MoRPh: a tool for assessing river habitats at biological monitoring sites

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

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

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

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

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

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

- Prof. Angela Gurnell, Queen Mary University of London

Persistence pays off in the pursuit of a pesticide problem

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

Nick Measham, CEO S&TC writes,

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

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

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

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

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

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

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

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

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

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

Media Coverage:


S&TC Recent Press Releases:

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

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

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.

Phosphorus, Chickens and the River Wye

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

Paul Knight, S&TC Fisheries Consultant

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

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

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

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

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

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

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

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

Toxic neonicotinoid washed off salad leaves into protected chalkstream

Toxic neonicotinoid washed off salad leaves into protected chalkstream exceeds acceptable concentrations by up to 400%.

NEWS RELEASE 23 June 2020

Data from a recent Freedom of Information request by Salmon & Trout Conservation shows that levels of Acetamiprid, a pesticide discharged by Bakkavör plc into the Upper Itchen catchment[1], have regularly exceeded acceptable concentrations. This toxic pesticide and many more are washed off leaves in preparing bags of salad.

Bakkavör plc supplies leading retailers, including M&S, Sainsbury's and Waitrose, with fresh produce such as watercress, baby leaf and organic salads and herbs.[2]

Acetamiprid regularly exceeded, by a factor of up to four times, the lethal dose (chronic and acute Regulatory Acceptable Concentration (RAC))[3]. Acetamiprid is in the neonicotinoid family, many of which were recently banned for use in Europe due to their acute toxic impact on bees. While Acetamiprid is considered less harmful to pollinators than its banned relatives, research shows that it is significantly more toxic to aquatic insects.[4]

Nick Measham, CEO Salmon & Trout Conservation said,

“Enough is enough. Bakkavör’s Alresford Salads factory has a long history of polluting the Upper Itchen. This latest revelation is the most troubling yet. Quite simply this pesticide pollution has to stop, and now. These chemicals will be killing aquatic insects, destroying the primary food source of wild salmon and trout. Bakkavör must end emissions of these and all other toxins which occur as a by-product of their processes. If they continue to refuse to do so, the EA must take decisive action.”

S&TC fears this is not the only insecticide discharging from the plant at quantities dangerous to aquatic life, and that, nationally, Bakkavör is not alone in this activity.  Until S&TC raised concerns over potential chemical inputs from the factory affecting the river, no-one was aware or monitoring what was actually being discharged. Current discharge permits require the operators to disclose to the EA any toxic substances which may be present in their discharge, and then monitoring procedures are established accordingly. Clearly, in this case, that did not happen. There are fundamental failures in the regulatory approach applied here, which must be addressed by the EA.

Additional Freedom of Information data obtained by S&TC suggests up to five hundred other sites throughout England of a similar nature could be operating under the same or similar inadequate permits with no pesticide monitoring requirements, but with pesticide residues being discharged.

Dr. Janina Gray, Head of Policy and Science, Salmon & Trout Conservation,

“Bakkavör is surely the tip of the iceberg. These issues appear to be widespread and will be causing ongoing environmental damage. The existing permitting regime wholly fails to protect the environment from the damaging effects of a range of toxic chemicals. What is even more worrying is the emerging science suggesting that a “cocktail effect” may increase the toxicity of many different chemicals beyond the sum of their parts. The EA has failed to keep pace with what is actually polluting our rivers.”

S&TC is calling on Bakkavör plc to stop their discharge immediately until they can be certain they are not discharging pesticides above regulatory standards and until they can demonstrate they are not impacting the river.

Bakkavör plc urgently needs to outline: 

  1. what action it is taking to remove Acetamiprid and other pesticides from its discharge;
  2. why it is taking so long to put proper protections in place for the Itchen;
  3. why as a responsible business, it should be discharging any pesticides into the headwaters of a highly protected chalkstream; and
  4. why, given the growing body of scientific evidence showing synergistic impacts of chemical cocktails, it routinely discharges a cocktail of 40 plus chemicals into the Itchen.

S&TC is calling on the Environment Agency to:

  1. accept no more delays and to vary Bakkavör’s discharge permit immediately, to give the EA the ability to regulate all chemical discharges made by Bakkavör;
  2. enforce permit variations at any other similar activities in England to require monitoring at any sites where pesticides are identified and, given the risk of synergistic effects, limit these discharges to well below safe levels.


(1) Salmon and Trout Conservation

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

2) Case History 

Fears about pesticides and other chemicals in the discharges from this salad washing plant have been long standing[5] and culminated in June 2018 when S&TC issued the EA with a formal notification of environmental damage pursuant to the Environmental Liability Directive. This followed the results of S&TC’s invertebrate sampling[6] at a site immediately downstream of Bakkavör’s outflows which indicated that chemicals were impacting the invertebrate communities.

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


[1] The salad washing plant is situated on the River Aire a tributary of the protected River Itchen, a Special Area of Conservation (SAC)


[3] The long-term chronic Regulatory Acceptable Concentration (RAC) for Acetamiprid is 0.0235mg/l, and the short- term acute RAC is 0.085mg/l.


[5] [6]

Appendices (3):

Graph 1: Presence of Acetamiprid in the overnight wash discharge of Bakkavör Alresford Salads. The Lowest Limit of Analytical Determination (LOD) refers to the lowest concentration of the analyte that can be reliably detected and quantified. [It is believed that salad leaves associated with Acetamiprid, and its use, are more commonly associated with Spring seasonal produce, hence the absence of data during other months].

Table 1: Results of the sampling of the water leaving the factory during the overnight wash of salads and other fresh produce. [Only certain laboratories have the ability to test for Acetamiprid at the levels at which it is found to cause harm].

Table 2: Monthly Bakkavor - April 2020 - Sampling Data Summary April 2020. Released as part of Environment Agency FOI: 200605 SSD171346 - Bakkavor Data


S&TC Cymru Update June 2020

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

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

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

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

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

Reporting with a purpose

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

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

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

SmartRivers launched in Wales

S&TC Cymru launches its first SmartRivers hub in partnership with the South East Wales Rivers Trust

S&TC Cymru is delighted to announce that South East Wales Rivers Trust (SEWRT) is to host the first SmartRivers hub in Wales. The hub is certain to play a valuable role in assisting SEWRT restore the natural beauty and biodiversity of the postindustrial Cynon.

SmartRivers, 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.

Quick and easy to deploy, but also producing robust and powerful information, polluters of rivers and streams have already been forced to take action. "SmartRivers Delivering Results"

Richard Garner Williams, S&TC National Office for Wales

"I'm delighted SEWRT has chosen to engage with S&TC's SmartRivers programme and look forward to seeing the positive contribution the hub will make towards the Trust's ambitions. It is heartwarming to see the rivers of the south Wales valleys returning to life and I wish the all those associated with the Trust great success in their endeavours." 

river cynon smartrivers

SmartRivers provides valuable 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.

The South East Wales Rivers Trust (SEWRT) was formed in 2007 to recover river habitats in the former industrial valleys of South Wales. The valley environment suffered a great deal in the industrial era, but is slowly recovering, although weirs, contemporary industrial pollution and waste water issues continue to present problems for fish habitats and migration. Thanks to European funding, SEWRT has spent in excess of£190,0000 over recent years on twenty fish easements and three habitat improvement schemes opening up an additional one hundred and thirteen kilometres of river to migrating fish. Regrettably, due to pressure of work, the Cynon did not feature heavily in the programme, benefitting from only five minor easements.  Historically, the Cynon valley was a major area of coal production and heavy industry, the consequences of which had a devastating impact on the ecology of the river. However, the very upper reaches were not so badly affected and over the years these have proved to be the areas from which life has returned to repopulate this bruised and battered river. Local interest in the recovery and importance of the Cynon has generated an enthusiastic band of volunteers, ready and willing to carry out much of the work. The driving force within SEWRT is working with the local community to value the river, carry out community river surveys and run river restoration and fly monitoring courses.

Tony Rees, Chairperson of the SEWRT said:

“As Chairman of the SEWRT I have been heavily involved in several fly monitoring programmes.  Reading about the SmartRivers project made me realise how well this would fit into a new project that SEWRT is running on a truly urban river, the Cynon. I already have funding for two fly monitoring courses locally as well as to run a river restoration course. Using SmartRivers will raise the standard of the work we will be doing to a higher level and is a perfect fit for the “River for All” project on the Cynon. It will ultimately help us to understand in greater depth the problems in our valley rivers. It will also be an excellent way to show those who join in with us the unseen life in the river that is so important to all our wellbeing, but that the public has little knowledge of.  We are grateful to Welsh Water, Pen Y Cymoedd wind farm community fund, Natural Resources Wales and Post Code Lottery for supporting the project.”

SmartRivers includes 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. This 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

We are delighted to be continuing our water quality work in Wales through SmartRivers. The Cynon is unlike any river we have enrolled in the programme to date, so the information we will obtain through the monitoring will be fascinating. It is astounding that tiny invertebrates can give us such vast insight into the subtle, and often invisible, pressures our young fish are being exposed to. We are very excited to educate the Cynon volunteers on these pressures. SmartRivers will give them the scientific power to understand what improvements are needed and measure the biological impact of any actions they may take.”

 Nick Measham, S&TC CEO said:

“The rivers of Wales rivers suffered so much in the industrial era and sadly continue to face a lot of pressure. We are always pleased to hear about the positive work being done and some good news stories about river restoration. SEWRT have achieved so much good for the rivers under their care. We hope our SmartRivers programme will help SEWRT turn high quality citizen science into meaningful real-world action that here and now improves outcomes for wild fish and the wider habitat.”

Dennis Baynham, Secretary of the SEWRT

“The Cynon starts above Hirwaun and runs down the valley through the middle of Aberdare and Mountain Ash joining the Taff in Abercynon. It is a truly urban river in need of some TLC. It suffered years of pollution from colliery waste and the Phurnacite plant in Abercwmboi, but in the years since they stopped production water quality has improved tremendously. It now suffers with water quality problems from sewerage over flows and poor connections. I welcome this initiative as a step in the direction of identifying all the problems the Cynon. The local angling fraternity are behind this.”

 Afon Cynon, A River for all: Gareth Edge Project officer

“My project aims to improve the biodiversity of the Cynon through meaningful education, community engagement and small-scale environmental improvements. Volunteers are encouraged to undertake a Level 1 accredited qualification in River Restoration. Partner Schools look after critically endangered European eels for release on the catchment, as part of a Europe wide restocking project. River clean-ups are undertaken in partnership with Keep Wales Tidy. Invasive species will also be managed with the aid of local authority. Partnering S&TC and the SmartRivers programme will enable me to take my work to a wider audience of volunteers.”

 Natural Resources Wales issued the following statement,

“NRW is keen to support initiatives like SmartRivers, that involve communities in citizen science, and engender a wider and increased understanding of river ecosystems. SmartRivers monitoring aims to pick up issues, and working together, we can better protect and improve our river environments.”

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

 For more information on the work of S&TC Cymru, please email our National Officer for Wales, Richard Garner Williams:

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.


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.

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.

Agricultural Pollution – Educate, Encourage, Enforce

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

Paul Knight, Outgoing CEO Salmon & Trout Conservation writes,

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

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

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

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

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

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

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

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

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

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

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

As the Axe Report states,

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

Reporting with a purpose

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

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

Environmental Land Management Scheme 2020

Environmental Land Management Scheme

Consultation 2020

Make your voice heard:


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

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

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

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

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

S&TC ELMS Response 2020

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

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

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

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

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

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

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

The objectives are:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

S&TC is not qualified to comment on this question

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

S&TC is not qualified to comment on this question

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Reporting with a purpose

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

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

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