Mr Rod Cutler                            WQR0010

Written submission from Mr Rod Cutler

1              Executive Summary

This is a submission to the call for evidence 338 – Water Quality in Rivers.  It addresses the questions asked:

This document provides evidence of pollution in the Colne Valley and how water quality continues to decline. It shows how the work done by citizen science groups can be used to:

It proposes changes to the way water companies and statutory environment agencies respond to citizen science groups and how such responses can be monitored.

2              Introduction

I work with the Colne Valley Fisheries Consultative (CVFC) in different roles and have done so since 2016. I write software applications for:

These can be found on the CVFC website ( and are in the public domain.

I am also a riverfly monitor on the River Colne and a trained riverfly tutor, coordinating riverfly monitoring on the upper stretches of the river on behalf of the Chilterns Hertfordshire and Middlesex riverfly hub.

2.1              The Riverfly Partnership

The Riverfly Partnership is a national collaboration of organisations and individuals working together to record the health of and protect our waterways and consists of anglers, conservationists, entomologists, scientists, water course managers and statutory agencies.

It is committed to furthering the understanding and conservation of riverfly populations.


2.2              Riverfly Monitoring

The Anglers’ Riverfly Monitoring Initiative (ARMI) is a citizen science initiative in which trained volunteers monitor water quality using a standard method to identify the abundance and groups of river invertebrates. The presence of invertebrates in our rivers is one of the best indicators of water quality.

Eight species in particular with different levels of tolerance to pollution are monitored monthly at hundreds of sites on UK rivers by trained monitors. This data is readily available to members of the public and provides historical as well as current data for comparison purposes.

Pollutions can be immediately identified in the recent history of the river by the sudden and dramatic changes in recorded abundance of river flies in these counts.

2.3              Colne Valley Fisheries Consultative

CVFC is a membership organisation open to local riparian owners, angling clubs, holders of fishing rights, private and commercial fishery managers, local government and environmental groups and anyone having an interest in aquatic habitats in the Colne Valley catchment.

Most of the people working in CVFC are trained riverfly monitors and dedicate their time to understanding the impacts of pollution and seeking resolutions. One of the many projects CVFC is involved in is to engage professionals to analyse chemicals in the waters of the River Colne and identify the pollution sources. This work has resulted in some surprising outcomes and will soon be published.

CVFC has a pollution reporting application on its website providing written and photographic evidence of over 120 pollution events between 2016 and 2020. CVFC can also show how invertebrates have declined over the same period from monthly records provided by riverfly monitors, also available from its website. 

CVFC run a non-native invasive reporting system for members of the public and has identified several non-native species. The data collected by this application has resulted in joint projects with other organisations which have reduced the spread of non-natives in the Colne Valley.

3              Water Quality

Ecological Status is classified in all Water Bodies and expressed in terms of five classes (high, good, moderate, poor or bad). Originally based on the European Water Framework Directive, these classes are established on the basis of specific criteria and boundaries defined against biological, physico-chemical and hydromorphological elements:

The overall ecological status of a water body is determined by whichever of these assessments is the poorer. For example, a water body might pass ‘Good Status’ for chemical and physico-chemical assessments, but be classed as ‘Moderate Status’ for the biological assessment: in this case it would be classed overall as ‘Moderate Ecological Status’.

To achieve the overall aim of good surface water status, the directive requires that surface waters be of at least good ecological status and good chemical status. To achieve High Status, the directive requires that the hydromorphological quality elements are also in place. For lower classes, although hydromorphological quality is not explicitly required, it is a supporting element of the biological and in some cases physicochemical status and must therefore be taken into account.

Chemical testing gives a precise assessment of the current chemical makeup of a river’s waters at the time of testing. However, ecological impacts are likely to linger long after pollutants have washed down a watercourse. Therefore, biological monitoring, such as river fly monitoring, is indicative of past pollution events and provides a history of water quality over time, often showing how pollution washing down a watercourse not only impacts the immediate area but further downstream.

Routine monitoring done by statutory agencies is typically taken on a rolling programme. Some years are not monitored at all and often only at a few selected sites. Unlike biological monitoring done monthly on several sites by riverfly monitors, this does not provide sufficient data or identify the type of pollution events that can cause the decline in invertebrates.

From experience, data collected by riverfly monitors is not often used by the Environment Agency or followed up when monitoring results fall below the expected target. This in part has to do with funding and a reduction in monitoring activities. 

3.1              Biological Impact of Pollution

The eight groups of invertebrates previously mentioned are sensitive to pollution and therefore indicate the water quality of a river by their presence, absence or abundance. Although there are some seasonal variations, this is unlikely to affect multiple groups at the same time. As they tend to remain in the same place, any drastic decline in their numbers is likely to be the result of pollution or changes in rivers and not due to a migration. Invertebrates are at the bottom end of the food chain, so what affects them will also affect those animals feeding on them such as fish and water fowl.

A secondary result of reduced invertebrates is the reduction in dissolved oxygen. Leaves and other organic material that biodegrade in water require oxygen. When sufficient numbers of invertebrates are available, particularly fresh water shrimps (Gammarus), they eat organic material such as leaves that are excreted as partially digested faeces pellets. These act as a fertiliser for certain plants that subsequently produce oxygen. This natural cycle balances oxygen demand resulting in healthy water bodies.

Invertebrates not only reduce the amount of oxygen consumed by decomposition, but also the nutrients that feed unwanted algae growth during the summer months.

Serious pollution events that reduce invertebrate numbers or completely destroy them can take years to recover and be far less obvious to the casual observer. Unlike dead fish that are easily recognisable and often reported by members of the public, only riverfly monitors will normally notice such intimate changes.

Successive minor pollution events that go unnoticed can be as devastating as single major pollution events. This is the case for example when sewage from a few residential properties enters a river due to misconnected pipe work.

Again, riverfly monitoring often identifies a steady decline in invertebrate numbers in the early stages. Examples of such events and how they have been resolved are available on CVFC’s website and show how CVFC has directly contacted water companies to clean up pollution.

3.2              Monitoring Pollution

Although riverfly monitoring is a tool that quickly identifies the biological impact of pollution, identifying and recording the source of pollution is equally important. Although certain pollution events may not be obvious to members of the public, the majority provide a visual indication or an unpleasant smell and can easily be recognised.

CVFC funded and pioneered an application in 2016 that allows angling clubs and members of the public to record pollution events and photographs without constraint. All data is in the public domain and can be viewed or downloaded as required without being restricted by having to register or enter passwords.

Originally intended for use in the Colne Valley, CVFC has upgraded its software (NPR) for national use and is working with the Angling Trust to launch the new software in February 2021. Due to its design, users can enter reports and photographs easily using mobile devices or PC’s.

3.3              Obstacles to Improving Water Quality

One of the main causes of pollution in waterways is sewage from combined sewer overflows (CSO) and sewage treatment works (STW) managed by UK water companies. CSO’s are necessary to avoid storm water and sewage water backing up pipes to peoples’ homes should they become blocked or overwhelmed with water. STW are required as a way of discharging untreated water in times of flooding.

It is estimated that over 20,000 CSO’s exist, many routinely discharging untreated sewage due to bad management practices.  The fines imposed are minuscule compared to the dividends paid to shareholders by water companies and provide no incentive for change.  As the Environment Agency has cut the number of visits to pollution incidents, the situation is not likely to get better as less pollution events will be investigated due to limited resources and funding.  The water companies are expected to self monitor and report failures of their systems so regularly report as one event a succession of repeated events over a period. Self-monitoring was warned against by the RFERACs when the change was proposed in the first decade of this century. Under pressure from government the change was adopted and the condition of our rivers has not improved and continuous pollutions are now the order of the day on many rivers.  Self-monitoring has become the byword for controlling industrial outputs to the environment as can be seen in the recent Permit EPR-QB3092NR for the disposal of waste water from the HS2 tunnelling through the Chilterns, which the EA is trying to persuade us means there will be no pollution of the aquifer in Hertfordshire and Buckinghamshire by the HS2 operations.

As water abstraction has also increased to meet the demand for new housing and industrial processes in urban areas, river levels have become much lower in summer months than ever before, and in some cases, dried up altogether. Reduced river levels compound the impact of pollution due to a lack of dilution.

Other sources of pollution include:

4              Conclusions

Since the introduction of the Water Framework Directive as a comprehensive river basin management planning system in 2000, water quality has been determined by five ecological classes. These directives have served the UK well and are understood by statutory agencies and citizen science groups alike. They have provided a lot of data about of our water quality over several years and can continue to provide consistent water quality data for the Environment Bill.

To change these five ecological classes as the prime method of reporting water quality would not only put us out of step with the long established and understood methods introduced by the European Union, but would require another method of accessing water quality that risks not providing a direct comparison with historical data. It would be pointless to change these five classes as it could only cause confusion; however, obtaining the data used to access water quality from a more reliable source would provide a higher degree of reporting accuracy.

The following addresses the question asked:

Biological monitoring done by the Riverfly Partnership is one of the best indictors of water quality and should be used to determine water quality under the Environment Bill.

As stated, biological monitoring is not only the best guide to water quality, it is regularly carried out by volunteers not constrained by resource or budgets and often funding their own monitoring equipment. The data is more abundant and accurate than data produced by statutory agencies and freely available from the Riverfly Partnership. Therefore, statutory agencies should use riverfly data results for all river basins as the only indicator of biological water quality. Not only would this proposal provide better data, it would not require statutory agencies to do their own biological monitoring and therefore free up some of their resources and budget.

Data collected by members of the public willing to give up their time is more trusted by the public and less complicated to obtain.

The following addresses the question asked:

As can be seen from several examples in the media, relying on water companies to report sewage discharges without permits or warn the public prior to discharging can at best be called suspect. Unfortunately statutory agencies are constrained by budget and staff cuts and virtually powerless to effectively investigate and prosecute in a meaningful and positive way. Unnoticed discharges from misconnected sewage pipes as previously described, compound the problem.

For these reasons, the current monitoring and reporting around water company discharges are inadequate.

The following addresses the question asked:

Given the estimated 2.9 million anglers and others such as walkers etc. using UK watercourses for recreational purposes, are the people that see pollution events and are directly impacted by them. Many of these are members of the Angling Trust and aware of the Trust’s initiative to fight pollution in our waterways (Anglers Against Pollution).

As more fishermen and others become aware of this initiative, they will be able to use it to provide pollution reports and photographic evidence using mobile devices. This type of technological approach will:


January 2021