May 2022
Our water environment is in a critical state.
No waterbody in England currently meets good status for chemicals, and only 16% meet a good ecological status. This means that not a single English river, lake, estuary or coastal water is in overall ‘good’ health. The government failed to meet an initial legal target for all waterbodies to be in ‘good’ health by 2015, and recently missed the second 2021 deadline.
Globally, freshwater species are declining more rapidly than any other group. In the UK, 13% of our freshwater species are threatened with extinction, and 90% of our wetland habitats have been lost in the last 100 years. Parts of England are projected to run out of water in the next 20 years, with the UK’s total water supply forecast to drop 7% by 2045 due to climate change and sustainable abstraction limits.
Ambitious action is clearly needed to turn this around.
On 16th March, the government published their proposals for legally-binding targets under the Environment Act which aim to drive action to protect and enhance our natural world. These included four targets for water. These are welcome, but do not go far enough. The way these targets have been defined and set lack ambition, focusing on what can be achieved, rather than what the environment needs.
Agriculture
Agriculture is the sector responsible for the greatest number of failures against water standards (‘Reasons for Not Achieving Good’).
In this context it is not clear whether a 40% reduction in agricultural pollution will be enough to return many if any rivers to good health. A national target defined in this way could be met in aggregate, but where reductions are easiest and cheapest rather than where they would be most beneficial. Instead, targeting by catchment would help to ensure that action occurs where it will deliver the greatest ecological gains, and equally that effort isn’t wasted; in some locations pollution may already be limited, and further reductions would be a burden on farmers for no discernable environmental benefit.
The inclusion of sediment is particularly welcome, as this will drive improved soil management and support farm resilience, but the achievement of ambitious and ecologically-meaningful reductions in agricultural pollution will also require strengthened farming regulation, practices and incentives.
Wastewater
Treated wastewater is the source of up to ⅘ of phosphorus entering rivers nationally, so a target that drives action here is welcome. This target appears to be one of reasonably high environmental ambition. Again, there is a question of prioritisation - a blanket 80% could see action prioritised where reductions are cheapest, rather than where it delivers against the greatest environmental needs.
The target does provide some flexibility for water companies to adopt nature-based and catchment solutions rather than focusing on expensive and chemical-intensive treatments at the works themselves. However, it does nothing to explicitly encourage these; elsewhere the lack of certainty around what nature-based solutions can deliver can be a barrier to their use. The long-term nature of this target should provide ample opportunity to identify, develop and implement schemes in the earlier years of the target window, and then build upon these in latter years if they do not perform as hoped. This would bring knock-on benefits compared to more traditional solutions. Instead of more chemical dosing to remove phosphorus we would like to see nature-based approaches adopted as much as possible, such as new wildlife habitat created as part of Integrated Constructed Wetlands.
The target also misses the opportunity to tackle other key components of wastewater pollution including nitrogen, emerging chemical pollutants, and anti-microbial resistance - perhaps topics for future targets? It also excludes untreated wastewater from Storm Overflows, so must avoid overshadowing targets being set under the Storm Overflows Discharge Reduction Plan, as a lack of progress here will severely alienate stakeholders.
Abandoned mines
Again, a target to drive action on a problem that has seen limited progress to date is welcome. But as a target representing ‘chemical pollution’ it covers only a small subset of the plethora of chemicals impacting our waters, and then only proposes to reduce the problem by 50%; this seems inadequate.
Regulations require that a large number of our waters are restored to Good Status by 2027 under the next round of River Basin Management Plans so this is the target which will already have been set for many of the waters affected by abandoned metal mines. This target should therefore build on that baseline and restore the remainder in the decade that follows, i.e. a target of 100%.
Water demand
We are pleased to see, for the first time, a proposal for a statutory water demand reduction target. We face a 4 billion litres per day shortfall if we want secure water supplies and a healthy environment. A statutory target on the government reflects the fact that success requires a cross-societal effort, including supportive policy action. We are also pleased to see the target covers water used in hotels, offices and other non-domestic buildings, as well as household consumption and leakage.
However, the proposed demand target is defined per capita, which means population growth could potentially negate all the potential benefits for the environment. If population growth is particularly high between now and 2037, more water could be taken from the environment and the target would still be achieved. A 20% reduction will also be almost fully met by actions already baked into existing water company plans, for example to reduce leakage by 50% by 2050. The target needs to spur additional action, including by the government, for example to bring forward policy to tighten building regulations and introduce minimum water efficiency standards for bathroom products and water-using white goods.
We need an overall water quality target
Critically, the proposals do not include a legal target for the overall condition of our water environment. This is a huge gap, and means that when the drive to achieve Water Framework Directive (WFD) requirements ends in 2027, we’ll lack a legal target to require improvements that build on the WFD’s baseline. There is a real risk that progress could be made on the proposed discrete sector-based targets, whilst overall water quality and environmental condition doesn't improve - or worse, declines.
We need a new, more ambitious outcome-based target for the overall condition of rivers, streams and smaller water bodies to drive improvements for our waters and the wildlife they sustain. This should set a goal for overall waterbody health by 2037 that encompasses the above targets and builds upon the existing 2027 WFD requirements. Such a target would drive holistic catchment-wide action to improve water quality, rather than siloed activity by individual sectors to tackle target pollutants where progress is easiest.
Expanding this focus to consider our water environment more holistically is crucial if we are to see its biodiversity recover. As the Environmental Audit Committee recently noted, “Improving the quality of the water in rivers in England should be considered a principal objective through which the Government and public bodies can deliver on the legally binding duty, established in the Environment Act 2021, to halt the decline in domestic species by 2030.”
Put simply, nature’s recovery across freshwater, wetland, estuarine and coastal habitats is reliant upon more than just reducing specific pollutant loads. It requires a more comprehensive approach that systematically addresses and removes the Reasons for Not Achieving Good so that waterbodies can recover.
We currently await the publication of evidence packs from Defra to accompany the proposed water targets. We will scrutinise this extra detail once published, and update our analysis.
Ali Morse is Water Policy Manager at The Wildlife Trusts. Nathan Richardson is Head of Strategy and Policy at Waterwise. Daniel Johns is Managing Director at Water Resources East.
Follow: @WildlifeTrusts & @Waterwise & @WaterREast
The opinions expressed in this blog are the author's and not necessarily those of the wider Link membership.
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