Some aspects of the plan are welcome; a proposed ban on plastic wet wipes, which block sewers, and £1million per year to restore beautiful and globally-rare chalk streams. But overall, the plan seems to be a list of disparate pledges, rather than the coherent approach that’s needed.
Prior to publication we set out five things we hoped to see. So how does the plan measure up?
1. Increased funding for monitoring and enforcement
Government says it is increasing the Environment Agency’s enforcement capacity “by boosting their budget by an extra £2.2 million a year”. This goes only some way to reversing past cuts, with around 40% of staff cut from the non-flooding part of the agency between 2008 and 2017, according to this report. The plan commits to more funding for inspections of water companies and to reviewing permit charges to further boost budgets. In addition, we suggest companies should be required to fund the agency’s monitoring, moving us away from past abuses of ‘operator self-monitoring’, not to mention the continued mistrust associated with ‘marking your own homework’. Annual funding for farm inspections and advice had already been boosted and looks set to continue, supported by grants for improved slurry management and better controls on fertilisers. But the worrying absence of any mention of the ‘Farming Rules for Water’ suggests we remain a long way from full compliance of regulations to prevent agricultural diffuse pollution. Measures to tackle farm pollution are simply not good enough.
On monitoring, the picture is perhaps more positive. The Natural Capital Ecosystem Assessment programme will deliver a larger, broader and more accessible evidence base which can only be helpful to underpin catchment planning.
2. Clarity on how Environmental Land Management schemes will be targeted to improve the water environment in line with Environment Act targets
The no.1 priority in the plan’s list of areas crucial to transforming the management of the whole water system is ‘Farming and our rural landscape’. This recognises that anything that happens in the catchment of a river, lake, pond or wetland can affect that waterbody and, since 70% of our landscape is farmed, reducing the negative impacts of unsustainable land management practices will be vital. To do this, Government aims to increase uptake of farm environmental schemes to cover 70% of farmland by 2028; a target that could see great gains for our waters – but only if the right measures are offered and implemented. Farmers will be incentivised to enhance protected sites and create nature-rich buffers alongside waterbodies to provide space for wildlife and protect rivers from run-off. These are positive ideas but lack the detail for us to understand how they will help halt the decline of species by 2030. Plus, it remains wholly unclear how schemes will ensure that farm pollution is reduced by 40% in line with Environment Act targets. In all, there is ambition here, but certainly not enough detail.
3. Local Nature Recovery Strategies informing all aspects of improving the water environment, to provide multiple societal benefits including nature’s recovery
The plan speaks of aligning everything – from the policy and legal framework right down to delivery – with Local Nature Recovery Strategies, to make sure actions have the biggest impact. On the face of it this is welcome and must focus not just on where to implement nature-based solutions, but also on priorities for nature protection and restoration. How this will be done is clearer for some areas than others; Tailored long-term catchment plans should ‘include priorities identified in Local Nature Recovery Strategies’, but it isn’t clear that the same approach will apply to farming. How will the strategies be used to determine where action under ELMS should be deployed to benefit nature? This is a big omission.
4. A hierarchy of delivery options that puts nature-based solutions first, to be adopted across relevant investment programmes including water company and flood risk.
The acceleration of £1.6bn of investment to protect water supplies and improve water quality is welcome. But so far, most of these schemes rely on concrete, chemicals and single-issue solutions. Ofwat said it had also ‘identified a further 37 schemes totalling £1.5 billion that could progress in 2024’ but which don’t yet meet its assessment criteria. Many of these are nature-based solutions that could deliver improvements in ways which are more affordable for customers and better for wildlife. We need to accept that such schemes may not always give 100% certainty on outcomes but are worth implementing anyway because they can take us a long way in the right direction, and their wider benefits are so significant. Currently, they are far from being top of the hierarchy and this must urgently change.
5. Fully embedding a catchment-based approach, including by supporting Catchment Partnerships
Front and centre within the plan is a recognition that the best way to manage water supply and pollution pressures is by taking an integrated approach across a whole catchment. This may sound basic, but it’s lacking from many current policies and plans. Today’s plan commits to more funding for catchment-scale partnerships that ‘coordinate action and investment where the river needs it most’, and the delivery of catchment action plans backed by new funding to improve all water bodies in England. Money from water industry fines – via a new Water Restoration Fund – will support water improvement projects. This is of course welcome, but funding dependent on first causing harm will not get us far enough. If it’s the prime source of funding it needs to be substantial enough to not just repair harm, but also to make improvements. Otherwise, we will be running to stand still. It would also suggest that Government isn’t putting its money where its mouth is – many a warm word, but perhaps not much in the way of cold hard government cash – is that sufficient?
