Salmon & Trout Conservation issues formal request to the Environment Agency under the Environmental Damage (Prevention and Remediation) (England) Regulations 2015 over horrendous damage caused to the River Lugg in Herefordshire.

Salmon & Trout Conservation (S&TC) has today issued a formal request for action under Regulation 29 of the Environmental Damage (Prevention and Remediation) (England) Regulations 2015 over damage caused to the River Lugg Site of Special Scientific Interest.

The formal request requires the Environment Agency to consider whether damage, as defined by the Regulations, has occurred and if so, to inform S&TC of the action it will take. The Regulations also indicate that the cost of addressing the damage caused and preventing further damage, and any mitigation or remediation as may be required, should be met by the person who has caused the damage.

Nick Measham, Chief Executive of S&TC UK said:

“Following their inspections, the Environment Agency and Natural England will be very well aware of the extent of the damage caused by the in-river dredging, tree-felling and bank profiling work conducted last week on the river Lugg at Kingsland.

The release of sediment into the river and the loss of habitat on the bed and banks of the river is shocking. The damage caused to protected species, including, but not limited to otters, dippers, bats and Atlantic salmon, is also, patently, very extensive.

There is a threat of further damage being caused downstream, due to the condition that the river upstream of Lugg Bridge has been left in, with exposed profiled mud banks liable to erosion during winter flows, increasing silt and sediment transfer downstream.

We trust that the Environment Agency will now be prosecuting the person or persons responsible for these terrible events. They will, no doubt, require some time to assemble their case, but we will be watching events very closely”.

Nick Measham, Chief Executive of S&TC UK added:

“There has been discussion about the need to address flooding at the bridge in Kingsland. Of course this is a legitimate concern for those who have been flooded. But what has been done here, the extent of the works, and how it was done, goes way beyond what would be considered to be reasonable in all the circumstances. It is for the Agency now to decide if it was also unlawful.”

ENDS

Further information is available from Janina Gray (janina@salmon-trout.org) or Nick Measham (nick@salmon-trout.org)

Notes for editors

1) Salmon & Trout Conservation UK (S&TC UK) was established as the Salmon & Trout Association (S&TA) in 1903 to address the damage done to our rivers by the polluting effects of the Industrial Revolution. Since then, S&TC UK has worked to protect fisheries, fish stocks and the wider aquatic environment for the public benefit. S&TC UK has charitable status in both England and Scotland (as S&TCS) and its charitable objectives empower it to address all issues affecting fish and the aquatic environment, supported by robust evidence from its scientific network, and to take the widest possible remit in protecting wild salmonid fish stocks and the aquatic environment upon which they depend. www.salmon-troutscotland.org

SmartRivers welcomes its first water company hosted volunteer hub

We are pleased to announce that Severn Trent is the first water company to enrol into the SmartRivers programme. SmartRivers is the volunteer arm of the Riverfly Census, where invertebrates are sampled and analysed to species-level. The species lists are then used to calculate biometrics that indicate what water quality pressures a river is experiencing. This information enables us to understand more about the subtle pollutants 'stressing out' our fish, and drive real improvements to the quality of water flowing through our rivers.

The monitoring will be taking place at Linacre, situated on the outskirts of Chesterfield. The landscape around the site is diverse, ranging from broadleaf and conifer plantation, to pasture and grassland. In regards to freshwater habitat, there are three de-commissioned reservoirs and the Linacre brook. Over the years, a variety of practical conservation projects have taken place to improve habitat on the brook for the wild trout that live there. However, the effectiveness of this work in regards to the health of the trout population is missing.

Lloyd Ross, Ranger for Severn Trent describes how SmartRivers will benefit Linacre:

“I am really keen to carry out work to improve the quality of the aquatic habitat for the trout and other fish and invertebrate species. Aside from the huge ecological benefit, I believe the healthy trout population could become one of a few “flagship” species for Linacre – we could design and install interpretation and education boards around site and plan engagement events centred around about aquatic habitats, species identification and water quality.

Having a monitoring scheme like SmartRivers in place would allow us to pick up and act on any risks to the aquatic habitat before damage may be caused. The scheme would also help with developing natural flood management in the area as I would have an up-to-date set of data to inform my decisions and planning. Involvement in SmartRivers would be a pro-active, positive contribution to our company pledge to commit to improving the natural environment on our sites”.

Lauren Mattingley, SmartRivers Project Manager says:

“We are really pleased to have a water company on board, and hope others will follow in the footsteps of Severn Trent. As water companies have a huge role to play in keeping our waters pollution-free we welcome engaging with them through SmartRivers”.

Benchmark samping has already begun in the Linacre Brook, with the volunteers due to receive their training in spring 2021, pending Government advice at the time.

Philip Dunne MP launches new Bill to tackle river pollution

Salmon & Trout Conservation warmly welcomes the introduction of the Sewage (Inland Waters) Bill, aimed at tackling the unacceptable levels of raw sewage being discharged into our rivers and streams.

Rt. Hon Philip Dunne MP for Ludlow has published his Private Member’s Bill designed to tackle river pollution from untreated sewage and improve water quality.

In 2019, raw sewage was discharged into rivers across England and Wales for over 1.5 million hours, compromising these vital habitats for wildlife and endangering the health of people who use our rivers for recreation.

Philip Dunne MP, who is also chairman of the Environmental Audit Committee, said:

“Our rivers are a vital part of our natural heritage. It is right the Government has committed to restoring at least three quarters of our waters to their natural state.

But it is clear from last week’s latest assessment from the Environment Agency that we are a long way from achieving that, with fewer than one in six of our rivers in good health. This threatens the aquatic life and iconic species that rely on these precious habitats, such as freshwater fish, kingfishers, otters and dippers.

The discharge of untreated sewage is a major part of the problem. It poses a significant health risk to those who wish to enjoy our rivers for leisure and recreation.

The River Severn and its tributaries the Clun, Corve, Kemp, Onny, Rea, Teme and Worfe all flow through my constituency. They are nothing like as healthy as when I was a child, but they should be.

That is why I have brought forward this Bill, which aims to cut discharges of raw sewage into our rivers - protecting our precious habitats for wildlife and people to enjoy.”

The Sewage (Inland Waters) Bill places a duty on water companies to ensure that untreated sewage is not discharged into rivers and other inland waters. The Bill will require water companies to set out plans progressively to reduce their reliance on combined sewer overflows (CSOs). It proposes increasing levels of transparency, as firms will be mandated to report publicly not just on the frequency and extent of sewage discharges from CSOs and any other sewer catchment assets, but also on the impact on water quality as this is enabled by advances in technology.

Nick Measham, CEO S&TC said,

“I am delighted to see this vital Bill introduced and have been pleased that S&TC was able to make use good use of the donations we receive from members, and elsewhere, to allow S&TC’s lawyer to play a significant role in drafting the Bill and the Explanatory Notes.”

Sewage (Inland Waters) Bill

Sewage Bill (Explanatory Notes)

The Bill also proposes measures to upgrade drainage infrastructure to separate household sewage from surface water drainage, helping reduce the risk of overspills. It includes measures to reduce harmful products such as non-biodegradable wet wipes, commercial fats and oils from being disposed down the drains. It also proposes measures to expand the number of inland bathing waters and establish targets to increase those classified as “good” or “excellent”.

Guy Linley-Adams, solicitor with Salmon and Trout Conservation said,

“The Bill is a welcome and necessary correction to the post-privatisation legislation for controlling sewage pollution of rivers, streams and lakes. As we leave the EU, we need to increase the level of ambition and this Bill does that. All sides in this debate, including water companies, recognise that we need to build back better post-Covid, including in our water infrastructure, so this Bill deserves, and I’m sure will get, very strong cross-party support.”

The Bill has additional support from environmental charities and NGOs including,

The Rivers Trust, Surfers Against Sewage, The Wildlife Trusts, The Angling Trust, Chalk Aquifer Alliance.

We encourage you to share the Bill with your local MP and lobby them to support it.

Who is my MP? https://www.writetothem.com

Notes

The Rt Hon Philip Dunne MP has been Member of Parliament for Ludlow since May 2005. In February 2020 he was elected Chairman of the Environmental Audit Committee. He is also a member of the Conservative Environment Network Parliamentary Caucus.

Untreated sewage is discharged directly into rivers from licensed Combined Sewer Overflows (CSOs) managed by the 9 water and sewerage companies in England, which are permitted by the Environment Agency (EA) to exceed consented concentrations during periods of heavy rainfall. Recent data obtained by the Guardian established 6,508 inland CSOs discharged untreated sewage into rivers over 200,000 times across England for over 1.5 million hours in 2019, meaning that they likely occurred far more regularly than just during periods of intense rainfall.

The government set an ambition in the 25 Year Environment Plan to improve at least three quarters of UK waters and return them to their natural state. However, the latest assessment by the Environment Agency showed that just 16% of England’s rivers meet the criteria for ‘good ecological status’, unchanged from 2016.

"If we can’t conserve the most protected, how can we ever conserve the rest?"

Feargal Sharkey, recently appointed a Salmon & Trout Conservation Vice President writes,

It’s the perfume that you notice first.

Not in that pleasingly attractive CHANEL N° 5 kind of a way but more in that acrid, back of the throat, ammonia filled reflux-inducing kind of a way.

It’s when you notice the used condoms, the sanitary products and the dead rat all trapped in a spiralling embrace, circulating anticlockwise in a backwater eddy that you really begin to notice that things just aren’t right. What one observer pithily described as “Dead rat and sanitary towel soup”.

Is this fiction? No. In 2019 raw sewage was discharged for more than 1,000 hours into an environmental wetland situated at the heart of Olympic Park, Hackney Marshes created as part of the London Olympics legacy.

Yes as part of an event designed to highlight to the world the greatest achievements of British athletes; an event who’s ambition was to build a legacy that would impact upon the lives of millions of Londoners and generations to come: to build a wetland in one of London’s most deprived boroughs. And yet, and yet in 2019 we allowed the local water company to spend more than 1,000 hours dumping sewage into that newly created wetland.

It was not an isolated event. According to recent reports in the Guardian during 2019 water companies across England spent more than 1,500,000 hours dumping sewage into our rivers.

Take for example the case of the River Avon in Hampshire. Just over 1,000 sq miles of catchment, some of the rarest, most precious rivers systems on earth: the River Avon and is tributaries. All chalks streams. All designated part of a Special Area of Conservation.

Yet in 2019, by my counting, Wessex Water spent 14,642 hours ejecting sewage into the River Avon and its catchment.

That’s 5 chalk streams, some of the rarest river ecosystems on earth, afforded one of the highest form of legal protection this country has to offer and we allowed the water company to do WHAT?

Or the Rive Kennett, given birth to in the lush rolling hills of Wiltshire but even by the time it reaches Marlborough just 10 miles later it is already polluted Thames Water having spent 1,636 hours dumping sewage into its once pristine waters.

46 miles later as it reaches Reading parts of the river have been designated a SSSI. And yet, and yet, in 2019 Thames Water spent a total of 12,734 hours dumping sewage into the Rive Kennett.

And the Environment Agency does what exactly?

Well it transpires at least in the eyes of th3e European Court of Justice (ECJ) not a lot that would bring the UK government into line with the Urban Waste Water Treatment Directive (UWWTD).

You see in 2012 the UK Government was taken to the EJC by the European Commission for been noncompliant with the Directive. My reading, the court agreed, the UK was breaking the law. Not only that the court ruled, again my reading that this should only ever happen, only ever happen in “Exception circumstances”.

Well all of that was in 2012. So here we are, 8 years later and in 2019 water companies spent over 1,500,000 hours worth of sewage dumped into England’s rivers. Would that be “Exception circumstances”?

Or the14,642 hours of sewage dumped into the River Avon catchment during 2019. Would that be “Exception circumstances”? Or the 12,734 hours worth of sewage dumped into the River Kennett. Would that be “Exception circumstances”?

As a nation it speaks volumes about the platitudes we allow government and others to heap upon the environment, the empty, meaningless words devoid of intent, the 25 year plans that simply perpetuate the obscenity and the complicity.

If we can’t conserve the most protected, how can we ever conserve the rest?

Chalkstreams are as internationally rare and ecologically important as coral reefs or rainforests, and 85% of the world’s chalkstreams are found in England.

With this comes a responsibility to protect them, something at the moment we are failing to deliver, with evidence of many stretches running dry, whilst others are clogged with nuisance algae and huge declines in flylife, the base of the food web.

Our Riverfly Census work has shown chalkstreams are under huge pressure from excess phosphates, fine sediments and chemicals, all exacerbated by vast over-abstraction. Chalkstreams are groundwater fed- when rain falls it sinks into the chalk ground through fissures and cracks, turning into underground oceans of trapped rainwater. Natural refilling of this underground water is essential to ensure our chalkstreams stay flowing. Yet, because this water is cool and stable and therefore ‘cheap’ to use, it is heavily relied upon and much is removed by water companies to become the water we use in our homes.

We, at Salmon & Trout Conservation, are calling for: New ambitious, bespoke regulatory

targets for all chalkstreams which recognise and manage them as the unique habitats they are.

Currently all our rivers are managed under the Water Framework Directive (WFD). Within

this all rivers are classified the same, working towards common ecological targets. Yet, our

data confirms invertebrate communities in chalkstreams are biologically distinct from other

rivers. So, this generic, one size fits all approach cannot adequately protect them. ‘Good’

according to WFD is not good enough for chalkstreams. By developing new chalkstream

specific ecological targets for all chalkstreams it will identify the elements which make

chalkstreams so special and protect and restore them.

To ensure all our chalkstreams are healthy and sustainable into the future requires radical

action now and a step change in the way we manage our water environment. It will require

new bespoke regulatory targets alongside a properly resourced Environment Agency to

deliver and enforce regulations, and an ambitious timeframe to stop all water company’s

reliance on ‘cheap’ chalk aquifer water and drive investment into alternative water supply

solutions.

We cannot afford to tinker around the edges any longer. The more degraded our

chalkstreams become, the more similar they are to other rivers. We are losing the things

which make them special. We have an international duty and moral obligation to raise the

bar and sustainably protect these precious habitats into the future.

As with everything right now, SmartRivers (the volunteer arm of the Riverfly Census) is navigating its way through the 'new normal'.

However, despite restrictions forcing us to postpone travelling and training courses this year, lockdown gave us the time to make SmartRivers even smarter.

SmartRivers - now an IFM certified course

We are delighted to announce that our SmartRivers training course has been accredited by the Institute of Fisheries Management (IFM). All volunteers who have completed and will be completing their SmartRivers training will qualify for this certification.

Having the SmartRivers training course fully certified by IFM is a great achievement for us. We have spent a great deal of time and effort working out how to transform the Riverfly Census methodology into an accessible, but scientifically robust, volunteer-friendly format. This certification gives us reassurance that our approach has been successful.

Paul Coulson, Director of Operations at IFM said:

“Following a review of the SmartRivers training course by the IFM Training Team the Institute is very pleased to be able to fully accredit the course. The course utilises an array of delivery methods and a wide range of learning materials, and is backed up with further guidance and support following the completion of the course. Trainees who attend this course will receive a high standard of teaching and will leave well equipped to assess their own waters.”

We want all our volunteers to have confidence that they are receiving the highest possible standard of training and support. We hope that knowing this course is recognised by such a prestigious body as IFM will give them that extra reassurance.

A new home for SmartRivers data

SmartRivers data is essential to our conservation and policy work. It is the scientific evidence we need to pinpoint local case studies that give us the power to make national changes. To make this data available and in an accessible form for all, we have built a free, open-access, online portal for all SmartRivers data to be uploaded, stored, interrogated and downloaded.

Lauren Mattingley, SmartRivers Project Manager, explains what the new database will tell us:

"When invertebrate species lists are submitted by volunteers into the database, they are automatically processed through a special calculator. The calculator generates values that indicate the impact of: organic pollution, nutrient enrichment, sediment, river flow and chemicals. You can look at each of these pressures locally and nationally, for a specific time period. This analysis can pinpoint what the problems are and where they are occurring, allowing us to control what is controllable and drive real improvements to the quality of water flowing through our rivers."

The existing data for hubs already part of Smart Rivers is live on the system, and the backlog of data from our Riverfly Census is being added over the next few months. If you want to take a look, we have put together a handy how-to guide with screenshots that explains how to use the database. To access the database open the guide here and email smartrivers@salmon-trout.org to request a login link.

What’s next?

We are constantly evaluating the situation based on the ever-changing Government guidelines, but we remain hopeful that training sessions will be able to resume in spring 2021.

We are still enrolling hubs into the project. To launch a SmartRivers hub on a new river, we collect a one year professional benchmark and provide two day-long courses for groups of volunteers. 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!

As you probably already know, SmartRivers is proud to be part of the Riverfly Partnership's 'Riverfly Plus' toolkit, alongside other exciting citizen science projects like MoRPh - the modular river survey

River organisms respond to their environment and so it is important to monitor any environmental changes. Often the environment is characterised through water chemistry and temperature, but the physical and hydraulic habitat structure of the river and its margins are also very important.

The MoRPh survey was developed to inventory habitats within a river channel and along its margins at a scale appropriate for characterising the physical environment at biological monitoring sites. Originally the biological monitoring was envisaged to be kick sampling of macroinvertebrate communities, and so MoRPh was designed to capture habitat within a rectangular area extending back 10 m across both river bank tops and along a length of river roughly equivalent to twice the river width. By conducting 10 adjacent MoRPh surveys along a river, a river length of approximately 20 channel widths is inventoried, which should be sufficient to capture the larger range of habitats available to more mobile species such as fish. I expect that both these scales are of interest to readers because invertebrates are food for fish!

The MoRPh survey records flow velocity patterns; sediments, including areas of siltation of the river bed; physical features such as pools, riffles, bars, bank profiles, ponds; the structure and extent of the river bed, edge and bank top vegetation; and the types of human interventions (pipes, weirs, bank reinforcement) and pressures from adjacent land use. These observations are recorded by not only ticking the type of feature that is present on a list but also by estimating the feature’s abundance through either a count (pools, riffles) or a category of percentage cover (gravel, vegetation structural type). There are three feature lists to complete, one for the bank tops, one for the bank faces and one for the river bed. In addition, the surveyor records details of where the survey is located, so that it can be shown on a map, and also the approximate size of the river channel, because river channel properties are strongly affected by river size.

MoRPh surveyors are allocated a log-in to an information system that stores and maps their data, calculates some useful indicators from their survey data, and allows raw data and indicators to be downloaded. The indicators include the degree of siltation, the average and largest sizes of the bed material, and the physical and vegetation complexity of the river bed. These bed-indicators are extremely useful for monitoring short-term (monthly, seasonal, annual) changes in the river bed that may impact on the invertebrate community. Broader changes in the river channel and its margins also have important impacts on river organisms but these changes usually occur more slowly, making monitoring most effective at an annual or longer timescale.

If you are interested in the MoRPh survey and would like to find out more, have a look at the Modular River Survey website: www.modularriversurvey.org.

- Prof. Angela Gurnell, Queen Mary University of London

This is a terrific outcome for the river, wild fish, the wider environment and the local community.

Nick Measham, CEO S&TC writes,

Bakkavör is closing its salad washing plant at Alresford on the Upper Itchen. In simple terms this should result in an end to significant chemical pollution and provide much needed respite for all biodiversity associated with the river.

It is difficult to celebrate this terrific result for the environment while at the same time local employees of Bakkavör face job losses. But, we should. In our experience it is rarely the case that it comes down to” jobs or the environment”, more often than not there are technical and operational solutions to pollution problems which require only modest investment. It really is the responsibility of Boards to balance their need for every penny of profit, over livelihoods and the environment of local people. Certainly, it is S&TC’s view that consumers and communities are increasingly demanding a “jobs and the environment” approach from business. The environment does not need to be sacrificed for economic growth. We wanted Bakkavor to discharge its environmental obligations to stop polluting the river. We were not seeking closure.

On purely environmental grounds the end to pollution from salad washing is an outcome which we are delighted with. We hope that the local people and community groups long associated with the river will reap the benefits of its increasing health. From our own perspective the closure is a reassuring vindication of S&TC’s unique, and demonstrably effective, strategy to drive change and improve river health to directly benefit wild salmon and trout. A combination of outcome focused scientific study, robust legal posture and patient but forceful campaigning.

Some years ago, following concerns raised by local residents, anglers and conservationists, S&TC lent its weight to efforts to end the environmental damage that Bakkavör was suspected of causing. It was as a direct result of S&TC’s model of producing scientifically analysed invertebrate data on the Itchen (which we popularised under the River Fly Census banner) that we were able to force the Environment Agency to undertake further research into potential pollution coming from the salad washing plant. In June 2018 S&TC made a formal notification of environmental damage to the Environment Agency (EA), pursuant to the Environmental Liability Directive. The EA investigation exposed a number of issues with the site, some of which were resolved promptly, but a pesticide threat was highlighted, which, until the recently announced closure of the plant, remained unresolved and subject to continuous pressure. At the time of the closure, the EA was in the process of imposing a monitoring regime on Bakkavor and Vitacress, its neighbour on a tributary of the River Test, with highly precautionary pesticide discharge limits. It remains to be seen how Vitacress will respond to the challenge of cleaning up its discharge.

S&TC’s role in leading a scientifically evidenced approach to highlight the environmental damage attributable to the operation allowed us to engage significant local and national media interest, including a feature on the BBC’s Countryfile.

Not only did S&TC’s investigations reveal problems with Bakkavör’s operations, it also shone a light on the serious inadequacies of regulation and enforcement options for the EA. Exploration of these issues has led to further revelations which are of national significance. The likelihood of the same issues at Bakkavör Alresford Salads and Vitacress being replicated in other settings, in terms of pollution and inadequate regulation, appear to be high.

A successful outcome in one location will provide a compelling case study, a proven model for eradicating chemical pollution and potentially significant reform of the EA licensing regime across the country.

The chemical problem is national in scale and, if it is to be addressed, it requires a robust, fit for purpose, regime around licensing, monitoring and enforcement. Both locally and nationally S&TC is using its scientifically based evidence to effect change. S&TC will continue to campaign and create energy and enthusiasm for change, but as with Bakkavör, patience will be required to accommodate the hurdles the EA faces.

Data collection, analysis, legal fees and staff time has come at a significant financial cost, and it is without doubt that our members and donors are owed a debt of gratitude. Being truly financially independent has its challenges, but it allows S&TC to campaign, free of conflicts of interest, more powerfully and effectively.

This is a terrific outcome for the river, wild fish, the wider environment and the local community.

Media Coverage:

Countryfile: https://salmon-trout.org/2019/06/17/bakkavor-alresford-salads-impacting-upper-itchen/

https://www.hampshirechronicle.co.uk/news/18602214.updated-salmon-trout-conservation-argue-alresford-salads-pollution-river-itchen/

https://www.endsreport.com/article/1690492/salad-washing-plant-pumped-harmful-levels-neonicotinoid-chalk-stream

https://www.hampshirechronicle.co.uk/news/18630704.bakkavor-close-alresford-salad-branch-loss-100-jobs/

https://www.hampshirechronicle.co.uk/news/18651943.mixed-reaction-bakkavor-factory-closing-doors/

S&TC Recent Press Releases:

Levels of Acetamiprid, a pesticide discharged by Bakkavor into the upper Itchen catchment, have regularly exceeded acceptable concentrations by a factor of up to four times.

https://salmon-trout.org/2020/06/23/toxic-neonicotinoid-washed-off-salad-leaves-into-protected-chalkstream/

Identification of 36 other chemicals from Bakkavor Alresford salad washing activities which could be causing environmental damage. The company declared they were permitted although the EA believed they “present a real or present danger to the environment”.

https://salmon-trout.org/2020/07/23/thirty-six-toxic-pesticides-washed-into-headwaters-of-sac-chalkstream/

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.

View River Dove Conclusions

View River Axe Conclusions

View River Wensum Conclusions

View River Camel Conclusions

View River Lambourn Conclusions

View River Ure Conclusions

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.

Bakkavör washing unknown quantities of thirty-six toxic pesticides, which present real danger to aquatic life, into headwaters of SAC chalkstream

Following on from our recent release about dangerous quantities of toxic neonicotinoid Acetamiprid being washed off salad leaves into the headwaters of a protected chalkstream, a further freedom of Information (FOI) request proves this is just the tip of the iceberg.

Information obtained by Salmon & Trout Conservation (S&TC), confirms thirty-six other chemicals, (Appendix 1) from Bakkavör’s Alresford salad washing activities, which could be causing environmental damage. The list of chemicals, which Bakkavör declare are permitted for use on the produce they wash at the site, highlights thirty-six chemicals of great concern where the Environment Agency believe they “present a real or present danger to the environment”. Current laboratory tests for these chemicals cannot detect the presence in the discharge low enough to ensure they are not causing environmental damage.

The problem is national in scale. Alongside neighbouring Vitacress on the Bourne Rivulet, a tributary of the River Test, there are several hundred similar factories across England which could also be discharging lethal quantities of pesticides.

The Environment Agency has produced, using the best available science on the ecological impact, a minimum reporting value (MRV) for each chemical, at which they believe they can be confident no damage to the surrounding environment, to its fish, bugs, kingfishers, otters and water voles, will occur. However, unfortunately for thirty-six of the pesticides listed current laboratories Limit of Quantification (LOQ), the lowest analyte concentration that can be quantitatively detected with a stated accuracy and precision, is in the worst case 3500 times higher than these “safe” concentrations.

S&TC believes the only safe and responsible solution is for Bakkavör to stop washing salads and discharging its lethal cocktail immediately while a means to measure and remove harmful pesticides is introduced. And the EA needs to demand Bakkavör meets the environmentally safe levels come what may.

Nick Measham, S&TC CEO states,

”Pesticides are, of course, by their very nature designed to kill unwanted animals, unlike industrial chemicals or pharmaceuticals whose toxic impact is an unfortunate side-effect. Is it really acceptable that any pesticides are allowed to be discharged into our natural environment whatever the concentrations? Surely as a responsible business Bakkavör must stop discharging all knowingly toxic pesticides into this river which in so importance to the local community and has international ecological importance, before it’s too late”.

The River Alre, which receives Bakkavör’s toxic discharge, is a tributary to the River Itchen, a Special Area of Conservation- the highest environmental protection a site can get, and a world important chalkstream, as 85% of global chalkstreams are in England. Yet, because of historical discharge permits, once small, but now industrial level salad washing activity is able to pollute this invaluable natural resource.

Janina Gray, Head of Science and Policy at S&TC added,

“Chemical pollution is arguably the biggest single threat to our wildlife and us. In truth, we know very little about most of the chemicals we are pumping into the environment, so governments have put it in the too difficult to deal with box for too long. With wild fish populations like salmon endangered, bugs both in the water and on land showing catastrophic populations collapses and 85% of our rivers considered unhealthy, we cannot ignore this problem any longer. Pesticides are the obvious place to start, and in particular point discharges like Bakkavör. I for one will not be buying any washed bagged salad until I know it isn’t silently killing our rivers with its washed-off pesticides”.

S&TC is calling on Bakkavör to stop their discharge immediately until they can be certain they are not discharging pesticides at toxic levels in the surrounding environment.

NOTES FOR EDITORS

(1) Salmon and Trout Conservation

Salmon & Trout Conservation (S&TC) was established as the Salmon & Trout Association (S&TA) in 1903 to address the damage done to our rivers by the polluting effects of the Industrial Revolution. Since then, S&TC has worked to protect fisheries, fish stocks and the wider aquatic environment for the public benefit. S&TC has charitable status in England, Wales and Scotland and its charitable objectives empower it to address all issues affecting fish and the aquatic environment, supported by robust evidence from its scientific network, and to take the widest possible remit in protecting salmonid fish stocks and the aquatic environment upon which they depend.

www.salmon-trout.org

2) Case History

Fears about pesticides and other chemicals in the discharges from this salad washing plant have been long standing and culminated in June 2018 when S&TC issued the EA with a formal notification of environmental damage pursuant to the Environmental Liability Directive. This followed the results of S&TC’s invertebrate sampling at a site immediately downstream of Bakkavör’s outflows which indicated that chemicals were impacting the invertebrate communities.

The resulting EA investigation confirmed S&TC’s findings; that there were pesticides present, which were on the salad leaves imported by Bakkavör and which were being subsequently washed off and into the Upper Itchen. It appears that Bakkavör had not self-notified the EA of the presence of these chemicals. Once made aware of the pesticide threat the EA began a monitoring and sampling regime. This testing revealed the presence of dozens of chemicals, pesticides and herbicides being washed off the fresh produce at Bakkavör

Appendix 1:

Pesticide Minimum Reporting Value (MRV) and Limit of Quantification (LOQ), where pesticides highlighted in red indicate Environment Agency concerns current monitoring cannot prove they are not impacting the environment.

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