Paul – a vicar and environmentalist – read my blog about Defra’s shelving of the chalk stream recovery pack and wrote to tell me of his own frustrations with officialdom. I offered him a guest blog. His story is fascinating and concerning. CRW.
I’ve been leading a team researching the persistent industrial chemical pollution of U.K. watercourses for the last five years. Our research was the basis of the recent ten part Radio 4 series Buried: The Last Witness.
Now that the ongoing neurotoxic PCB problem in U.K. watercourses and wildlife is garnering attention again (what a UN Environment Programme factsheet called a conveniently “forgotten legacy”) I’d like to explain how this ongoing watercourse pollution has been allowed by government to happen.
The identification of contaminated land under Environmental Protection Act 1990 Part 2A has been radically undermined by its own statutory guidance. The Act itself is admirable. That makes it all the more surprising that two of its key clauses were rescinded in 1995 during Lord Deben’s tenure as Environment Secretary, after a sustained industry lobbying operation during Lord Howard’s tenure. How that was done was chronicled in the Journal of Environmental Law at the time by the chair of the Environment Select Committee, Sir Hugh Rossi:
Implementation of the Act was delayed for ten years from 1990 until 2000 and the statutory guidance was written strangely in several aspects.
1. Most obviously and damagingly divergent from the original Act, it excludes as receptors (SG 3.8b) of pollution all watercourse lengths that do not come within a highly restrictive designation:
This means the majority of river lengths in the UK which do not come within this tight Table 1 definition may be polluted by industrial neurotoxic chemical leachate to an infinite extent: they are excluded from recognition within the Act as a receptor of that pollution.
Thus over half of the U.K. rivers by length and most of the downstream lengths of most of our major rivers are excluded from the primary legislative protection of the environment from chemical pollution.
2. The guidance states that Councils should “give priority to particular areas of land that it considers most likely to pose the greatest risk to human health or the environment”.
Sadly, especially in Wales, that last word “environment” gets systematically deprioritised in the detail of the guidance and its implementation. The preamble to the guidance sets a subtly chilling tone. Multiple councils in England and Wales, after reading the guidance, instruct their favoured consultants in such a way that only human risk gets reported on, fully in contrast to the Act’s comprehension of human AND environmental harm potential.
A consultancy report written by Helsby-headquartered RSK for the local Council was used tacitly to determine that a leaching neurotoxic chemical waste dump is not contaminated land within EPA Part 2A. There is no written record in 2009 that Cheshire West Council or its predecessor even made a determination decision after the helpful consultancy report was received. This 2024 Cheshire West and Chester Borough Council.Council PR summary retrospectively summarises:
“In 2009, we concluded that, based on the assessments undertaken, the tip did not meet the definition of Contaminated Land and investigations were drawn to a close”
It’s seems to me a national scandal kept in place by a surprisingly wide-ranging official code of silence. A housing estate is currently being built over a PCB-contaminated factory site with extremely high readings at nearby Helsby, without purchasers even being made aware.
A variety of Councils use strategies to keep the false negatives in place.
3. Wrexham council claimed that it has an infinite timescale to even reach a decision, ie to comply with the law (see SG 2.9);
5. NRW has had Caerphilly council area data on file since 1994 showing that wildlife in the river Sirhowy is contaminated with elevated PCB levels. Yet bizarrely it didn’t even share that data with Caerphilly council until my team resurfaced the data via an FoI and intervened. As toxicdocs.org discloses, it seems as if a payment was made by Monsanto to the predecessor Council. We can’t know for sure because many details of NRW’s formal agreement with Monsanto are hidden under lengthy redactions.
NRW still claim there’s no wildlife or sediment PCB for the entire river Usk including where it runs past the site of the biggest PCB factory in Europe – do you believe that absence of data? O is it FOFO – fear of finding out?
6. Another way the statutory guidance undermines the Act is in defining what environmental damage qualifies as damage. Unless the pollutant is increasing the contamination doesn’t officially exist (SG 4.38b “sustained upward trend”). So a plateaued high chemical leachate flow would not qualify within the wording of this statutory guidance section, however damaging to invertebrates or fish the leachate may be. Thankfully Councils seem so embarrassed by this drafting error which misrepresents the Act wording that they tend simply not to follow it. It’s no wonder the Law Commission concludes in report:
“The first issue is at the very least a policy reform issue, which may involve elements of law reform (including a role for the Law Commission).”
– Henni Ouahes, Head of Public Law, 12/4/24
7. Additionally, the main EA method for testing for the mainly insoluble heavy congeners of indicator neurotoxin PCB is midwater, not testing in the sediment where PCB adsorbs into the vegetative silt. Dangling a test tube off Cefn Mawr bridge every week won’t tell whether the PCB used at the factory there (Monsanto’s European PCB research headquarters) has leached underground and into the river Dee:
The Environment Agency systemically using suboptimal testing protocols which potentially miss the main flow of a particular neurotoxin is surprising, especially given the reproduction disruption characteristic of PCB as it biomagnifies, known to EA chief scientist Gideon Henderson. I’ve emailed Gideon and EA Senior Chemicals Adviser Richard Hawkins about it several times without acknowledgment.
Using a type of testing which intrinsically misses the main benthic zone presence of this immunosuppressant contaminant greatly helps underestimate the scale of the UK national contamination problem. Regulatory toleration of UK POP pollution is perplexing. It’s all so different in America …
Here the EA, NRW, MMO and Cefas all appear to tolerate the pollution. My team may soon be testing whether this is legal, supported by a kind new philanthropist. But I’d prefer it if our legislators faced into the problem and sorted it themselves. Why have politicians issued this ongoing distorted mandatory ‘guidance’ – a passport to ongoing river pollution? Will our Lords Deben, Howard, Young and Mills and senior civil servants dare to now fess up for the public good and move to helping civil society to solve the problem they’ve allowed?
The EA now claim in a new information release refusal this month not to have the key American court action document, Appendix B listing sites where the main polluter should be held liable, despite Baroness Young having written to assure The Ecologist magazine in 2007 that the EA had an official plan.
This whole narrative – especially the failings in the statutory guidance – has significant practical impacts for the ecological health of us, and for the wildlife of iconic rivers like the Severn, Dee, Tees, Thames, Mersey, Usk, Taf, Ely, Sirhowy.
It’s brilliant that the Environment Agency has, through the national framework, identified the flow deficits that exist on our chalk streams.
It’s great that Environment Agency has signalled to the national framework groups that chalk streams should become a priority in terms of addressing those deficits.
Thus far, however, the Environment Agency has inclined to stand back – at least publicly – from guiding the decision-making that will be needed to apportion those abstraction reductions strategically and cost-effectively over time. This is being left to regional groups and partnerships, but it is not yet clear how these decisions will actually be made or if they will be consistent and logical.
Our CaBA chalk stream strategy called for the collaborative development of a prioritisation process and while everyone agrees the need, it still hasn’t quite happened.
In all of the meetings I have ever attended in which abstraction reduction is discussed the idea is aired that we will need evidence to justify and ensure wise decision-making, including evidence that ecological gains will follow mooted abstraction reductions.
On the face of it, the call for evidence seems only prudent and sensible – after all public money is at stake.
But the idea that such evidence could ever exist is a chimera.
Clear cause-and-effect evidence according to a robust, before / after / control / impact method of proof, is – I argue – impossible to acquire. And it is so, precisely because of the infinitely complex web of cause and effect that is leant upon to justify the call for evidence.
Water companies will argue, and rightly, that reducing abstraction is expensive and, therefore, that there’s no point doing it if no benefit follows. Or if the potential benefit is neutered by some other factor such as a heavily modified river channel, or pollution from farms. In certain settings we run a real danger of spending millions reducing abstraction, when other factors – like the fact that the river is navigable and impounded by locks and weirs – are as big or even a bigger brake on the ecological health of the system from which there is no possible relief.
There are also settings where the cost of reducing (some of) the abstraction could be more cost-effectively spent (in terms of ecological gain per buck) improving the physical habitat. We have transformed canal-like channels in Norfolk into vibrant, wild and free-flowing streams for modest amounts of money, all things considered. £200,000 per km is dwarfed by the £4 million cost of replacing 1Ml/d of water. For that you could rebuild 20 km of knackered chalk stream.
I’m all for the intelligent and undogmatic trade-offs and counter-intuitive thinking that will be needed if we really are to balance the needs of society and nature.
But the call for evidence is self-deluding at best and a delaying tactic at worst.
Why?
In the insanely busy and pressured landscapes we are talking about it is virtually impossible to strip out the variables: the physical condition of the channel; the micro and macro stressors of water quality which are highly complex and some of which we barely understand; shifts in the global agricultural markets which might generate or ease an agricultural pressure beyond one’s control or easy quantification; road run-off which might be terrible in a year when a local farmer is rearing pigs, or not too bad when the farmer gets rid of the pigs or in a mild, dry winter; the weather; the climate; the impact of invasive species like signal crayfish, or predation from cormorants when a cold winter forces them off the reservoirs: etc. etc. etc.
I defy anyone to design an experiment into the teeth of those variables, that could possibly isolate the beneficial or non-beneficial impacts over time of one single action.
The only way you could construct such an experiment would be to select a stream where abstraction is pretty much the only pressure and a significant one, gather baseline data for at least five years, ideally a decade and then COMPLETELY TURN OFF THE ABSTRACTION in that stream and all nearby streams (because you need the signal to be significant to rise above the variables you can’t eliminate no matter how hard you try) and study for another five to ten years. The study periods would have to either equally include or exclude periods of drought and very wet years too.
When helping to write Defra’s now scandalously abandoned chalk stream recovery pack, I was looking for exemplar case studies of where abstraction reduction had made a significant and demonstrable beneficial impact to ecology. I struggled to find a slam-dunk example, mostly because the reductions that have been made – though significant – have been made from very high totals and are actually quite small against the volumes still abstracted. For example, on the River Ver, while abstraction once exceeded 50% of recharge, it is still 30% of recharge.
This reach of the River Piddle used to dry regularly in the late 1980s early 1990s.
I cited the River Piddle in the end, even though the changes made there since the dark days of the late 20thC when the river dried up regularly, include flow augmentation as much as abstraction reduction. The Piddle, however, is indeed much better now than in 1989 – 93. I know because I’m lucky enough to co-own the bit that used to dry up and it is now an exemplar of chalk stream health. It is an example.
But even so, water companies and others will often say abstraction reductions made thus far haven’t yielded the hoped-for results. Either in terms of flow or clear ecological gains.
In terms of flows, this is not true. John Lawson’s analysis of the flow-recovery following abstraction reductions shows unarguably that flows do recover in proportion to abstraction reduction. But when the abstraction is really high and you only reduce it a bit … hmmm.
John’s report also shows that the reductions made, though significant and expensive in water resource terms, have been far too small relative to the size of the overall catchment abstraction and far too small to rise above the “noise” made by all the other variables (and many of these variables haven’t been attended to properly, either. We still have a lot to learn about high-quality and cost-effective process-based habitat restoration).
In the only really good long-term BACI type flow scenario that exists, flows on the River Ver reduced and then recovered exactly in sync with the abstraction increase and then reduction. Of course they did: where else would the water have gone to?
So, if slam-dunk cause and effect evidence that reducing abstraction Y will lead to X ecological recovery doesn’t exist and can’t be found, how do we approach the problem?
Without knocking the idea that data and evidence are useful tools to guide our decision-making, we should not abdicate our own common sense. In the same way that we don’t need science to tell us that it’s warmer in summer (though we need science it to tell us why) we don’t need science to tell us that abstraction adversely impacts the ecology of a river (though we do need it to tell us why).
Many fine minds have spent a lot of time discussing and agreeing that sustainable abstraction in chalk streams should generally cause less than a 10% reduction in natural low flows, (which also, give or take, amounts to 10% or less of the average aquifer recharge). That is why we have the Environment Agency’s Environmental Flow Indicator, which is based on the UK Technical Advisory Groups deliberations on exactly this flow / ecology balancing act.
What we need beyond this work (that has already been done!) is not so much more impossible-to-find evidence but rather a screening process that aids and brings logic, common sense and consistency to the thorny issue of how to spend public money most cost-effectively in our collective goal of achieving sustainable abstraction on chalk streams.
To give a really obvious example: we need a screening process that stops us spending billions of pounds reducing abstraction in a river that is navigable and therefore doesn’t really have a flow-dependent ecology, but compels us to crack on with spending millions of pounds reducing abstraction in iconic chalk streams which can also be physically restored for 200k per km!
As far as I have been told Defra has abandoned publication of the promised chalk stream recovery pack. A great shame for beleaguered chalk streams like the Ivel (above), the Lea, the Ver, the Darent, the Misbourne, the Cam, the Granta and dozens of other globally unique but over-abstracted and polluted rivers. Is the door open for a change of mind? I truly hope so.
That dogged river warrior Feargal Sharkey – who will no doubt be leading the river of people through London this weekend – repeatedly asked the last government after the fate of the chalk stream recovery pack that had been promised by then Minister Rebecca Pow.
Twenty-one times he asked on Twitter what had happened to the document – Defra’s response to the recommendations in the CaBA chalk stream strategy – that the minister had said on the 15th June 2023 would be published by the end of that year.
It wasn’t. (Not the minister’s fault, btw … see below)
But since the general election Feargal has stopped asking. Which is a great shame, because his tireless needling does resonate in government. And the pack is worth publishing.
I have to admit, it used to bother me that he once asked so often, because elsewhere Feargal has written that the CaBA chalk stream work is a waste of time. I felt it was a taunt, much that I also wanted him to keep chasing. I don’t agree with him. Our chalk stream work is not a waste of time. But here was Defra proving him at least partly right, and utterly failing to fulfil a promise.
Feargal’s tweets and the lack of anything material suggested that the pack was a total fiction.
But I knew it wasn’t a fiction … because I was helping Defra to write it.
And by December, the date by which it had been promised, it was all but ready to rock. Feargal kept on asking and I kept on waiting for Defra to prove him wrong and publish the damn thing. But the promised chalk stream recovery pack has gone round and round in circles ever since, every component repeatedly sliding back to the bottom of the negotiation tree as staff are cycled from one place to the next.
Following months of groundhog day delays, it has now been shelved. Defra told me there is now “no mandate”.
I suspect their reluctance to publish might partly be because myself and the brilliant Ali Morse – water policy director at the Wildlife Trust and vice-chair of the CaBA chalk stream group – worked so hard to make the pack amount to something: we were nettlesome and pushy, for sure. But I like to think always in a positive way.
There may also, of course, be an element of the new administration wanting no part of the old: after all the pack was promised by the Conservative minister Rebecca Pow. But I prefer to think not.
Anticipating a Labour victory in an upcoming election I went to see the Cambridge Labour MP Daniel Zeichner in December ’23, when the chalk stream recovery pack was all but ready, but was failing to find a publishing runway or clearance from the Defra conning tower.
I must have had some notion that Defra officials might filibuster the thing for as long as they could. I had met Daniel at a chalk stream conference in Cambridge and I had a hunch that he would be an important figure in a new administration. I wanted to emphasise how important it was that our collective approach to chalk stream conservation should transcend party politics if we were to stand any chance of making progress.
Nothing he said made me doubt his commitment to that truth. Apart from anything else, he knew Feargal would hold them to account. I hoped, even believed, that a Labour government would be as supportive of our work to improve chalk streams as the Conservatives had been.
And much as it runs against the grain of the popular view, some Conservatives politicians, certainly Rebecca Pow, and the likes of Sir Charles Walker and Sir Oliver Heald (all gone from Parliament) were very supportive. As were MPs in other parties, of course: Sarah Green MP, for example. And members of the House of Lords, notably Viscount Trenchard and all those who spoke in favour of including chalk streams in the Levelling up and Regeneration Act. Chalk streams have cross-party support.
The delay in publishing the chalk stream recovery pack actually had nothing to do with the Minister, Rebecca Pow. She was committed and passionate about making a difference, and appeared as frustrated as I was at the procrastination. My reading is that Defra was focussed on one thing: ending the media onslaught about raw sewage discharges. And their policy-making – in spite of good words about chalk streams in the Plan for Water – appeared to be focussed on this single BIG issue.
If my hunch is true then, ironically, the ferocity of the raw sewage campaign was undermining the possibility of progress in all the other areas where rivers are equally, if not more pressured. The raw sewage scandal gets easy media attention and of course that is what government then responds to.
Techie, nerdy stuff like perfectly legal discharges of phosphorus, which arguably do more damage in many vulnerable, headwater settings, are then ignored.
But we should not ignore the full range of ills that beset our streams.
Our chalk stream restoration strategy and Defra’s unpublished chalk stream recovery pack, were based on the interconnectedness of pressures on rivers. It’s so important to build this understanding into advocacy and ultimately into policy, because otherwise you get skewed action or unchallenged inaction and you waste money.
For example, the impact of sewage and other components of poor water quality are inextricably bound up with abstraction and the quality of the physical state of the river. In the case of abstraction, most obviously because abstraction reduces flows and thus drives up the concentration of nasties in the water. As well as water temperature which turbo-charges the activity of those nasties.
More subtly these pressures are bound up because in many places (especially headwaters of chalk streams like the Lea and Lark) we abstract so much that our river flows become – in summer – entirely supported by sewage discharges!
Alternative abstraction and water treatment arrangements could feasibly and cost-effectively provide the same amount of water to public supply and allow naturalised flows which would immeasurably improve water quality.
But this will only ever be possible if people think around the policies in a three-dimensional way and do not get swayed by single-issue protest into chasing half-baked policy responses.
As Ali and I tried in vain to persuade Defra to create a policy and economic driver that would address phosphorus impacts from small works in upper catchments we were told that what would be happening (instead?) is legislation to enforce the highest technical standards on designated rivers. In other words, only the places that were already good would get any better.
Now the new government appears to have ditched the troublingly joined-up chalk stream recovery pack and vowed to jail water company bosses who break the law, a populist policy, but not necessarily an effective one.
Steve Reed has announced a review of the water industry but the terms of reference do not look auspicious. There’s no sign of the nationalisation that some so hope for, but instead talk of ‘trade-offs balancing affordability with service and clean water’: which is exactly what we’ve had since forever. Only, without the clean water.
The environment always picks up the bill.
So, we have “a march clean water” but we should also march for “more water” and “better habitat”.
In the time I have dealt with Defra over a chalk stream strategy instigated by Defra – or at least their minister – I must have interfaced with at least half-a-dozen individuals who were handed the chalk stream brief. They have all been very bright, committed and well intentioned. They have all learned quickly about the pressures and the whys and wherefores of the policy recommendations in the CaBA strategy. Then just as they are getting their feet under the desk, they have been moved on and another fresh face has appeared on the Teams screen. This makes progress quite challenging.
The last new face I met had been shoved to the fore to tell us the recovery pack had been shelved, but that instead the government would focus on chalk streams in national parks and areas of outstanding natural beauty. In other words, as far as I could tell the new Labour government wanted to double down on the concept of privileging the privileged and abandon the chalk streams whose condition is most abject, in the suburbs and orbit of London, in the intensely farmed landscapes of East Anglia, and in ordinary towns like Dover, Driffield, Bridlington, Dorchester, Luton, Fakenham, King’s Lynn, Bury St Edmunds, which are the focus of so much concern.
I hope everyone who reads this will think that is as misdirected as I do.
Knowing that I wasn’t speaking to the general and was therefore wasting my breath, I nevertheless pointed out that a central plank of the chalk stream strategy, signed up to by all parties, including the Environment Agency, Natural England, Defra and Ofwat and the water industry, was the urgent need for the protection of ALL chalk streams to match those few already well protected.
The abandoned but oven-ready recovery pack addressed that protection through a range of commitments including time-bound goals for abstraction and phosphorus reduction bringing all chalk streams to good or high status by certain key dates. It also included undertakings to consider chalk streams irreplaceable habitats in planning law, to consider better practical measures to reduce run-off in improved farming rules for water, to include special consideration for chalk streams in national highways and local road network technical guidance, and in restrictions relating to septic tanks.
Okay, so over time much of it became watered down by undertakings to review rather than to act. Frustrating but that’s the way these things work. And as statements of intent and clear support from government, it was still very much worthwhile.
Besides, when the pack wasn’t published before the election this became a golden opportunity for a new government, committed to the restoration of our rivers – as this one claims to be – to inject a bit more oomph and send it to the printers.
I haven’t entirely given up hope however, because as I say, I’m not entirely convinced this decision – in as much as it is a decision, as opposed a slow and relatively silent abandonment – comes from the new government so much as the permanent department. In a recent debate on chalk streams Minister Emma Hardy was asked by Sarah Green MP when Defra would publish the chalk stream recovery pack. The minister didn’t entirely sound as if she’d been briefed about it.
If only the minister had known it was ready to go, is a total no-brainer, could be made more impactful in a jiffy and would go down very well with all those people marching through London on Sunday.
I’m pleased to say that I heard yesterday from Paul Jennings – chair of the River Chess Association – that the Environment Agency had contacted him to say they will not go ahead with the resumption of the Alma Road abstraction: not for now anyway (see previous post).
Paul’s official statement reads: “The Environment Agency has announced that work on the resumption of abstraction at Alma Road, Chesham has been halted. Affinity Water has been asked to stop work. The Chiltern Society, River Chess Association and Chiltern Chalk Stream have been told that the EA want to engage with local stakeholders to present their evidence. The River Chess Association feels there will be little data to support the resumption of abstraction. It believes the focus should be on tangible flood risk identified by volunteers over the past 5 years not theoretical models.”
Respect to the EA for being gracious enough to listen to the public unease at their poorly explained and apparently not well justified plans, to act quickly and halt their work.
We’ll see now the real case for the proposal, but as I suggested in the previous blog post, manipulating groundwater levels to mitigate fluvial flooding is a very convoluted approach and unlikely to work, in my view. Fluvial flooding is all about channel conveyance capacity. The best way to use a chalk aquifer to mitigate flooding would be to address run-off in the upper catchment and make changes to ditches, drainage and land-management (encourage zero till, for example) so as to increase aquifer recharge rates and slow in-channel flow rates. The aquifer itself will then act as a buffer. Do that in combination with easing conveyance pinch-points in the channel, of which there will be many in a town like Chesham.
I also questioned whether repurposing a public utility groundwater abstraction licence towards so-called flood mitigation could possibly be within the conditions of the licence.
And finally I asked if deliberately increasing one form of environmental damage – abstraction – to off set another – flooding – might be in breach of water framework directive rules.
I hope all these issues are addressed when the EA engages with stakeholders.
Why, oh why has the Environment Agency asked Affinity Water to turn abstraction pumps back on in the River Chess catchment?
In the late 20-teens John Lawson came to me with a great idea that could end over-abstraction in many chalk streams, especially those near London. He explained how in the next ten years or so Affinity Water would be building a pipeline to connect their southern region (south of the Thames) where they have more than enough water, with their northern, where they do not. This pipeline, said John, would enable the wholesale reduction of groundwater abstraction in the chalk stream tributaries of the Colne: iconic streams like the Ver and Chess that have been far too heavily abstracted for over half-a-century. And maybe the chalk streams of the Lea too.
If you turn the groundwater pumps off, a lot of the water you “leave in the ground” so to speak, comes back as flow in the stream. With a pipeline you could abstract the water at the lower end of the catchment instead, store it in reservoirs (of which there are several in the London area) and take the water back to the places it came from, to be used as public water supply. The difference being that this way, the rivers actually get to flow. We called John’s brilliantly simple idea “Chalk Streams First” because it gives the river first use of its water. With the support of a coalition of eNGOs we started trying to interest the water companies, the Environment Agency and Ofwat-Rapid (Regulators Alliance for Progressing Infrastructure Development).
Rapid was interested from the start. Paul Hickey, who directs Rapid, is passionate about ensuring we actually deliver on our environmental ambition. The Environment Agency was interested too. Even Affinity Water took to the idea, especially once the Environment Agency indicated that it might allow some variations on the theme and flexibility with licence relocation favoured by Affinity’s very clever technical guru, Doug Hunt.
The introduction of the Grand Union Canal transfer scheme promised to underwrite any losses to public supply (ie. disparity between what you no longer abstract at the top end and what you get back at the lower end of the streams) and thus Affinity Water started to build abstraction relocation into their business plan. They will address the Colne chalk streams to start with, but in due course all the chalk streams of the Lea could also be included. The first shots, the prequel shots in fact, were fired in 2020 when Affinity Water voluntarily shut down their Alma Road abstraction on the River Chess.
Through these same years the CaBA chalk stream strategy has gained momentum, with support from Defra, the water industry and all stakeholders. The Colne version of Chalk Streams First promised to become a national flagship for how to realign abstraction, put the environment first, but still take account of public supply. Literally everyone liked the idea. Who in their right mind wouldn’t?
So why, in the name of all that is Holy, has the Environment Agency asked Affinity Water to resume abstracting from Alma Road at a rate of up to 7 million litres per day, without much in the way of explanation (at first) or consultation (thus far)? The decision itself seems bizarre. The way it has been handled given how the plight of our chalk streams has touched the national consciousness and has been debated in Parliament, is clumsy, to put it politely.
In the interests of fairness, I ought to say that the Environment Agency has now explained that this request was made of Affinity Water in order to conduct a five-year modelling exercise to study the relationship between abstraction, groundwater levels and fluvial flood risk in the Chess catchment. Note the words I have placed in italics.
The River Chess has historically suffered from excessive abstraction which has reduced flows in the river and sometimes caused it to dry up altogether in its upper reaches. As with other Chilterns streams groundwater abstraction climbed massively through the 20th century, in the Chess from a minimal 2.5 Ml/d in the 1920s to a peak of over 20 Ml/d between 2008 and 2018, almost 38% of the average aquifer recharge, placing it amongst the highest impacted chalk streams in the country (in the more impacted, such as the Ivel and Darent, abstraction exceeds 50% of recharge).
The cessation of the Chartridge and Alma Road abstractions has reduced the overall catchment abstraction to more like 25% of aquifer recharge: still far too high, but enough to show noticeable benefits.
The River Chess Association report that otters, water voles, brown trout, water crowfoot, mayfly and rare invertebrates such as the winterbourne stonefly have all returned to Chesham. In fact nothing monitors improving river health more effectively than invertebrates. The Association has been recording river-dwelling invertebrates in Chesham since 2009. In recent years species previously unseen in Chesham have been recorded, including mayfly (Ephemera Danica), caseless caddis (Rhyacophilidae ), turkey brown (Paraleptophlebia submarginata), and the nationally rare winterbourne stonefly (Nemoura lacustris).
Personally, I remember taking photographs in Chesham of a dry river in May 2017 and of a flowing river full of ranunculus in August 2022. The Chess stood for hope.
The River Chess a mere puddle in 2017The same reach in 2022
So why toss that all away? The stated explanation seems feeble. When asked by the River Chess Association what reasoning and data were behind the decision, the Environment Agency replied:
“The Environment Agency used their current understanding of the relationship between groundwater abstractions, groundwater levels, and river flows in the Chess catchment. This included information from two reports … which concluded that there is a relationship between groundwater abstraction and river flows. Based on the conclusions from both reports, a potential increase in fluvial flood risk [arising from a reduction of abstraction – my clarification not EAs] could not be ruled out. Implementing temporary adaptive abstraction, as set out in the operating agreement, minimises the potential impacts of abstraction reductions on fluvial flood risk until these impacts are better understood and managed.”
This states the obvious – that there is a relationship between abstraction, groundwater levels and flows – and presents it as an explanation. Of course there is a relationship! That’s why we want the abstraction to be reduced, to increase flows in the river and thus river health. In as much as it is an explanation it seems to be saying that the resumption of abstraction will be used to assess if abstraction can be used to reduce flows in the river, and via this reduce the risk of flooding.
Taken at face value this is very strange reasoning. The idea appears to be to use abstraction to reduce flows in the river. Despite what the EA state about adaptive abstraction* in the operating agreement I wonder a) if repurposing an abstraction licence from its use for public water supply to a different use of so-called flood-risk mitigation is within the remit of the licence and b) whether it is entirely legal under WFD legislation to deliberately reduce the flows in the river in order to theoretically reduce flood risk.
(*adaptive abstraction essentially comprises the variation of pumping rates across time, but I’ve only ever heard of the idea as a means to reduce ecological damage, which is the unfortunate by-product of the public water use, the reason why the licence exists. The EA’s idea here is actually putting the abstraction to a entirely different use than intended by the existing licence)
But these queries aside, this plan is not even a good way to reduce fluvial flood risk. Of course flooding is related to flows (and flows to groundwater levels), but in a chalk stream fluvial flooding is much more likely to be influenced by things such as impoundments, culverts, drainage, ditching and land use in the upper catchment. The EA would be far, far better off looking at these issues in order to mitigate fluvial flooding.
And that aside, using groundwater abstraction as a temporary measure to reduce fluvial flooding is like blowing the other way in order to slow down a tanker. The impact of groundwater abstraction accumulates over time and its impact on flows is geared via its impact on groundwater levels. By the time you realise you might have to reduce groundwater levels to reduce flows it is too late. You could only reasonably make this idea work if you run the abstraction all the time and reduce flows all the time, which is exactly what groundwater abstraction does.
Besides, where are they going to put all the water? Pump it downstream?
To me this feels like a nonsense explanation.
As anyone with a Twitter account knows, the sewage works at Chesham spills groundwater ingress sewage all the time when groundwater levels are high. In other words the groundwater spills through cracks in the pipes and overwhelms the sewage works. It is almost certain that the increase in groundwater levels that has followed the reduction in abstraction has increased the groundwater sewage spills (that and some very wet winters).
Is this really about modelling something we know all about already (the relationship between abstraction, groundwater levels and flows, which it is perfectly possible to accurately model), or is it a designed to see if the groundwater ingress flooding can be reduced by resuming abstraction?
You decide. Maybe I’m being too cynical. But if my suspicions are correct the EA would be trying to play tunes on the theme of ecological damage, resuming one form of damage to reduce another and I’m not sure that’s such a great idea. Or maybe Defra is exploring ways to meet its own stormwater reduction plan targets for chalk streams? These pesky groundwater ingress discharges are going to be a hard nut to crack.
If the issue really is fluvial flooding, where is the risk occurring exactly? And why not consult the Chess Association, and the Chilterns Society / chalk streams project to explore how the flood risk could be addressed without pumping all the groundwater away? I will be happy to publish any reply or further explanation from the EA.
The impact of sewage on nature and wildlife and what we do about it are now casualties in an ideological and political war. Our rivers will suffer.
The release a few weeks ago by the Environment Agency of the total duration (in hours) of raw sewage spills in 2023 signalled the highest total ever recorded.
These were the headlines.
“Spills of raw sewage into England’s rivers and seas reached their worst on record last year.” Sky news.
“Water companies in England face outrage over record sewage discharges.” The Guardian.
“Raw sewage discharges in England and Wales hit record.” The Financial Times.
“Sewage spills in England double to record level.” The Times.
To be clear, before 2017 only 6% of licensed spill sites were monitored and virtually no one was paying any attention. So, we really have no idea. These headlines all imply it was the worst year ever for sewage discharges into rivers. They do that because it makes a better headline. And maybe because the authors think it’s true.
But to anyone who knows their history 2023 can’t have been a record year for the amount of raw sewage put into the water environment. We didn’t even treat sewage until the late 19th century. Bazelgette’s combined sewage system was commissioned after the Great Stink of 1858. The population might have been half what it is today, but in any town, city or village with a river or stream, it was ALL raw sewage before that. Latrines were built over rivers. Shit from buckets and night boxes was thrown into rivers. Streets, yards and gutters were washed into rivers. And as a result the poor, who tended to be housed on the low-lying “miasmic” land near rivers were all generally ill from what was called “low fever”, a form of chronic cholera. Thousands died from it and from dysentery every year.
The actual 2023 record, if there is one, relates to how extensive the monitoring now is, and also – if it could be measured – to how much people now care about what that monitoring tells us. Both of these are at an all time high and a very good thing too. Provided we respond with sensible policies that actually address the problem.
In attempting to contextualise the alarming figures, the EA was lambasted by some campaigners as playing “lacky” and being an “apologist” for the water industry (see Emma Gatten, Telegraph 27th March 2024). Helen Wakeham drew criticism for highlighting that although the figures set apparent records, 2023 was also the first year we had achieved 100% monitoring and the 6th wettest year since 1836.
That doesn’t make her an apologist. Helen Wakeham said that the figures were disappointing but not surprising. Both obviously true. The information is relevant because it puts the spills into perspective and perspective is important if you want to actually fix the problem. 3 million hours of raw sewage spills from 14000 overflows is awful. We all know that.
But I doubt it’s the worst we have ever experienced. The actual record years most likely went unrecorded and unnoticed. They were only ‘experienced’ as such, by wildlife.
I have some insight into this because I worked with Dr. Rose O’Neill and Kathy Hughes to flag the crisis in WWF’s 2017 report Flushed Away, when very few were paying any attention. Sewage in rivers wasn’t an issue in the public consciousness. But it was definitely an issue in rivers.
Figure 1. shows the coverage of storm overflow monitoring each year since 2016, when only 6% of storm overflows were monitored. The graph on the right shows the total hours of recorded spills since 2016. Before 2016 we know the data is scant and not generally representative. When Dr O’Neill put in an FOI request to water companies to help with the WWF report she got very little information back, not least because there was very little information. What we did get back suggested is was already a big problem.
The response to that report from Water UK pushed back against some of the findings – time has shown WWF had a strong case – but did reference the £billions the industry had invested since 1990, highlighting that sewage discharges (legal ones at least) had been of a generally lower standard through most of the 20th century. We know they were.
Out of context, the figures for 2023 don’t tell us a great deal, other than that we have a big problem with raw sewage discharging to rivers because the system is designed to spill when the works are overwhelmed by flow, which they are far too often. As WWF highlighted, under-capacity at the works was a problem in 2017 and had been an incipient problem for many years, because of a shortfall of investment under public and then privatised ownership.
It’s worth pausing on that word “shortfall”, because there has been investment. Far more under private ownership than state, in fact, albeit not enough under either. The shortfall has been created by two things: higher standards and higher loads. More stringent standards of water treatment, and higher expectations from the public (the latter, very recent); and increases in population, urbanisation, water consumption, the use of wet wipes and since 2020 different working patterns. To cope with all this, clearly we should have been investing more and at a faster pace. Now, we have been caught with our proverbial pants down. Just like WWF said we would be.
So, we know there was a problem and we know we weren’t measuring it. In contextualising and understanding 2023 figures therefore, surely the % coverage of monitoring (it’s the first year we’ve known the full picture) and the rainfall (the amount of rain is a major contributory factor) are at least relevant? To think so doesn’t suggest that the spills are okay. But it might help us get a more accurate picture of where we are historically – or rather a less inaccurate picture – and some inkling into whether recent investment is making any impact.
It might also help us define the true scale of the issue and think about the nuances within it and therefore set about the best strategy for actually fixing things. It’s all very well banging on about the hole in the roof. We need a plan for how to repair it correlated to articulated aims and available funds. “Woe betide the iniquities” is not a plan. “Just enforce the law” is not a plan.
The public deserves to understand that these works will carry on spilling for years to come, because you can’t just shut the system down. From the left, or right, state-owned or private, we need to fix the system strategically according to agreed priorities. I’m sure most people – once they understood the complexities and the unavoidable need to choose what comes first, second, third etc. would agree that our strategy should prioritise according to the relative severity of harm caused to the natural environment. So, why aren’t we discussing how to do this? Because, in the media and social media at least, the issue has been hi-jacked by political ideology. Some actors want 2023 to have been the worst year on record, because it suits their political allegiance and narrative. In the same way, they recite that “no river in England or Wales is at good overall status”, even though this statistic is only true if you loop in the assessment of esoteric chemicals we could not even detect until a few years ago.
In Figure 2. I have compared actual recorded hours (which until 2023 obvs only recorded a % of the overflow sites) with an estimated total hours of spill duration in earlier years, which I have calculated by taking the total recorded hours in the given year, dividing by the % coverage of monitoring, and multiplying by 100. It’s a crude guesstimation, but this might, at least, give a more comparable set of numbers.
This graph suggests that had we been able to record all the storm overflows, 2019 is more likely to have been a worse year – a lot worse – than 2023. 2020 was perhaps worse too. Given that the monitoring up to 2016 was generally confined to protected sites and therefore not widely representative, the adjusted figures for 2016 and maybe even 2017 / 2018 could be considerable underestimations of what was going on. The Flushed Away report suggested as much.
So, what about the rain? 2023 was a very wet year (God knows what 2024 figures will show). The 6th wettest in England since 1836. Not an excuse or apology, just a fact. Interestingly and worryingly, it’s only the 3rd wettest since 2000. Changes in the climate are not making us drier, as the long-term trendline in the chart above shows.
In figure 3. I have plotted the average England rainfall since 2010 against those adjusted figures for spills. There is clearly a strong correlation between rainfall and spilling hours. Of course there is. The driest year in that period, 2022, is also the year with the lowest adjusted figure for spills. In fact a 1% difference in rainfall seems to have a big gearing impact on spills. A difference of 34% in rainfall between 2022 and 2023, correlated to an increase of 54% in spills.
In these figures there are some interesting indications.
2019 was not the wettest year by a long way. And yet it seems to have the worst adjusted figure for spills, also by a long way. 2020 should have been worse, but wasn’t.
2019 through to 2022 shows a marked year on year decline in the estimated spills, which might suggest improvements. On the other hand the possible apparent “improvements” might also be explained simply by the lower rainfall through those same years.
But going on the preceding estimated figures, the final year 2023 – the year that has caused these “record spills” headlines – saw considerably fewer spills relative to rain than 2019 (albeit these figures do have to be viewed with caution).
So, it may even be that spilling relative to rain is marginally better now than in 2019 at the start of the “conscious” sewage crisis. But it also looks as if normal parameters of rainfall change make a big difference. We all know that shouldn’t be the case. Our creaking infrastructure is undoubtedly overstretched, even at the best of times.
In short, I suspect that 2023 wasn’t the worst year ever. 2019 might well have been worse. But if we could only go back in time and monitor the situation I suspect that 2012, being wetter still, might well have been even worse than that.
And then what about the 1970s. I can vividly remember the stink of the Tyne in about 1976 when I went there to visit my godparents and we stood on the high bridge over the river and wondered if any fish could live in it at all.
And what about the 1870s and the decades before?
Michael Faraday wrote to The Times in 1855 describing the River Thames: “Near the bridges the feculence rolled up in clouds … The smell was very bad, and common to the whole of the water; it was the same as that which now comes up from the gully-holes in the streets; the whole river was for the time a real sewer”.
You could call it a “real sewer” today, from time to time: I’ve been in a boat on the river when a sewer was spilling near the mouth of the Colne and it was horrendous. But I’m still alive. In 1831 cholera killed 6,536 people in London. In 1847 it killed 14,137 people. And in 1855 it killed 10,738 people.
People were metaphorically and perhaps even literally drowning in sewage. The sewage system that so frustrates us is also, in fact, a miracle. Half the increase in the longevity of people in Britain that accrued between 1850 and 1950 is directly attributable to improvements in sewage disposal and treatment.
As Hans Rosling wrote in his excellent book Factfulness, there is such a thing as “bad, better”.
That is where we are. It’s still bad. Really bad. But it is also … better. Much better. Better than it has been since probably before the 19th century.
The reason why it is important to acknowledge the complex truth – one that doesn’t fit the inclination of the media to dramatise and simplify – is because, as Rosling says, “when people wrongly believe that nothing is improving, they may conclude that nothing we have tried so far is working and lose confidence in measures that actually do work.”
Alarmist headlines that don’t tell the whole truth may lead to the evolution of radical measures that won’t work at all. Or ones that might feel good, but still won’t address the problem. Or, worst of all, to damaging unintended consequences.
Nuance is dull. It doesn’t sell papers. It doesn’t make you a folk-hero. But nuance does matter when you have limited resources, when there are many other pressures on our environment which also need to be addressed, and when we want the best overall outcome for nature.
How many people would now believe that water quality in rivers is generally getting better? Not universally, but in terms of foul sewage, this is actually the case. Is water quality in British rivers “better than at any time since the end of the Industrial Revolution”? (MJ Whelan et al) describes a mixed picture of recovery in water quality since the industrial revolution and also compared to a three-decade period 1980 to 2020. Their conclusions – summarised in the diagram below taken from their paper – broadly suggest that faecal indicator organisms downstream of urban centres are much lower now than at any time since before the industrial revolution, while pollutants from diffuse and rural pollution are likely to be higher. They also point to a reduction in industrial pollution and a rise in novel pollutants.
Ecologically, things aren’t obviously getting worse, either. Water quality – as reflected in invertebrate data – is arguably better now than it was 30 years ago, albeit improvements appear to have stalled in about 2010. The paper referenced above shows that across six invertebrate taxa with an aquatic life stage a nadir occurred in about the mid 1980s (something I have long thought just going on my own observations as a conservationist / angler: our English rivers, certainly our chalk streams, were absolutely screwed in the mid 1980s and have been steadily improving since then)
The authors of this paper: The recovery of European freshwater diversity has come a halt speculate – and I’m sure they’re right – that an increase in richness and abundance reflected improvements in water treatment in the 1990s and early 2000s. The improvements have plateaued for a number of possible reasons. Pollution from road and farm run-off may now be the greater limiting factor in many places, especially in less absorbent catchments with higher drainage densities and more surface flow pathways than chalk streams. Physical habitat may also be a limiting factor: the authors observed that physical modifications and urbanisation seemed to inhibit recovery.
But I would also hazard that improvements have plateaued because most of the upgrades in our sewage systems have been driven by urban wastewater treatment rules focussed on larger sewage works serving populations of at least 2000 or greater, while smaller descriptive works have been left behind and are still discharging – perfectly legally – sewage that is very rich in the nutrients that drive eutrophication.
These larger works that have benefitted from investment tend to be in the lower reaches of catchments where populations are higher. Meanwhile, headwater streams and the upper reaches of rivers in the countryside, places offering the greatest potential for biodiversity improvements, have received comparatively little investment.
In short, our water quality policies are already skewed by economic assessment algorithms which send investment to places where population centres are biggest, not where wildlife is most fragile, or where there is the greatest potential for gains in biodiversity and abundance. Cost-benefit calculations are based on cost per head of population instead of cost per linear length of improved watercourse, or cost relative to the ecological impact.
Now, the outrage people feel about the sewage crisis – and the way in which some organisations and individuals are focussing solely on this at the expense of paying any heed at all to other pressures – threatens to catalyse policies that double down on this utterly anthropocentric approach.
The CaBA chalk stream group has been arguing since 2021 that these cost-benefit algorithms are wrong and that we urgently need to upgrade the hundreds and thousands of small, rural sewage works that dribble nutrient rich, but legally discharged sewage, into small streams, tributaries and headwaters all day long, every day of the year.
But sadly ALL the noise is about raw sewage discharges mixed with ideological and political campaigning.
The difference in ecological impact is almost incomparable between the unsung discharges of these works into countless small streams in August and groundwater discharges into swollen rivers in February. The outraged public are being poorly served all round, not just by water companies and government.
Unless we start to articulate the complexities and interconnectedness of the pressures on our rivers we will get ham-fisted and ineffective policy responses. Steve Reid, for example, who has a great opportunity to articulate some really good policy commitments has said only that Labour will make “law-breaking water bosses personally criminally liable if they refuse to stop illegal sewage dumping”. A vote-winner of a statement no doubt, but these water company bosses don’t wake up of a morning and pull a lever marked “illegal dumping” whilst stroking a white cat. The system dumps. For sure, the system is overloaded and has been terribly neglected. And water company bosses, along with Ofwat, regulators, government and private equity all share some responsibility for that. But you can’t stop the dumping today, without stopping the system, which would involve everyone in the country popping a cork up their backsides or waddling back to the garden privy and long-drop.
What do we actually want? To send water company bosses to jail? Or cleaner rivers for wildlife and people?
If we want the latter, then sewage treatment or lack of it, needs to be put in context, assessed soberly alongside all the other pressures and subsumed into an overall plan to improve rivers.
Mike Blackmore, senior project officer with the Wessex Rivers Trust, knows what he’s talking about when it comes to river conservation. No one could question either his motivations or knowledge. Or, in fact, his bravery. Mike has dared to articulate on his Twitter / X account, that there is an urgent need to divorce the social justice and environmental action components of the debate around the sewage scandal.
I couldn’t put his case any better than to simply quote it in full. Mike says:
“We REALLY need to separate out the social justice and environmental action elements of sewage campaigning.
Yes, it’s unjust for water companies to profit from bad practice, and maybe the responsible execs/shareholders do need locking up.
But that alone WON’T FIX OUR RIVERS
As a population we have almost zero understanding of how sewage treatment works (or doesn’t).
The bits that do work are a scientific marvel, but other bits were designed to pollute, built at a time when almost nobody cared.
The problem is bigger than anyone wants to admit.
Nobody is pressing a “dump button”. These systems pollute all by themselves whenever they’re overloaded, which is sadly nearly all the time.
The causes for overloading are diverse. Some simple, some complex, some criminal, some legal, some actually caused by legislation.
Underinvestment, negligence, neglect, and dishonesty have played a major role. This culture can be changed, but the damage cannot be instantly corrected. It will take a depressingly long time and eye-watering sums of money to fix.
However, the regulation is even more broken.
Rules on how water companies invest, commission/decommission, repair etc. often prevent a lot of improvements. It’s archaic, unworkable, and opaque. Arguably this has suited some venture capitalist “investors” fine, but not WC staff who want to improve things.
Public understanding is poor, as is understanding of water quality in general. CSO spills are disgusting, but fix them all tomorrow and we still have major problems with final “treated” effluent, pharmaceuticals, household chemicals, microplastics; a plethora of pollutants.
Combined (fowl and stormwater) sewers were a terrible solution, but nobody cared back then and fixing it now means widespread infrastructure replacement. Even then, with separate systems there are millions of household misconnections sending fowl water straight to our rivers.
We need honesty and transparency regarding both the technical and legal machinery of the sewage system, and also honesty from campaigners regarding what they actually hope to achieve.
I don’t want justice for murdered rivers, I want life support installed to save them now.
There are people working hard to design and deliver solutions to make a real difference right now. To intercept rain before it reaches the network, to create nature-based treatment systems, to restore natural pollution resilience in rivers.
Campaigns rarely mention them …
Social justice is important. Environmental criminals shouldn’t get away with it.
But solutions are MORE important.
You can’t fix massive infrastructure problems just with noise.
More energy needs to go into proposing solutions.
I suppose I’m asking for clarity of purpose; unity on the actions we want to see.
Privatised or nationalised, we need more short-term action. We can’t wait for long-term change.
As well as a few comments supporting what Mike wrote, there were a few questioning his argument, most notably perhaps from the Windrush WASP account. Windrush WASP – founded in 2018 – has done tons to highlight the scandal of sewage pollution and its various causes, regulatory, financial etc. Windrush WASP commented to the effect that resolving the social justice issues “will at least make the rest worth doing – take away the motivation to pollute for profit. Those elements are entwined whether you like it or not.”
Mike replied that albeit the issues might be entwined, they are not equally important.
To which Windrush WASP replied “profit has to be taken out of pollution or the rest of it is just a series of sticking plasters on an open wound. The biggest solution is ‘simply’ end pollution, isn’t it.”
That’s a really interesting thing to say. And it’s worth quoting the exchange because here we have two people, both knowledgeable and passionate, and ultimately wanting the same thing: healthy rivers. But with apparently different ideas about the interdependence and weighting of social justice and environmental impact in the sewage debate.
My view – and the reason I find the WASP comment so pivotal – is that you can’t take the profit out of pollution, any more than you can take the profit out of profit. Pollution is profit.
By this I mean that there are rafts of human activity that have the potential to pollute: how we treat sewage, how we farm, how we manufacture things, how we move about in various modes of transport, how we pack products, what we do with that packaging, how we heat our homes, how we wash the dishes, how we clean the loo and even how we wipe our bums. The potential for pollution is collateral to all these activities all the time. And thus, in all of these areas of activity there is the potential to pollute quite carelessly or to perform the activity in some way that consciously limits the pollution or to not pollute at all. And without exception – regulation and fines notwithstanding – it is always cheaper, or less effort (which amounts to the same thing) to pollute carelessly, than to limit pollution or not pollute at all.
(In fact, there is a really good case for arguing that it isn’t actually cheaper in the long run not to pollute, if you take in a wider range of considerations such as the value of nature to mental and physical health etc. But seeing stuff at that scale is not something humans are very good at.)
Therefore, in terms of how things actually pan out that underlying, albeit short-termist and blinkered truth applies regardless of whether the potentially polluting activity is state-run or privately run.
Of course, lack of regulation, fines and an absence of genuine legal jeopardy also makes pollution profitable. Regulation through the courts is also entwined with what I set out below. I have written about it HERE: the losing battle between riparianism and utilitarianism which sets out, in my view, why the mantra “just enforce the law” hasn’t ever worked and won’t ever work.
But, let’s say we did have a state-owned water industry and in that respect at least the “profit had been taken out of pollution”. Keeping the infrastructure up to date will still cost money. Year to year, it will always be cheaper not to upgrade than to upgrade. Chancellors faced with competing calls on the public purse will likely put the alleviation of pollution of water quite far down the list, relative to the NHS, defence, the police, schools etc. In other words it would still be profitable to pollute. The financial structures and activity / asset ownerships might be subtly or significantly different, but the cost of not polluting versus the saving of costs derived from polluting will be exactly the same.
On the nationalised versus privatised debate I try to be agnostic. If a nationalised industry could be shown to bring about a transformative uplift in the health of our rivers, well great. But while I try to be agnostic, history suggests to me that relatively unaccountable state-run institutions are more impervious to criticism than private and regulated ones (albeit, we all agree regulation has been wanting). Don’t those who advocate for state-run solutions also reserve a fair chunk of their frustrations for the state-run institutions supposed to regulate this area? When the implications for reducing abstraction, say, or reducing pollution would be to increase the cost of water (as they are), I don’t think we’d get anywhere at all with a government not absolutely at the gun-point of public opinion on the matter. And like it or not, the clarity of a chalk stream in the House Counties is not something the mass of the electorate much cares about.
Whereas in reality, we are actually getting somewhere with this flawed, and iffily regulated private industry. There is plenty of good scientific evidence to show that water quality in our rivers is generally better now than in the mid-1980s. I’ll write more on that in the next post.
Whether the activity is state-owned or privately owned, if the cost to the consumer doesn’t reflect the cost of production PLUS the cost of the associated environmental protection, then of course the environment picks up the tab for that difference. That is exactly what happens all the time, with everything: whether its milk production, or water treatment. Nature picks up the bill. The public purse is protected. Pollution is rendered, essentially, profitable.
Taking a longer view at the arc of history and the dawning of environmentalism in the West, it is more or less historically inevitable that we are where we are with the environment. Still bad, but getting better. No nation on Earth, evolving through industrialisation to a point of relative affluence (in global terms) as we have, was ever going to trim the wings of that economic advancement and then recovery from two world-wars by taking extreme care not to screw the environment up on the way. State-run activity. Private activity. It makes no difference. The 1950s to 1980s saw state-funded vandalism of our rivers on a truly epic scale, through dredging, as great a brake on their ecological recovery now as water pollution. All those abstraction licences? That was the state licensing itself.
However, we are now arguably at a point in history where we can and should afford to take more care of the environment, where we can see that it might even be more cost-effective in the long term to do so. We are at the point where we need ideas for how to do that, correlated to specific, practical and evidentially reliable cause-and-effect environmental outcomes.
In short, I agree with Mike, the social justice debate should not be conflated with or overshadow the discussion about how we address the myriad of stresses affecting our rivers, many of which have nothing to do with water-company activity.
I have been neglecting my blog of late: things have been so busy working on behalf of the Rivers Trust with Defra on their long awaited (and not long now, I hope) chalk stream recovery pack. Back in the world of fixing the wild and the wet – the bit I really enjoy – chalkstreamfly has now finished and launched its film of our recent Water Environment Grant (WEG) restoration project on the River Nar. You can see the film HERE on their YouTube channel. Already there are loads of kind comments on there, which is incredibly heartening.
The film was sponsored by the Wild Trout Trust and the Norfolk Rivers Drainage Board, in the hope that it might inspire other projects along similar lines on other chalk streams. Personally, I feel we are just getting started with this type of restoration, one that looks at the whole width of the floodplain and tries to create a mosaic of habitats, not just the flowing channel of the stream, but the side channels and wet woodland and fen. The basis of the WEG grant.
One of things I really enjoyed about this project was seeing how we could repurpose the old, diverted channel, the mill leats effectively, which had been dredged and were quite homogenous. Of 2km of old channel, bypassed by the rediscovered and reinvented meanders, we only filled in the top 50m. The rest is flowing with groundwater and really seems to be enjoying life in it’s new identity as a spring-fed fen. The transformative power of process-based restoration at scale is astonishing in my view and I hope we can all start pushing the boundaries and learning from each other.
I would like to emphasise that this project was all about collaboration. The landowners were amazing. Holkham, West Acre and Narford, all thoroughly embraced what amounted to radical change. The Norfolk Rivers Drainage Board – brainlessly traduced by some campaigners in Norfolk – were fantastic project managers.
The public were great too. A path runs alongside the river here and every single person who passed was supportive, in spite of the fact that the site did look a bit raw during the delivery.
The new channel, by the way, is rammed with wild trout and the flooded woodland is bullhead soup with a side helping of very, very fat trout parr. All very nice to see.
I’m very sad to say that my good friend Richard Slocock died peacefully at home with his family on Saturday January 13th after battling with cancer for several months. For me Dorset will never be the same without him. One of my best friends and mentors is no longer there to brighten my visits with a “What-ho, Chuck!” and a natter.
I first met Richard – I can remember the day vividly – in the autumn of 1987. I had left university and was teaching Art in Dorset. My head of department, Rob, was also a fly fisherman. We soon became known as the fishing department and keen not to let our reputation falter, Rob took me one afternoon – after we’d ushered all those pesky students outside – to fish in Richard’s lakes at Tolpuddle. Heavy rain had flooded a lake Richard called the Oxbow (it was on a former bend in the river) and a few rainbow stockies had escaped. Instead of fishing the lake, Richard suggested I drag a lure through the pools of the River Piddle and see if I could recapture the escapists. I had the best afternoon ever, tempting bow-wave attacks from naive stockies in a stream I could jump over.
It was the first time I’d cast a fly on a chalk stream and though my tastes have refined over time (wild trout if at all possible!), it was Richard who planted the chalk stream seed. Over the next few years we became firm friends. I loved teaching Art, but was occasionally bored by the whole business of explaining how to mix green or looking for the scissors and so when I could, I escaped to a river and wondered how I might one day combine my passions for rivers, writing and art in what might pass for a career. Often that river was the Piddle at Richard’s place, where I would cut the ranunculus with him and then afterwards we would chat in his kitchen over a cup of tea or a lager.
Richard had himself taken a sharp turn in the road of his career. He’d studied Agriculture at Christ Church, Oxford (exactly where I went to read Fine Art fifteen years later) and started down the road of farming on land he bought with his father and brother, in Dorset. There he started a family with his lovely wife Sally, but it was perhaps too small a parcel to really make the business really work. So, Richard got rid of the sheep, excavated some lakes, opened a fly fishing school and never looked back.
I could pretty much cast a fly by the time we met, but even so he gave me a few good tips from time to time. He was effortlessly skilful with a fly rod and quite the all-round sportsman. We both played golf with inconsistent skill. Richard’s excuse was a set of hickory blades of great vintage: even so when he caught them right, the ball just flew. His grandfather had captained the English rugby team and was a pretty handy cricketer too and most of the sporting genes had made their way down to Richard. He would stand on the lawn with his new pupils – including my wife Vicky once – tie the rod butt to their wrist and within the hour they’d be laying out the most elegant line you’d ever seen. Hundreds of novice anglers must have found their way to a lovely pastime through Richard’s passion and patience.
Through the early years of our friendship the chalk streams were in a really bad way, although Richard’s were better off than most. He kept his beats wild and fenced off from the hordes of cattle that populated EU-subsidised pasture land in the 1980s; and he was a pioneer of wild-trout, catch-and-release fishing at a time when the world was marching in the opposite direction, increasingly relying on stocked fish as river habitats were being decimated. It is hard now to appreciate the radical nature of Richard’s chalk stream management at a time when the River Test was dubbed ‘the longest stew pond in Europe’.
Abstraction and dredging were rife on the chalk streams and Richard took a stand against both, catalysing investigations and eventually significant abstraction reductions on his beloved River Piddle. It took him years to battle and win the fight with Wessex Water, but eventually they turned down the pumps in the headwaters, halved the abstraction and installed mitigation flows in the middle river. The River Piddle has not dried since. It is one of the few notable chalk-stream recovery stories since the dark days of the 1980s and is now a shining example of what a wild chalk stream should be like. We have Richard to thank for that.
The year I moved from teaching in Dorset to teaching in Scotland – 1995 – a particularly deep drought reduced many of Dorset’s chalk streams to a trickle. The River Tarrant near where I lived in Blandford simply vanished into the ground. Richard came over and helped me and a heavily pregnant Vicky rescue trout with nets I had borrowed from the NRA. We put them in bins of water and ferried them down to the main River Stour.
Then, in early July, Richard and I left Dorset behind and went on a fishing holiday to Ireland, to a little limestone stream called the Awbeg. Apart from the forever funny memory of Richard annunciating his name “Slow Cock” to a blushing post-mistress, who crossed herself furiously as she wrote out his fishing licence, I also remember vividly that we could hardly believe the contrast between the drought-stricken chalk streams we had left behind and this spring-fed Irish stream, brim full in spite of the drought, extensively grazed and therefore unfenced, full of trees and tangles and wild fish everywhere. Most amazing of all were the complex and abundant hatches of insects. Something the chalk streams were famous for, but which we never saw anymore. We knew that Ireland had had its issues with dredging too, but the Awbeg seemed to have escaped them and was showing us just what was possible when the habitat is right, and there is enough water for nature.
Over the next few months we hatched a plan to coalesce the efforts of Richard, and a few others we knew who had also become fed up with ersatz fisheries, stocking, over-abstraction and intensive agriculture, and together form a society to champion the very opposite. We wrote to Trout Unlimited but soon realised that a UK chapter was not the answer. So, we came up with our own ideas and in 1997 launched the Wild Trout Society, which would later become the Wild Trout Trust.
All the early meetings were held at Richard’s place in Dorset. Mike Weaver agreed to chair our group. Ronnie Butler, Ron Holloway, Roger Mills and myself formed the hardcore. Friends called us the Powder Keg Society, so revolutionary were these ideas to a new Environment Agency that hadn’t yet fully embraced the idea of river restoration, to a water industry still in denial over the impact of abstraction and to a Salmon and Trout Association that was a wee bit club-tie-and-sherry to our disruptive beer-and-wellies. Throughout this all, Richard kept a steady hand on the tiller with good-humoured wisdom and diplomacy.
In later years he became the chairman of the Wild Trout Trust, with Simon Johnson as director, and steered the trust through a crucial, formative phase as it evolved from a seat-of-the-pants amateur outfit, to a more professional incarnation with multiple employees, grants and a heavily-in-demand offering of expert advisory visits and practical demos. The project officers came on board during Richard’s tenure and he very much guided the creation of the Wild Trout Trust that exists today.
For a while, after we moved back from Scotland, Richard and I worked closely together on those streams in Dorset, as I started eking out a freelance living from an eclectic mix of letting fishing and writing for magazines. Then my mother died too young – meaning I know all about the pain his family are going through now – and we had to move home to Norfolk. Vicky remembers our very young son Patrick shortly after the move spotting a stranger walk down the hill in Hunstanton and mistakenly squealing ‘Richard!’ with such delight it rather underlined what we were missing. But we weren’t going to find anyone like Richard in Norfolk and over the past 25 years I have gone back to Dorset every May to fish and to catch up on the gossip.
Richard was a great father, to Katherine and Niff, and grandfather to Jack, Archie, Molly and Harry. He was married to Sally for 50 years. I have got to know his family very well over the decades and can remember his daughters from when they were very small. They both sent me messages over the last few days through which it became obvious that I wasn’t going to see Richard again.
He had had a nasty run-in with a prostate tumour and had just got over it when the doctors found something else. He told me in November that it was terminal this time, but with a mix of sang-froid humour and realism and a complete absence of self-pity. None of which surprised me at all.
I tried to go and see him in December, but didn’t plan it properly and Richard was out shopping in Yeovil: a recent convert to the niche business of collecting silver nik-naks, he had decided he might as well get some of those silver spoons and creamers he’d never quite allowed himself. Then I caught some dreadful lurgee over Christmas and we had to stay away. He told me he had found an expert in London who could probably give him a chunk of extra time which, Richard said, he wouldn’t have minded having, all things considered. And so, I hoped I would see him in May as usual. Then he caught Covid and suddenly the letter I had wanted to send him by post – he loved a handwritten letter – had to be sent by email and in a hurry. I reminded him of all the fun times we had shared. I hoped it would made him laugh.
And that was that. As if by the proverbial wolf in the night Richard was swept away. He was with his loving family at the end and as much as one can go well, Richard managed it.
Dear Richard, or Cock o’ the Pidd, as you signed yourself, I am going to miss you like hell. I do hope they aren’t abstracting the rivers wherever you are. And that the sea trout runs are abundant. And the lager is at least as strong as Londis’ own-brand special-brew, the tongue-tangler. The chalk streams – and I – owe you a great debt.
Today I am posting a guest blog by Ali Morse – water policy director at the Wildlife Trust and chair at Blueprint for Water – on why it is so important to ensure our new, ambitious phosphorus reduction targets are applied to the parts of the landscape where we will see the greatest ecological benefit for the money spent. It’s astonishing to think that although we have been spending millions reducing phosphorus from sewage (66% reduction 1995 to 2020 … and now a new target of 80% reduction 2020 to 2038) we still haven’t found a way to ensure that we reduce phosphorus from the small works in the upper reaches of rivers where the reductions would have the greatest ecological outcome. Essentially, ever since the UWWTD (Urban Wastewater Treatment Directive) was passed to drive these reductions, cost-effectiveness has been measured by population attached to a given works as opposed to for example: % length of river d’stream of the pollution source, or the volume of flow in the receiving waterbody relative to the volume of flow from the pollution. This doesn’t make sense. We create targets to reduce phosphorus because it has a negative ecological impact: the primary outcome should surely be, therefore, to minimise the ecological impact, regardless of the local population size. In practice we reduce phosphorus in such a way that the ecological impact its secondary to accounting methodologies. This means we have rivers like the Frome in Dorset (a SSSI chalk stream) where the phosphorus concentrations go down as you travel downstream and are lowest just above the estuary (see the map below which I drew up when working on the chalk stream strategy, (based on 2016 WFD data)). It cannot be rocket science to find some simple policy drivers that would make the difference. All the river-oriented eNGOs should take a united front on this in my view, change the raw-sewage record for a few turns of the dance floor, and implore government to develop a way to maximise the ecological outcome for their ambitious Environment Act targets.
Here’s Ali’s excellent blog, first paragraph with a link across to the Wildlife Trusts site:
“In November 2021, the Environment Act became law and, with it, the promise of ambitious targets that would turn the tide on nature’s decline. Early last year, new regulations set out the detail of targets on water[i], waste, woodland and other topics that all contribute to the overarching and ambitious ‘apex’ goal, of seeing declines in species abundance halted by 2030.
For our watery habitats, the targets are intended to tackle the key pressures against which there has been stubbornly little progress to date. Nutrient pollution is a key factor that blights the freshwater environment, not just in England but around the globe. Although there are downsides to having targets on specific, potentially siloed topics, the logic of seeking to drive action on THE greatest pressure faced by our rivers, lakes and coastal waters is understandable. In freshwaters, phosphate is the pollutant causing the greatest number of failures against ecological standards. It’s a reason that more than half of England’s rivers, and three quarters of lakes, are assessed as not being in good health.
Of particular concern is the impact of phosphate pollution upon England’s chalk streams …”
Chalk-Streams 