NASCO 2020

Paul Knight reports on the 37th Annual Meeting of NASCO

The North Atlantic Salmon Conservation Organisation (NASCO) met for its Annual Meeting in the first week of June, although this year, uniquely, all the meetings were held virtually by video link, with those not directly involved being able to listen in by phone.  Despite concerns that such a large international conference would be difficult to organise and run – it involved a Council and three separate Commissions – it actually went very smoothly, albeit with some of the more important issues, particularly from an NGO viewpoint, being postponed until Council is able to meet face-to-face, hopefully this autumn.

The main objective for the NGOs was to influence support for a full day Theme-based Special Session (TBSS) on salmon farming at next year’s Annual meeting.  This follows increasing concern right across the north Atlantic – and also the Pacific – that open-net salmon farming is the most damaging issue for wild salmon and sea trout that NASCO parties and jurisdictions actually have the power to do something about.  The NGOs were therefore delighted to receive unanimous support from all the Heads of Delegation for the TBSS in June next year, even agreeing to extending the meeting by a day if that is needed to accommodate the event.

The main concern driving the NGOs is that, despite NASCO resolutions going back at least 17 years, and a Council direction that open-net salmon farming should receive particular attention from relevant countries, the Implementation Plan process – the 5-year plans for salmon conservation put forward by each party and jurisdiction – clearly show a failure to protect wild fish from the adverse impacts of sea lice infestations killing migrating smolts, and escaped farmed fish interbreeding with natural salmon populations.  Two countries with significant salmon farming industries openly admit that they have no action to regulate sea lice emanating from open pen farms, while another has a national policy allowing 30% of wild salmon smolts to be killed before any serious regulation is considered.

So, the TBSS is a small but significant step along a very long road needed to turn around the juggernaut of political commitment so that appropriately effective regulations are introduced (in those jurisdictions where they are still absent) and are enforced rigorously to protect wild fish.  It is a sad admission that no country with both a salmon farming industry and wild salmon populations presently protect their natural fish stocks adequately enough.

Another pleasing aspect of this meeting was that, following several incidents last year when the NGOs felt they were being kept at arms’ length from important Council decisions, there were signs that our complaints had been taken onboard.  However, there are still serious issues to address for the NGOs at the autumn intersessional Council meeting, including:

  • The process for completing and reviewing the Implementation Plans – we want to see far more genuine commitment in these plans to protecting wild salmon, particularly from the harmful effects of salmon farming
  • An opportunity for NGOs to input fully to the upcoming external performance review, which will be an independent audit of NASCO’s performance since the previous review in 2012 in achieving its primary objective of protecting wild salmon.
  • Confirmation that NASCO is committed to a fully transparent process in all its work, including NGO access to and involvement in all Council and Commission decisions
  • Through our representation on the Implementation Plan and Annual Progress Report Review Group, NGO involvement in developing TBSSs for upcoming annual meetings
  • Following on the success of this virtual meeting, how much of NASCO’s work could be delivered in this way in future, so cutting down time and money resources in attending meetings, particularly those outside of the main annual event, which we agree should remain face-to-face under normal circumstances

In summary, therefore, a useful meeting where the NGOs achieved our main goal of a TBSS on salmon farming next year.  Much still to do and agree, and we now look forward to the face-to-face intersessional Council meeting in the autumn – provided we are able to travel again by then, of course.

The SAMARCH Project International Salmonid Coastal and Marine Telemetry Workshop

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The "Blue Book"

Based on a workshop organised by Salmon & Trout Conservation and Game & Wildlife Conservation Trust on behalf of the SAMARCH Project and the Atlantic Salmon Trust in Southampton, UK, on the 5th and 6th November 2019.

SAMARCH is a five-year project with a grant of €5.8m from the EU’s France Channel England Interreg Channel programme.

Download HERE

Increase in abundance: A dangerously simplistic view of river health

Species richness and assemblage gives a far more accurate assessment of invertebrate communities………..

Dr Janina Gray, Head of Science & Environmental Policy, responds to a recent article in The Times,

Your article Boom in freshwater bugs bucks trend of disappearing insects (April 24th) sets a dangerously simplistic view of the health of our rivers and water life.

The article reports only one metric – increase in abundance – and not the diversity of species present. Species richness and assemblage gives a far more accurate assessment of invertebrate communities and consequently a river’s health.  For instance, our work has shown that chironomid species can have very high abundances, but they are an indicator of poor water quality, and so their abundance/biomass should not be applauded.

Using abundance data is not a metric which can be used to infer ‘bugs are not disappearing’. S&TC’s Riverfly Census, which recorded 34,000 insects from 480 species across 12 English rivers, showed that pesticides, sediment and excess phosphate are adversely impacting all our rivers to some extent, and are especially damaging to our chalkstreams – once the byword for pristine water quality.  We therefore strongly suspect that your article reports false positives on the true state of freshwater biodiversity and health, by inferring an increase in abundance of pollution-tolerant bugs is a good thing. In order to understand the true state of freshwater bugs, studies must use species richness and abundance data together to form an accurate assessment.

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.

Chalk-Streams First

Abstraction is a major threat to UK rivers but is, arguably, at its greatest in relation to the chalk-streams, a globally unique ecological wonder located mainly in England, especially the highly populated south of England.  S&TC Water Action campaign is working to counter the abstraction threat, terrifyingly highlighted in a raft of recent Government plans for water supply.

This threat requires urgent action across a number of fronts. We have joined forces with the Rivers Trust, the Angling Trust, WWF and the Wild Trout Trust to promote a scheme called Chalk-Streams First (CSF) to save the Chilterns’ chalk-streams. The scheme obviously only addresses a fraction of our threatened chalk-streams, but it is a start and may have application elsewhere. It is not the whole solution, but it does have an important local role to play.

Charles Rangley-Wilson, a tireless campaigner for the UK’s chalk-streams, explains the problem and CSF’s clever solution to the Chiltern streams plight.

It’s high time we put chalk-streams first

Ten years ago, I worked on a campaign with WWF focusing on the terrible impact of abstraction in English chalk-streams. We called it Rivers on the Edge, because they were … on the edge of survival. In a speech on the banks of the River Mimram in the heart of the Chilterns I highlighted how locals there and on the neighbouring River Beane had been protesting about their drying rivers for at least twenty years. They still are. For too long it’s been Groundhog Day with our over-abstracted chalk-streams. But finally, we may just dare to hope that we can fix this problem once and for all, at least in the Chilterns.

It’s high time we did.

Chalk-streams are paradisiacal rivers. Their qualities of clear, cool water, equable flows, and abundant wildlife all derive from that qualifying word, chalk. We all know it from black-boards. Chalk is common enough geologically too: there are great swathes of it across eastern Europe. But the unique way in which the English chalk lies at the surface and was worn away but not completely worn away by the last Ice Age has given us eight-tenths of the global total of the rivers we know as true chalk-streams. The remainder are found over the channel in northern France.

That’s some natural heritage. The unspoilt chalk-stream is a watery Garden of Eden. With their chequered beds of water crowfoot swaying in the marbled currents, their banks decked out in a bunting of marsh marigolds, water mint, and flag iris, they are utterly beautiful in a way that almost defines the southern English countryside. Chalk-streams are rich in wildlife too: under the surface there are brown trout and grayling, white-clawed crayfish, freshwater shrimp and all sorts of darting insects; in and over the plashy meadows there are snipe and otters, water voles and mayflies. Chalk-streams are an English Okavango, an EnglishGreat Barrier Reef, an English rainforest.

Which ought to mean we should value this heritage as highly as we would any other globally-unique eco-system.

Sadly, we don’t. Or we haven’t. Instead these unique rivers are too often abused: some to the extent that they have dried up and ceased to be rivers at all. In May 2017 WWF commissioned me to take photographs of the same Chilterns chalk-streams we had mourned in 2010 … what was left of them at least. They were dry (again) or hardly flowing at a time of year when chalk-streams are usually at the fullest. The worst I’d ever seen. The rivers were dry, or mere trickles, far downstream of their winterbourne headwaters, far downstream of ancient mills, and old market towns and "No Fishing" signs and even Environment Agency flow-gauging weirs.

In spite of, or perhaps because of, how bad it got in 2017 we can at least say that some progress has been made: no-one is denying there’s a problem anymore. No-one is questioning the link between abstraction and drying chalk-streams or suggesting that further research is needed before we can be sure. There have even been some moves to lessen abstraction.

But the real problem at the heart of all this is that southern England is full of people and water is scarce. The Water Companies have an obligation to supply water to the public. They have a right to abstract it, and although nowadays the Environment Agency has the power to revoke licences they deem to be environmentally damaging, in reality alternatives to the water in the chalk aquifer are very difficult and expensive to realise. So, for year after year we make incremental progress without ever fixing the problem.

Until now?

A new idea called Chalk-Streams First has the potential to completely re-naturalise the flows in all of the Chilterns chalk-streams with potentially only a small net loss to overall public water supply. It is a scheme that could be delivered in the near future using as its basis infrastructure that is already planned for and costed in the water company management plans.

Chalk-Streams First is supported by a coalition of The Rivers Trust, The Angling Trust, WWF UK, Salmon & Trout Conservation and The Wild Trout Trust and we are calling for the idea to be included in OFWAT's multi-million pound strategic review of water resources across the south east.

Thus far the proposal has been independently reviewed by expert hydrological engineer Colin Fenn whose key conclusion was …

“ … that the draft Chalk-Streams First proposition, as put, identifies a feasible and a viable solution to the problem of chronic flow depletion in the internationally-rare and precious chalk-streams of the Chiltern Hills; it being to allow flows in the upstream chalk-streams of the Chilterns to run unreduced by abstraction, with water being taken from the correspondingly enhanced flows in the downstream Colne and Lee, and as needs may be from a range of other less-environmentally fragile sources to meet the needs of demand centres in the Chilterns, using Affinity Water’s already planned ‘Supply 2040 scheme.”

Full Report HERE

The Chalk-Streams First coalition is calling for an urgent, and detailed and fully independent investigation of the idea as part of OFWAT’s strategic investigation of water resources across the South East England.

It’s high time we put Chalk-Streams First.

How Chalk-Streams First Works

If Chalk-Streams First sounds too good to be true, it is also relatively easy to explain how it works. First you need to understand the relationship between the level of the underground body of water - the aquifer – and the flow in the river. It is both a very complex relationship – there are all sorts of nuances and no two valleys are the same – and yet a rather simple one which can boiled down to: the higher the groundwater, the higher the flow in the chalk-stream. There’s even an equation that is remarkably accurate across many streams: a 10% increase in the groundwater level equates to a 25% increase in the river flow. And as the groundwater level increases, so the chalk-stream rises further and further up the valley.

To illustrate it, let’s see the chalk aquifer and chalk-stream as a bucket with holes up the sides. Those holes up the sides represent the length of the river: the highest few holes are the winterbourne headwaters, and below them are the middle and lower reaches down to the bottom of the bucket.

The bucket itself is the chalk aquifer. Now we can fill the bucket with a hose: the water coming out of the hose is rainfall. The water spilling out through the holes: that's the river flow. If we turn the tap up really hard so that the bucket starts to fill: that's the winter recharge period. If we turn the tap down so that the bucket starts to empty: that's the summer discharge period.

The real chalk aquifer rises and falls seasonally, just like this simplified model. Aquifers fill in the winter when inflow tends to exceed outflow (even if the main natural outflow is the river, a real chalk-stream valley has other forms of natural outflow … transpiration and evaporation and some movement of water through the chalk underground) and discharge over the summer months, reaching a low point in early autumn, before the winter re-charge period begins. Winter rainfall is key therefore: the chart below from the River Tarrant shows how important winter rainfall is for the replenishing of groundwater levels.

The real chalk-stream flows like this too. The flow increases as the bucket fills: just as the river flow increases as the groundwater builds in winter. The river (represented by the holes up the side) gets longer, too. And then as we turn the tap down through ‘the summer’ the holes at the top falter to a trickle and then one by one they stop altogether as the water level drops further. That's the upper reaches of the river drying up and the overall flow decreasing, seasonally.

Notice how the water spurts farthest from the holes lower down the bucket and also as the level in the bucket falls during the summer discharge the flow from all the holes added together diminishes too. That's because the flow rate is a response to the hydrostatic pressure in the bucket. The lower the level, the lower the flow: just like in a real chalk-stream.

Now to see the impact of abstraction … let’s set the tap so that all the holes are flowing and the water coming in from the hose matches the water going out through the holes.

Then let's drill another hole in the side of the bucket and create a new outflow that represents abstraction, with some of the water going in a different direction towards “public water supply”.

As soon as that hole is tapped, the bucket will start to empty until it reaches a new state of equilibrium at a lower level: that is the impact of abstraction. The new abstraction hole has supplanted the top three river holes (shortened the river) and it has lessened the flow in all the others.

It’s very simple: what goes in goes out. Under natural conditions it goes out down the river (plus the transpiration and evaporation I have mentioned). Under the unnatural conditions of an additional out-flow called “abstraction” the flow in the river diminishes: in this case by the exact amount abstracted, in the real world by an amount that is proportional to but not quite the exact amount abstracted (because of the other forms of outflow).

It stands to reason therefore that if we stop abstracting – or in this case put a bung in the “abstraction” hole in the bucket – the aquifer level will rebound and the river will eventually recover to the same level it was at before the abstraction. This is called “flow recovery” and it is the key idea behind Chalk-Streams First.

Detailed modelling of flow recovery in chalk-streams in Dorset (the River Tarrant) and Berkshire (the Kennet) – both slope-face streams similar to the Chilterns rivers – suggests that for every unit not abstracted from the groundwater in the upper valley, approximately 80 to 85% of that unit will become surface flow in the river.

So …. Let’s stop taking water from the aquifer. Let’s allow it to flow down the chalk-streams. Then let’s take it from the lower end of the catchment instead, after the chalk-streams (and the fish, birds, plants and insects) have had use of it first.

Hence we have called the scheme Chalk-Streams First.

Chalk-Streams First very simply makes use of the way chalk-streams function by moving the point of abstraction from the groundwater at the top of the valley, to the surface water at the bottom of the catchment where it can be taken into storage in the big reservoirs around London.

The obvious question which follows this simple idea is, how do we provide water to those towns formerly supplied by the groundwater, when all the water is now downhill at the bottom of the Rivers Colne and Lea?

The answer is a pipeline scheme called "SUPPLY 2040" which is already included in Affinity Water's business plan. Affinity Water plans to build this pipeline (in fact a development and reinforcement of existing infrastructure with additional components and sections) anyway, to move water from their own excess zone south of the Thames to the deficit zone in the north. It is also needed for many other strategic infrastructure schemes currently under consideration, including Abingdon Reservoir and other options.

SUPPLY 2040 would enable the water that has been liberated to flow down the chalk-streams (or its equivalent volume) back up to the towns currently supplied directly from the groundwater. Better still SUPPLY 2040 could relatively easily be shifted forward to become SUPPLY 2030, meaning the re-naturalisation of all the Chilterns chalk-streams is within reach in less than ten years.

What we need now is a really detailed, independent investigation of the viability of the scheme. The Chalk-Streams First coalition has asked RAPID to run that investigation (RAPID has been set up by OFWAT to administer the strategic review of water resources). So far, the reception of the idea has been really encouraging.

But the more this scheme is talked about, the better. We need it out there in the conversation. If Chalk-Streams First can work in the Chilterns it could eventually become a model for how we save other chalk-streams in the future.

It’s high time we put Chalk-Streams First.

To read the proposal click HERE.

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:

http://bit.ly/ELMS_2020

CLOSING DATE FOR COMMENTS 5th May 2020

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.”

image1

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: smartrivers@salmon-trout.org

 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.

ENDS

Issued by Corin Smith comms@salmon-trout.org (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.

Change of Chief Executive at Salmon & Trout Conservation

S&TC’s CEO, Paul Knight, is to retire at the end of June and Nick Measham, currently Deputy Chief Executive, will take over the reins of the UK’s premier wild fish charity.

Paul Knight stands down on June 30th after 26 years with the organisation, 18 of which have been as CEO, although he will continue for a further year with some part-time consultancy work, mainly connected to his Co-chairmanship of the NGOs at the North Atlantic Salmon Conservation Organistion (NASCO).

Paul Knight and Nick Measham, third and fourth from right respectively.

During Paul Knight’s tenure, the organisation evolved from being the governing body for game angling into a fisheries charity (2008), changed its name from Salmon & Trout Association (S&TA) to Salmon & Trout Conservation (S&TC) in 2016, and had two office moves from Fishmongers’ Hall, culminating in its first ever dedicated HQ, which is now located in Wiltshire.

Above all, the charity has gradually developed the focus of its work from being an angling interest group to a fisheries conservation organisation with policies built on sound scientific evidence.  S&TC now sees angling as being a dividend of its work to create healthy wild fish stocks, water quality and freshwater and marine habitats, and its membership base is still mainly anglers, albeit those with a vision of their place within the wider water environment and their critical role in its future protection

Paul Knight had this to say about his time at S&TC, 

“I have been extremely proud to work for this organisation for a quarter of a century, during which we made some substantial changes to the way in which we operate.  I am very grateful to the six Chairs, all the Trustees and, before them, Council and Committee members, and of course the many volunteers at branch and national levels, all of whom have helped make my job so enjoyable.  I am handing over to a very able successor in Nick Measham, with whom I have worked for five years and so continuity is assured.  Despite our hard-won achievements over the years, there is still much to do to protect wild salmon and trout and the water environments on which they depend, and I wish S&TC, Nick and our tremendous staff the very best for the future.”  

Nick Measham has a background in investment management and a near life-long fascination with rivers and fish. He joined S&TA, as it then was, in 2015.  He project-managed S&TC’s highly successful Riverfly Census initiative and oversaw the expansion of freshwater campaigns to improve water quality and riverine habitat, and still found time to be an extremely effective fundraiser.

Nick Measham said,

“I am excited to take on the challenge to build on our achievements under Paul Knight to protect wild salmon and trout from the harm wreaked by over-exploitation, fish farming, poor water quality, land management issues and over abstraction. I inherit a talented and committed team and together we will strive to carry forwards our evidence-based advocacy for wild fish and their habitats.”   

High-frequency phosphorus monitoring for water quality management

Using high-frequency phosphorus monitoring for water quality management: a case study of the upper River Itchen, UK

Gary R. Fones & Adil Bakir & Janina Gray & Lauren Mattingley & Nick Measham & Paul Knight & Michael J. Bowes & Richard Greenwood & Graham A. Mills

Abstract Increased concentrations of phosphorus (P) in riverine systems lead to eutrophication and can contribute to other environmental effects. Chalk rivers are known to be particularly sensitive to elevated P levels. We used high-frequency (daily) automatic water sampling at five distinct locations in the upper River Itchen (Hampshire, UK) between May 2016 and June 2017 to identify the main P species……..

Read the full paper HERE

Dr Janina Gray, Head of Science & Environmental Policy at S&TC said: 

"This peer-reviewed article has come from our phosphate (p) monitoring work on the Itchen. It highlights the spiky nature of P, which is typically missed in the EA’s current monthly monitoring regime, and the need to better understand the impact these spikes could be having on river ecology. As a next step, S&TC, alongside EA and HIWWT, have joint funded a PhD at Nottingham University, which started in Sept 2019, to investigate the ecological impact of the P spikes."

Nick Measham, S&TC Deputy CEO said:

"We have already taken this science and turned it into action. The work underpinned changes to watercress companies’ discharge permits on the Itchen and contributed to a massive reduction of this pollutant in the river. 

The spiky nature of the discharge implies that the EA’s monthly sampling, combined with permit limits set in terms of annual averages, does not provide the protection our rivers need. Permit reform and the use of monitoring technology is urgently required. The current regime makes no sense.

Much more remains to be done but this is a start."