Draft river basin management plans

The principles are all important and necessary to achieve water quality and biodiversity improvements. They need be frequently advocated and adequately funded by Government.

Research, including that carried out for the Trust, has demonstrated the wellbeing benefits of spending time by water. In 2016-17, the total wellbeing value of all trips to the Trust’s waterways in England and Wales was estimated at £3.8bn. The equivalent figure today is likely to be significantly higher due to the significant increase in the number of visits to the Trust’s network that began with the Covid-19 pandemic lockdowns in Spring/Summer 2020. This wellbeing benefit is an important consideration and we suggest that it should be recognised in the principles in order to ensure that measures to protect and improve the water environment are developed in the context of the benefits to society of public access and enjoyment of it.

For the principles to work, there is a need for more joined up working/sharing of ideas on a catchment scale. The CaBA groups are essential and have great potential to do this and should continually be looking for new businesses/companies (from different business sectors) to join local groups. In some areas the Canal & River Trust have been unsuccessful in linking up with local CaBA groups.

The Canal & River Trust would like to take a more ‘collaborative approach’ (a stated principle) on the WFD classification of canals and how the data sets/assessments are put together. It appears that much of the data used to make canal classifications is stated as being uncertain or low confidence, and/or is dated. There's no clarification on how this data was obtained as there appears to be no distinction between any of the Trust’s watercourses. Trust environmental staff may be able to help with these assessments by providing Trust obtained water quality data and help identify potential pollution sources.

The Trust uses pumping stations at strategic locations around the canal network. These may have multiple purposes. Some pumping stations abstract water from rivers into canals, whilst others may recirculate/backpump water displaced by lock movement or achieve net-transfer by moving water from one section of the canal to another. As such, constraints on abstraction (licences) that may have been as a result of (failing) WFD classification may as a knock on effect lead to more pumping within the canal network. This potentially increases the Trust’s carbon emissions, something we are keen to avoid as we look to reduce our carbon footprint.

We would suggest that additional objectives are added:

- relating to the control of INNS, to reflect the number of measures/potential measures which relate to INNS control?

- to provide greater transparency of data to external stakeholders via the Catchment Data Explorer (inclusive of actual sample data on canals).

Linked with the Q1, apparently the natural chemical recovery of the canals with regards to priority hazardous substances etc. is 2063? Is there nothing we can do to improve the chemical health of the waterbodies more quickly? Again, we need to understand what these substances are so we can resolve these issues.
In regard to the cessation of discharges objective, please ensure that this is focussed on release into surface waters not remobilisation within waters (e.g. hydrodynamic dredging). The Trust’s statutory obligations to maintain navigation should not be compromised by requirement to clean up others pollution.

WFD needs to have regard for not just the canal system waterbodies but the waterbodies that interact with or are downstream of the canal system. Waterbodies downstream of reservoirs or abstractions should be appropriately classified as artificial/heavily modified if required if they would not meet GEP without having a disproportionate impact on the connected waterbodies where the reason for failing to meet GES is navigation. Thus, GEP may be a more realistic target in some locations.
The EA is in the process of determining or has already determined abstraction licences for 144 previously exempt abstractions under the New Authorisations process. The EA is applying Hands Off Flows (or other similar conditions) to protect the donor watercourses. WFD classifications are being used to determine the conditions on licences. These licences are time limited and will be reviewed at the common catchment end date. As such incorrect or inappropriate classification of donor, or downstream waterbodies has the potential to impact on canal abstraction licences. It must be noted that the canal water system crosses and connects river catchments. As such WFD should have regard for this. Whereby the EA may seek to control the Trust’s abstractions in one location this may ultimately have an impact on abstraction (to make up a water demand shortfall) in a neighbouring river catchment.

The Canal & River Trust are leading on several funded projects which will deliver nature & biodiversity enhancements. These funded projects include - Green Recovery Challenge Fund – Pollinators & Water Voles, Canal & River Invasive Species Eradication Project (CRISEP) funded by Severn Trent.

The potential new measures need to ensure that canals are recognised as being integrated within river catchments. The environmental measures the Canal & River Trust are undertaking will benefit the wider catchments that the canals operate in.

The Measures spreadsheet and Potential Measures spreadsheets are useful documents, outlining all the measures that different sectors are taking forward. It would be useful to keep these documents as live documents, so all stakeholders and new stakeholders can see the work that is being undertaken and any measures they could contribute to. As a live document it would be useful to use these spreadsheets to update on progress.

Suggestions/comments on new measures:
- “develop a system of classifying sediments… as beneficial material for restoration/maintaining GES”- which allows for more cost effective and sustainable disposal of dredgings. The Canal & River (Yorkshire & North East Region) have expertise in this area and would be happy to runs trials.

“historical issues, contaminated sediment. Explore options (legislative change or voluntary action) to improve approaches for dealing with historical contamination which may be a source of chemical pollution” – the Canal & River Trust have already been involved in this work and are happy to contribute to the further development of this work.

“legacy nutrients (e.g. sediment loading) will continue to impact lakes but could potentially hinder action if not addressed, Explore with stakeholders how to fund remediation from historic inputs via sediment removal in some places”- the Canal & River Trust are aware there was a Peoples Postcode Lottery funded project at Harthill/Pebley reservoirs looking at suitability to apply Phoslock, which would lock phosphorous and so that it become part of lake sediment.

“dredged material hierarchy is needed to help promote beneficial use as a priority (ISO Standard, Good Practice or otherwise)”- the waste hierarchy already applies to dredged material and the Trust does not believe a voluntary code of practice will achieve this, a legislative change is required. Changes must be made to the MMO guidance to clarify the disposal to sea Vs beneficial use activities and also the environmental permitting regime to develop either additional exemptions or standard rule permits that encourage beneficial use of dredged materials. A standard rules permit specifically for reuse of dredged material may be a good option and the Trust has already been in discussions with the EA about this. Could we ask that we are involved?

We have some concerns about how the EA will continue to work with partners to achieve new measures with their resources so stretched.

Consideration should be given to including a measure or potential new measure within the plans at a national level that relates to ensuring that waterbodies and watercourses are seen as valuable assets within Local Nature Recovery Strategies, with appropriate funding opportunities and protections through the planning system to follow. This should include canals. Even though our understanding is that canals are excluded from the list of priority habitats within the UKBAP Priority Habitat Inventory on account of their engineered history, some of the qualifying criteria for rivers often apply to canals. The Lawton Report (2010) recommended that more should be done to better achieve the potential of linear features (including canals) as wildlife corridors.

The following is identified as a potential new measure:

‘Continue exploring existing planning reform, to build on planning mechanisms such as Bio Net Gain and Env Net Gain, to encourage local development plans to address physical modification and plan for better river morphology including improved access to private investment’. As a guardian of the country’s inland waterways and a statutory consultee in the development management process, the Trust believes that it is well positioned to provide advice on this measure and would welcome conversations about it as the workstream develops.

With a national waterway network spanning many catchments, it is challenging for the Trust to identify and engage with priorities for the local partnerships. Is there an alternative mechanism by which the local priorities could be consolidated for discussion with the Trust, akin to discussions with water companies.

There is nothing specific with regards to addressing the poor / failing chemical health of canals. Whilst there do appear to be measures outlined at a national level (e.g. working with agricultural sector to address nutrients / diffuse pollution, improving discharges from sewage plants / large water companies) it's hard to understand how these will be implemented at a local level to improve the canals when all other measures are exclusively centred on rivers - despite their connectivity with our watercourses.

Ensuring that funding streams used for water quality improvements can be used on dredging without needing to suggest it’s for habitat improvement, and can simply be for water quality improvement, would be of significant benefit.

Biodiversity net gain through development planning is identified as a national measure that will contribute to achieving objectives in all catchment plans. However, there is a significant risk that the approach that developers and local authorities are required to take in Biodiversity Metric 3 will result in direct negative impacts on waterways from development adjacent going unmitigated and will see no requirement for a developer to deliver a net gain to waterways. The Trust has explained its concerns to Natural England, Defra and the EA and has asked for changes to the Biodiversity Metric, which we understand are still being considered. We would be happy to provide further information on the reasons for our concerns. However, unless the Biodiversity Metric is amended, it is the Trust’s opinion that the scope to use Biodiversity Net Gain as a tool for achieving catchment plan objectives is, at best, uncertain.