Is the Environment Agency fit for purpose?

According to Unearthed, possibly not.

According to the Environment Agency, yes.

According to me, well read on and see…in particular I want to comment on the Unearthed article which, while having a core of truth is guilty of misrepresentation in places.

Staff reductions

Let’s start with the gross misrepresentation of

“nearly 1,000 EA staff – all of which were in corporate services such as finance, HR and IT – have been transferred to the department since July 2016.”

In practice this doesn’t represent a loss to EA field staff (the ones who collect samples, investigate pollution incidents and inspect premises) and doesn’t really represent a loss to the EA as these people are still providing the same services to the EA. What bothers me about this particular aspect of the arrangements is that they may not have the same priorities as directly employed staff. You can bet your bottom dollar that once in Defra any flexibility of movement or interpretation or creativity will quickly get knocked out of them.

A paradox resolved?

The article makes a big play on the number of inspections being reduced. So what? Our drinking water is self-monitored by the privatised water companies and is generally (and correctly in my informed opinion) considered to be amongst the best in Europe. A good self regulation scheme, with strictly controlled sampling regimes, quality assured analysis and routine reporting of results to both the regulator and the public can lead to a massive improvement in quality at negligible cost to the regulator. Maybe, just maybe, this is what lies behind the apparent paradox of reduced inspections yet also reduced non-compliances? I would welcome a comment from the EA (or perhaps some recently departed member of staff) on this proposition.

Enforcement

A big play is made about the reduced number of prosecutions and a shift towards Enforcement Undertakings. (I will overlook, no I will not, the factual error suggesting that the EA imposes fewer fines. The EA does not impose ANY fines, they are matters for the independent court system).

I personally support the concept of Enforcement Undertakings and want to see them used much more extensively. Believe me, from the discussions I have had with the EA they do not regard them as “less-costly and less-risky”, in fact I see the parts of the EA putting obstacles in the way of their use rather than facilitating them. The great advantage of an EU is that the money, which as to be of a similar amount to that which would have been levied as a fine, goes directly to environmental charities to spend improving the environment rather than into the ‘chancellor’s back pocket’. The recent emergence of Environmental Liability Notices is a development that we should follow with interest.

 “Things are (not) getting worse”

The article propagates the oft repeated view that

“Only 14% of the rivers in England are classed as having ‘good ecological status’, down from 27% in 2010.”

I read statements such as this with dismay. Having spent the last 42 years of my life dedicated to improving our rivers, let me tell you that they are better than ever.

When I started on the River Aire in 1974, the prospect of fishing the river in the centre of Leeds was laughable, now we have reliable records of salmon being caught there and we are starting on a major project (DNAire, a partnership project with the EA) to return salmon to the headwaters and hence stimulate a sustainable migratory fish population.

Nearly all of these reported changes are to do with standards so low as to be unachievable (e.g. Phosphate in sewage effluents) or recategorisation of water bodies using rules drawn up to report compliance in line with European Legislation, many of which are much more lax in other countries. If any of the complainers can truly convince me that matters are getting worse, then I promise to pack up tomorrow and consider my life’s work to have been a waste of time. 

Investigations and Sampling

Now let nobody get the idea that I am not critical of the EA, for I am indeed critical of certain aspects of how they go about their work (and not just in the environmental field, as a member of the RFCC I have been a persistent champion of getting more from the FCRM programme). We can quote examples of grossly inadequate incident investigations, damaging riverbank maintenance, inadequate levels of sampling and monitoring of their  own capital schemes and of baseline environmental data (the silence on the long standing Strategic Monitoring Review is worrying) etc. These are to some extent caused by staff and money shortages and need challenging. The prospect of many of these functions being handed over to an even less well resourced Civil Society is worrying. Catchment Hosts are already expected to draw up Integrated Catchment Plans using the grand sum of £15000 per year (yes, thousands of pound not millions!), the funding we might receive to do some of this other work fills me with no enthusiasm whatsoever.

Summary

Yes, by all means criticise the EA for their weaknesses, but the argument is diluted by inaccuracies and misrepresentations.

Your thoughts are welcome, I have opened Comments on this post.

River Aire inspires poets

Daltaire
Yes, I know this is actually the canal but it’s such a great shot!

In the lead-up to Saltaire Festival, our River Aire has been inspiring poets.

The competition, with the theme of ‘The World in Saltaire’, attracted entries from across the country and from poets of all ages.

The winning poems have been published in the latest edition of the Saltaire Review and will be on the BBC Big Screen in City Park, Bradford, later in the summer.

The winning poets have been invited to read at the Festival poetry event on 11th September at the Dandelion Café, where Sharena Satti’s poetry will also be featured.

The winner of the Adult class was Mark Batty and I quote his winning poem here with his permission.

The Aire by Mark Taylor Batty

The rain pleads down over sandstone grassy Dales;
Tight stone walls, cudding sheep, sheer open land.
Space pelted sodden, sheeted grey skyfall,
Rained and soaked, wrung and rinsed downstream
Where becks released from stillness skip gleefully
And all shove down, collude to make the Aire.

The eager rush steadies as it heads around Skipton,
Cutting at the turns, rinsing through low leaves,
Splaying into the depth of the valley,
Playing in brief eddies to wait and catch up,
Before gliding under the canal aqueduct
To corner and face the home run to Saltaire.

By the bolted boating hut, shift by Hirst mill,
Swish low, stream bold, thick, deep like soup
To the Boathouse Inn, and nonchalant ducks,
Where the heavy river swells like a distended belly
And bloats sated to claim the summer’s shore
Spilling at the path in the park.

The river would kiss the canal here by the thin green bridge,
Were it not for the pub, a gooseberry in between.
The mill then shouldering the canal away to Shipley
The river veering to roar its claim over the weir,
And farewell down dirty to Otley Road bridge.
Then confidently on to beat that canal to Leeds.

©Mark Taylor-Batty 2018

Is water company pollution getting worse?

Pollution from sewage outfallThe recent publication of the Environment Agency’s summary of the environmental performance of the 9 English water companies has led to the usual scary headlines about increasing pollution in our rivers. Let’s explore the topic.

Those headlines come not least from The Angling Trust who claim that:

The Environment Agency has published a report this week has highlighted an increase in the number of the most serious ‘category 1’ pollution incidents from the nine largest water companies’ operations over the past two years from 4 in 2015 to 9 in 2016 and 11 in 2017.  Such incidents can be catastrophic for fisheries and wildlife in the stretches of river affected, but there are also concerns about lower level pollution which can contribute to the ‘death of rivers by a thousand cuts’. That is the main reason for 50% of aquatic wildlife being in decline and 13% of aquatic species being threatened with extinction.

An alternative view might be expected from Water UK, the industry representative body:

The Environment Agency notes in the report that there has been a significant improvement in water quality, and acknowledges the industry’s role in achieving it through substantial investment. By 2020, water companies will have invested around 25 billion in environmental work since 1995, and this action will mean around 10,000 miles of UK rivers have been improved and protected since then.

In addition, the water industry has invested well over 2.5 billion since the 1990s to protect UK bathing waters, with the result that two thirds of UK beaches are now classed as excellent, compared with less than a third 25 years ago.

Even the BBC got in on the act:

Water companies are still not doing enough to protect streams and rivers, the Environment Agency reports.

Let’s finally take a snippet from the EA’s own blog on the report:

We are pleased to report that the overall performance of water and sewerage companies continues to improve….We have also seen widespread improvement to asset management, enabling quicker action to reduce pollution, and companies have invested in improving flood risk management. This shows a commitment to public wellbeing, resilience of the service to customers and protecting the wider environment.

Your average punter, not necessarily well-versed in the data or the politics, might wonder where the truth lies. You will not be surprised to hear that, as with much of the stuff we read in the media, by and large they are all correct, although each party emphasises the parts of the report that suits their aims. The Angling Trust is a lobbying organisation who actually took the government to court for an inadequate response to EU legislation on improving water quality (The Water Framework Directive); Water UK – well, whose side do you imagine they are on? And finally the EA who seem to have produced a fairly balanced summary in their blog. In her introduction to the report, Emma Howard Boyd, Chair of the EA highlights this apparent discrepancy:

All of this could lead you to believe that England’s water is in dire straits, but water quality is better than at any time in over a century, thanks, in part, to the hard work and investment of water companies.

Maybe now is the time for me to declare a past interest. I worked for Yorkshire Water for 26 years, initially as a Pollution Prevention Officer on the Aire and ultimately as Head of Safety Health and Environment in which role I had strategic responsibility for monitoring and challenging the company’s environmental performance and negotiating at regional and national level with regulators including the EA. So I claim to know a bit about both sides of this story and let me tell you that the River Aire, along with most of Yorkshire’s rivers, has been transformed since 1974 – have a look at this film for a bit of an insight. 

I want to start my comments with a typical headline “Serious pollution incidents on the rise”. Since the reported peak of 135 incidents per year  in 2005, such Category 1 & 2 incidents have fallen to 52 with a year-on-year reduction for the last 5 years. There have never been fewer pollution incidents per year! Yes, there has been a disappointing increase in the most serious incidents (from 9 to 11 – I am surprised that nobody headlines this “22% increase in serious pollution”) and the target should certainly be zero. If you want to put this in context, the companies are responsible for tens of thousands of kilometres of sewers (taking away your waste) and thousands of sewage works (treating that waste); add to that the water treatment and supply network (yes, they can cause pollution too) and the possibilities for infrastructure failure should be all to obvious. This is not to excuse the companies, because they certainly could do better and the fact that they have spent £billions improving the systems which were miserably neglected by the predecessor local authorities has certainly helped.

Please click on the table below to show all of it – it’s a big image!

Water company environmental perfomace details from EA repeort 2017Fortunately for The Aire Rivers Trust, we do not live in the South West, for SW Water has an ongoing record of poor compliance and, taken with Northumbrian Water they are responsible for most of the current headline issues. According to Table 1 in the report, our regional company, Yorkshire Water, has maintained or improved performance against all of the targets reported on in this report, although there is still room for improvement to meet the future aspirations of the EA and ourselves. Those aspirations for the future are admirable:

Performance expectations 2015 to 2020
In 2013, we set out to the water companies our expectations in a number of areas, including their operational performance. We give the full list of expectations in Annex 2. Below are our expectations of companies that are directly relevant to the EPA. We expect:

  • a plan in place to achieve 100% compliance for all licences and permits
  • a reduction in category 1 and 2 pollution incidents, trending towards zero by 2020
  • a trend to minimise all pollution incidents (category 1 to 3) by 2020 with at least a third reduction compared to 2012
  • high levels of self-reporting of pollution incidents with at least 75% of incidents self-reported by 2020
  • that management of sewage sludge treatment and re-use should not cause pollution and must follow the Sludge (Use in Agriculture) Regulations and the Code of Practice for Managing Sewage Sludge, Slurry and Silage or Environmental Permitting Regulations (EPR)
  • environmental improvement schemes to be planned well and delivered as agreed (for example, Asset Management Plans and Water Resource Management Plans)
  • security of supply outcomes to be achieved as defined in Water Resource Management Plans

We will continue to work with out regional company, Yorkshire Water, to achieve these aims, whilst holding them to account where necessary. If you want to help in this important work improving the environment, then get in touch and ask about volunteering opportunities.

Walks around Bradford’s Becks

Friends of Bradford’s Becks have just published a (FREE!) guide to a series of walks around Bradford’s Becks. The booklet contains detailed guides to several walks around the area as well as background information on the becks, the wildlife to be found, the history of the beck and how to keep our watercourses clean. You ccan download a copy by clicking on the image to the left or by sending your name and address along with a 56p stamp to:

Friends of Bradford’s Becks
c/o Kirkgate Centre
39A Kirkgate,
Shipley BD18 3EH

 

Cleaning up the debris after the floods

ADRI 280216
Mat Holloway and the many volunteers has has recruited and organised have been doing a magnificent job cleaning debris from the river banks after the recent flooding. Word of his work is spreading and support has been requested from the Sikh community in Leeds who want to clean up the banks near their ashes disposal point.

The latest effort will be held on Sunday 28 February as per the attached flyer. Maybe YOU can find a couple of hours to go along and help?

Clean up the Aire

Aire cleanupSo impressed at how many individuals and organisations are banding together to clear the debris left behind by the flooding.

As it says at the bottom of this poster, be careful near deep and/or flowing water and be careful about picking stuff up (use strong gloves to prevent puncture wounds).

We have a small amount of kit that will help if you get in touch and will have an advice note ready in a few days time.

Improve the Environment Agency, don’t scrap it

I have a lot of respect for Dieter Helm, but on this suggestion ,that we should remove the flood defence responsibilities from the Environment Agency he is jut plain wrong.

Yes, there are challenges facing the flood risk people, but separating them for the rest of the organisations accountable for the water environmemnt is not the answer. The FRM people already face enough challenges liaising with the rest of the EA and ensuring collaborative outcomes, separating them and putting them in some other agency can only make that worse.  Much of the recent moves to seriously considering upland management techniques instead of/as well as engineering solutions has come about because of pressures from those of us who take wider issues that simply FRM into accountOne of his arguments is that “…developers could continue building in high-risk flood locations knowing they would be prioritised for flood defences. ” Well that is not the EA’s fault – they do not grant planning permission. It’s the planning authorites who need to be instructed, not encouraged, to refuse planning permission on flood plains. And of course soem of those planning authorities are also flood risk managemen,t authorities themselves – it’s not all the EA’s responsibility.

On the other hand he does at least support the catchment-wide approach “Flood risk would be managed across river catchments, balancing defences with other measures such as incentives for farmers to store water on their land.” But why we have to pay farmers compensation for having their flood plains flooded bemuses me; farming on flood plains is so productive precisely becasue they flood and every flood brings new rich silts to enrich the soils.  The whole system certainly needs more connectivity and some of the many schemes through which EU money is handed out to farming need better integration with wider catchment benefits. Single interests such as farming, grouse shooting, fishing, should not be considered in isolation from the rest of the users of the river and its’ catchment.

River AIre Fact File

Just found this archive document produced by the Environment Agency “River Aire Fact File”.

It is a little out of date – not quite sure how old – but very interesting all the same as not much has changed since it was produced and the base data about the river and its catchment is still valid. However a LOT has changed over the centuries…

“Until the 17th century, the river was used as a source of drinking water by the people of Leeds. The onset of the industrialisation soon made this a hazardous pursuit.

At the turn of the 19th century, salmon could still be caught in the Aire downstream of Bradford. By 1825 though, the river was nearly devoid of life and remained so for another 100 years.”

Flooding – possible responses

CIWEM Flood PolicyFollowing the flooding on the Somerset Levels (guess why they are called ‘levels’?), the premier professional institution in the arena – Chartered Insitution of Water and Environemntl Management – published a policy paper on the subject of flood risk management. That report followed some of the heaviest rain on record; we have just experienced rainfall way above that previously recorded, so the conclusions have particular resonance for us today. I quote below the Foreword as an introduction to the topic and in anticipation of calls for more dredging of rivers. The full document is available here.
The Aire Rivers Trust is ready, willing and able to contribute to preventing and/or alleviating the worst effects in the future.

It is only right that we respond compassionately to the severe difficulties faced by communities. But as water engineers, environmental managers, wildlife enthusiasts and anglers we are uneasy about the lack of science and evidence in public debate that  surrounds the recent flooding and what might be done to mitigate future losses. In particular, claims that the widespread use of dredging can act as a flood prevention measure are not only unsupported by both science and evidence, they are a cruel offer of false hope to those living in flood prone communities. That is why we are calling for a ‘reality check’ on flooding and dredging.

The public debate has of course focussed on the plight of those on the Somerset Levels – a landscape where farming maintains rich wetland habitats and where water level management underpins both. Our review of the Environment Agency’s modelling results suggests that dredging of the Parrett and Tone rivers could make a difference in the duration of flooding, but would only have had a limited impact on the extent and height of the floods. That’s why the local Internal Drainage Board and others propose such works as part of an integrated package that includes measures to increase resilience and support for those seeking to relocate.
More generally, this report shows that dredging is not a universal solution to flooding. Numerous studies dating back to the 1980’s have shown that dredging can speed up flow and potentially increase the risk of flooding downstream and have devastating unintended consequences for wildlife and people’s homes and businesses. The ways in which we can get the best from our rivers by working with nature are discussed in an opinion piece accompanying this report, written by Tony Juniper.
That is not to say dredging has no role to play. It can reduce water levels on a local scale and may be critical to flood risk management in key locations; that’s why the Environment Agency spent £45 million on channel maintenance in 2012/13.2 However, dredging cannot hope to prevent flooding caused when heavy rainfall results in flows that vastly exceed the capacity of the river channel. So we are calling for a more solutions-focused debate. We know that extreme rainfall is the driving force of the flooding we are witnessing: the Met Office’s statistics show that Southern England had its wettest January, 200% of its long term average, in records going back to 1766. Climate change is only likely to make such extreme weather events more common. At the same time, development on floodplains puts more people at risk, while compacted soils and damaged uplands channel more water down the catchment at a faster rate. Without a change in approach, it is inevitable that low lying land and communities will be exposed to greater risk of flooding.
But there is an alternative. In recent years many studies and practical schemes have pointed the way to more effective methods for controlling flooding, by slowing the rate at which the landscape drains, and increasing its capacity to capture and store water. Working with nature, rather than against it, is sustainable both in terms of monetary cost and environmental impact. Restoring wetlands, planting wet woodlands, encouraging rivers to meander over the floodplain and creating ‘upstream’ holding areas and buffer strips are just some of the ‘slow water’ techniques which allow time for underground reserves to fill and prevent flash flood peaks racing downstream. These approaches also deliver improved habitat for wildlife, better quality water and a range of other benefits that impact positively on people and businesses.

Such solutions – as well as proven ‘hard’ and ‘soft’ engineering – must lie at the heart of future strategies for mitigating flood risk. A catchment based approach provides by far the best platform for developing these strategies, in partnership with stakeholders, including local landowners and land managers, and gives us the best chance to respond to the ever increasing threat of extreme floods as our climate changes.