chain.  So, P, especially in conjunction with sediment, is actually toxic to water life unless kept down to natural values, 30 in our scenario.

S&TC is now using this evidence to press Welsh government and Natural Resources Wales, and Defra/Environment Agency (EA) in England, to take river pollution seriously and tighten agricultural regulation to ensure that the wildlife of rivers such as the Wye have a much more natural environment in which to thrive.  We can never return our watercourses to their truly natural state, there will always be human impact in such a closely managed countryside as we have in the UK, but there are issues we can do something about if we have the political commitment to address them, and cutting back agricultural impact on our rivers is definitely one of those.

Strong regulation is a must, but we do not just advocate the stick approach.  If you read the executive summary of the Axe Report, you will see that financial incentives for farmers to improve their infrastructure can produce dramatic results, albeit that they were threatened with heavy regulation if they didn’t comply.  Persuading farmers to adopt better soil management techniques is also critical, so that P is kept where it belongs, on fields, rather than being allowed to leach into rivers.

However, the most important aspect of the Axe example is that sufficient resources were made available to the EA to properly address the poor ecological state of the river, and they did that by visiting farms and advising farmers, many of whom had no idea they were polluting the river.  The result was nearly £4m of inward investment into updated infrastructure, and that is the sort of funding we need replicated across the whole of Wales and England if we are to protect our rivers into the future.

So, S&TC’s agricultural policy is simple; incentivise farmers to invest in their infrastructure and spread the word about modern soil management, but always be prepared to use the current legislation to regulate persistent offenders so that it becomes uneconomic for farmers to pollute watercourses such as the Wye.  If we can achieve that, then our wild fish and all other water wildlife will have the best possible chance to thrive, even in our micro-managed environment.

S&TC Cymru Update June 2020

Richard Garner Williams, S&TC National Office for Wales writes:

In a spirited demonstration of enthusiastic collaboration S&TC Cymru, the Wild Trout Trust, the Grayling Society and the Game and Wildlife Trust recently joined forces in writing to Lesley Griffiths, Welsh Government Minister for Environment, Energy and Rural Affairs offering broad support for Natural Resources Wales’ Salmon and Sea Trout Plan of Action. The Plan was launched at the Minister’s request in response to the outcome of the Local Inquiry on Natural Resources Wales’ proposed All Wales Salmon and Sea Trout Byelaws earlier this year. We understand the Plan of Action will be underlain by a detailed Forward Delivery Plan which all four organisations look forward to examining and discussing upon publication. The letter also urged the Minister to ensure that the implementation of the Plan be adequately funded to ensure that Wales meets its national and international obligations towards these two keystone species.

Agricultural pollution continues to wreak havoc on the fragile populations of the wild fish of Wales with a recent slurry containment failure killing fish along at least 4km of the Afon Peris, near Llanon on the Cardigan Bay coast. It must be presumed the invertebrate population within the affected reaches fared little better than the fish, further compounding the effects of the spill on the river’s biodiversity. Although diminutive in size, S&TC Cymru is becoming increasingly convinced that rivers such as the Peris play an important role in sewin stock recruitment, with emerging smolts supplementing returning numbers of mature fish in larger, neighbouring rivers. With the Teifi to the south and the Rheidol, Dyfi and Mawddach to the north, we can only begin to wonder what the long term, more distant impacts of the spill might be. Regrettably, the incident was only brought to the attention of the authorities when members of the public noticed dead fish floating in the polluted water. It would appear that the farmer was unaware of the incident until alerted to it by NRW. Equipment or storage failures such as this are a far too frequent an event and suggest widespread negligence and lack of investment in the infrastructure required for today’s more intensive methods of dairy production. S&TC Cymru have repeatedly called on Welsh Government to address these issues and while the recently announced Draft Water Resources Regulations give some hope for improvement in the control of agricultural pollution, we have yet to see evidence of the commitment to the extra resources required for their enforcement.

Originally planned for introduction in January of this year, the new agricultural regulations designed to tackle the scourge of agricultural pollution remain in limbo as Welsh Government addresses the issues posed by Covid-19. S&TC Cymru wrote to congratulate the Minister on her original forthright announcement of the need to take action but have since become increasingly concerned at hints of mission creep. During the latter months of last year, at the behest of the Minister, Natural Resources Wales and NFU Cymru collaborated on a project to explore potential voluntary options, suggesting a more flexible approach based on “earned autonomy” which would release individuals from strict regulatory control. Unlike Scotland and England, where the impact of agriculture on water is regulated by statutory basic rules, Wales has no such general binding measures, relying instead on voluntary compliance with guidelines laid put in the Code of Good Agricultural Practice (CoGAP). Patently, this has failed, as the regular reports of both acute and chronic incidents of pollution make clear. We therefore conclude there can be no further place for the provision of voluntary measures with regard to the impact of agriculture on the freshwater environment if Welsh Government is serious in its intent to conclusively address the matter. With that in mind and again in the spirit of collaboration and cooperation, the Grayling Society and the Wild Trout Trust recently joined with S&TC Cymru as co-signatories to a letter to the Minister calling for the introduction of a suite of basic rules for water for all land users across the whole of Wales, in advance of the currently proposed regulations, whatever their final form. I look forward to reporting, hopefully, a positive outcome to this and thank the WTT and the GS for their ready participation in our collaborative approach.

Finally, I’m sure you were all as disappointed as was I that we had to postpone our spring seminar. This has become an extremely popular event and this year’s bookings were already close to capacity when we suddenly found ourselves overtaken by events. With so much uncertainty continuing to surround the resumption of normal social interactions we have decided to formally cancel our 2020 seminar and start instead to prepare for the 2021 event. Until then, thank you for your valued support and please feel free to get in touch at any time should you wish to discuss matters in greater detail.

Reporting with a purpose

S&TC is 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.

Milk. A serious environmental threat?

So, here’s the shocking news about the potential of milk to pollute rivers.

Paul Knight, S&TC CEO writes,

One of the consequences of the coronavirus pandemic has been that the demand for milk has slumped and so dairy farmers have had to pour away their excess, cows still have to be milked, after all, so production cannot just stop.  In Wales, home of the new crop of mega dairy units, the rules state that unwanted milk should be poured into slurry storage if possible, and only sprayed onto fields if absolutely necessary.

Slurry from diary units is a consistent polluter of our rivers. It is sprayed onto fields and the first decent rain shower takes it straight into the nearest watercourse as run-off.  We have heard reports some farmers even dispose of slurry directly into rivers, often at night in an attempt to hide their nefarious activity. The results can be devastating for local fish stocks, because of oxygen depletion due to the micro-organisms feeding on the organic material in slurry.

So, here’s the shocking news about the potential of milk to pollute rivers.  Take treated human sewage as our baseline. A biological oxygen demand (BOD) of up to 60 mg of oxygen per litre of pollutant.  From this, these impacts have the following BOD:

No-one is yet suggesting that milk is finding its way into rivers, but the purpose of the above table is to show just how potentially polluting these agricultural waste products can be if they enter water courses. It is not so much that they are directly toxic to fish and water life, it is that they extract the oxygen out of the system to the extent that, in serious cases, all affected life will die as a consequence.

This is why S&TC is demanding government agencies are properly resourced to monitor watercourses effectively and enforce existing legislation.  We have the legislation, we just need the political will and funding to deal with those farmers who continue to pollute our rivers and damage wild fish stocks.

We are also determined to influence post-Brexit agricultural policies that incentivise farmers to invest in such infrastructure as new storage facilities for slurry or silage that don’t leak. But, while we lobby for these incentives to help farmers, we need the existing laws and regulations to be enforced. We are being fair to fish, not unfair to farmers.

Agricultural Pollution – Educate, Encourage, Enforce

"Up to 2016, a staggering 95% of farms did not comply with storage regulations and 49% were polluting the River Axe. Environmental law breaking, albeit mostly through lack of knowledge, on a massive scale."

Paul Knight, Outgoing CEO Salmon & Trout Conservation writes,

S&TC’s Census Report, published in May 2019, provided evidence that the main damage done to our rivers in rural areas was a result of poor land management – especially excess fine sediment and phosphates, and pesticides.  Intensive farming, including livestock, dairy and arable, often on an industrial scale, is the main culprit.

However, farmers provide a significant proportion of our food in the UK and so we have to find a way of protecting our rivers – and the whole environment – while allowing farmers to operate efficiently.   Impossible, you may say. Actually, we don’t believe it is – there are solutions which actually benefit farmers at the same time as stopping soil, pesticides, too much phosphate etc falling into our rivers and damaging wild fish and the water ecology.   

First, though, we need to understand how rivers operate, and why every landowner has to cooperate, otherwise none of this will work.  Put simply, rivers connect headwaters to the sea, and everything in between. This connectivity means that it only takes a few non-compliant farmers to undo all the good work done by their neighbours.  There are plenty of examples – slurry run-off, pesticide and fuel spills, sediment smothering riverbeds – affecting a waterway well downstream of where the pollution actually occurred.

There is a fundamental problem we recently unearthed.  During a meeting with NFU representatives and local farmers in Wiltshire, it became clear that few farmers were aware of the Reduction and Prevention of Agricultural Diffuse Pollution Regulations 2018, designed to protect the environment and under which all farmers should be operating. The EA staffer present described it as the softest regulation launch he had ever known. Education on a massive scale is therefore required to ensure all landowners are aware of their legal responsibilities.

We have left the EU and, shortly, our farmers will be bound by a new agricultural policy to replace Europe’s Common Agricultural Policy (CAP).  This means that we have the opportunity to influence government thinking about how farmers can be rewarded for protecting fragile environments such as river corridors, but under a much more effective programme than CAP.  As stated above, all farmers in a catchment have to cooperate, otherwise the plan will fail.  

A classic example of how things could work better in future comes from the recently published Environment Agency (EA) River Axe N2K Catchment Regulatory Project Report 2019.  After years of advice to farmers on Devon’s River Axe, and the very occasional farm inspection, the river was in a terrible ecological state, as confirmed by S&TC’s Axe Riverfly Census data.  Up to 2016, a staggering 95% of farms did not comply with storage regulations and 49% were polluting the river Axe. Environmental law breaking, albeit mostly through lack of knowledge, on a massive scale.

The EA then intervened and, with £120,000 of resource, carried out 86 farm audits (well above national average) and encouraged farmers to invest in 33 slurry stores, 3 silage clamps, 10 fuel stores and undertake 21 infrastructure repairs – all costing nearly £4m, so not a bad return on a £120K enforcement budget.  

However, an important message from the Axe Report is that tough regulation was threatened but was not required, at least up until the Report publication date, although time will tell as to whether behavioural change will result in long-term adherence to regulations.  Agricultural regulation had been flouted for many years because of a lack of regulation – no political commitment coupled to a lack of funding – but when the EA cracked down with some meaningful resources behind them, improvements were swift and, as a result, we hope the river will begin improving over the coming years.  The Axe example clearly shows that a combination of advice and financial incentives, supported by the threat of tough regulation, was sufficient to encourage farmers to act in the short term, but S&TC remains adamant that more resources are required for monitoring and enforcement so that land managers know they will get caught if they have the urge again to cut corners.  We completely support the continuation of subsidies for farmers, but we must have public benefit in return, rather than the old system of cross compliance under CAP, which was never properly monitored and, as a result, completely failed to protect our rivers. 

The question is, of course, will this action be sufficient to result in a lasting improvement to the river? S&TC will be re-running its Riverfly census next year to look for improvements, but we believe that the EA will need resources to make visits over the long-term to ensure improvements in water quality endure

From the evidence of our Riverfly Census, S&TC believes that a new government agricultural policy can encourage farmers to utilise methods which benefit them as well as protect the environment.  For instance, we believe that, if farmers were incentivised to embrace good soil management such as zero tillage (where appropriate), there would be benefits all round - farmers would keep their natural resource in place (soil); a more natural soil function would be encouraged (earthworms rather than ploughs), lower inputs in terms of fuel and size of equipment required and, medium-long term, increased yields – so, a bottom line benefit for farmers and better protection for rivers from sediment, chemicals and phosphate seepage.  A classic win/win scenario.

So, S&TC’s message to government is that the River Axe example gives a view of how things might happen in the future.  It needs government commitment to roll out across the country, and the Treasury to allow Defra to fund the new agricultural policy properly to allow long-term changes in the EA farm inspection regime, but if that happens, our rivers, wild fish and water ecology could receive a massive boost and we could start to reverse the degradation of the past decades – and farmers will benefit too.

As the Axe Report states,

"This evaluation clearly demonstrates the power of advice (to farmers), backed up by regulation and supported by financial incentives to create positive benefits for water quality. Neither advice, incentives nor regulation delivered in isolation of the others will generate the desired environmental improvements in water quality."

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 conservation groups can focus their management efforts to achieve the best health outcomes for each of the rivers.

Environmental Land Management Scheme 2020

Environmental Land Management Scheme

Consultation 2020

Make your voice heard:


Overview of Salmon & Trout Conservation (S&TC) Response

• The main requirement is for political commitment to finally tackle the issue of pollution by inappropriate land use - particularly relevant to our rivers and aquatic life (EA River Axe N2K Catchment Regulatory Project Report 2019)

• The continual cuts in the EA’s budget and resourcing needs urgently addressing, otherwise this ELM will fail through lack of effective monitoring and, where necessary, enforcement

• Whether it be breaches of diffuse pollution rules by farmers, deliberate release of slurry, or just ‘bad practice,’ we already have sufficient legislation in place to deal with these issues. What we need is independent monitoring, inspection and robust enforcement of ELM (See River Axe Report below on the use of the Red Tractor assurance scheme) that shows persistent offenders they are far more likely to be identified and potentially prosecuted than at present – ie a 1 in 200 chance each year of having a farm inspection

• We refence our evidence to EFRA on diffuse pollution and farming rules (attached) that shows that Codes of Practice for farmers going back to the 1980s have been saying roughly the same thing and yet we still suffer huge damage from poor land use, because there has been no enforcement ( see River Axe Report, page 17, para 11, Despite significant amounts of advice and grant aid in the last 10-15 years, there has been an absence of basic regulation).

S&TC ELMS Response 2020

6. Do you have any comments on the design principles on page 14? Are they the right ones? Are there any missing?

Salmon & Trout Conservation (S&TC) does have some concerns over the design principles. We fully support the overall objective in (a) of focusing on achieving environmental outcomes and helping to deliver Defra’s 25 Year Environment Plan and net zero target. However, there are some aspects of the design principles which require tighter definition if the proposed environmental outcomes are to be achieved:

Under (e), the proposal is that farmers, foresters and other land managers have greater flexibility over how they deliver environmental outcomes. While this might be acceptable as a general rule, there are current impacts of poor land management on rivers and watercourses that require targeted remedial action as a matter of urgency, and much closer protection in the future, if aquatic ecosystems are to be healthy and support abundant biodiversity. S&TC’s Riverfly Census data shows that pesticides, excess phosphates and sediment, much of it sourced from poor land management, impact many English watercourses, and these require specific remedial measures to restore and protect our river systems. For instance, we believe that improved soil management will solve many stressors impacting watercourses, but this requires incentives for land managers to concentrate on the specific outcome of their actions, rather than allowing flexibility which might not deliver the required result.

Under (f), you state that you wish to ensure minimal complexity and administrative burden for participants and administrators, considering lessons learned from similar past initiatives. This is a worrying objective, because S&TC believes that one of the strongest lessons learned from past initiatives is that, without sufficient monitoring and, where necessary, enforcement, environmental damage to rivers will continue. We go into more detail below under question 15, but there has to be much tighter control over land managers so that they achieve genuinely effective outcomes in terms of river protection, before they receive public subsidies. We therefore see Flexibility as a potential barrier to this new scheme achieving its environmental objectives.

Under (g), we fully support the harnessing of new technology and digital solutions if they can be shown to add value and improve the scheme design and operation. Again, we go into more detail below under 15, but if self-monitoring is to continue to be a significant part of this scheme, then participants will have to provide far better evidence that their actions have achieved the required environmental outcomes, and we believe that modern technology could have a major role to play in that scenario.

Under (i), S&TC is not in favour of re-using / improving existing systems and data. We believe that the existing system has frequently failed to protect watercourses, wild fish stocks and aquatic wildlife and that a completely fresh look is required as to how environmental objectives can be genuinely achieved. We of course appreciate that land management produces an important proportion of our food supply, but we can no longer use that as an excuse for allowing environmental damage on the scale of the past few decades, especially when we believe that solutions are available that benefit farmers at the same time as protecting river corridors – i.e. zero tillage arable farming where appropriate, which allows natural processes to improve soil quality and water permeability while keeping soil on the field rather than allowing it to run-off into watercourses during storm events, taking with it residues of chemical toxins and excess nutrients.

7. Do you think that the ELM scheme as currently proposed will deliver each of the objectives on page 8?

The objectives are:

"To secure a range of positive environmental benefits, prioritising between environmental outcomes where necessary" – as stated above, S&TC’s data has shown the significant current impact on our rivers from farming activities over recent decades. At the very least, environmental objectives that must be achieved under the new scheme include the restoration of watercourses and their future protection. We believe that this is a major priority and anything less than minimising future agricultural impact on rivers and their ecosystems must be regarded as a failure. We are well aware of the stressors on our river systems and the solutions required to address their impact, and so the proposed ELM scheme has to incentivise land managers to undertake the necessary measures or be prepared to enforce legislation and withhold payments until relevant measures are undertaken. Anything less than this will signal a failure of the system and our rivers will continue to be impacted by poor land management activities.

"To help tackle some of the environmental challenges associated with agriculture, focusing on how to address these in the shorter term" – this is exactly what S&TC means, but we are disappointed by the weak language.

As above, we know what needs to be done, and the current impacts on our watercourses need urgent remedial action under a comprehensive plan, rather than under a system where just some of the environmental challenges are addressed, which is far too ambiguous for what is required to achieve environmental objectives under the 25 Year Plan. Measures must be put in place under ELM that genuinely minimise the danger of either point of diffuse pollution entering watercourses – measures such as improved soil management, livestock exclusion from streams, effective slurry storage and disposal etc.

In summary, S&TC believes that these objectives go some way towards greater environmental protection, but that Defra needs to tighten them if the environmental objectives contained within the 25 Year Plan are to be achieved for watercourses and aquatic biodiversity.

8. What is the best way to encourage participation in ELM? What are the key barriers to participation, and how do we tackle them?

S&TC believes that the scheme should lead with sufficient incentives to encourage land managers to participate, but that participation should be compulsory, at least for those managers who have the potential to adversely impact sensitive habitats, especially river corridors. Protecting rivers on a catchment basis is essential due to their connectivity, where just a few polluters can negate all the good work done by neighbours who take their responsibilities toward river protection seriously. In these instances, the carrot of incentives must be supported by effective enforcement of those who continue to pollute rivers.

We do not wish to denigrate those land managers who have protected the particular environments within their land holdings under past schemes, and much good environmental protection work has undoubtedly been undertaken by many land managers. However, our evidence, alongside many other datasets, prove that rivers in particular continue to be adversely impacted by poor land management, and so past subsidies/cross compliance schemes have obviously been insufficient to protect rivers and aquatic biodiversity. This has to change under ELM.

S&TC believes that one of the main reasons for participation in the past has been the ease with which subsidies have been distributed with very little monitoring or enforcement of, for example, cross compliance – i.e. the widespread perception that the public should not expect environmental benefits in return for subsidies. Many land managers appear to have thought that they had little chance of being prosecuted for failing to achieve cross-compliance – a reputed 1 in 263 chance of having a farm inspected in any one year – and so took the risk. With the tightening of environmental objectives that must be included within ELM, there is the potential for land managers to shy away from the initiative because they see the monitoring/enforcement issue as making their responsibilities under the scheme too onerous.

We believe that a fair distribution of incentives to encourage the adoption of actions to achieve environmental objectives, supported by strong, well-resourced monitoring and enforcement, is essential for this scheme to be successful – it has to be financially attractive enough for widespread uptake, but sufficiently monitored/enforced to ensure compliance. It will also require education for some land managers that they can no longer expect subsidies without providing a return in terms of public benefit.

However, if voluntary participation still does not protect our watercourses effectively, S&TC believes that mandatory inclusion in the scheme, supported by strong, well-resourced enforcement for any persistent offenders, is the only way to reverse the decline in ecosystem health across many of our river systems. A voluntary approach has not worked under previous schemes and we have deep reservations that it will work under ELM unless the conditions are strong enough in terms of achieving environmental outcomes and strictly adhered to through effective monitoring.

S&TC is beginning to work with farm clusters in river catchments to monitor the success of measures designed to protect rivers, and farm clusters have been very successful in coordinating terrestrial environmental improvements in recent years. Individual land managers working within clusters are far more likely to be encouraged to adopt ELM actions and so this form of cooperation should be further encouraged throughout the country.

9. For each tier we have given a broad indication of what types of activities could be paid for. Are we focussing on the right types of activity in each tier?

Tier 1 – S&TC believes these are exactly the issues which need to be included in Tier 1 to make the scheme successful. As discussed above, data from our Riverfly Census, which used species-level invertebrate analysis to produce water quality biometrics, provided evidence that the greatest stressors on English rivers are chemicals including pesticides, sediment and excess phosphate, much of which is derived from poor land management. If the measures in Tier 1 were adopted by all farmers with watercourses running through their land, then riverine water quality and ecosystem health would undoubtedly benefit and we could begin to reverse the degradation of recent years.

However, S&TC is adamant that subsidies should be paid against outcomes, not against proposed actions. The latter will, in effect, only perpetuate the cross-compliance element of previous schemes which have been shown to be ineffective at protecting river corridors. There has to be a level of monitoring to ensure that actions have been taken and outcomes delivered before funds are received, otherwise we cannot see how environmental objectives will be achieved in anything other than a piecemeal fashion which, as already stated, is insufficient for river protection because of the connectivity issue within watercourses.

While flexibility might be a preferred option in attracting land managers to participate in ELM, we do not believe that allowing a choice of actions from a menu is sufficient to protect the water environment. We strongly believe that there should be basic standards set for all land managers, especially those with watercourses flowing through their land, to which their actions must be targeted. Those that adopt those actions responsibly and provide the required public benefit should receive subsidies, whereas those that do not should have to improve the quality of their outcomes before subsidies are paid – with strong enforcement for persistent offenders.

S&TC is pleased that the Payment by Results trial run for Defra by Natural England and the Yorkshire Dales National Park, is showing encouraging results and we believe this is the way forward to best deliver public benefit in return for subsidies to land managers.

While we would far prefer well-resourced monitoring and enforcement from the government regulator, we fully appreciate that lack of funding could make official monitoring ineffective. We could therefore support the idea of Smart self-monitoring if the evidence produced by land managers was strong enough to show proof of required environmental outcomes under the scheme – and then subsidies paid in arrears on receipt of that evidence (see response to question 15 below). Any self-monitoring must be robust with both the methods used and the results obtained being routinely published and made accessible to the wider public.

Tier 2 – S&TC supports the types of activities included under Tier 2. Our concerns for monitoring and payments are similar to Tier 1 above, but we are more encouraged that, Defra is suggesting that tier 2 payments could initially be based on actions, offering top-up payments for delivery of additional results (where output result indicators can be tested and proven to be feasible). Over the longer term, where land manager experience and confidence has been established and our methods for monitoring outcomes have advanced, we could move towards pure results-based payments for certain outputs where tested and proven to be feasible.

Again, though, monitoring is an issue and we would urge that more resources are made available by Defra/The Treasury for monitoring, both in terms of researching the effectiveness of actions under Tier 2 and compliance that environmental protection is delivered and continues over time.

As an example of our concerns, S&TC understands that the overall EA agricultural budget is £650,000 pa, but that covers more than just monitoring/enforcing the Reduction and Prevention of Agricultural Diffuse Pollution Regulations 2018 ie it includes groundwater inspections for sheep dip and pesticides, running advisory events, making planning visits and dealing with planning and grant applications. Therefore, only a fraction is for compliance visits and enforcement action.

Assuming, say, a probably optimistic half of this agricultural budget is aimed at monitoring the 2018 Regulations, that would equate to £325,000pa. DEFRA (2016 farm survey) states that there are some 106,000 farm businesses in England, so this budget would equate to just £3 per farm business in terms of monitoring and enforcement of diffuse pollution impact. While we appreciate that farm visits are evidence led, this is still a tiny fraction of the budget required to ensure minimising environmental impact on rivers and aquatic ecosystems from poor land management.

The EA states that, for 2018/2019, they made 403 farm visits, (as against the 106,000 farm businesses), since the 2018 Regulations came into force – which equates to approximately 0.4% of farms having received a visit. Even following an evidence-led campaign, this is quite obviously a totally inappropriate level of monitoring to ensure effective environmental protection and the delivery of public benefit outcomes – a 1 in 263 chance of a farm being inspected in any one year.

Tier 3 – S&TC agrees with the overall thinking around Tier 3, which is looking at landscape-scale environmental objectives. S&TC, alongside other environmental organisations relevant to watercourse and aquatic ecosystem protection, believes that management at the catchment scale is the only way to be truly effective in restoring ecosystem health within rivers and protecting them for the future. With this in mind, cooperation between the three Tiers would be essential in ensuring that, for instance, actions in Tier 1 and Tier 2, as well as contributing to local environmental protection, are planned as part of an overall catchment plan for individual river systems.

We believe this is the best way of ensuring maximum return for subsidies and grants and has the potential to provide multiple public benefits. For example, adopting natural flood defences by reversing upland drainage and restoring wetlands on marginal agricultural land, will result in storm-event run-off decreasing as more water is stored in headwaters and flood plains, resulting in more even river flow regimes to better control downstream flooding, with added benefits to biodiversity, especially within aquatic ecosystems.

10. Delivering environmental outcomes across multiple land holdings will in some places be critical. For example, for establishing wildlife corridors or improving water quality in a catchment. What support do land managers need to work together within ELM, especially in Tiers 2 & 3?

As in our response to question 8 above, farm clusters are a proven way of coordinating environmental protection actions across a catchment/landscape and should be further encouraged. However, land managers are not necessarily specialists at environmental planning and will require advice to maximise the benefit of landscape-scale measures. This should be coordinated by the government regulator but must be sufficiently funded to make the process effective.

The Catchment Based Approach (CaBA) is an inclusive, civil society-led initiative that works in partnership with Government, Local Authorities, Water Companies, businesses and more, to maximise the natural value of our river environments, and coordinating ELM with existing CaBA groups and farm clusters would be an advantage in delivering maximum public benefit, especially at Tier 2 & 3 scales. Again, though, increased resources are required to make the catchment-based planning and delivery approach truly effective.

11. While contributing to national environmental targets (such as climate change mitigation) is important, ELM should also help to deliver local environmental priorities, such as in relation to flooding or public access. How should local priorities be determined.

We have covered this issue above in terms of the part ELM could play in natural flood defence, and the knock-on benefits that would have to aquatic biodiversity. Local priorities must be determined at catchment level and, again as above, the CaBA approach has a role to play in bringing together local stakeholders to agree priorities. Once agreements have been reached, one organisation needs to take ownership of delivering actions and achieving outcomes and S&TC believes this should be the national regulator answerable to DEFRA.

12. What is the best method for calculating payments rates for each tier, taking into account the need to balance delivering value for money, providing a fair payment to managers, and maximising environmental benefit.

S&TC is not qualified to comment on this question

13. To what extent might there be opportunities to blend public with private finance for each of the 3 tiers?

S&TC is not qualified to comment on this question

14. As we talk to land managers and look back on what has worked from previous schemes, it is clear that access to an adviser is highly important to successful environmental schemes. Is advice always needed? When is advice most likely to be needed by a scheme participant?

We believe that, to make an environmental scheme successful, specialist advice is required at both the planning stage – especially for Tier 2 & 3 initiatives – and prior to, and probably during, delivery of actions. As stated above, land managers are not necessarily specialist environmentalists and so they will require guidance if their actions are to be effective in achieving objectives.

However, the Environment Agency Report on the impact of agriculture, especially dairy farming and maize growing, on the River Axe Special Area of Conservation, is highly relevant:

Despite over a decade of advisory visits in the period up to 2016, the catchment continued to decline and there were no significant improvements in farming practices. 95% of farms did not comply with storage regulations and 49% of farms were polluting the river Axe. (EA River Axe N2K Catchment Regulatory Project Report 2019)

Clearly, as the River Axe case study shows, advice alone is insufficient in protecting the environment. There must be suitable incentives to encourage farmers to participate in environmental schemes, and effective enforcement for those who persist in ignoring advice or incentives and continue to pollute rivers. The Axe report states:

"The Environment Agency secured £120,000 in local funding for a three-year regulatory farm visit campaign during the winter periods 2016 to 2019, during which time we carried out 86 farm audits. As a result of these advice-led but regulatory visits farmers in the catchment have either constructed or are in the process of constructing 33 slurry stores, 3 silage clamps, 10 fuel stores and have carried out 21 infrastructure repairs.
These infrastructure investments are estimated to total nearly 4 million pounds and were sourced by both farmers and from grant aid incentives. Or put another way, every pound spent by the Environment Agency in regulatory visits has resulted in investment of £33 for infrastructure improvements."

This case study clearly shows that the combination of the right incentives, but supported by effective regulation, can have multiple benefits for the environment and, therefore, for the public. The River Axe Report also states:

"All the improvements have been achieved without recourse to prosecutions or formal cautions, although we made it clear these would be the sanctions should compliance not be reached. A minimal number of notices were served to secure compliance and a number of warning letters were sent in response to actual pollution incidents observed during the visits.

This evaluation clearly demonstrates the power of advice, backed up by regulation and supported by financial incentives to create positive benefits for water quality. Neither advice, incentives nor regulation delivered in isolation of the others will generate the desired environmental improvements in water quality."

Apart from this excellent and ground-breaking work on the River Axe, elsewhere the EA has recorded just 14 breaches of the Reduction and Prevention of Agricultural Diffuse Pollution Regulations since April 2018 – equating to just 3.5% of the 403 visits discussed under Question 9 above (Tier 2), even though these visits were, apparently, evidence led. There has been no hard enforcement of those 14 breaches, merely the sending of 7 warning letters.

S&TC therefore believes that Defra and the EA have much to learn – and urgently replicate – from the River Axe case study.

15. We do not want the monitoring of ELM agreements to feel burdensome to land managers but we will need some information that shows what’s being done in fulfilling the ELM agreement. This would build on any remote sensing, satellite imagery and site visits we deploy. How might self-assessment work? What methods or tools, for example photographs, might be used to enable an agreement holder to be able to demonstrate that they’re doing what they signed up to do?

As already discussed, monitoring of outcomes is essential if ELM is to be more effective at achieving environmental objectives than previous schemes have been. We fundamentally disagree with the statements made on page 9 (h) that, under previous schemes, the compliance requirements placed on land managers were overly complex and demanding, or that, In the past, where land managers have been found to be in breach of their agreements, the approach to enforcement has been overly-punitive and harsh. We believe that one of the major problems with past schemes has been the failure to monitor and, where necessary, enforce compliance. The EA River Axe N2K Catchment Regulatory Project Report 2019 has shown the reality of what happens within a river catchment when land managers are not properly regulated, and frankly gives a lie to the notion that farmers have been over-burdened by legislation and enforcement in the past. The Report also clearly shows that, to be effective, the ELM scheme will require, "The power of advice, backed up by regulation and supported by financial incentives to create positive benefits for water quality…."

S&TC recently undertook an audit of agricultural codes of good practiced published by DEFRA and its forerunner departments over the past four decades. The most telling issue was that we already have all the codes and written advice we require to protect watercourses from agricultural impact. Fundamentally, what is missing is the commitment to enforce these Codes via legislation, as witnessed by the fact that a land manager has approximately a one in two hundred chance each year of being inspected by the regulator. The very soft touch regulation so far being applied in the case of the Reduction and Prevention of Agricultural Diffuse Pollution (England) Regulations 2018 merely continues this failure. This smacks of a lack of political commitment to challenge land managers, especially the agriculture sector.

S&TC fully supports initiatives that incentivise land managers to protect the environment, but anything like cross-compliance has already been proven to be totally inadequate in achieving environmental objectives. It is S&TC’s firm belief that Defra, supported by the Treasury, has to commit far greater funds to ensure that ELM achieves its public benefit targets, otherwise the scheme is doomed to failure.

For ELM to work, it must be properly incentivised, monitored, the rules enforced and any breaches sufficiently penalised to discourage non-compliance.

However, S&TC also believes that modern digital technology could be utilised to allow a level of self-assessment for Tier 1 initiatives, but this must not be an excuse for a lack of official monitoring. The self-assessment evidence must be compulsory, submitted to the regulator within strict timelines and properly scrutinised before compliance is confirmed.

16. Do you agree with the proposed approach to the National Pilot? What are the key elements of ELM that you think we should test during the Pilot?

With the plan to run two large Pilots for Tier 1, we suggest that one is conducted with payment of subsidies up-front for actions, on a par with existing schemes, while the other has subsidies paid in arrears subject to environmental outcomes.

For Tier 2 & 3, the planning will be critical, together with the actions required to achieve the agreed target outcomes, who should deliver the actions and what advice is required to assist delivery.

However, S&TC is concerned at the lack of ambition in relying on Pilots until 2024, with the roll-out to the whole industry coming after that date. Under the Water Framework Directive, at least 75% of rivers must be in good ecological status by 2027 if the main objective is to be met. Currently, just 14% of rivers achieve GES, with poor land management one of the major reasons for lack of achievement. Leaving just three years to reverse the ecological declines due to agricultural stressors is totally unrealistic. However, as previously stated, we already have the legislative powers to enforce regulation on poor land management, and so the national regulator must be given increased resources, supported by strong political commitment, to tackle offenders now.

17. Do you have any other comments on the proposals set out in this document?

S&TC leaves the final word to the EA River Axe N2K Catchment Regulatory Project Report 2019:

"All the farms visited are Red Tractor Assured. The findings of this campaign demonstrate that Red Tractor is not effective at assuring farms are meeting environmental regulations

To maintain these improvements (gained under a three-year regulatory farm visit campaign during the winter periods 2016 to 2019), dedicated EA officers, with the skills to engage farmers will be needed. Having secured investment in basic infrastructure, further regulatory improvements could be gained by focusing on wider land management in the catchment."

The approach taken in this catchment could clearly be transferred to other priority catchments in the country to generate similar improvements for relatively small regulatory investment.

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.

S&TC launches first SmartRivers hub in Scotland

S&TC launches first SmartRivers hub in Scotland in partnership with Flow Country Rivers Trust.

The River Halladale is set to become the first river in Scotland to join SmartRivers, as Salmon and Trout Conservation continue trials of the innovative scheme.

The scheme, born out of the Riverfly Census, uses aquatic invertebrates as a diagnostic test to tell us about the health of rivers and possible pollutants affecting wild fish populations.

Nick Measham, S&TC Deputy CEO said:

 “We’re delighted to be able to support Flow Country Rivers Trust with our SmartRivers programme. SmartRivers is what S&TC is all about, turning science into meaningful real-world action, that here and now improves outcomes for wild fish and the wider habitat.  We are very much looking forward to working with FCRT over the coming years.”


Quick and easy to deploy, but also producing powerful information. Polluters of rivers and streams in England have already been forced to take action.

"SmartRivers Delivering Results"

SmartRivers provides both information to assist with catchment management decisions, as well as establishing an insurance policy for rivers in the form of a benchmark of their health. Real world empirical evidence about the diversity of invertebrate species which form the foundation of the food web in rivers will support the indicative monitoring of conductivity, pH levels and fry numbers.

Reuben Sweeting, Head Ghillie on the River Halladale said:

“SmartRivers is the final piece of the puzzle.  It complements the range of monitoring already being carried out, helping to develop a fuller picture of the health of our rivers and, crucially, allowing us to better understand the potential they hold.

 Being part of the team to bring SmartRivers north to Scotland for the first time is very exciting.  With the opportunity to attain professional level benchmarking, combined with sampling and identification training, the benefits will be felt by all involved.”

A comprehensive online and field based training scheme, 1-2-1 support and good use of information technology, including a dedicated S&TC Invert ID App, ensures that local community groups themselves are able to monitor the water quality in their rivers to a near-professional standard.

Lauren Mattingley, SmartRivers Project Manager S&TC said:

 “We are overjoyed to be extending our water quality work into Scottish rivers. Ensuring young salmon and trout are as fit and healthy as possible before they migrate to sea is crucial for them to successfully complete their life cycles.

 It is astounding that tiny invertebrates can give us such vast insight into the quality of the water our young fish are being exposed to. Working with the FCRT volunteers on the Halladale is going to be fascinating.”

Benchmark monitoring on the River Halladale will be carried out in spring and autumn 2020. The first independent monitoring by the volunteers, under the auspices of the Flow Country Rivers Trust, will occur in spring 2021.

Alan Youngson, Scientific advisor, FCRT

"Over the last few years the FCRT and the local Fishery Boards have worked hard to build a better picture of the northern rivers and the salmon populations that they support. However, we still know very little about the invertebrate populations that the fish depend on for food. We look forward to learning much more from the professionals driving the Smart Rivers project."

John Mackay, Chairperson, Flow Country Rivers Trust said:

 “Currently the North of Scotland rivers are in very good health, but we are mindful of the deteriorating situation across the UK. We have a database of the juvenile numbers, biomass density and the water conductivity for all the 10 rivers in the FCRT area. The Smart Rivers project to measure the insect food supply will add to this database and provide a benchmark, which will hopefully give us advance warning of a change in our environment.”

 For more information about SmartRivers and how it could support your river management activities, please email:

 Please note: We can only run courses with groups of around 10 volunteers and not for individuals. However, if you are struggling to establish a 'hub' group your local Rivers Trust or Wildlife Trust may be able to help.


Issued by Corin Smith (T: 07463 576892)

Reporting with a purpose

S&TC is 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.

Sewin and their habitats


Update 14 March 2020: This event has been postponed. All those who expressed an interest will be contacted once a new date is fixed.

10am - 4pm, Monday, March the 30th, 2020

Salmon and Trout Conservation Cymru warmly invite you to their Annual Seminar for 2020

An opportunity to hear the latest developments aimed at stock recovery

Lantra, Royal Welsh Showground, Llanelwedd, Builth Wells

A light lunch will be provided. Please advise us should you have any specific dietary requirements

RSVP by Monday, March the 16th to

Attendance is free but applications from members will receive priority.

Please include your membership number with your application.



10yb - 4yp, Dydd Llun, Mawrth y 30ain, 2020

Mae’n bleser gan Gadwraeth yr Eog a’r Brithyll yng Nghymru eich gwahodd i’w Seminar Flynyddol ar gyfer 2020 

Cyfle i glywed y diweddaraf ar gamau i amddiffyn ac adfer eu niferoedd

Lantra, Maes y Sioe Fawr, Llanelwedd, Llanfair ym Muallt

Darperir cinio ysgafn. Rhowch wybod i ni os oes ganddoch unrhyw anghenion bwyd arbennig

RSVP erbyn Dydd Llun, Mawrth y 16eg i

Ni chodir tâl mynediad ond rhoddir blaenoriaeth i geisiadau gan aelodau.

Nodwch eich rhif aelodaeth gyda’ch cais am le os gwelwch yn dda.

Snapshot survey of the River Tywi (Towy) 2018

In pursuit of Perfection

“We are honoured by Hardy’s support for our conservation efforts. Together we share a vision for abundant wild fish stocks, flourishing biodiversity and rivers free of pollution.”

Paul Knight, CEO, Salmon & Trout Conservation

To celebrate the coming wild trout season S&TC is delighted to announce a very special limited release of Hardy Perfect fly reels and Smuggler fly rods.

Restricted to a run of just one hundred and fifteen units, these timeless fly-fishing pieces are being sold as "The Smuggler Set".

These special sets contain a Hardy Smuggler 9ft, 5 weight, six section rod, matched with the iconic Hardy Perfect fly reel, both hand built in Alnwick, England. The Smuggler set is presented in a custom-built aluminium flight case, along with a Hardy WF5 floating fly line and a Wheatley fly box containing an assortment of flies.

Each rod and reel is engraved with its own unique number.

John Henderson of Hardy said:

“Hardy are delighted to collaborate with Salmon & Trout Conservation on this one of a kind project. Since 1903 the charity has fought hard to keep UK waters wild and healthy and S&TC remains a powerful voice for our rivers and the wild fish that inhabit them.”

The Smuggler Set will sell for £1,500, a portion of which is donated to S&TC.

To discuss placing an order please contact S&TC or Hardy, who can arrange purchase and delivery through a handful of selected retailers.

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.

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.

Agricultural Pollution Update – Nov 2019

Government figures show currently only 14% of rivers are classified as healthy…..


Government figures show currently only 14% of rivers are classified as healthy and rural areas are impacting 35% of waterbodies (EA, 2015). Evidence from the Riverfly Census has shown the greatest stressors on our rivers are sediment, excess nutrients, pesticides and other toxic chemicals – many of which are derived from agricultural practices through the poor management of soil, the storage/application of livestock slurry/manures and the use of pesticides.

The Environment Agency (EA) admit compliance with the regulatory baseline is low and progress is slow, variable and not secure as farmers react to market factors and incentives that put them under financial pressure. In 2018, the Government finally introduced ‘new’, legally enforceable Farming Rules for Water. The rules require farmers to manage their land to avoid water pollution. They provide a step by step checklist to safeguard water quality by requiring farmers to judge when it is best, for example, to apply fertilisers, where to store manures and how to avoid pollution from soil erosion.


However, in our evidence to the Environment, Food and Rural Affairs (EFRA) Committee’s consultation on the Agriculture Bill, we pointed out that the 2018 Regulations largely mirror earlier Codes of Good Agricultural Practice and Government guidance dating back to the 1980s. They are in essence the same rules repackaged that have failed to limit the impact of agriculture on our rivers or change farmer behaviour on the ground.

Yes, now they are enforceable in law. But being enforceable and actually being enforced are two very different things. That’s why at S&TC we want to see a firm commitment from Government, backed up by action, to enforce these new rules.

However, a recent Freedom of Information request made by S&TC revealed that the EA for 2018/2019 only made 403 farm visits. As there are 106,000 farm businesses, since the 2018 Regulations came into force, only about 0.4% of farms have received a visit. At that rate every farm business will get one visit every 263 years.


As for breaches of the new rules, the rate of breaches found by the Agency suggests that if all farm businesses all were visited in a single year, we would expect about 4,000 breaches of the 2018 Regulations in the last year alone.

No doubt the EA would suggest these 403 visits were in some way targeted inspections of high risk sites, but it’s also important to bear in mind that visits only occur on one day out of the 365 and actions like spreading slurry on frozen ground or spraying herbicides just before rainfall only takes a day and is likely to be missed.

In short, the EA currently does not have the resources to monitor or enforce the 2018 Regulations effectively and our rivers are paying the price. Until we have an enforcement system where people know they will be caught and action taken if they do the wrong thing, things will not change.

One requirement of the 2018 Regulations is for the Secretary of State to periodically review the provisions contained with the 2018 Regulations. The first report must be published before 2ndApril 2021.

So, we welcome your help to help provide the evidence that the 2018 Regulations on the statute book is not enough.

The EA must have the proper resources to ensure the new rules are implemented and enforced.

And that’s not just S&TC saying that – this was the EFRA Committee of MPs back in 2005:

“Time and again over the course of our enquiries into environmental crime, it has been brought home to us that unless there is a real threat of being detected, the offender will continue to offend.  We cannot stress strongly enough the importance of the threat of detection as a deterrent."

Of course, we need to continue with positive incentives too, and we will continue to lobby for post-Brexit farming regulations which reward farmers for effective environmental protection, but this alone will not achieve healthy watercourses. We need an enforcement and regulation system with teeth.

Reporting with a purpose

S&TC is 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.