Draft river basin management plans

As a general point, we are conscious that there is currently a lot of change underway and proposed around environmental policy which will have a major influence on the delivery of the plans. We note the statutory need to produce plans now but recommend that these are live documents which will need to evolve with changing Government targets and ambition.

We consider the proposed principles to be sound and it is particularly good to see climate change so explicit as it has been somewhat in the background in previous RBMPs. A more proactive approach around developing fit for purpose and adaptive responses would be welcome. We have some concern about how the principles will be applied. First, the wording in the consultation document implies that there is a degree of flexibility in the whether the principles are adopted. Given the objectives of the RBMPs and the urgency in restoring nature and mitigating and adapting to climate change, we feel that these principles should underpin the plans as a default. Secondly, the principles are clearly high level but there is potentially a range of interpretations and hence some further detail might be useful.

Whilst mentioned elsewhere, we are disappointed that there is no reference to protected sites and their role for freshwater/wetland biodiversity in the principles. The RBMPs are an important tool in reversing the declines in our freshwater and wetland species and habitats and it would be good to see the principles acknowledge the importance of the best sites. Overall, we would like to see a more explicit commitment to getting freshwater, wetland and coastal protected areas into favourable condition.

We encourage the Environment Agency to include a principle around managing and improving the whole of the freshwater and wetland landscape. Previous RBMPs have focused on the main river network and the very largest lakes and yet there is evidence that the smaller parts of the water environment, headwaters, ponds and small lakes are more important in determining overall catchment biodiversity. In addition, actions to create and improve these small waters are often easier due to their small catchments and will have positive impacts on downstream water bodies.

We are concerned that, whilst there is a principle about ‘collaborative place-based approach’, there is no explicit mention of existing processes such as Catchment Partnerships and CaBA or indeed the development of the Coastal Based Approach (CoBA) to ensure greater recognition of coastal and transitional waters. It is also important to note that ‘place’ may be different for different water bodies; for example many coastal waters are influenced by a number of catchments and hence actions will need to be coordinated across catchment partnerships. At present there doesn’t seem to be any reference in the principles to delivering the commitments of Water Framework Directive or the 25 Year Environment Plan objectives. We understand that these are presented later under a section on objectives but feel there should be some reference to aims under the principles, particularly as, taken in isolation, some principles could drive actions that undermine the overall objectives.

We also support the points raised in Wildlife and Countryside Link’s response.

We understand the draft RBMPs to be the statutory plans to enable delivery of Government commitments for the water environment. As such some of the wording feels rather weak and perhaps reflects the resourcing challenges and a lack of new mechanisms and approaches needed to deliver the step change in river, lake and coastal water status. For example ‘aiming to achieve good status for all water bodies’ is subtly different wording to the 25 Year Plan commitment to ‘improve at least three quarters of our waters to be close to their natural state as soon as is practicable’. We believe the wording must equal the ambition of the 25 Year Environment Plan at the very least; resourcing challenges are not a reason to water down ambition, when these vital habitats are under immediate threat.

We are pleased to see other biodiversity objectives (such as species and chalk streams) included but as with other aspects of the plans, it is difficult to see the step change needed to make progress on these fronts when we are failing to achieve on the core objectives of the plans. It is clear from the most recent status classification data that current investment, mechanisms and approaches are insufficient. The draft RBMPs largely reflect ‘more of the same’ and we are concerned that this will not be enough to meet either the objectives or the public’s growing interest in the health of the water environment.

As an example, we recognise the significant challenge of chemical status failures and the impact of legacy chemicals and unknown effects. We would welcome a much more explicit acknowledgement of this challenge and a plan for addressing it as part of the RBMP process, beyond the current focus on priority hazardous substances alone.

We also support the points raised in Wildlife and Countryside Link’s response.

As we have outlined above, we are concerned that the draft RBMPs fail to describe the step change required to meet Government targets. We understand that there are issues of both inadequate resources for the Environment Agency and insufficient mechanisms. For example, whilst the recent changes to Farming Rules for Water are broadly welcome, given the significant role of agricultural diffuse pollution in preventing waterbodies meeting good status we are concerned that these will not go far enough. Dealing with this major pressure on the water environment requires more stringent rules, better enforcement and a comprehensive package of support and advice for farmers to change practices. It is therefore important that the forthcoming ELM proposals deliver this necessary change.

In terms of resources, we note that ‘(e)ach year, about 90% of the money to protect and improve the water environment and associated public health is spent on measures to prevent deterioration. The remaining 10% funds improvement measures’. This statement highlights the pressures on the water environment and the effort required to simply ‘stand still’. It clearly illustrates why as a society we are failing to make any progress with water body improvement. Recent campaigns around water companies CSOs and bids for bathing water status on inland waters show the level of public interest and support for better investment and tougher controls on sources of pollution.

The challenge of preventing deterioration is, we believe, exacerbated by the size of many river, transitional and coastal water bodies. Activities and developments are assessed for impacts on status but given the size of a waterbody even relatively large impacts can be permitted. This then creates the potential for gradual deterioration through multiple small impacts. The application of biodiversity net gain to these developments has the potential to help with offsetting these impacts but only if rigorously applied. At present many river restoration schemes are short reach scale projects, which do little to offset the cumulative effect of many small impacts and a legacy of centuries of river and coastal modification. We are pleased to see larger scale restoration included within the potential measures but note from our own experience that even where there are funds and the will, the current consenting regime can make these projects difficult to realise.

One measure we believe should be in the draft RBMPs is around creating ‘buffers’ to pollution around rivers, streams, lakes and wetlands. If implemented in the right places and at the right scale this could deliver for WQ, flood, drought, climate resilience and be an integral part of the Nature Recovery Network. The Woodlands for Water project being delivered by the Riverscapes Partnership on behalf of Defra is a good start but there is scope for a bigger initiative (as part of ELM) embedding these approaches more widely and in a more holistic way. We believe that incentives for new woodland, floodplain meadows and wetland mosaics in the floodplain and riparian zones could deliver significant results if targeted in the right places.

The proposed Environment Act targets (which are currently under public consultation) are presented under the programme of measures, but we are concerned that there is a level of detail missing on how these will be implemented and regulated. In many respects these targets are simply a reframing of objectives we already have in the draft RBMPs and we are currently not convinced that these new targets will have any greater effect than the suite of ‘targets’ we have been pursing as part of RBMP process since 2009. In fact, the Environment Act targets are less sophisticated than current objectives as they are not related to ecological outcomes and hence there is the risk of considerable investment into pressure reduction which fails to meet meaningful levels, The proposed targets could help with RBMP delivery if applied at catchment scale and with reference to ecological status categories and we will be recommending to this to Defra in our response on those targets.

We also support the points raised in Wildlife and Countryside Link’s response.

The potential new measures include many measures that we believe could help with delivery of the RBMPs. It is not clear why some of these are not currently being adopted given the pressing need for a step change in the health of our waters. The current list is rather preliminary and it would be helpful to see more detail and some prioritisation and recommendations for uptake. Arguably, many of these measures have been identified since early in the RBMP process (e.g. those around INNS) and it therefore disappointing that these are still viewed as only potential.

The importance of properly resourced catchment partnerships working with an appropriately funded and targeted Environment Agency is critical to the delivery of both proposed and potential measures. Delivering the objectives of the RBMPs relies on a combination of strong and fair regulation, appropriate advice and incentive and targeted long term investment. Where catchment partnerships are well resourced (such as where one of the larger Rivers Trusts is active) there are good examples of progress being made and we would like to see capacity developed to replicate this elsewhere. As these partnerships have shown with a clear plan and programme of activity it is possible to generate additional investment including from the private sector. Such support for catchment and coastal partnerships and the overarching Catchment Based Approach will be important in realising some of these potential measures.

We also support the points raised in Wildlife and Countryside Link’s response.

No response – the National Trust is only commenting at a national level

We recognise the complexity and challenge of delivering the objectives as set out in the Water Framework Directive and in part this is why the current status classification for our waters is as it is. It is clear that more of the same will not be sufficient and a step change in approach is needed. This is even more important given the growing public awareness of issues and additional government ambition. The Environment Agency needs adequate resources to deliver from enforcement through to coordinating and providing strategic leadership to catchment partnership activity.

There is huge opportunity to join up across government climate, nature and water ambitions and many actions to restore the health and function of our catchments will have multiple benefits. To realise these benefits we need an integrated approach from policy through to delivery joining up across the sectors identified in the drafts plans. Finally, we believe that getting ELM right is key to making a step change in the health of our waters as it has the potential to drive better agricultural practice (SFI) as well as creating the opportunity for the sorts of land use change and habitat restoration that could displace some of the problems and create wildlife and carbon rich wide ‘buffers’ to protect the freshwater and wetland environment.

We also support the points raised in Wildlife and Countryside Link’s response.