Challenges & Choices Consultation 2020

Water Challenges and Choices Consultation 2020

Make your voice heard:


Are you currently watching the river you care about deteriorate and wild fish stocks decline? Concerned with how water is used in the England? Is there a fair balance between nature and industry? What changes do you want see to the current system of regulation and enforcement?

This is your chance to have your voice heard on how the pressures impacting our rivers and lakes are managed until 2027. The consultation features 27 questions, however, you may choose to answer only those you feel are most relevant to you or your organisation.

S&TC have submitted a full response to all questions which is shown below for reference.

We feel agriculture represents an area where there's an abundance of opportunity for quick wins and outcomes that are mutually beneficial. Particularly the need for resources to establish an effective regulation baseline. A relatively small investment in this area could reap huge rewards both for nature and for people and our water bills!

See Sections 8, 19 and 20 for our responses concerning Agriculture.

S&TC Challenges and Choices Response 2020

S&TC Response to the Environment Agency’s Water Challenges and Choices Consultation

  1. The way we treat water today will shape all our futures. What changes can you make to improve the water we rely on?

  • Individuals can play their part on rivers locally, by actively getting involved in river restoration and monitoring schemes, as well as reducing domestic water use, and by supporting national campaigns for government policies that protect water and the aquatic environment – but ultimately, change has to come from political commitment to river and water wildlife protection. Water is vital to all our lives- in the future we must put a true value on water as a finite resource which needs conserving in its own right.
  • Government’s present focus is on climate change mitigation, which is quite right for a medium to long term strategy. However, there are a myriad of other environmental issues impacting rivers and water life which need urgent attention now, otherwise there is no chance of closing the gap between the present 14% of rivers achieving GES and the aspirational 75% by 2027. Delivering on these pressures now will also help build resilience in the natural system to better cope with future pressures of climate change.
  • The proposed Office for Environmental Protection must have the same or increased powers as does EU DG Environment at present to protect rivers and water life post- Brexit, and to ensure regulators abide by their statutory responsibilities toward environmental protection. A strong and influential environmental watchdog is fundamental to increase the number of our rivers achieving GES by 2027.
  • More resources for regulators to conduct fit-for-purpose monitoring on all river systems and to regulate effectively enough to create a deterrent for would-be polluters. At present, there is a woeful lack of funding for effective monitoring, which is a fundamental requirement of an effective enforcement policy, and there has to be greater political commitment to challenging polluters.
  • Government must take the lead and work with the public to improve the water environment, for example;

- Individually, we must reduce water consumption and Government must roll out 100% water metering

- Individually, we must report any incidents of water pollution to the Environment Agency ‘Hot Line’. However, Government must ensure adequate resources for enforcement, and that fines are fit for purpose and deliver benefits back to the environment

- We must reduce chemicals entering our waterbodies. Government agencies must assess the risks to aquatic ecology from both chronic, low level chemical exposure and the cumulative, cocktail effect of multiple chemicals entering rivers, and amend discharge permits accordingly.

  1. What more can we do to tackle the impacts of climate change on the water environment and what additional resources (including evidence, targets, tools and additional mechanisms/measures) do we need to do this?

Increasing water temperatures will significantly impact riverine ecology unless we act now to mitigate its effect. We need to accelerate the implementation of action to manage catchments in ways that reduce freshwater pollution, improve water quality and regulate the quantity and timing of flow, so increasing a catchment’s natural resilience to adapting to climate change. We must restore wetlands and, wherever possible, re-naturalise rivers, including tackling morphology issues and managing water flow patterns in ways that promote ecosystem processes.

We need to:

  • take into account the impact of future climate change when calculating whether water abstraction is, or is likely to be, environmentally damaging. The greater the flow down a river, the more chance it has of resisting temperature increase, with the added benefit of increased dilution of contaminants entering the system;
  • better natural water retention in rivers that even out flow regimes and keep water flowing, reducing temperature and diluting pollutants as well as benefits for natural flood defense and biodiversity. This can be achieved by reconnecting rivers with their floodplains wherever that is possible, reversing upland drainage, establishing wetlands - and catchment management plans that include planting native woodland, which evidence shows can retain up to 60 times more water than pasture (Pontbren Project, Wales) and so help to even out flow regimes;
  • where extensive woodland is not possible, establish more shade along riverbanks to help control increases in water temperature so that in-river habitats are protected. This is particularly important in shallow streams such as upland tributaries, which are vital for spawning and juvenile fish habitat that could be particularly vulnerable to temperature increases, as could invertebrate assemblages within the food chain;
  • river restoration projects that encourage pool/riffle sequences to both speed up flows along some river lengths but also create deeper holding pools of cooler water as a refuge for fish and water life
  1. What can we do to address this biodiversity crisis and meet the 25 Year Environment Plan targets for wetlands, freshwater and coastal habitats and wildlife?

As already stated, we must change political commitment, adopting national policies which place a true value on rivers and water life and the services they provide for us, linking environmental resilience to a healthy economy and multiple benefits to human populations. It is not a question of prioritising the economy over the environment or vice versa – the economy needs successful businesses to prosper but humans in every walk of life require a healthy environment in which to exist. Rivers and water quality with high ecological status are an essential part of that healthy environment.

The regulator must be properly resourced to regulate and enforce existing potential polluters. This will require;

  • an increase in resources for EA monitoring that is fit for purpose and effective across all river systems – including data partnerships with 3rd sector organisations. As an example, the present spot sampling of phosphates (P) once a month, and then an average of the 12 samples in a year to arrive at a P standard for discharge permit holders, is totally inadequate, as S&TC’s daily P monitoring on the River Itchen between 2013-2017 has confirmed - potentially damaging P ‘spikes’ can last less than a day and are invariably missed by monthly spot samples. By accepting S&TC’s academically analysed data, the EA would have received accurate evidence on which to base local decisions and saved resources on ineffective monitoring.
  • Post-Brexit Agricultural Policy must include incentives for managers to protect the water environment running through their land, so that subsidies are received in return for public good. This requires sufficient resources to police environmental protection on all English rivers and, conversely, enforcement where adequate protection is not provided, so that a strong deterrent is evident to would-be polluters. Shifts and strategic planning of wider land management use will also be required, given the impacts of agricultural land management on the freshwater environment.
  • As well as increased Government commitment to riverine protection, catchment management is essential to address issues at a local level - from source to sea, including issues such as reversing upland drainage, creating wetlands, reconnecting rivers with floodplains, reversing morphological damage and creating natural coastal defenses which benefit water life as well as acting as natural flood defenses. However, catchment management must be properly resourced so that plans can realistically be delivered – including sufficient Government funding to support local catchment

management partnerships. Delivery of catchment-based measures to reverse riverine degradation is essential to improving the GES of English rivers and should be seen as a natural partner to improved national policy commitment to monitoring and enforcement.

  1. Environmental targets can generate action and provide a strong signal of intent. Could additional statutory targets contribute to improving the water environment? If so, what types of targets should be considered?

  • Specific chalkstream targets:

Chalkstreams are our rainforests or coral reefs. 85% of the world’s chalkstreams are found in England, and as such we have a duty to protect them. Yet, despite this, the S&TC Riverfly Census, which reported in May 2019, confirmed that our chalkstreams are under huge pressure and their current management is failing them. Even the most ‘protected’ in terms of environmental regulations - e.g. the Rivers Itchen and Wensum SAC’s - were shown to be suffering from excess sediment, phosphates and chemical pressures, and declining invertebrate species richness as a result. This situation is unacceptable for such important ecosystems as chalkstreams, for whose protection UK Government and its agencies hold a global responsibility.

The Riverfly Census confirmed that chalkstreams are biologically distinct systems- yet they are managed and classified the same under the Water Framework Directive (WFD) as other rivers. This means a chalkstream at ‘good’ or even ‘high’ according to WFD is not functioning as a healthy chalkstream should. This led S&TC, alongside local EA, to produce bespoke targets for mayfly species richness and Gammarus numbers to better represent a healthy chalkstream system.

Nationally, new chalkstream specific targets should be developed to help protect these incredibly rare and special ecosystems.

  • Another glaring omission is a standard for sediment, which the S&TC Riverfly Census highlighted as a major polluter across English rivers - on its own but also for the nutrients, toxic chemicals and other contaminants that may be bound with it. S&TC commissioned and co-authored a peer-reviewed paper showing that sediment directly kills invertebrates, especially when bound with excess phosphate. A national monitoring standard for sediment and river specific targets are therefore overdue and need addressing as a matter of urgency. The focus on reducing sediment at source via Catchment Sensitive Farming advice alone has not worked. We now need a mechanism to monitor and measure sediment in rivers, along with incentives and stronger, better resourced enforcement to help target further reductions in stressful discharges from land management and drive forward improvements in watercourses.
  • Small waters and headwaters are a valuable component of the freshwater biodiversity resource which largely fall outside of the WFD monitored network and can therefore

be overlooked in terms of funding and delivery, so targets promoting their protection and restoration would be beneficial.

  • However, we also need to achieve the environmental targets we already have – which are seldom being achieved because of lack of political commitment and funding for effective monitoring and enforcement. As already stated, we need properly resourced regulation that acts as a genuine deterrent to would-be polluters, making it uneconomic to contaminate rivers. At present, there is evidence that polluters believe they will get away with their activities or, if they are ever prosecuted, that they see any fine as merely a business cost rather than a serious deterrent to counter future pollution.
  1. What can be done to address the challenge of changing water levels and flows?

  • In order to properly manage our water levels and flows, we must invest in real-time monitoring equipment, so abstractions can be flexible and based on actual available water. In light of climate change and altered flow patterns, extreme weather events and shifting seasons, current water management is not fit for purpose.
  • S&TC believes we need a fundamental review of the national abstraction policy so that it is future proofed to mitigate climate change and population growth. In particular, that policy must have a genuine regard for river protection, rather than a presumption that current abstraction licenses should be supported unless there is irrefutable evidence of environmental damage - which is extremely difficult to prove in the current climate. In many cases, our rivers are currently not being effectively protected from over-abstraction.
  • There should be pressure placed on water companies to find new, sustainable sources of water for potable supply within agreed timelines. This is especially important in aquifer-fed systems, where abstraction from the ground is a relatively cheap and easily accessible source of clean water that requires minimal processing for potable supply, and so there are commercial benefits for companies to increase abstraction from aquifers up to their licence limits. Many companies do not yet abstract to those limits and so, despite the potential for environmental damage, the temptation is to increase current abstraction sources rather than seeking alternative, more environmentally sustainable supplies. For example, this is arguably the case with Southern Water, who appear to have done little over the past decade in researching new sources of water, and now have to rely on increased abstraction from the River Test in times of drought while they wait for a new reservoir and desalination plant to come on-line - still many years away from completion.
  • There are many public benefits to retaining more water in river systems, as well as providingamoreconsistentsourceofpotablesupply. Togetherwiththeconstruction of new reservoirs, which S&TC sees as imperative in water-stressed areas, catchment management plans should also include initiatives to reconnect rivers with their

floodplains, reverse upland drainage, establish wetlands and plant native woodlands to retain water within river systems. These actions would create multiple benefits apart from increased water retention, including evening out river flows, natural flood defence and general biodiversity protection and enhancement.

  • As already stated, many water company sources and other abstraction licenses are not fully utilised, and so water abstraction could be legally increased in relevant catchments, regardless of any (hard to prove) environmental damage caused by doing so. S&TC therefore calls for all unused water abstraction licence capacity to be immediately revoked so that the urgent future-proof planning and assessment of water sources can take place.
  • Agriculture is a significant water abstractor and S&TC believes that there should be fiscal incentives for farmers to construct individual farm reservoirs, and for licenses to be flexible, with real-time in-river flow monitoring, so that they can be refilled at any time above agreed local river flows - the trigger level to be sufficient so as not to cause any environmental damage in supply rivers. This was suggested when the National Flood Group met in 2012 but does not appear to have been followed through.
  • Government must champion water as a scarce resource - for example; support 100% water metering, underpinned by better water labelling and smart pricing, and other initiatives to increase public awareness around water saving approaches.
  1. The abstraction plan, referenced in the changes to water levels and flows narrative, explains our current and future approach for managing water abstraction. What else do we need to do to meet the challenges of climate change and growth while balancing the needs of abstractors and the environment?

  • As the climate continues to change, land use management must adapt to mitigate the impacts of warming temperatures on the water environment. For example, the growing of particularly water-hungry crops in the south and south east, or other water-scarce areas, may no longer be sustainable.
  • The Environment Bill, when adopted, will create the ability to remove or change environmentally damaging licences without the need to pay compensation. This power is extremely welcome but, with changes affecting only licences modified after 2028, S&TC, via the Blueprint for Water Coalition, is advocating an amendment to the Bill to enable action to be taken sooner.
  • And as above, the onus must be on water companies to provide new and sustainable sources of water that take pressure off the environment rather than add to it. For example, as the climate continues to change, land use management will become central to agricultural policy. We may, for instance, have to stop growing particularly water-hungry crops in certain water-stressed areas, such as the south and south east

of England. There also needs be be greater public/commercial education on the need for more responsible demand management

  1. What kind of a water flow environment do we want? Should we maintain statutory minimum water flow and level standards universally across England as we do now, or go further in some places based on environmental risk?

We need to go further. As discussed, we must invest in real-time monitoring equipment, so abstractions can be flexible and based on actual available water. And we need more robust and environmentally sustainable national and local water flow standards:

  • We have to have minimum flows on a catchment basis, taking into account the multiple requirements of specific habitat protection and the fish species likely to be present in individual rivers, the majority of which will have to undertake at least some migration to complete life cycles. We need to update the Environmental Flow Indicator work to incorporate the best science available and invest in new research to fill knowledge gaps - and then action the resulting recommendations!
  • As already discussed, catchment calculations must be based on a new national abstraction policy that has river and water life protection at its core. A national benchmark must be that all rivers should have sufficient flows to allow unhindered migration for fish species from estuaries through to spawning grounds, although this basic tenet would be tailored on a catchment basis (as above) to accommodate the specific species present.
  1. What can be done to address the challenge of chemicals in the water environment?

The best way to counter chemical contamination in rivers is to stop pesticides and other toxins from entering watercourses at source, which can be achieved with stronger regulation and enforcement alongside incentives for land managers to protect river corridors.

With all new chemicals the precautionary approach should be applied, and the burden of proof should be on manufacturers to ‘prove’ no adverse impact- that the chemicals are not toxic, do not persist in the environment or bio-accumulate.

The S&TC Riverfly Census used species level invertebrate data run through the SPEAR calculator to analyse the presence of pesticides and other toxic chemicals in water courses, and the results highlighted chemical signatures from many of our target rivers. One case study in the headwaters of the River Itchen, where S&TC data showed chemical impact on invertebrates, led to the EA investigating the discharge from a Salad Washing Plant and confirming the presence of pesticides, washed off imported salad leaves, in the discharge entering the river.

The S&TC/EA experience on the River Itchen has highlighted the urgent need to review all discharge permits directly into watercourses which have the potential to discharge pesticides and other toxic chemicals into watercourses. S&TC believes no industry should return water in a worse condition than they receive it - therefore no new permits should be granted that allow such discharges directly into any watercourse without the use of technologies to remove such residues.

S&TC strongly believes the Environment Agency has a duty to better understand the impact of low level, continuous exposure to cocktails of chemicals on biota. Managing each chemical in isolation and according to an Environmental Quality Standard (EQS), is no longer acceptable given the high numbers of chemicals being discharged within a single discharge. These chemicals may separately each be below EQS but combined they may be far more damaging to the ecology, or the lower-level chronic, day in day out impact on ecology may be greater than an EQS breach. As a minimum, the EA should adopt the SPEAR metric into its routine monitoring, which will highlight chemical pressures on invertebrate assemblages, which in turn will allow more in-depth, evidence-led and cost-effective research to be undertaken by the EA into potential contamination sources.

The case-study on the Itchen also highlighted that current compliance monitoring for discharge permits - i.e. once a month sampling to produce an annual average - is not fit for purpose in offering environmental protection from seasonal activities, such as the application of pesticides or fertilisers. We believe an urgent review of current compliance monitoring is therefore required.

We also believe;

  • There should be a statutory responsibility for farmers to prevent chemical run-off from their land into rivers. This could be connected to a new Agricultural Subsidy Policy whereby farmers are incentivised to protect the environment, but penalised if they fail to do so.
  • Farmers should have to follow mandatory soil management protocols within an agreed timeframe, including zero tillage where appropriate. Evidence shows that zero tillage minimises soil loss - and any chemicals bound to it - and is a win/win in that it improves yields after an initial short-term dip in production, and also decreases inputs such as fuel costs. There are, therefore, medium to long term benefits for farmers through improved soil management, as well as protecting river corridors from soil and chemicals leaching into watercourses. If zero tillage is not applicable, then contour ploughing and/or control of tramlines must be adopted to minimise run-off into rivers. While not as effective as zero tillage, this type of management will lessen run-off of soil and toxic chemicals entering rivers and will benefit farmers by keeping more soil in fields.
  • Buffer strips should be a mandatory requirement for arable riparian land, together with fencing to keep livestock away from riverbanks. Buffer strips act to filter

contaminants entering watercourses, and minimising livestock access to rivers stops contamination from faeces and any chemicals bound within them.

  • As already stated, there must be properly resourced monitoring, including data partnerships with the 3rd sector, to ensure that toxic chemicals are not impacting watercourses.
  1. Do you support the Environment Agency's proposed strategic approach to managing chemicals as referenced in the Chemicals in the Water Environment challenge document? If not, what changes would you make?

We believe more needs to be done. S&TC’s policy on addressing chemical contamination in rivers is well covered already in this document.

10. What balance do you think is needed between current chemical use, investing in end-of pipe wastewater treatment options and modifying consumer use and behaviour?

  • It is far more cost effective and environmentally-protective to stop chemical inputs at source rather than trying to extract at end of pipe from sewage effluent – see above under 8. However, this takes time, so in the short-term, we need both in order to improve our aquatic habitats now and to help make them more resilient in the future.
  • There must be an increased public education programme to cease using household products containing potentially toxic chemicals that could discharge into rivers via the sewerage system – eg as has happened successfully in Sweden
  • A genuine move to ban toxic chemicals in hygiene and other products which could enter the sewerage system, within timelines – again as has happened in Sweden :

A scientifically based suspicion of risk is enough under Swedish law to act against a chemical, according to Bo Walstrom, senior international advisor at the Swedish Chemicals Inspectorate. To avoid action, an industry must show beyond a reasonable doubt that the suspicion is unfounded and that their product is safe. This is called the reversed burden of proof, and it is combined with the “substitution principle,” codified into Swedish law in 1991. If a safer alternative exists, a company must use it or be subject to penalties.

  • S&TC’s monitoring work on the Upper Itchen system has shown that poorly maintained septic tanks can have a significant impact on rivers and their ecology. At present, there is a lack of regulation of septic tanks and S&TC believes there should be an agency tasked with the responsibility for ensuring proper maintenance and approval of any new developments relying on septic tank systems, so that neither potentially toxic chemicals nor phosphates can enter watercourses from household products via this source.
  1. What can be done to address invasive non-native species?

  • Care must be taken in moving water around the country so as to protect against the spread of invasive species, many of which are very small and easily transported in water – eg aggressive non-native invertebrates and the spawn of larger species such as signal crayfish. Where possible, water retention for potable supply should be local to avoid moving water from one catchment to another
  • Water users should be made aware of the dangers of non-native species and the part they could potentially play in spreading environmental problems to other areas. The Check, Clean, Dry message is a good way of achieving this (see below under 12) but should also be enforced by riparian owners, clubs and other water business operators at facilities and points of activity.
  • The Government and agencies must have mitigation/contingency plans - regularly updated to keep pace with new evidence - for when dangerous non-natives are identified, and to stop them from entering the UK where feasible. The potential danger of Gyrodactylus salaris (Gs) to wild salmonid species is a particularly important issue and a contingency plan for minimising its spread and impact, should it ever arrive in the UK, is vital for the wellbeing of its target species and should be regularly updated in the light of best available science.
  • Experience from Norway suggests that the vast majority of incidents of the spread of Gs was through the movement of fish from an infected source to contaminate another river system, and there is strong evidence that much of the distribution of aquatic non-native species is by human introductions. There should be stronger enforcement of legislation designed to manage non-native introductions - cutting off the source is obviously more effective than putting contingency or mitigation measures in place.

12.   How would you promote Check, Clean, Dry to all recreational users of water, including those who are not in clubs or attend events?

Information must be distributed as widely as possible to water users so that they are made aware of the dangers of non-native species and the part they could potentially play in spreading environmental problems to other areas. Along with succinct explanations as to these dangers, the Check, Clean, Dry message should be spread through:

  • notices on national representative organisations’ websites;
  • notices on local club web sites and facilities that non- members can access;
  • notices at point of activity facilities frequented by members of the public - eg

angling, sailing, boating, water skiing etc;

  • inclusion of relevant statements on national licenses - eg Annual rod and net fishing licenses in England.
  1. Are there any barriers stopping you adopting good biosecurity when you are in or near water?

There are considerable barriers to adopting biosecurity measures, as witnessed by the widespread distribution of non-native fish, invertebrates, plants and animals throughout UK rivers. These barriers include:

  • public ignorance of the potential dangers from non-native species - either from intentional or accidental introductions;
  • the lack of sufficient non-native danger explanations, or the Check, Clean, Dry message, at access points to water-based activities or on club/organisational websites etc
  1. What can be done to address the physical modification of our rivers and coasts?

Physical modifications to rivers have been identified by the EA as the major reason for such a low number achieving GES under WFD, and there has also been a presumption that hard-coastal defences are more effective than natural habitat in defending against marine storm events. S&TC therefore believes there are a number of measures that can be taken to reverse ecologically damaging man-made changes in morphology:

  • Wherever feasible, rivers should be reconnected with their floodplains. As already stated, the benefits are considerable - to fish, invertebrates and especially natural flood defence. In England, many floodplains have been developed for housing and commercial activities, often resulting in properties being flooded in storm events and so reconnection with rivers is no longer feasible. However, the historical attitude of draining water to the sea as quickly as possibly - dredging out main river channels to speed up the process - has to change. Evidence is that rivers with natural meanders and the ability to flood over adjoining land when necessary, offer much better flood defence than those with straightened and deepened channels, quite apart from the benefits to fish and other freshwater biodiversity.
  • Existing work to identify and remove unnecessary/defunct structures, and enforcement to deal with unconsented works, must continue. This work must be adequately funded. Where any new structures are required, their impact upon freshwater ecology can be reduced by legally requiring the installation of fish passage measures (rather than ‘making provision for’ them), as is already the case for European Eel.

So, where possible, rivers should be restored as closely as possible to natural flow regimes - reversing upland drainage, reinstating meanders, replacing dredged gravels etc

A presumption against dredging rivers for flood defence. In particular, we need to initiate natural flood defences by stopping the input of sediment etc at source to prevent the need for dredging. We must have better joined-up approaches to river management, which adopt measures in section 8 above as prevention against having to artificially alter morphology while initiating catchment management plans which reverse historical damage as outlined above.

We must use catchment management initiatives to educate local stakeholders over the need for naturally flowing rivers, rather than perpetuating physical modifications, dredging etc

There is increasing evidence that softer, more natural coastal defences are more effective than hard-wall protection, in that they break up wave actions in marine storm events. Natural coastal defences also have huge biodiversity benefits, providing habitat for fish, mammals and plants, and will become significant carbon storage systems. They will arguably also have socio- economic benefits in terms of attracting ecotourism.

In summary, we need catchment management plans from source to sea that, wherever feasible, restore natural processes within rivers, estuaries and coastal zones. There should be a preference to schemes which utilise nature-based solutions and natural flood management- working with nature, not against it. This requires joined-up and coordinated planning to achieve best-possible results for morphology, natural flood defences and biodiversity.

  1. Giving more space for rivers and coasts to move and adjust naturally will regenerate habitat, improve wildlife and help us adapt to climate change. What can you and others do to support these changes?

While these are laudable aims, there are significant obstacles to overcome in the tightly managed English landscape. Spatial planning must prevent further development on floodplains, and land management (e.g. crop rotations) and land use change (e.g. arable reversion) will need to be considered as we adapt to climate change, helping to restore the functionality of some floodplains. High proportions of rivers are disconnected from their floodplain by embankments and flow control structures, limiting the scope of those floodplains to hold water during high flows and contributing to downstream flooding issues. This loss of connectivity must be reversed wherever feasible.

S&TC therefore believes that:

  • where wetland/reserve creation is not possible, it may be feasible to include riverbank movement within a revised agricultural policy that establishes buffer strips alongside rivers running through farmland. Buffer strips will consolidate banks and so make erosion more natural and slow down the process of river movement, as well as having benefits for water quality by acting as run-off filters.
  • as stated in section 14, soft coastal habitat that protects against storm events, rather than building walled defences, will allow natural movement of channels and sediment etc, as well as arguably providing better protection by breaking up wave action rather trying to stop it against a solid barrier.
  1. What can be done to address plastics pollution in the water environment?

As with other issues within this consultation, the only realistic way to deal with plastic pollution is to stop it entering watercourses in the first place. For this, S&TC believes we must need:

  • support actions to reduce the manufacture and use of single-use plastics, such as The Plastic Pollution Bill (PPB), and measures to reduce plastic littering such as deposit return schemes. Most marine plastic pollution comes via river discharges, including through sewerage systems, so individual actions (via increased public awareness) can make a difference in ceasing to use products containing microplastics or single use plastics.
  • We must also start preparing to deal with the plastic already in the environment. Measures such as water sensitive urban design (WSUD) and increased implementation of SuDS must be flagged for new developments, recognising the role that these measures play in filtration.
  • to influence the improvement of recycling plastic products – both increasing collection points and processing plastics efficiently in UK recycling plants rather than removing the responsibility by shipping plastic waste abroad.
  1. What actions should the Environment Agency take to reduce plastic pollution?

University studies have shown microplastics in all inland rivers surveyed. Microplastics should be added to the list of pollutants regularly monitored in inland waters, requiring agreement of an accurate, repeatable, reportable method for microplastic quantification. The full consequences microplastics are having on organisms and ecosystems are not yet known and requires research.

  1. What can be done to address pollution from abandoned mines?

Some 3% of English river length is impacted by pollution from abandoned mines. While the treatment of coal mine impact is well understood, cleaning up the residue from other mines is more problematic. To address the problem, S&TC believes that:

  • there should be a single agency given the responsibility for addressing pollution from abandoned mines, with sufficient resources for it to carry out its work effectively. The agency should apply best practice from successful clean-up operations in former mining regions of England and Wales, where several rivers are now thriving ecologically, having once been heavily impacted by pollution from mining;
  • there should be more research into treatment methods for metal mines and the recovery of resources from residues to help pay for processing costs;
  • water quality should be monitored and treatment planned on a catchment scale, taking into account that some former mines are protected as sites of special interest
  1. What can be done to address pollution from agriculture and rural areas?

Many of the measures required to address pollution from agriculture have been covered in section 8 above. Although that dealt with chemicals, the measures are similar because they are based on stopping the input of potential pollution into water courses, whether that comes from soil loss leading to sediment, excess nutrients or toxic chemicals - the three most damaging stressors from agriculture identified by the S&TC Riverfly Census. S&TC therefore believes that:

  • measures should be adopted as in 8 above – the carrot and stick approach, especially greater commitment to effective monitoring and regulation, including sufficient funding and commitment to effective enforcement that deters would- be polluters;
  • notice should be taken of the evidence contained in the S&TC Riverfly Census Report as to the impact of chemicals, sediment and phosphate, much of it from agriculture, and their impact on freshwater ecology;
  • an agency should be made responsible for managing septic tanks. We now know that in areas where septic tanks are prevalent but poorly maintained, they can be the source of excess phosphate and toxic chemicals in adjacent watercourses;
  • Ofwat should allow sufficient investment in rural sewage treatment works to prevent overspill of stormwater events directly into rivers - as part of Ofwat’s resilience and environmental responsibilities;
  • regulation (such as Nitrate Vulnerable Areas and Water Protection Zones where appropriate) should be introduced where current initiatives are failing.
  1. How can we support the farming sector to excel at innovative solutions which benefit both productivity and the environment? What should these solutions look like?

As already stated, S&TC believes that win/win solutions for farming and the environment must be encouraged and are more likely to be supported by Government in post-Brexit agricultural policies. A new Environmental Land Management Scheme should identify suitable options that fund farmers to genuinely deliver for nature, Meanwhile:

  • experimental farms such as Game and Wildlife Conservation Trust (GWCT)’s Allerton Project in Leicestershire have shown benefits to farmers from adopting techniques such as zero tillage that increase productivity, cut inputs but also protect the environment. This information should be distributed as widely as possible and included in agricultural college curriculums;
  • we need to reward good practice that protects rivers by paying farming subsidies for innovative practices, but a fallback ‘stick’ measure is still required to punish malpractice by withholding payment from persistent polluters until the offending practice is stopped and the damage rectified;
  • S&TC is finding that farmer clusters are increasingly interested in working with conservation groups to monitor any ecological damage from their operations - eg we are presently working with a farming group on the Wallop Brook, a tributary of the River Test, training them to carry out SmartRivers -species level invertebrate sampling- so that they can identify sources of pollutants and act swiftly to minimise their impact. The EA must embrace this type of high quality, 3rd sector data and include with its own monitoring evidence so that resources are maximised and overlap avoided;
  • there is mounting evidence that many farmers do not have sufficient storage capacity for manure waste, leading to the spreading of slurry etc on fields during inappropriate weather conditions, which is leading to a widespread issue of slurry pollution in rivers due to run-off - especially prevalent in areas with intensive dairy farming. There must be fiscal incentives for farmers to improve manure storage, and greater use of technology that processes waste and so avoids direct spreading on riparian land, so taking away need to spread onto land at inappropriate times. Manure storage and disposal should be integrated into post-Brexit agricultural policies.
  1. What can be done to address pollution from towns, cities and transport?

Urban areas pose distinct problems for rivers for many reasons, including extensive hard areas of tarmac, concrete, garden decking etc that prevent water percolation and increase

run-off into local watercourses. This is especially dangerous in storm events, when combined sewage overflows (CSOs) discharge directly into rivers and can carry pollution with them. S&TC suggests the following solutions:

  • Make SUDS compulsory on all new building projects
  • There should be incentives for retrospective SUDS fitting where feasible
  • Ofwat should allow Investment through the AMP process to ensure urban sewage treatment infrastructure is modern and effective, and connected to CSOs so that storm water is not allowed to enter directly into watercourses.
  • Adopt the initiative from other countries – eg USA – where drain covers have the picture of a fish and a short statement that drains end up in rivers/estuaries and can cause pollution.
  • Explore imposition of phosphate (P) neutral building development. Any additional P to be offset by reductions in P used by agriculture or released via STWs.
  1. How can sustainable drainage systems and green infrastructure be most effectively used to tackle pollution from urban areas? What challenges are there to using them?

As above; Green and blue infrastructure should be integrated through planning policy and be made mandatory in all greenfield development and brownfield redevelopments, recognising the role that these measures play in improving water quality as well as providing multiple benefits around biodiversity, greenspace, air quality and human health & well-being.

  1. What can be done to address pollution from water industry wastewater?

Recent experience has shown that water company treatment of wastewater is not always effective and can cause pollution events in rivers and the coastal zone. S&TC believes that the water industry needs more effective regulation and potential penalties that deter pollution events:

  • There must be sufficient Investment in infrastructure allowed by Ofwat through the AMP process.
  • Water companies must pay for regular, independent monitoring of all their discharges into rivers and coastal zones.
  • Where licence breaches occur, there must be strict enforcement - properly resourced - with potential fines large enough to deter malpractice and re-invested back into the environment affected by the pollution event
  • Catchment management plans should include all water company responsibilities for wastewater discharges - and abstraction for potable supply - including roadmaps for protecting watercourses from the potential environmental impact of accidental spillage and malpractice.

We support mandatory drainage and wastewater management plans to formalise and standardise processing wastewater for the future.

  1. What opportunities exist for water companies to collaborate with other sectors and organisations on measures to improve the water environment?

  • as above, water companies must play a full and inclusive role when setting and delivering catchment management plans, including agreeing local measures to limit environmental damage from sewage discharges, funded by water companies where applicable.
  • Abstraction policies which look to genuinely sustainable sources of water, including new reservoirs, where applicable, in catchment management plans and support for initiatives aimed at natural storage of water within catchments
  • Funding river restoration projects under their social responsibility budgets – but NOT as compensation for non-sustainable abstraction, discharges etc
  • We require more transparency in the production and monitoring of Water Resources Management Plans, with clear timeframes for delivery to ensure stakeholders have the information to drive collaboration at a catchment scale .
  1. How can local partnerships become more inclusive and representative of all of the stakeholders within their catchments?

This is down to local structures and leadership, coupled with sufficient funding to make stakeholder engagement worthwhile. The biggest criticism we hear of ineffective catchment partnerships (there are many effective ones as well!) is that they become talking shops that, however well-meaning and effective at producing plans, know those plans stand little chance of becoming actioned because of a lack of funding. Again, political commitment is vital if catchment management is to be truly effective.

  1. How can local partnerships achieve a better balance of public and private funding to support and sustain their environmental work?

There must be more commitment to Government funding to support local initiatives, because delivery of measures to restore watercourses are inevitably at the catchment level and therefore Government must be a genuine funding partner for actioning catchment plans: S&TC calls for:

  • greater government commitment to environmental protection through post- Brexit funding pots that at least compensate for the loss of EU finance for environmental projects;
  • a change in legislation that allows fines for river pollution to be hypothecated into river restoration projects - this seems an obvious moral method of funding environmental improvement;
  • Local information which encourages everyone likely to benefit from environmental work on local rivers to contribute to restoration initiatives;
  • greater involvement of local authorities in funding river restoration projects which contribute to the public good locally.
  1. How should the step change in protecting and improving the water environment be funded and who should pay? Are there any barriers to doing this?

There are current barriers to funding water environment work but they can be largely overcome with more political commitment to do so. There must be:

  • greater political commitment to enforcement of potential polluters (currently a significant barrier). The agricultural section must, in the third cycle of River Basin Management Plans, pay its ‘fair share’ in order to deliver environmental improvements;
  • greater Government resources provided for monitoring and enforcement (currently a significant barrier);
  • legal requirement for potential polluters to pay for regular independent monitoring of their discharges – taking pressure off the regulator’s budget and forming a deterrent for would-be polluters;
  • replacement of current EU funding streams by new post-Brexit government schemes to fund river restoration and protection initiatives;
  • pollution fines hypothecated into river protection schemes. At present, Ofwat does not have the power to hypothecate pollution fines for environmental restoration, regardless of the damage caused to river systems. We believe that legislation must be changed to allow all environmental fines to be hypothecated back into restoration works - that is morally correct and an obvious source of funds for the work that desperately needs addressing across many English rivers;
  • those individuals/companies benefitting from environmental work should be made to contribute.

Reporting with a purpose

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

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

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

Incinerator proposal raises serious concerns

"This proposed incinerator at Barton Stacey in the Test Valley raises serious environmental concerns"

Nick Measham, Salmon & Trout Conservation

S&TC do not normally comment on local planning issues but the proposed incinerator at Barton Stacey in the Test Valley raises grave national environmental issues:

1. Abstraction in the headwaters of a fragile chalk stream, the River Test which has an endangered population of genetically-distinct Atlantic salmon

2. A pollution threat from carcinogenic dioxins and endocrine disrupters in the incinerator’s gas discharge which will settle on the chalk and leach into the aquifer with a threat to insect, animal and human life.

Please respond to the consultation at:


The case against the incinerator is on:

As a UK charity with the objective of protecting wild fish and their habitats the proposed incinerator raises two issues of direct concern to us. It is for others to discuss the wider negative environmental impacts stemming from the construction and operation of the incinerator.

S&TC's first concern is with water supply. We do not believe that Southern Water Services (SWS) has the ground water resources to supply the stated required demand of 135 megalitres a year continuously from an already depleted aquifer without risking environmental damage. The fundamental direction of abstraction policy should be to reduce dependency on the aquifer, not increase it. Should SWS seek to supply from its surface water abstractions, we also believe it does not have the resources to meet the incinerator’s demand without increasing stress on the already over-abstracted Rivers Test and Itchen, until it has developed permanent offsets to meet its recent abstraction licence reductions. The proposed siting of a highly water consumptive plant in the headwaters of such a rare, sensitive and stressed environmental asset as the River Test is a fundamental error. The precautionary principle should apply in this case.

We believe that to safeguard this fragile ecosystem there must be a full examination of the environmental impact of the proposed abstraction, whether or not SWS believes it is able to meet the demand, both now and in the future.

Our second concern is with the impact of toxic chemicals, especially carcinogenic dioxins which will be discharged within the incinerator’s gas/steam plume and also retained within the ash. While we understand there are plans to safely dispose of the ash, some 60% of the dioxins can be expected to be released within the gas/steam plume and, although these toxins become inert above 850 degrees centigrade heat, they will reactivate once the temperature cools. The dioxins will settle on the surface of the surrounding chalk. This will impact insects, wild birds, mammals and livestock and will inevitably leach into the aquifer and quite possibly directly in the river. The groundwater, and subsequently the river, will be polluted with a deadly, carcinogenic chemical cocktail which will also possess endocrine disrupting properties, posing serious threat to the ecosystem of this fragile chalkstream environment. Again, we expect a full environmental impact assessment of this potential impact to be carried out.

Given the potential threat to the chalkstream environment from excessive water abstraction, and to insect, animal and human health from toxic dioxins, the precautionary principle again implies that this project is potentially too dangerous to be sited in its intended position and should therefore be scrapped.

Reporting with a purpose

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

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

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

Agricultural Pollution Update – Nov 2019

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


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

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


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

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

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


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

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

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

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

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

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

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

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

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

Reporting with a purpose

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

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

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

SAMARCH technical workshop


SAMARCH Technical Workshop

On behalf of the SAMARCH project, we invite scientists and fishery managers to attend our technical workshop. REGISTER BY: 30 SEP 2019 The event is organised by Salmon & Trout Conservation, GWCT, and Atlantic Salmon Trust.

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

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.

Discharges from salad washing – Update

Salad washing on the Upper Itchen: A local problem with national significance…

Nick Measham , Deputy CEO, S&TC writes…….

S&TC’s battle to stop Bakkavör discharging pesticides and chlorinated plant-cleaning chemicals from its salad washing activities is achieving increased environmental protection, and not just for the Upper Itchen. [Previously covered by BBC Countryfile]

As a result of an Environment Agency investigation, in response to S&TC’s Environmental Damage challenge, both Bakkavör and The Watercress Company will be subject to individual pesticide discharge limits and required to carry out monitoring for a wide range of toxins.

The outcome so far is an improvement but much more remains to be done both on the Itchen and nationally to provide protection against pesticides in combination. Our fight to change national policy to require consideration of the impact of a mixture of pesticides continues.

Results so far:

  • On the Upper Itchen, the Environment Agency (EA) is seeking to revise the discharge permits of both Bakkavör and The Watercress Company’s to limit pesticide concentrations. Bakkavör discharges its overnight factory cleaning waste water directly into the river, but the daily water used to wash the salad leaves goes to The Watercress Company cress beds. TWC does not use pesticides in its growing activities and has therefore not been monitored up to now.
  • We understand Bakkavör is already trialling equipment to remove the pesticides from its discharges to enable it to meet the limits the EA imposes. The company has already stopped using chlorinated chemicals in its plant cleaning waste water.
  • It looks like the EA will require Vitacress’ salad washing plant on the Bourne Rivulet, a tributary of the Test, to meet the same pesticide discharge standards as Bakkavör.

What’s next?

  • The immediate next step is to ensure any revised discharge permits protect the river from the salad washing activities. While the EA has accepted the need for pesticide limits and associated monitoring, S&TC will scrutinise proposed permit changes, when they are published, to ensure the pesticide limits deliver the highest standards of protection currently available.
  • These current standards only consider pesticides individually not in the cocktail which is discharging into the Upper Itchen. There is an urgent need for the Government to investigate the impact of chronic, often low-level pesticide impacts in combination. We are extremely concerned about the impact of multiple different pesticides in combination. The EA’s investigation report following the Environmental Damage challenge in respect of the Upper Itchen refers to the risks on page 36:

“this poses a potential risk of exposure to invertebrates downstream of the discharge and being exposed to multiple different pesticide compounds intermittently at low concentrations (which may be above the Probable No Effect Concentration on infrequent occasions). 

 Current UK policy is to look at the effect of individual pesticides, not the effective exposure to a mixture. A change to policy is being considered at a European Union level, but we are a long way (temporally) from this policy being revised.”

This delay in acting on potentially lethal cocktails of pesticides is just plain wrong and, like so much government policy, completely ignores the precautionary principle. S&TC has written to Dr. Thérèse Coffey to ask what Defra intends to do about this on the Itchen, other SAC rivers and, indeed, any river.

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.

Chalk streams debated in parliament

We always intended the Riverfly Census to be a lobbying document as well as reporting on the science, and this has been an excellent first political outing for it.

Paul Knight, CEO, S&TC

In a speech during a House of Commons debate on "Degraded chalk stream environments", Richard Benyon MP cited evidence from S&TC’s ground breaking Riverfly Census Report. Further, he referenced our investigative work into previously unknown pesticide issues associated with a salad washing plant owned by multinational food group, Bakkavör. [recently covered by BBC Countryfile]

By way of response, Department for Environment, Food and Rural Affairs minister, Dr Thérèse Coffee, rather worryingly pointed to the EA’s permitting system for discharges into rivers as giving them adequate protection. S&TC does not agree.

Nick Measham, S&TC’s Deputy CEO (Project Manager for the Riverfly Census and SmartRivers) said,

“Richard Benyon used S&TC’s professionally sampled and analysed data to show that our rivers are far from being protected at the moment, especially our chalk streams, which we have shown are badly impacted not only by toxic chemicals, but excess phosphate and sediment as well.  We suspect that one of the outcomes of our Bakkavör work may well have national implications for discharges directly into watercourses, so Dr Coffee might not be quite so confident in her agency’s permitting performance in the near future.”

S&TC’s Head of Science, Dr Janina Gray, added,

“Our Riverfly Census results show the power of good science to establish the ecological health status of our rivers and at the same time encourage the Environment Agency to actually take action when problems are highlighted.  It also shows that by producing sound science such as the Riverfly Census results, we can support Richard Benyon and his Parliamentary colleagues with solid evidence to help them influence change at the highest level.”

S&TC’s CEO, Paul Knight, said,

“Richard Benyon’s speech was a welcome public endorsement of our approach to protecting wild water and all that relies on it. He outlined that our data had shown a pesticide discharge from Bakkavor’s plant into the River Itchen that had gone unnoticed, until the arrival of the S&TC team to analyse the invertebrates. This precipitated the Environment Agency conducting their own analysis, which confirmed our results. It is clear none of this would have happened without our intervention, data gathering and subsequent lobbying.”

Follow the full debate in Hansard

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.

Salmon stock exploitation: Wales delays, while England acts

Salmon stock exploitation: Wales delays, while England acts

On the 14th June 2019, in response to troubling results from their own analysis of Severn salmon stocks, the Environment Agency (EA) implemented an emergency bylaw prohibiting the use of certain nets in the estuary and imposed compulsory catch and release on all other nets and rod and line fisheries on the whole of the river for the remainder of the season.

Richard Garner Williams, S&TC Cymru said:

“S&TC Cymru congratulate the EA on this decisive move and trust that the bylaw will be observed by all.” 

Somewhat worryingly however, until the Welsh Minister for the Environment, Energy and Rural Affairs decides to approve similar bylaws for Wales, proposed eighteen months ago by Natural Resources Wales (NRW), this EA bylaw cannot be enforced on the Welsh reaches of the Severn, nor its tributaries. Further, despite the stock assessment for 2018 showing every salmon river in Wales to be "at risk, or probably at risk, of failing to meet its conservation limits," NRW remain unable to extend the enforcement of compulsory catch and release of salmon to all Welsh rivers.[1] Solely the result of political feet dragging.­­

NRW have previously conducted three comprehensive regional consultations on proposed changes to rod and net bylaws with regard to salmon and sea trout in Wales. The first and most extensive, in terms of geographical coverage, concerned every river in Wales but for the Dee, Wye and Severn. Two further, more specific, consultations then followed. One concerning the Dee and the Wye, both of which rise in Wales but bless England with their presence for part of their journey to the sea, and another for the Severn, which while it rises in Wales, flows for the greater part of its length through England.

By reciprocal arrangement the regulations relating to the exploitation of the salmon populations of the Dee and the Wye are governed by NRW, while management of the Severn salmon stocks falls to the EA.

With salmon stock assessments in Wales showing a continued decline, NRW contends it is imperative to implement a policy of compulsory catch and release on all Welsh waters to protect remaining salmon populations from further exploitation. As a result of the NRW consultations, bylaws were proposed placing restrictions on method, such as banning the use of treble hooks and all forms of bait. Further restrictions to those stipulated in the current bylaws relating to sewin (sea trout) were also put forward for consultation.

2018 Salmon Stock Assessment:

In early 2018 these bylaw proposals were endorsed by the board of NRW and submitted to Welsh Government for confirmation. Six months later, in the autumn of 2018, in a wholly unexpected turn of events, Lesley Griffiths, the then Cabinet Secretary for Energy, Planning and Rural Affairs and more recently Minister for the Environment, Energy and Rural Affairs announced her conclusion that given “the level of response to the consultation, the number of outstanding objections to the byelaw proposals and the nature of the correspondence” it is “the most appropriate course of action to conduct a local Inquiry which will allow independent scrutiny of NRW’s proposals.”[2]

Richard Garner Williams commented:

“Proposals to protect salmon stocks in Wales have been put on hold while a protracted enquiry runs its course. The Inspector has now delivered his report but we remain none the wiser about the future intentions of the Welsh Government towards regulating the exploitation of a rapidly declining species. Meanwhile NRW have published their stock assessment for 2018 showing every salmon river in Wales to be at risk, or probably at risk, of failing to meet its conservation limits. Time is not a luxury we have in the fight to save wild Welsh Atlantic salmon for future generations.”

  1. Compulsory catch and release of salmon is already force on the Wye, Taff and Rhymni under the demands of an existing bylaw.

For more information please contact:


Dear Phil, Thank you so much!

What can we say other than a huge THANK YOU!!

Phil Chessum took on the challenge of running the Race to The King ultramarathon to raise money for S&TC. An exhausting 52.4 mile slog across the South Downs.

Completing the course in a very respectable 10 hours 26 minutes and finishing 71st out of 750 competitors, Phil's feet seemed to take the brunt of the effort.

Phil said:

"It was a bit gruelling - glad to get it over with. Feeling quite positive about it all at the moment - although having to work from home, as I can't get my shoes on!" 

Phil raised just short of £3,500 for S&TC and is still receiving donations.

The funds will be used to fund the benchmarking of a river of Phil's choice through our SmartRivers initiative, a lasting legacy worthy of such incredible efforts.

SmartRivers plays a crucial role in ensuring the longterm protection of wild waters by establishing a solid science led reference point of biodiversity, against which any future impacts can be measured and evidenced.

SmartRivers enables volunteers, supported by a training scheme, training videos, an invertebrate-identification App and support programmes, to monitor the water quality in their rivers to a near-professional standard.

Phil celebrated his achievement with a pint. And yes, his eldest son is correct. It was TWO full marathons!!

Well done Phil, and thank you so much. It's appreciated.

From all of us at Salmon & Trout Conservation

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.

Response to Southern Water Fine

Ofwat has imposed the biggest fine ever on a water company for "significant breaches of its licence conditions and its statutory duties." Southern Water has been fined £37.7m, but this has been reduced to £3m because the company has undertaken to pay customers some £123m over the next five years.

Ofwat states in its report:

We have concluded that Southern Water has deliberately misreported data to us about the performance of its wastewater treatment works. We have also concluded that it has failed: to have adequate systems of planning, governance and internal controls in place to be able to manage its wastewater treatment works; to accurately report information about the performance of these works; and to properly carry out its general statutory duties as a sewerage undertaker, to make provision for effectually dealing with and treating wastewater.”

It is extremely frustrating that this financial penalty will only compensate Southern Water’s customers and does not include any funding to clean up the environmental damage that the company has quite obviously caused in both rivers and along the coastline.

Ofwat is only concerned about regulatory obligations over which it has authority, and this does not include scrutiny of Southern Water’s environmental permit failures or, indeed, whether its employees behaved criminally in covering up its woeful operating performance.

These issues are currently being dealt with by the Environment Agency, although the Ofwat report suggests that appalling practices were endemic throughout Southern Water’s structure  “…including at senior management levels” including some designed “to prevent samples of wastewater from being taken at treatment works to check compliance with environmental permit conditions”.

Guy Linley-Adams, Solicitor for S&TC said:

“S&TC has been pursuing this matter, including through the Information Commissioner’s Office for some time now. Given what we now know, it is inconceivable that the Environment Agency will not prosecute Southern Water, and for multiple offences. We expect nothing less. 

There must be no ‘deal’ made with Southern Water. Quite simply, the company set out to cheat the system, knowing that would harm the environment, and it must both pay for the environmental damage it has caused and be punished for what it has done. 
The entire green lobby - and its lawyers - will be watching what happens now”. 

S&TC has reported on Southern Water’s appalling environmental record before.  Although we have no evidence of similar operating practices in other water companies, it is fanciful to think that they are all lily-white in their performance since privatisation.  Some £55 billion has been paid to shareholders since privatisation, which would suggest the greatest driver for these companies is profit-sharing among investors rather than any serious sense of responsibility for environmental protection. The damage the water companies cause  either from inadequately-treated sewage polluting our rivers or the impacts of excessive water abstraction from rivers and aquifers, is immense.

As we cannot trust water companies any more, the time has arrived to require independent monitoring of all water company’s sewage works and abstractions.

S&TC’s Head of Science and Policy, Dr Janina Gray, said:

S&TC’s recently published Riverfly Census Report highlighted the parlous state of our Southern chalkstreams, which is the freshwater habitat most vulnerable to Southern Water’s operations.  S&TC is now calling for full independent environmental monitoring of all water company operations in England.  It is not an excuse to cite lack of resources for failing to comply with adequate monitoring – it should be a legal requirement for these companies to pay for independent monitoring; they can surely afford it!”

Paul Knight CEO of S&TC UK said:

No-one can be so naïve as to think it is only Southern Water cheating like this at the expense of the environment. This is the direct result of years of cutting the regulator to the bone and relying instead on self-monitoring by polluters. It is time to reverse that trend and require independent monitoring of all large companies that can have such massive impact on the environment”.

William Hix, Chairman, Salmon & Trout Conservation commented:

“These are shocking revelations which make it difficult for the public to trust Southern Water’s treatment of the environment. It is the environment that has suffered as a result of this appalling behaviour, and if the fine is to be dramatically reduced because of undertakings given by Southern Water, then those undertakings should relate primarily to the environment rather than customers. OFWAT’s statutory duties and strategic priorities and objectives include the environment. The way in which this compromise arrangement with Southern Water essentially compensates customers (rather than the environment) for damage to the environment, reinforces the impression that OFWAT places little weight on the environment. If there is to be a massive reduction in the fine levied in response to undertakings, then those undertakings should relate to expenditure on protecting the environment. If trust in the environmental protection activity of Southern Water is to be restored, then an effective system of independent monitoring of Southern Water’s emissions to the environment must be put in place as a matter of urgency. Financing such a system, rather than refunding customers, would be the appropriate course to take in accordance with OFWAT’s and Southern Water’s duties to the environment and the nature of the failures.”


Issued by (07463 576892) on behalf of Salmon and Trout Conservation. For more information please contact and on 01425 652461

For more information and resources please visit:

Notes to Editors

(1) Salmon and Trout Conservation

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

(2) The Riverfly Census


The Riverfly Census utilises the invertebrate assemblage: presence, absence and abundance of certain invertebrates and the specific set of conditions they need to thrive, to indicate the types of stress our rivers are experiencing. This species-level resolution shows pressures which family-based Water Framework Directive (WFD) methods fail to capture.

The Riverfly Census has spanned three years, across 12 rivers in England. Multiple sample sites were carefully selected on each.

Kick-sweep sampling was completed in spring and autumn to EA-accepted guidelines, at all sample sites. Sampling and species-level identification were carried out by professional entomologists at Aquascience Consultancy Ltd.

Species data were inputted to Aquascience’s biometric calculator to obtain scores against key stress types: chemical, nutrient, sediment and flow. The data was then evaluated in a whole catchment context to pinpoint the likely suspects contributing to the river’s deterioration.

The data was compiled for, and is being reported to, local stakeholders and policy makers to improve management and conservation of our rivers.

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.

Bakkavör Alresford Salads Impacting Upper Itchen

Sewage and pesticides from a salad washing factory owned by Bakkavör Group Plc may present a serious threat to aquatic invertebrate life on a highly protected English chalkstream.

 The Environment Agency’s response to a formal notification of environmental damage made by S&TC in June 2018, pursuant to the Environmental Liability Directive, confirms the wild fish conservation charity’s fears: discharges from Bakkavör’s site at Alresford are threatening the fragile Upper Itchen and Alresford Pond.

Bakkavör is a leading supplier of fresh food and salads to UK supermarkets.

The EA’s wide-ranging investigation was prompted by the results of S&TC’s invertebrate sampling at a site immediately downstream of Bakkavör’s outflows.

A copy of the sampling report (produced by Aquascience Consultancy Ltd) is available here:

The threat from these activities was highlighted by Joe Crowley on the BBC’s Countryfile Chalkstream Special.

The EA investigation firstly exposed a failing in the factory’s own sewage works. The sewage is now being tankered away and S&TC says discharges should not restart. The headwaters of a chalkstream is not the right place to dump sewage.

The EA investigations also exposed a potential pesticide threat. The EA has not been able to rule out damage caused by traces of pesticides present on the salad leaves used by Bakkavör and which are being subsequently washed into the Upper Itchen. The EA is now undertaking more monitoring work. S&TC will follow the results of this work closely.

The S&TC notification has highlighted a wider national issue, that of the EA being unable to look at the impact on wildlife from chronic, low level and cumulative exposure to combinations of different pesticides.  This is directly relevant, not just to salad washing but to agriculture in general. S&TC will continue to raise its scientific evidence at the highest levels within UK Government and the European Commission to influence the changes required to provide our chalkstreams and all rivers with proper protection.

The EA also recognised specific damage to Alresford Pond from nitrates, which now requires remediation plans to be drawn up, as well as a severe sediment issue in the pond that threatens its long-term value to wildlife. Alresford Pond is a Site of Special Scientific Interest.

Nick Measham, S&TC’s Deputy CEO comments:

“The EA’s response to S&TC’s species-level monitoring shows the necessity to go beyond the technical confines of the Water Framework Directive to tackle the worrying declines in aquatic invertebrate life in the Upper Itchen. The EA’s “family-level measure” shows invertebrates to be fine at its chosen sample point well downstream of the factory, but our sample point, and the EA’s own work at Alresford, indicate real threats. The only sensible way to protect the river is for Bakkavör to be required to put the water it uses back into the river at the same quality at which it abstracts. If it can’t do that, it must cease discharging altogether.”

S&TC is delighted that the EA has persuaded Bakkavör Group Plc to consider its whole operation at Alresford to protect the Itchen. S&TC’s fierce lobbying has already stopped the company using chlorinated chemicals in its overnight wash.

S&TC is happy to work with Bakkavör Group Plc if its management begins to show a genuine willingness to undertake efforts to remedy the impacts of its operations and contribute towards restoration efforts, but S&TC will pursue the company relentlessly if it does not fulfill its obligations to protect the Upper Itchen in the future.

Dr. Janina Gray, S&TC’s Head of Science & Environmental Policy added:

“The EA cannot continue to put chemicals, especially pesticides, in the too difficult to deal with box. The Upper Itchen highlights urgent action is required to monitor and regulate the synergistic and/or additive effects of chemicals. This cocktail of chemicals is having an environmental impact now and can no longer be ignored. S&TC see the formal notification to the EA as a first step in better understanding the pressures impacting the Upper Itchen, now we will be seeking action to address these. Business as usual is no longer an option.”


Issued by Corin Smith (07463 576892) on behalf of Salmon and Trout Conservation. For more information please contact and on 01425 652461


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.