Draft river basin management plans

The outlined principles capture many important priorities and we welcome an increased focus on working with natural processes to create resilient, biodiverse, functioning catchments, able to recover from a variety of pressures. In particular, a collaborative approach, however the concept of 'place based' should build on the proven need for a 'catchment-based' (i.e. CaBA) as well as local-knowledge-driven approach.

In practice, to achieve these aspirations, the strategies and mechanisms required to deliver on these principles must also be more firmly established and supported by stronger legislatory mechanisms and adequate resources. For example, 'evidence-led' decisions should not be contradicted by a lowering of standards by the regulator where the solution - as a whole - is seen as 'too costly' - an outcome that leaves local communities dismayed and continuing to endure repeated pollution incidents year after year without implementation of cost effective incremental improvements that could 'progress to good'.

The evidence from previous RBMP cycles indicates that good principles are frequently not fully applied or integrated into planning and permitting processes by the regulatory authorities, in particular the Environment Agency (as WFD competent authority).

Promote restoration and recovery of freshwater, estuarine and coastal habitats and species: We strongly support this as a principle, however the evidence of failing ecological status* targets highlights a need for stronger tools and mechanisms to deliver the mandatory 'no deterioration' and progress to 'good ecological status/potential' as required by the Water Framework Directive Regulations.

*For example, 110 surface waters deteriorated by at least 1 ecological status class between 2015 and 2019. As Section 2.2 of the Planning Process Overview document highlights, that ‘deterioration from one status class to a lower one is not permitted’.

What steps are to be taken to address the unlawful deterioration of these water bodies?

Despite attempts to connect River Basin Management Plans with Flood Risk Management Plans, the ongoing lack of integration between WFD and FCRM team principles within the EA, in particular the slow progress with integrating wider benefits into decision making for funding natural flood management and nature based solutions to flood alleviation, presents a significant obstacle towards delivering the good practice captured in the principles, as they meet risk-averse 'old school' thinking that persists in channelling funding towards traditional engineered approaches without consideration for legacy or ongoing aftercare which could deliver many more wider benefits.

This juxtaposition makes it difficult, time consuming and more costly, to deliver on measures and principles within the RBMP.

To progress towards delivery of these principles, a full review of the EA permitting system and funding criteria is required, to ensure these are still fit for purpose with regards to the listed principles that have evolved since introduction of the 25 Year Plan. In particular, there is an urgent need to streamline permitting for catchment partners working on RBMP projects that meet the listed principles, making it more cost-effective for external Catchment Partnership project delivery e.g. with an extended list of exemptions for measures that deliver WFD outcomes.

Furthermore, providing adequate revenue seed funding for specific legacy (post-project) activities to support essential local maintenance activities, needs to be recognised as a highly cost-effective way forward to meet multiple integrated environmental, social and economic objectives to support inclusiveness and diversity in natural and social contexts.

As noted, under WFD Regulations (England and Wales) the delivery of the RBMP objectives are used to primarily prevent deterioration (the legal minimum), thereafter to AIM to improve the water environment. As per the principles, these objectives require a multi-sector, multi-level (grass roots to government) plan and not one organisation is solely responsible for delivering them.

In short, achieving RBMP objectives and standards should be for ALL water bodies, not just protected areas. In particular, where social impacts arise in the most heavily impacted urban river catchments, higher aspirations for good ecological potential are urgently needed. Drawing upon more effective evidence, regulatory standards should NOT be reduced where a single solution is determined to be 'disproportionately costly'. The principle of incremental 'progress to good' should highlight a step-wise reversal of the 'death by 1000 cuts' analogy (of deterioration to current bad status) to build upon evidence of progressive improvement and local wider benefits arising from a truly collaborative integrated approach (as per principle 1).

Properly resourced catchment partnerships are ideally placed to deliver integrated solutions for water bodies by connecting across sectors and organisations; as a collective, catchment partnerships can slow down the rate of deterioration of the environment, by working with local groups to capture timely local evidence of deterioration and co-design nature-based solutions that inspire involvement in their aftercare.

However, under current funding regimes, a lack of investment in catchment partnership hosting (making match or 'self-sufficiency' funding very difficult to achieve) sits alongside of ongoing deterioration for ecological status as evidenced in the RBMP classification cycles in 2015, 2019 and 2021 .

The objectives data for the Ravensbourne catchment states that by 2027, 4 water bodies must be at Good Ecological Potential. Currently no water bodies in the catchment meet Good Ecological condition and so a jump to 4 in 5 years seems highly unrealistic. While we work collaboratively towards this transition to Good, further resourcing will be needed and many barriers must be overcome before such improvements are likely to be gained through measures identified in the Plan.

There appears to be no data displayed in the table for Chemical status objectives by 2027 however, it is noted that the target to achieve Good Chemical status for the 4 water bodies by 2015 failed as they currently all have the ‘Fail’ Chemical status. Similarly to the above point, further resourcing will be needed and many barriers must be overcome before such improvements are likely to be gained through measures identified in the Plan.

Addressing pollution Priority Hazardous Substances is commendable, however widespread pollution from a vast array of equally recognised highly hazardous substances urgently need overarching objectives if progress towards preventing sustained or increased surface water pollution is to be achieved - even by 2063. e.g. from Phosphate / Nitrate, and other sewage and road-runoff related hazardous contaminants.

Where evidence exists for continually failing WFD standards within Ravensbourne water bodies, without the delivery of robust support and sanctions by the regulatory authority, the excellent objectives of 'Preventing deterioration of the status of surface waters' and even 'Aiming to achieve good potential' in all Ravensbourne water bodies are immediately contradicted by the lack of support by the regulatory authority - therefore what incentive will there be for others to contribute to achieve these targets?

Widespread challenges, such as high levels of development that are not water-efficient or continue to disconnect and limit the capacity of the floodplain, undermine improvements being made by catchment partnerships [and others]. These are examples of activity that can really only be overcome by changes in regulatory mechanisms that will be delivering action by Government or at Regulatory level.

We welcome new policy approaches for Nature Recovery Networks, however we question why other policy changes are not being made in parallel to safeguard any improvements gained on the ground from delivery of such schemes [e.g. more coherent connectivity between landscape and water networks, i.e. highlighting the connectivity throughout river corridors and catchments more effectively].

We firstly welcome the recognition that 'All sectors of society have a role in implementing the programmes of measures' - this is exactly where Catchment Partnership work can deliver outcomes by working with diverse partner organisations to build interest and investment opportunities for resourcing multi-benefit collaborative projects HOWEVER this approach must be properly resourced to (i) begin effective cross-sector engagement, then (ii) identify / create / apply the tools (financial mechanisms) that will enable contribution towards the implementation of measures.

The sustainable resourcing of Catchment Partnerships is essential to extend their reach to new sectoral partners, and GOV.UK must recognise that to achieve the desired economic 'self sufficiency' ambitions for CaBA and catchment partnerships, both revenue AND capital funding is required as seed AND more substantive match funding over successive annual cycles (reflecting true project development life cycles).

None of the confirmed (funded) measures / actions for the Ravensbourne Catchment appear to be on the list for RBMP 2021-2027. This is because no confirmed measures are listed on the catchment partnership pages for confident delivery, however confirmed measures do exist. These include:

1. Increased flood resilience and public accessibility and engagement with the River Ravensbourne in Beckenham Place Park East.

2. Invasive species management and litter clean-up activities on the Rivers Pool, Ravensbourne and Quaggy through the annual and three-week-long 3 Rivers Clean Up.

3. Sediment and pollution filtering and flood resilience improvement through the creation of SuDS in Chinbrook Meadows.

4. Reduction of siltation of Glassmill Pond, removal of a barrier and restoration of healthy river functioning of the River Ravensbourne to improve biodiversity levels and climate change resilience.

5. Fish and eel passage improvement works on priority barriers in the catchment.

6. Road runoff pollution monitoring and nature-based solutions to resolve identified road runoff pollution.

7. Quaggy Links – landscape-scale project along the River Quaggy aiming to improve the river’s ecology and hydro-morphological quality as well as public access to and engagement with the river through the delivery of connected subprojects between Chinbrook Meadows and Sutcliffe Park.

8. Outfall Safari – surveying the outfalls in the catchment to reduce pollution from misconnections and cross connections with the foul wastewater drainage system.

9. Riverfly monitoring – a highly successful UK-wide citizen science project involving the monthly surveying of key invertebrate species at set sites around the catchment to monitor water quality and detect pollution events.

11. Delivery of the Thames and Tributaries Plasticblitz – a citizen science project to clean up the tidal Thames.

There are over 280 potential measures listed in the RBMP, which is overwhelming and unhelpful. Many of these measures appear to be an iteration of each other and could be amalgamated into fewer, stronger measures and then grouped into categories [e.g. education] that are easy to search and develop further.

There are several "potential measures" which we would argue should become "confirmed measures" in the 2021-2027 RBMP, as these would help overcome barriers to achieving the environmental ambitions of the RBMP and may comparatively only require a small investment of resource, for example, making Invasive Non-Native Species distribution data publicly accessible on the EA catchment data explorer website (row 29).

This question is very ambiguous on what it is asking for, but from our opinion, we cannot specifically locate any of our potential measures that we've listed as part of our priority potential measures.

For the Ravensbourne Catchment, our potential measures include:

1. Quaggy Trails – exploring ways to extend public access in the vicinity of the river between Sutcliffe Park and Lee Green.

2. A21 Development Framework – river restoration and public access and engagement improvement potential with the development project around the A21.

The "challenges" spreadsheet highlights individual counts of reasons for not achieving good status, per sector, per waterbody. The main water management issues highlighted within the Ravensbourne Catchment are:
1. Urban and transport

2. Water Industry

3. Domestic general public

Therefore these issues pose these three main challenges:
1. Physical modifications

2. Pollution from towns, cities and transport

3. Pollution from wastewater

The current challenges on the catchment partnership pages include invasive species and not pollution from wastewater. It is a disappointing and arbitrary decision to limit the number of challenges to three because pollution from wastewater should also be included in the current challenges and should not take the place of any of the other three current challenges listed: all four are top challenges for the catchment. Future challenges remain the same.

The "challenges" spreadsheet highlights individual counts of reasons for not achieving good status, per sector, per waterbody - and we would question whether this has the correct level of RNAGs listed under each, which we believe to be a lot higher based on local catchment knowledge than is noted in this section. For example, there is only one count of invasive non-native species as an RNAG, specifically of Chinese mitten crab just upstream of Cornmill Gardens on the River Ravensbourne, which we know is not true due to the annual running of the 3 Rivers Clean Up (3RCU) since 2008 that was specifically designed to combat and manage the presence of invasive species throughout the catchment. Volunteers primarily focus on Himalayan balsam, but several people have also been licensed to treat and remove Japanese knotweed and giant hogweed. Therefore, as well as the counts of invasive species being incorrect, invasive species may need to be considered as a future challenge. Through the 3RCU events as well as the other numerous river activities, we have been able to collate detailed local knowledge of the expansive presence of invasive species throughout the catchment:

Hot spots for Himalayan balsam:
1. Brookmill Park - River Ravensbourne
2.Manor Park (Dermody Road end) - River Quaggy
3.Sutcliffe Park – River Quaggy
4. Cornmill Gardens – River Ravensbourne
5. Beckenham Place Park – River Ravensbourne
6. Dorset Rd allotments – River Pool river system
7. South Norwood Country Park – Chaffinch Brook, River Pool river system – however abundance has reduced considerably in recent years so that only one or two plants are present in the Pool catchment each year
8. Downstream end of Harvington Woods behind the houses – The Beck
9. Behind Langley Park School – The Beck

Hot spots for Japanese knotweed:
1. Beckenham Place Park to Shortlands Golf Course
2. Capel Manor College to Sydenham Cottages stretch – River Quaggy
3.Brookmill Park – their presence is sporadic though
4. Relatively prevalent in the Pool catchment, for example on the stretch from Catford to Winsford Road, from Worsley Bridge Road to Cator Park and on the short branch of the Chaffinch Brook from the Pool Confluence to King’s Hall Road

Hot spots for giant hogweed:
1. Largely under control, but there are still populations at South Norwood Country Park and Dorset Road allotments
2. Small populations scattered around the catchment including at Brookmill Park, Sutcliffe Park and Ladywell Fields but these are noticed and removed quickly before the numbers can increase

As for invasive fauna, Chinese mitten crabs have been found upstream of Manor Park (River Quaggy) and are also known to be on the River Ravensbourne in various places.

The less certain measures listed on our catchment page still stand. However, in addition to these, the following two measures need to be added as less certain measures for delivery before 2027:
1. Quaggy Trails – exploring ways to extend public access in the vicinity of the river between Sutcliffe Park and Lee Green.

2. A21 Development Framework – river restoration and public access and engagement improvement potential with the development project around the A21.

Moreover, the following measures need to be added as confident for delivery before 2027 on our catchment page:
1. Increased flood resilience and public accessibility and engagement with the River Ravensbourne in Beckenham Place Park East.

2. Invasive species management and litter clean-up activities on the Rivers Pool, Ravensbourne and Quaggy through the annual and three-week-long 3 Rivers Clean Up.

3. Sediment and pollution filtering and flood resilience improvement through the creation of SuDS in Chinbrook Meadows.

4. Reduction of siltation of Glassmill Pond, removal of a barrier and restoration of healthy river functioning of the River Ravensbourne to improve biodiversity levels and climate change resilience.

5. Fish and eel passage improvement works on priority barriers in the catchment.

6. Road runoff pollution monitoring and nature-based solutions to resolve identified road runoff pollution.

7. Quaggy Links – landscape-scale project along the River Quaggy aiming to improve the river’s ecology and hydro-morphological quality as well as public access to and engagement with the river through the delivery of connected subprojects between Chinbrook Meadows and Sutcliffe Park.

8. Outfall Safari – surveying the outfalls in the catchment to reduce pollution from misconnections and cross connections with the foul wastewater drainage system.

9. Riverfly monitoring – a highly successful UK-wide citizen science project involving the monthly surveying of key invertebrate species at set sites around the catchment to monitor water quality and detect pollution events.

11. Delivery of the Thames and Tributaries Plasticblitz – a citizen science project to clean up the tidal Thames.

1. Development in our catchment is a major stumbling block to achieving water sustainability across public supply and environment. Population is growing, more developments are planned and more water will need to be found to supply the Ravensbourne catchment in future years. We have yet to see a clear commitment from Government in addressing the water-gap that increased development is creating. Though water is featured heavily in the 25 Year Plan, it is left to under-resourced Local Authorities, water companies and catchment partnerships, to try to plug the gap between development targets (authorities), the right to connect (water companies) and reducing impacts on the environment resulting from over-abstraction for public supply (catchment partnership). It is unhelpful for Government to assume Local Authorities and regional EA teams have the resources to regulate and enforce sanctions on developers as a backstop for achieving water sustainability. Without a strong change in national government policy on development and housing (i.e. National Planning Framework and the Building Reg's) the issues creating the water and biodiversity crisis in our catchment will not ever be fully remedied and it completely undermines our partnership's ability to achieve a healthier water environment. We would therefore welcome stronger national planning policy linked to water efficient development, which will be helpful to Local Authorities assessing water impacts of a development at planning application stage - e.g. all development mandated to include grey-water reuse systems in water stressed regions like the South East.

2. It is critical that a substantial increase in funds for monitoring of the water environment and the undertaking of enforcement to ensure that the polluter pays, is required. Citizen Science can play a key role (as identified by the EAC Water Quality report) in identifying waterbody status, determining key pressures and identifying priorities for action.

3. Much needs to be done to ensure climate resilience. However, the Plans do not set out a visibly strategic approach to the issue. Catchment-wide approach to water resource management, nature-based solutions in both rural and urban landscapes, natural flood risk management and private investment for peatland restoration are all mainstream initiatives within Rivers Trusts and CaBA. This framework for environmental delivery that crucially also holds substantial conveying power can provide a step change towards embedding resilient catchments nationwide – provided adequate resourcing, which it does not currently receive.

4. With respect to the agricultural sector, a marked change in approach is required to ensure the provision of advice and guidance to farmers nationwide. This can encompass policy and legislation, ensuring that the Farming Rules for Water are fully adhered with and that opportunities through ELMS are fully utilised. Funds should also be made widely available to ensure that soil nutrient levels and farm nutrient budgets are quantified, adopting the recent approach in Northern Ireland.

5. We do not think the process by which DEFRA decides and administers funding to regional EA teams is fit for purpose. Currently Water Environment Improvement Funding [and other], which goes some way towards supporting delivery of environmental objectives by catchment partnerships and EA, is awarded on an annual basis. This presents a major blocker to partnerships delivering capital improvement projects, which commonly span more than 1 financial year to design, permit and deliver. Without the financial security of knowing a WEIF grant will be awarded to the full amount across multiple years, it puts delivery partners under higher risk of a) losing other match funding brought in to deliver the improvements, b) being unable to fully deliver the agreed objectives, or c) losing out financially if they have to cover the shortfall for capital costs not anticipated. Given that Government is relying on catchment partnerships and regional EA teams to deliver environmental improvements and meet targets in the RBMP/25 Y.P. we would encourage DEFRA to review its financing procedures to move away from annual, into multi-year funding for regional EA teams [and catchment partnerships].

6. We welcome use of the updated catchment data explorer and think this is a very useful tool for understanding what is set out across objectives, challenges and measures for each catchment. However, the structure of this consultation has been difficult to navigate - there are lots of documents and data sources to review and ascribe correctly to the consultation questions. In future it would be useful to have a "summary - how to" sheet which links each section of questions to the relevant document/section of document it refers.