Bakkavor ends use of cleaning products containing chlorine

Bakkavor has stopped using chlorine-based cleaning products at its Alresford Salads salad washing and packaging factory near Alresford.

This means that the chemicals used every night to clean the factory’s equipment will not be able to react to form chloramines which are highly toxic to water life even in extremely low concentrations. The EA and others stopped Bakkavor using chlorine in the daytime salad washing water some years ago.

This is one small victory in our campaign to stop Bakkavor’s salad washing factory at Alresford polluting the headwaters of the River Itchen SAC and SSSI - one of our finest and most highly protected chalkstreams.

However, two huge issues remain:

  • The overnight cleaning products are still being discharged straight into the upper reaches of the Itchen rather than to the sewage system;
  • Pesticides washed off the salad crops are also entering the river via an adjoining watercress bed with no monitoring for these potential lethal pesticides taking place.

The solution to the overnight wash is clear: under the precautionary principle, it must be tankered away or connected to the sewer (as Vitacress does at its nearby plant on the Bourne Rivulet). We find it incredible that industrial effluent should be discharged to any river. Bakkavor will howl about the cost but why should any business, let alone a multi-million pound one, be allowed to dump potentially toxic chemicals in the headwaters of a SAC river.

The pesticides could be an even bigger threat to the Itchen. We notified the EA formally last summer about our discovery of a potential pesticide impact below the discharge point from Alresford Salads and the discharge point from the watercress bed operated by The Watercress Company (TWC). The water used to wash the salads is pumped to this adjoining watercress bed, flows through the cress beds and then discharges into the river.  TWC’s discharge permit has no pesticide monitoring conditions. Thus, it is possible this potentially lethal pesticide brew has been entering the Itchen without any monitoring.

After our intervention, the EA has been carrying out intensive pesticide monitoring of these discharges and is due to report soon. We await the results with interest. Whatever the outcome, it seems clear that pesticides washed off the salads should be monitored and, if present in harmful quantities, removed whatever the cost.

Septic tanks – the UK’s secret sewage problem

Septic tanks are not the most glamorous topic...

...But they are definitely the ‘elephant in the room’ when it comes to protecting our waters from nutrient pollution.

What are septic tanks?

There are a vast array of homes that are not linked up to main sewage treatment works. Where properties are located at least 50 metres from a sewer, septic tanks or package treatment plants are the dominant method of sewage disposal.

Septic tanks are essentially underground tanks. Solids sink to the bottom, forming sludge, and liquid flows into a drainage field, where bacteria take out the bad bits as it soaks into the ground. When used and maintained properly these ‘micro-treatment works’ do their job very well.

Why are septic tanks an issue?

It seems quite obvious, but to keep our wild fish and other water life thriving, they need a sewage-free place to live.

Wastewater contains nitrogen and phosphorus from human waste, food, certain soaps and detergents. If a septic tank is not operating correctly, these nutrients are discharged into watercourses. Excess nutrients are bad news for river systems.

There are a variety of reasons why septic systems fail, but one of the most common is poor maintenance. For example, irregular septic tank emptying may cause solids in the tank to block the soakaway and clog the complete system, increasing the risk of an environmentally damaging incident.

Another big issue is regulation around these micro-treatment works. Despite more rigorous regulations being recently introduced for installation of new septic tanks, the vast quantity of unregistered older systems still remain, with their condition and effectiveness largely a mystery.

Rules around septic tanks are also mostly advisory with a lack of top-level ownership around the issue. The absence of a single authority control has led to frequent installation of systems with inadequate drainfield designs, in unsuitable locations and with no common policy covering their registration or maintenance. Systematic inspections are also lacking, currently only discharges of larger systems with specific permits are routinely monitored for discharge quality.

What you can do

To keep our rivers healthy and bursting with life we need your help to keep them sewage-free.

  • If you are a septic tank owner, be responsible & educated.
  • There is some fantastic information around that will answer any questions you have. One of our favourite resources is http://www.callofnature.info/
  • If you know other family and friends with this kind of system, share your knowledge!
  • Report incidents - If you see a suspicious septic tank discharge to your local river, report it! Send us a photograph and a google maps location and we’ll happily take a look.

From source to sea: S&TC unite with Marine Conservation Society (MCS) to highlight plastic’s destructive journey

Present at every stage of their journey, wild fish are facing yet another threat: plastic pollution.

We've teamed up with Marine Conservation Society to highlight the issue, as we start to build a campaign which aims to educate on, and ultimately tackle, the enormous plastic problem our wild fish are facing.

Plastic Pathways

The continuous increase in synthetic plastic production and poor management in plastic waste has led to a tremendous increase in its presence in our water environments. Plastic does not decompose, it simply gets smaller and smaller. Consequently, plastic particles less than 5 mm in size - commonly defined as microplastics - are produced and persist in both seawater and freshwater systems.

Around 80% of marine microplastics come from freshwater run-off, meaning there is a whole period where microplastics persist in rivers before they are flushed into the ocean.

Where do microplastics go?

There are few watery places untouched by plastics, microplastics have been found even in the deepest parts of our oceans. Similar to ocean currents, rivers have their own distinct flow ‘fingerprint’, whereby no two rivers will transport material exactly the same way. A lot of this uniqueness comes from human interference - wherever we abstract water or build structures, we change a rivers flow regime.

This regime has a big influence on the journey of microplastics and determines what quantities remain in rivers and what quantities are delivered to oceans. In relatively fast flowing rivers with no obstacles, microplastics can be transported directly and rapidly downstream, straight into marine environments. However, in rivers with lower flows, or places where flow is disrupted (structures like dams and weirs) it is more likely that plastics will sink and persist in river sediments. Weather events can also facilitate or impede movement of microplastics. For example, heavy rain can trigger flood events that flush out plastic particles bound up in sediments, speeding up delivery to the ocean.

Sadly, the ultimate fate of microplastics, regardless of their delivery route, is usually in the digestive tracts of wildlife.

These plastic particles are easily mistaken for food and ingestion can mimic fullness and deliver harmful toxins to the animals that eat them. From riverfly insects to whales, plastic pollution is disrupting the natural balance of our ecosystems through its influence on food chains.

Working together

It is essential that to protect our oceans and rivers we stop plastics at source.

We are excited to be working with MCS to raise awareness about the connectivity of plastics from source to sea. Their work on changing policy around single-use plastics has never been more important and we will be adding our voice to help strengthen the case for protection of our freshwaters, as well marine.

To kick start the collaboration, we have developed this infographic to help teach more people that when it comes to plastic, rivers and oceans go hand in hand.

plastic pollution

As our plastics campaign lead, Lauren Mattingley summarises,

"Only by understanding the dynamics of microplastics in freshwater, will we be able to effectively measure and manage the contribution to our oceans, in turn protecting both marine AND freshwater life."

Visit our plastics campaign page to find out more:

A dismal end to 2018 for water companies, their regulators, and the government

The end of 2018 was not pretty for water companies.

Sadly, as always, our environment and waterways bear the brunt. 

 

Thames Water: deliberately ignoring alarms

First up was Thames Water, fined £2 million at Oxford Crown Court on 21st  December for a pollution incident in 2015 in which two Oxfordshire streams were polluted with raw sewage killing many fish.  

The Court heard that Thames Water had disregarded more than 800 high priority alarms in the six weeks prior to the incident, and a further 300 alarms were reportedly not properly investigated, which would have indicated that a key sewage pumping station was about to fail. A further alarm was apparently deliberately deactivated by staff during a nightshift.

Thames Water should hang its head in shame.

Southern Water: ongoing Ofwat investigation

Next up was Southern Water. Following a freedom of information battle with Ofwat, just before Christmas, we finally received confirmation from Ofwat that an investigation into Southern Water, begun in 2017, remains ongoing.

Ofwat has revealed that it is investigating breaches relating to the company’s general duty to provide and maintain its sewerage system to ensure its area is effectually drained, pursuant to section 94 of the Water Industry Act 1991.  Section 94 is, in effect, the core duty for the bigger water companies – the law requires them to collect and treat sewage properly.

Ofwat has confirmed that the investigation covers all of Southern Water’s wastewater treatment works, and that it is looking also at the company’s own reporting of compliance information to Ofwat between 2010 and 2017 in relation to those wastewater treatment sites.  

Obviously, while nothing is yet concluded, the fact that an investigation is now one and half years old and is dealing with such fundamental issues as the company’s general duty to provide and maintain a sewerage system, strongly suggests that Ofwat is not happy.

Ofwat and the Water Conservation Report

But Ofwat itself has hardly been the most aggressive of regulators and it is about time that it found its teeth. If any further evidence was required that Ofwat needs to start biting, it was delivered by the Government’s Water Conservation Report 2018  - slipped out on 19th December as we all left for the Christmas break.

The Water Conservation Report identified that water company leakage still represents about 22% of all treated water put into the supply network and has scarcely reduced since 2014.  In 2018 eight water companies missed their leakage targets. On the demand management side, per capita consumption of water has scarcely changed in recent years and only 50% of households have a metered supply.  

If one delves into Hansard, the record of Parliamentary debates and committees, it is not hard to find references going back over many years to the need to reduce leakage, increase metering and conserve water.

If one were to read watery debates from the 1990s or, indeed, those leading up to the Water Act 2003, the story would be depressingly familiar to the one we are presented with today.  

Moving forward in 2019

Both Government and Ofwat need to pull their respective fingers out – there are positive signs that the new regime at Ofwat might deliver more environmental protection than in the past, but the jury is still out.

We must have decisive action to reduce per capita consumption of water, introduce universal metering of domestic and industrial consumers (with appropriate safety nets for those essential users who need large supplies) and to finally get a grip of water company failure to address leakage.  

On protecting rivers from low flows due to over-abstraction, the Water Act 2014 requires the Government to report to Parliament by the end of May on progress on abstraction reform. One fears it will have very little new to say.

If the Government’s bold claims, to wish to be the first generation to leave the environment in a better condition than we found it, are to mean anything at all, the time for writing more reports, reviews and consultations is over. Action involving aggressive enforcement of the existing law must now follow.

Water companies must improve

However, while we can and should bemoan the chronic lack of firm action by Government, and by Ofwat, and indeed by the Environment Agency in failing to pursue more prosecutions against water companies, the real blame for the damage caused to the water environment by over abstraction, by sewage pollution, and by a general lack of stewardship, falls clearly at the feet of the water companies.  

Those of us in the NGO sector who have been ‘around the block’ have attended so many meetings with water company representatives, all so wonderfully reassuring, promising to sort out the problems. But it is easy to forget that it is now thirty years since water privatisation.

The ongoing failure of the water companies to bring their environmental performance up to a reasonable standard over three decades is a national shame.

 

- Words by Guy Linley-Adams, S&TC's Lawyer

2018: A year in review

What have we achieved this year?

2018 has been our biggest year yet! So where has your support got us, and what have we done for wild fish protection and conservation? Our CEO's Year In Review summaries our influence, accomplishments and campaigns over the past 12 months. 

With the help of our many donors, members and grant-making Trusts, S&TC has had a successful year in influencing a number of wins for wild salmon and trout. The below is a quick summary; however you can download the full review here.

Accomplishments:

  • Salmon farming - we were the major catalyst in achieving TWO game-changing Scottish inquiries into salmon farming impacts on wild fish and environment:
    • ECCLR – they conducted the first Inquiry and their Report included the one-liner: the status quo is no longer an option.
    • REC - their Autumn Report was highly critical of the way salmon farming is operated and regulated and presented 65 recommendations for improvement, including most of our main asks.
  • NASCO - we work internationally on wild salmon issues through NASCO, our CEO being co-chair of the accredited NGOs which gives us unprecedented influence. Amongst other issues, we have used NASCO to influence netting closures and pressurise Scottish salmon farming.
  • Riverfly Census - 3 years and 20 rivers later, we have professional and actionable evidence of various pollutants impacting river health, nationally and locally.
    • Census results have shown up the alarmingly poor condition of some of our most high-profile rivers, particularly from sediment and phosphate, and we co-authored a peer-reviewed paper showing the lethal impact of those two stressors on mayflies.
    • The full Riverfly Census report is currently being compiled but has already influenced new invertebrate species and abundance targets for chalkstreams. The Test and Itchen report is now available.
  • Living Rivers - we've been sampling daily phosphate and chemical levels on local chalkstreams, highlighting and challenging some appalling ecological conditions, specifically:
    • Using a case study on the Upper Itchen at Alresford Salad’s washing plant to fight for the elimination of toxic chemical discharges into SAC rivers.
  • Other S&TC policy work - There has been plenty of other work this year, including but definitely not limited to:
    • Water abstraction reform.
    • Agricultural post-Brexit policy.
    • Our seat on the EA’s Water Leaders’ Group, which covers all environmental water issues.
    • Our seat on the National Drought Group, where we have represented wild fisheries since 2011.

Next Steps:

  • Salmon farming - drive the REC Committee’s recommendations through Government so that they are acted upon rather than ignored.  In particular:
    • Scottish Government to adopt legal responsibility to protect wild salmon and sea trout from the impacts of salmon farming.
    • An independent agency to regulate salmon farming against sea lice trigger levels that protect wild fish, with the sanction of forced harvest on persistent offenders.
    • A moratorium on establishing/expanding farms in sensitive locations and movement of existing farms away from migration routes.
    • Incentives for companies to move into closed containment production.
  • Netting - we are concerned that sea trout will still be exploited in some of the north east coastal nets and we will be seeking more action in 2019 to protect sea trout.
  • SMARTrivers - Our new project, based on training and utilising high resolution citizen science to understand and improve wild fish water quality.
  • Living Rivers - We will continue to fight for the protection of the Upper Itchen and have major chemical sampling plans for other rivers in 2019.
  • Much more - stay tuned for our 2019 plans, in January.

Latest data on River Test and River Itchen reveals concerning issues

Test and Itchen are no exception to national decline in water quality and flylife

The S&TC Riverfly Census continues to reveal worrying declines in flylife and water quality in rivers across England and Wales, as confirmed by our latest report on the River Test and the River Itchen (the king and queen of our precious chalkstreams).

In our comprehensive Test and Itchen report published today, the results from three years of independent species-level invertebrate data reveal:

  • Significant loss of mayfly species.
  • Low gammarus counts.
  • Worrying impacts from sediment, phosphate and, occasionally, pesticides.

Mayfly and gammarus declines

Comparing historic data with our findings has revealed that both the Test and Itchen have four less mayfly species, on average, than their historical averages. This decline in mayfly species richness, and the worrying low numbers of gammarus, are powerful indicators of an ecosystem in distress.

The flylife in both rivers is far poorer than we would expect for chalkstreams in good condition  - let alone these SSSI (Sites of special scientific Interest) and SAC (Special Area of Conservation) rivers.

Mayfly species have declined from an average of 12 to 8 (33.3%) on the Itchen and 11 to 7 (36.36%) on the Test, over the period from the late 1970s/early 1980s to today.

The current levels are also well below local targets of 10 mayfly species - targets agreed with the Environment Agency for what would be expected in a healthy river.

Gammarus, a key staple of the aquatic food chain, is also well below our 500-target level at most sites (historically, gammarus counts went into the thousands).

Excess sediment and phosphorus

Our report reveals the extent that chemical, phosphorus and sediment pollution are impacting the invertebrate community in both the Test & Itchen.

It is clear that a reduction of sediment and phosphate inputs (from point and diffuse sources, including septic tanks, agriculture, sewage treatment works, industry, etc) are essential to conserve these rivers.

Importance of the S&TC Riverfly Census

Lauren Mattingley, S&TC’s Science Officer, explains why data like this is so important:

“We frequently hear stories and concerns about missing flylife and lack of fish compared to the 'good old days', but anecdotal evidence has little weight in environmental decision making.

The Riverfly Census was launched as a ‘myth-busting’ tool to collect much needed high-resolution, scientifically robust data about the real state of water quality in our rivers.

Switching from opinion to fact-based evidence gives us real power to drive national and local improvements to our waterways.

“The Test & Itchen report is a fantastic example of why we need to break away from data ‘silos’.

The Riverfly Census data tells a story on its own, but when linked up with additional local invertebrate and phosphorus monitoring data, we can really start to grasp the pressures on these rivers.

The environment is complex, and stressors rarely work in isolation, so why would we conduct monitoring this way?”

Turning science into action

The Census is no mere academic exercise. We are using this powerful data to inform and build effective strategies which improve wild fish habitat:

  • We are acting on the Census results to improve water quality in these rivers, working with stakeholders in the area.
  • We are tackling known sources of pollution; such as the Bakkavor salad washing plant on the Itchen headwaters, and intensive watercress farming on both the Test and the Itchen.
  • Our findings on the Itchen impelled us to challenge the EA under the Environmental Damage Regulations. We are awaiting the EA’s response.
  • To share the Riverfly Census results from the Test and Itchen and drive further improvements to these rivers, we will be holding a workshop on 12th February 2019. A key aim of the workshop will be to highlight knowledge gaps and develop next steps with a range of stakeholders, regulators and scientists. Please contact Lauren (lauren@salmon-trout.org) if you or your organisation would like to book a place at the workshop.

#ProtectWater campaign success: brilliant news for our waters and fish

First success for #ProtectWater campaign

Thanks to an extensive collaborative effort from over 100 NGO's across Europe, including S&TC, an important first milestone has been achieved in the defence of our water's environmental protection laws.

A paper drafted by a group of government officials, seeking to weaken the laws which currently protect our waters, has NOT been endorsed at the recent Water Directors' meeting.

Government officials from Member States prepared a paper for last week’s meeting of Water Directors - who represent their national governments on all decisions related to water management. The paper included a series of proposed changes to the WFD which, if ever put into effect, would constitute a significant weakening of the legislation.

Collaborative effort from NGO's

However, thanks to a joint and sustained policy and communications effort from NGO's across Europe, the paper was not endorsed by Water Directors. Prior to the meeting, Water Directors were sent numerous letters and communications urging they maintain the environment and protect the WFD - as explicitly recognised in the discussion and in the final report of the meeting, which stated:

"Water Directors reiterated their conviction that the WFD is a center-piece of EU water legislation and has been highly instrumental for progress achieved in protecting and improving the status of European waters so far.

They emphasized that the level of ambition of the WFD and its objectives should be maintained. They also stressed the need to focus efforts on achieving the WFD objectives, and highlighted that water using sectors responsible for the pressures leading to a failure in achieving the objectives should contribute to these efforts."

These succesfull communications and documents were borne of, and sent on behalf of, the Living Rivers Europe coalition; as well as a multitude of individuals, NGO's and other government officials. Water Directors were receptive, indeed;

"They thanked the consultation group for its work and the document prepared. They took full note of the concerns raised by NGOs and stakeholders".

This could not have been achieved without such a co-ordinated effort, and this result is a testament to the power of the #ProtectWater movement of 100+ organisations, of which S&TC are proud to be a part of.

Next steps

The paper will now be discussed at the meeting of the Strategic Coordination Group (SCG) early next year; the issues it contains to be addressed by the Water Directors of the Member States only after various European Commission assessments, i.e. the end of 2019.

So there is still a long way to go, and we still need many more submissions to the European Commission's consultation...

Help us Protect Water and wild fish in the UK

Despite this strong start, the battle is far from over and we still need your help to keep our water laws strong, especially on the eve of Brexit.

Please click here to find out more about the campaign and to have your say with the European Commission, using our simple consultation form. Please, for the sake of our wild fish and their habitats, ACT NOW and help us #PotectWater.

S&TC Cymru welcomes new agricultural pollution regulations

Welcome news from Wales: New regulatory measures to tackle agricultural pollution

Following an extensive lobbying exercise, S&TC Cymru are greatly encouraged by the recent announcement by Lesley Griffiths, Welsh Government Cabinet Secretary for Energy, Planning and Rural Affairs, to introduce regulatory measures to combat the growing threat to the freshwater environment from agricultural pollution.

The regulations will come into force in January 2020 with transitional periods for some elements to allow farmers time to adapt and ensure compliance. The regulations, to be confirmed next spring, will include the following measures:

  • Nutrient management planning
  • Sustainable fertiliser applications linked to the requirement of the crop
  • Protection of water from pollution related to when, where and how fertilisers are spread
  • Manure storage standards

A statement by Lesley Griffiths explained the the need for stricter regulations:

"...poor practice is leaving many stretches of rivers devoid of fish.

...In the long-term, we will develop a regulatory baseline, informed by responses to the Brexit and our Land consultation.  But in the short term, we must take action now to deal with these unacceptable levels of agricultural pollution.

...The regulations will replicate good practice which many farms are already implementing routinely - this must become the norm.

...The regulations will enable firm and consistent enforcement to be taken. The regulations will also ensure there are no barriers to trade of agricultural produce with the European Union following Brexit and help us meet national and international obligations on water quality.

This is the right thing to do – for the environment, for the economy and for the reputation of farming in Wales.”

View: Agricultural Incidents to Water in Wales (from 1st Jan 2010 to 28th Feb 2018 ) [Source: NRW]

S&TC Cymru's observations

S&TC Cymru welcome this news; indeed our rivers and fish have told us for some time that stricter rules, and more stringent enforcement of such rules, is urgently needed to protect against bad agricultural practice.

Our National Officer for Wales, Richard Garner Williams, summarises our thoughts on the announcement below; following consultations with our environmental lawyer, who provides the legal analysis which supports our demands for revision of the law; and based upon professionally-analysed scientific evidence of direct impact on invertebrates and the freshwater ecosystem.

agricultural pollution regulations

Above: Slurry spreading in wet weather, violating voluntary CoGAP.

Voluntary code is not enough

Unlike in Scotland and England, where basic measures or general binding rules place statutory constraints on the dispersal of, among other materials, farmyard slurry, the only guidance currently relating to such practices in Wales is the voluntary Code of Good Agricultural Practice (CoGAP).

A review by S&TC Cymru of this, and earlier codes, showed that little has changed since 1991 and, in some cases, since 1985, in the advice given to Welsh farmers on methods of practice that would avoid polluting our streams and rivers.

Read More: Our response to EFRA regarding the Agriculture Bill in England

welsh agricultural pollution regulations

Above: Dead fish following a pollution incident in the Clywedog in September.

A minority of farmers

Regrettably, a minority of farmers have consistently chosen to disregard these codes, resulting in increased incidents of acute pollution and a rise in the pervasive effects of widespread diffuse pollution.

S&TC Cymru appreciates that the majority of farmers operate to commendable levels of stewardship, but there exists a minority who have ignored voluntary codes of practice and will probably ignore new basic measures as well. This results in reputational damage; not only to the Welsh agricultural sector, but also the wider rural economy and the international standing of Welsh produce.

welsh agricultural pollution regulations

Above:River water polluted with slurry following spreading on nearby fields.

Rigorous enforcement needed

The success or otherwise of new basic measures in addressing the persistent and pernicious effects of agricultural pollution will require more rigorous and regular inspection of farmed premises than at present, if we wish to see a change in the behaviour of this recidivist minority.

It is therefore essential that an undertaking is given to provide the necessary financial provision for Natural Resources Wales to fully exercise their authority as statutory environmental regulator from the outset, in order that the new measures can be enforced without delay.

Welsh agricultural pollution regulations

Above: Highly poluuted water from the Cywyn in September, following a slurry pollution incident.

S&TC & agricultural pollution: next steps

Over recent years S&TC Cymru has committed a large proportion of its limited resources towards highlighting the impact of agricultural pollution on the wild fish of Wales, and we are relieved that Government has finally chosen to act.

We look forward to hearing the details of the Cabinet Secretary’s intentions in due course, and trust that they will fulfil our hopes for a reversal in the current troubling decline in numbers of our precious salmon and sewin.

In the meantime, you can learn more and help us tackle agricultural pollution by visiting our campaign page and following the instruction to report any incidents to us.


Related Articles:

Our View: is a Green Brexit possible?

S&TC response to the Environment, Food and Rural Affairs Committee consultation over the Agriculture Bill 2018

River Itchen damage below Alresford Salads: Autumn 2018 photos

New photos show damage in River Itchen below Bakkavor's Alresford Salads factory.

At S&TC we have long been campaigning to stop Bakkavor discharging their salad wash effluent into the headwaters of the River Itchen.

The Itchen is a designated Special Area of Conservation (SAC), and we fear that the chemicals in their discharge are harming the environment.

Read more: Chlorine in our conservation areas?

Read more: Toxic chemicals keep coming

Our latest autumn samples of invertebrates and algal growth, from a site just downstream of the Bakkavor factory, reinforces our concern.

Our autumn river bed photos, and samples of invertebrates and algae, taken on 5 October 2018, immediately downstream of the Bakkavor salad washing factory (Alresford Salads), show the Itchen headwaters remain heavily polluted. This is in stark contrast to the condition of the Upper Test.

 

Excess algal slime demonstrates damage

The bed of the Itchen headwater stream at our sample site is covered in algal “slime”.

This is a short distance downstream from Bakkavor’s salad washing factory’s discharge point.

River Itchen photos

The bed of the stream should show clear, un-sedimented gravel like this photograph of the Test headwaters at Polhampton taken last Autumn:

Dr Nick Everall of Aquascience has analysed this sinister algal growth. This is what he reports:

“There was extensive area coverage (over 90%) of the river bed area with the thick biological growth or slime which upon microscopic examination was, aside to a bit of chalk and sediment adhesion, entirely composed of filamentous and attached algal and lesser fungal growth…

The dominant and major composition of the biological growth covering metres of the bed of the River Itchen below Alresford Salads was, often filamentous, algae (diatoms, blue-greens and green algae) with some fungal component…

It was typical of organic and nutrient enriched benthic ‘slime’ or sewage fungus’ (Fjerdingstad, 1964 and Hellawell, 1986).”

Read Dr Nick Everall's October 2018 report here

Invertebrates (or lack thereof)

The invertebrate sample from the Itchen headwaters was devoid of insects sensitive to pollution. There were no mayflies or gammarus.

The associated biometric measurements indicate an impact from pesticides, siltation, nutrient enrichment (phosphates) and organic pollution.

In short, the lack of invertebrates signifies the water quality is extremely poor in general – and exceptionally so for the headwaters of a Special Area of Conservation chalkstream.

Read Dr Nick Everall's October 2018 report here

The Upper Test sample taken in autumn 2017 was dramatically healthier. There were over 1800 gammarus and two species of mayfly, for starters. The biometrics indicated no impact from siltation, phosphates or organic pollution.

 

What are we doing about it?

We were so horrified by the invertebrate sample taken in May 2018 from the same Upper Itchen headwater site that we formally notified the Environment Agency (EA) to investigate the problem.

Read more: Alresford Salads EDR

That investigation is continuing; meanwhile we will share our latest findings with the EA, whom we are also fighting to stop Bakkavor discharging its salad wash effluent into the headwaters of the Itchen.

Read more: Will Alresford Salads end use of their chorine-free cleaning products?

In response, the EA is seeking a variation of Bakkavor’s discharge consent, but progress is painfully slow.

Overall, our data is providing strong evidence for the EA to insist Bakkavor stops pumping its effluent into the river. This is the only environmentally acceptable outcome.

As Nick Measham, Deputy Chief Exectuive of S&TC, summarises:

"It is a nonsense that biocides are discharged into any watercourse, let alone the headwaters of an SAC.

Such chemicals can be highly toxic to aquatic life, negatively impacting the health and abundance of wild salmon and trout in our waters - as well as all the other creatures that live there and together sustain freshwater's delicate ecology.

Has the EA got the courage to say no, or will industry triumph over one of Britain’s natural wonders?"

S&TC response to the Environment, Food and Rural Affairs Committee consultation over the Agriculture Bill 2018

S&TC's EFRA response

S&TC respond to the Environment, Food and Rural Affairs Committee consultation over the Agriculture Bill 2018.

Our Head of Science and Environmental Policy, Dr Janina Gray, recently wrote about the Bill, stating that, while we cautiously welcome the Bill, the devil will be in the detail and especially in the amount of commitment to resources by the Government to enforcing the legislation for the minority of farmers who persistently pollute our rivers and streams.

Read More - Our view: Is a Green Brexit possible?

Read More - View our full response to EFRA

 

What does the Agriculture Bill 2018 propose?

The Bill basically proposes that farmers should still be paid subsidies and grants from Government, as they have been under the EU Common Agricultural Policy, but that public money in future should only be distributed in return for public goods.

In our case, that means genuine protection for our rivers, fish and waterlife, which, under the current system, is by no means assured.

Sediment from poorly managed soils, excess nutrients (especially phosphates), slurry and dry manure from dairy farms and agricultural chemicals all currently pollute waterways and, while it is a minority of farmers who are responsible, it is a significant minority. Furthermore, the connectivity of rivers means that just a few irresponsible farmers in a catchment can negate all the good work of their responsible neighbours.

 

Enforcement required

In our response to EFRA, our legal adviser, Guy Linley-Adams, has highlighted that, far from being  a significant advance in the protection of watercourses from agricultural pollution, the new Reduction and Prevention of Agricultural Diffuse Pollution (England) Regulations 2018, passed earlier this year, merely repeats the codes of good practice dating back as far as 1985.

True, the new Regulations make certain poor agricultural practices a criminal offence; but previous codes and legislation were not all voluntary, and yet enforcement has been sadly lacking for three decades. Many of our rivers have steadily declined in health over that time.

Read our response to EFRA

 

Moving forward

The Agriculture Bill now gives us all an opportunity to make sure the new 2018 Regulations are met on all farms, by ensuring that, in future, farmers who do not meet the new Regulations cannot be given public money.

As Guy says,

“To deal with the stubborn problems of agricultural diffuse pollution, the new system must combine the ‘stick’ approach of regulation, inspection and enforcement, with the ‘carrot’ of public money for public goods.”

Please read our full response, together with our analysis of past codes of good practice - codes which failed sufficiently to protect our rivers and streams from that minority of poor-performing farmers.

S&TC hopes that the 2018 Bill becomes a progressive act, setting a baseline minimum performance for all farmers, as well as dangling the carrot of public money for public goods.