Mr Gary Cyster WQR0062
Written evidence submitted by Gary Cyster MIFM
This has been written in the hope that it will be of service to all those concerned with the problems of water pollution, but who are not specialists in freshwater biology. These are the opening words of Professor H.B. N Hynes classic work The Biology of Polluted Waters first published in 1960. The book was essential reading for all those concerned about pollution and those like myself who worked to protect the water environment and its unique ecology.
At that time many of the rivers referred to in Professor Hynes book were still grossly polluted. Indeed the River Tame, a tributary of the River Trent and the River Churnet, a tributary of the River Dove were considered amongst the most polluted in Europe. The Water Act of 1973 established 10 new regional water authorities and investment in improved treatment of sewage discharges brought about steady improvements in river water quality.
In 1976 I began a career in Environmental Science with the Severn Trent Water Authority as a Fisheries Technician working in the River Trent catchment. The River Tame and Churnet were still polluted but the gradual cleaning up of those rivers led to the recovery of fish populations and by 1985 those rivers were able to support fish populations. At that time I was working as a Fisheries Inspector on the River Dove and part of the Trent Salmon Study group with a view to reintroducing Atlantic salmon to the River Trent. This was starting to be seen as a possibility with continued improvements in water quality.
The privatisation of the water industry in 1989 saw the separation of water and sewage services and the monitoring of those discharges and led to the formation of the National Rivers Authority (NRA). The Fisheries function was transferred to the NRA and I became a Senior Fisheries Inspector in the Upper Trent catchment. The formation of the NRA as the environmental regulator was viewed as positive move by the majority of people working in Fisheries, as water authorities were now no longer a part of the enforcement process in monitoring their own discharges.
Water quality continued to improve and in 1995 the NRA published a report into the feasibility of reintroducing Atlantic salmon to the River Dove via the River Trent that concluded conditions in the Rivers Trent, Dove and Derwent were suitable for the re-establishment of salmon. However the NRA was short lived and in 1996 the functions of the NRA were taken over by the newly created Environment Agency.
The early years of the Environment Agency saw the return of salmon to the River Trent with the first stocking taking place of salmon parr from the Kielder Hatchery in 1998 and in 2001 the first returning adults were observed leaping a weir on the River Dove. All good. But a major reorganisation in 2002 aimed at introducing modern regulation of waste with the implementation of BRITE (Better Regulation Improving the Environment) was what I believe to be the beginning of the steady decline in monitoring river water quality and in enforcing the laws designed to protect our rivers.
I retired as a Fisheries Technical Officer in 2011, after 35 years of service for the Environment Agency and its predecessor bodies. Having worked on the front line investigating the impact of pollution of our rivers and assessing the damage I hope you will consider the content of this report and its evidence. We badly need a change in direction if we are to protect our rivers.
This document is in response to the Environment Audit Committee inquiry into water quality in rivers opened on the 8th December 2020. This evidence based report examines the implications of the deterioration in water quality in rivers and the reasons for this from the perspective of a former investigating officer of the Environment Agency and its predecessor bodies the National Rivers Authority and Severn Trent Water Authority over a 35 year period. I have fished the River Trent for each of the last six decades witnessing the changes in water quality and fish populations. In 2007 I bought a house on the banks of the River Trent and so now able to observe in great detail these changes. The report contains case studies of pollution incidents from combined sewer overflows and sewage works and other untreated effluents investigated in the River Trent catchment. The impacts of these pollutions and the remedial and enforcement actions taken are also examined, together with the costs involved. Finally some recommendations on the reforms needed to halt the decline in the water quality in our rivers.
Water pollution remains a major problem in achieving targets established under the EU Water Framework Directive (requiring all European surface water to reach “good ecological status” by 2015 with a maximum deadline of 2027), which will be carried over in some form to targets under the forthcoming Environment Act. In September 2020 the Environment Agency reported that only 16% of English rivers met good ecological status and no river met good chemical status under the Water Framework Directive classification cycle 2.
The Angling Trust is the national governing body representing all game, coarse and sea anglers and angling in England. The trust insists that the waters we fish are in crisis: “Pollution is the main cause with every water body in England assessed against the Water Framework standard failing and things are becoming worse, not better.
2. Case Studies in the River Trent Catchment.
The River Trent is the third longest river in England at 298 km (185 miles) and its catchment covers an area of 10,452 km 2 (4029 miles 2 ). Major tributaries join the Trent from the Peak District (Dove, Derwent), Central Midlands (Tame and Soar) and the Lower catchment (Torne and Idle). Although 70% of the land use within the River Trent catchment area is agricultural, it is home to around six million people, containing much of the metropolitan area of Birmingham, which is the second largest city in the UK. The other main urban areas of the catchment include the West Midlands conurbation, Stoke-on-Trent, Derby, Leicester and Nottingham. The physical characteristics of the catchment vary significantly, including both low lying ground, such as the broad flat flood plains of the Tame and Trent, and steep dramatic landscape, such as that in the Peak District National Park in the northwest of the area.
From the mid-1990s and through the first part of the 21st century the River Trent catchment suffered some of the worst pollution incidents in England. The many storm water discharges that resulted in untreated sewage entering the river and killing millions of fish in the River Tame and Trent and its tributaries. Cyanide pollutions of the upper Trent and River Anker and diffuse agricultural or slurry, silage and sheep dip pollution on the Rivers Dove, Manifold and their tributaries all contributed to a decline in fish populations across the catchment.
2.1 River Tame and River Trent Pollutions caused by storm water discharges from multiple CSOs.
In the July of 1995 and 2009 the River Tame and Trent suffered two major pollution incidents that caused huge ecological damage. In both incidents very heavy rainfall in Birmingham resulted in untreated sewage from combined sewer overflows (CSOs) entering the River Tame resulting in very large fish mortalities due to low oxygen levels (<2% saturation) and high levels of ammonia. The 1995 incident wiped out the River Tame and killed fish in the Trent below Burton on Trent. The 2009 incident killed fish in the Tame and the Trent downstream of its confluence as far as Shardlow some 50 miles downstream. In both incidents it was impossible to count all the dead fish due to the size of the river in that area but it was estimated that hundreds of thousands of fish were killed in the 1995 incident. In the 2009 incident 5000 dead fish were observed in the Trent between Alrewas and Burton and the total mortality in that area alone estimated at around 20000.
In the 2009 incident the National Rivers Authority (NRA) deployed oxygen injection at Burton on Trent that helped minimise the mortality downstream and following the investigation a Hydrogen Peroxide dosing facility was introduced at Lea Marston, Birmingham on the River Tame in an attempt to protect the river during similar CSO discharges. In the 2009 incident the Hydrogen peroxide dosing was deployed together with other units downstream but failed to prevent fish mortalities in the lower parts of the Tame and in the Trent due to the high Biochemical Oxygen Demand (BOD) of the effluent discharged.
Both mortalities included large mature fish species so not only was there a huge fish loss but also a loss of production in terms of the loss of fish eggs and sperm. For example a mature female barbel can produce 80,000 eggs and a male barbel 90 billion sperm/kg per reproductive season (Policar et al, 2011). The loss of a many mature barbel could therefore have a significant effect on future recruitment to the population.
For this reason the NRA in 1995 and the Environment Agency in 2009 carried out major restocking of the rivers affected using fish produced at its Calverton Fish rearing unit. The 2009 incident resulted in the largest restocking operation ever undertaken by the Environment Agency in England and a 5 year restoration plan was implemented to compensate for the loss of production caused by the pollution. In 2010 22,000 yearling, 61,000 1+ and 550,000 advanced reared larvae of river coarse fish including roach, dace, chub, barbel and bream were introduced to the Trent and the Tame.
In both incidents no enforcement action was taken and the costs of investigation, protection measures and restocking were never recovered. In the 2019 Water Framework Directive classification of the Tame and Trent affected by those pollution and subsequent others is of poor ecological status and failing in chemical status.
2.2 River Trent Cyanide pollution 2009.
In October 2009 a second major pollution occurred on the Trent when an illegal discharge of cyanide into the sewer entered a Severn Trent Water sewage works at Strongford in Stoke on Trent causing untreated sewage and cyanide to enter the river. Public health warnings were issued as there was a risk to livestock and wildlife as the polluted water laced with poison made its way downstream from Stoke-on-Trent towards Alrewas some 22 miles downstream. An investigation was launched into the incident and hydrogen peroxide oxyjet units were deployed in an attempt to protect fish and invertebrates in the river, but the combined effects of cyanide and low dissolved oxygen killed thousands of fish. In 2010 the river was restocked with river coarse fish from the EA Calverton fish rearing unit with 13,000 yearling, 24,000 1+ and 150,000 advanced reared larvae introduced.
The pollution investigation continued and he Environment Agency eventually began prosecution proceedings at North Staffordshire magistrates court in 2012 against Red Industries and a director who operate a waste management and transfer site in Stoke on Trent. They were charged with allowing poisonous, noxious or polluting matter to enter controlled water in breach of sections 85(1) and (6) of the Water Resources Act 1991 and for failing to comply with permit conditions under regulations 38(l)(a) and (b) of the Environmental Permitting (England and Wales) Regulations 2007.
Both the company and the director pleaded not guilty to all of the charges. In early 2013, Red Industries sought to stay the charge of water pollution on the grounds that there had been an abuse of process. It said the Environment Agency’s prosecution was using evidence gathered by Severn Trent Water, which was itself a suspect. That meant there was a conflict of interest. The agency had only stopped investigating Severn Trent itself in April 2010.
Red’s application was successful at Stoke-on-Trent crown court, but overturned on appeal in July 2013.The Court of Appeal said there had not been any allegation of bad faith on the part of Severn Trent Water and it was not argued that a fair trial was impossible. The case eventually went to Stafford crown court. On 14 May 2014, the Environment Agency said it would advance no further evidence on the water pollution charge and the jury entered a not guilty verdict as a result. Following this, the agency initially said it would press ahead with the waste charges but a few days later dropped them altogether. In court, the judge described the Environment Agency’s case as “shambolic”.
Red Industries’ costs were paid through a defendants’ costs order of £1.5 million. The Environment Agency legal costs were about £260,000 and investigatory costs another £140,000. In addition, the initial response to the incident cost £92,000 and restocking of the river with fish has cost £240,000 (ENDS 2014).
In the 2019 Water Framework Directive classification of the Trent affected by that pollution and subsequent others is of poor ecological status and failing in chemical status.
2.3 River Tean Pollution 2014
The River Tean is a minor tributary of the River Dove and is unusual in that it has a large sewage works operated by Severn Trent Water at Checkley discharging treated effluent from the south of Stoke on Trent. Between 1980 and 2014 there were a number of incidents resulting in major fish mortalities downstream of the works discharge. In June 2014 and incident occurred and an investigation revealed a substantial mortality of approximately 1000 fish including salmon, brown trout and grayling. The incident was classified as a Category 1 with major impact to the ecology of the river and attributed to the escape of final settlement sewage at the Checkley works.
The incident was the first in the Trent catchment to involve the death of Atlantic salmon. The Tean had been stocked with salmon parr the previous year with fish from the Agencies Kielder hatchery as part of the project to restore salmon to the Trent catchment. Subsequent electric fishing surveys undertaken on behalf of Severn Trent revealed severely depleted fish stocks immediately below the Checkley discharge with no live salmon captured.
No enforcement action was taken by the Environment Agency and the river was never restocked, even though Severn Trent offered to fund the restocking of the watercourse and the Agency had previously restocked the river following pollutions. The Agency has a world leading river fish fearing facility that produces grayling for restocking rivers where pollutions have occurred.
Following incidents that involve the death of salmonids it is normal to carry out an assessment of the loss of production due to the mortality. The surveys carried out on behalf of Severn Trent did not include this and none was carried out by the Environment Agency. It is astonishing that the Environment Agency did not pursue enforcement considering it was a category 1 incident involving the first deaths of salmon by pollution in the Trent catchment in modern times. Instead the Agency came to an agreement whereby Severn Trent donated undisclosed sums of money to fund sustainable improvements to the river.
In 2016 the Wild Trout Trust carried out a walkover survey to assess areas of habitat improvement. The report commented on the Water Framework Directive classification for the River Tean described as in poor ecological status, because of poor classifications for fish and phosphate. The change from good to poor status for fish between 2009 and 2014 probably reflects a severe pollution event in June 2014, which killed hundreds of trout and grayling and thousands of smaller fish species and invertebrates between Checkley and Beamhurst. It is notable that the measures of organic pollution, ammonia and biochemical oxygen demand (BOD) are only moderate status. (Wild Trout Trust 2016)
There was no mention in the report of the deaths of Atlantic salmon.
In the 2019 Water Framework Directive classification, the River Tean is described as of moderate status, but failing in chemical status. Issues preventing the Tean reaching good status and the sectors identified as contributing to them, are pollution from waste water, towns cities and transport.
2.4 River Trent near Trent Vale 2016.
The River Trent in Stoke on Trent has suffered from multiple pollutions involving untreated sewage entering the river the last 30 years. In September 2016 a major incident that caused a mortality of thousands of fish occurred when sewage entered the river from a Severn Trent sewage pumping station at Trent Vale causing a rapid depletion in oxygen and high ammonia levels. The fish mortality investigation revealed over 15,000 dead fish in 3.7 km of river including brown trout, barbel, dace, chub, roach and eels. The Environment Agency deployed hydrogen peroxide dosing further downstream to reduce the impact and the incident was classified as a Category 1 major fish mortality incident.
The investigation continued but there was no prosecution of Severn Trent. Instead an Enforcement undertaking was accepted by the Environment Agency in 2020. This was a reactive offer whereby Severn Trent Water will contribute £306,509 to Staffordshire Wildlife Trust. (Environment Agency 2020)
Although the Environment Agency recovered its costs it did not think it appropriate to restock the river with fish from its Calverton fish rearing unit. Riparian owners and fishing interest affected downstream received no compensation for the loss of amenity. The offences committed were under the Environmental Permitting (England and Wales) Regulations 2010 section 38(1) operating without an environmental permit (water discharge activity) and 38(2) failing to comply with a permit condition (water discharge activity).
Penalties for offences under the Environmental Permitting (England and Wales) Regulations 2010 include unlimited fines if convicted in a crown court. Considering this was a Category 1 incident and unlimited fines were available on conviction it’s not surprising that Severn Trent would have opted for a reactive offer as a cheaper option.
In the 2019 Water Framework Directive classification, the River Trent in this area is described as of moderate status, but failing in chemical status. Issues preventing the Trent reaching good status and the sectors identified as contributing to them, are continuous and intermittent sewage discharges and high phosphates.
2.5 River Trent at Castle Donington – East Midlands Airport.
East Midlands Airport is the 13th busiest airport in terms of passenger traffic carrying 4.8 million passengers with 77,067 aircraft movements in 2017. The airport is the UK’s busiest pure cargo airport and second only to Heathrow, handling over 320,000 tonnes of flown cargo every year. It is also the UK hub for DHL and UPS, and support operations for TNT and Royal Mail.
One of the main environmental challenges faced is the use of de-icing agents during winter operations. In addition to managing the risks posed by spillages and the storage of chemicals and fuel on site, each year hundreds of thousands of litres of de-icing agents are used, including chemicals to treat apron, taxiway and runway surfaces and chemicals to treat airframes to prevent ice accumulation on departure.
Historically, these materials have caused severe and persistent pollution of the Diseworth and Long Whatton Brooks, with the impact lasting well into summer (Environment Agency, 1997). Over the years a number of options have been considered by EMA to control surface water pollution. Reverse osmosis, absorption by activated carbon and distillation were all considered expensive and/or not technically feasible. Aerobic biological processes were considered the best method of treating storm water containing de-icer chemicals however this process proceeds at a greatly reduced rate at temperatures below 5C and thus not feasible during extreme winter conditions.
The preferred treatment option was the pumping of contaminated surface water to a nearby Severn Trent Water Authority sewage treatment works. Feasibility trials were carried out in 1988 but STWA were not prepared to take the risk of accepting the airport effluent fearing the STWA would not be able to meet the standards set by the National River Authority.
If the contaminated surface water from EMA could be discharges to a large body of water such as the River Trent, the dilution available would be so great that the impact of the intermittent discharge during the winter upon water quality would not be of major significance and prior treatment would not be required (Dimbylow et al., 1996). The National Rivers Authority issued a consent to discharge the surface water drainage during the winter months to the River Trent at Castle Donington and the consent was modified by the Environment Agency on 2nd May 1999.
On site surface water drainage is diverted to summer and winter storage reservoirs. Surface water with a BOD of < 15mg/l is diverted to summer retention lagoons and then is discharged to the Diseworth and Long Whatton Brook. Surface water with a BOD > 15 mg/l is diverted to winter retention lagoons and then discharged to the River Trent.
The expansion of the airport particularly since the runway was extended and cargo terminal opened in 2000 has seen increased usage of pavement and airframe de-icers. Resurfacing of the runway with BBA asphalt in 2016 may also be responsible for additional BOD load. There have been no significant improvements in the treatment of the effluent and the consent issued by the EA enables an effluent high in BOD to enter the river.
The BOD of the effluent entering the River Trent has regularly exceeded that of raw sewage or farm slurry resulting in the smothering of aquatic life and stripping essential oxygen out of the river each winter. The only thing that can survive in these conditions is sewage fungus, the prime indicator of gross pollution (Cover Photograph).
Biological samples taken by the EA in 2017 confirmed that the discharge point has a detrimental effect on the invertebrates and by extension on the ecological water quality of the local area. “The impact only appears to be present when the discharge operates, between November and April. Our invertebrate data for 2017 reflect this clearly with a serious impact evident in April 2017, but a swift recovery to normal levels in May 2017 just a month later”.
In 2018 following pressure from Derby Railway Angling Club the Environment Agency carried out a permit variation to add a condition to ensure that “the discharge to the River Trent, so far as is reasonably practicable, does not have a significant adverse visible effect on the receiving water, the bed of the watercourse or any plants or animals within the watercourse”.
The 2018/2019 winter discharge period was comparatively mild and dry and produced the lowest BOD load discharged to the river in the last 5 years. However this still resulted in the formation of sewage fungus on the bed of the river downstream of the discharge and an immediate breach of the new permit variation resulting in a formal written warning issued to the airport on 19th March 2019.
The River Trent at Castle Donington contains at least seven fish species protected under the European Habitats Directive and UK Biodiversity Action Plan including critically endangered eels in the IUCN Red List of Threatened Species. The River Trent is one of only 5 rivers in the country that contain Spined loach. Spined loach are specialised filter feeders in fine sediments and require the cover of submerged and emergent aquatic plants for spawning and a sandy/silty substrate to bury themselves in. It is essential therefore that any discharge should not damage the special habitat that Spined loach require. Spined loach have been found both upstream and downstream of the discharge site in surveys undertaken by the Environment Agency at Willington and Sawley (Environment Agency, 2014)
East Midlands Airport is allowed to discharge an effluent with a BOD in excess of 400 mg/l to the River Trent by a permit issued by the Environment Agency. This results in sewage fungus smothering the bed of the river for up to 170 metres downstream. This occurs every winter and each incident investigated by the EA has been classified as a Category 3 incident (minor incident).
Severn Trent discharge treated sewage effluent to the river approximately 1000 metres downstream of the airport discharge. Their permit to discharge issued by the EA sets a BOD limit of 40mg/l and does not discharge continuously. East Midland Airport is the only major UK airport with a permit condition on BOD that is allowed to discharge an effluent with a BOD greater than 40 mg/l. In the 2019/20 discharge period the BOD in the effluent discharged to the River Trent exceeded 40mg/l on 29 days, with 12 days in excess of 100mg/l and 3 days in excess of 200 mg/l.
In the winter of 2019/2020 sewage fungus again appeared below the discharge point. The Environment Agency confirmed it would take no action as they did not consider it a breach of the permit. In May 2020 the airport carried out in river dredging in breach of two flood risk exemptions approved by the EA. The works were carried out in the coarse fish close season and gravel was removed from the bed of the river together with macrophytes. The unique micro habitat of protected fish species was destroyed.
The Environment Agency attended the site and concluded “Whilst it cannot be completely ruled out, there was no visible evidence of any harm to protected species at the time of their visit”. The airport was therefore sent a formal written warning for breach of exemption ref. EXFRA007083
In the 2019 Water Framework Directive classification, the River Trent in this area is described as of moderate status, but failing in chemical status. Issues preventing the Trent reaching good status and the sectors identified as contributing to them, are continuous sewage discharges and transport drainage.
It is clear that all rivers assessed under the Water Framework Directive are failing chemical pollution standards. In 2019, combined sewage overflows (CSOs) released raw sewage into our waterways 204,134 times, for a total duration of 1.53 million hours. The Environment Bill will place a statutory requirement on water companies to produce drainage and sewerage management plans to help deliver more of the actions needed to address the risks sewerage assets may pose to the environment. But as I compile this response the Storm Overflows Taskforce – made up of Defra, the Environment Agency, Ofwat, Consumer Council for Water, Blueprint for Water and Water UK – has agreed to set a long term goal to eliminate harm from storm overflows.
However the water companies are already under obligations to publish much of this data but have failed to do so. At the heart of the problem is the Operator Self-Monitoring regime where the polluter checks its own records and too often polluters are not held to account and are simply getting away with polluting our waters. There is a pressing need for a radical change in protecting our rivers. In the face of climate change with an increase in extreme weather events, it is almost certain we will see more storm water discharges. They will be more often more deadly and contribute to the damaging eutrophication of our rivers. The time has come for government to deliver proper regulation, monitoring and enforcement to protect the water environment.
When the water industry was privatised in 1989 the UK population was 57 million and reached 66.8 million in mid-2019. It is predicted to reach 69.6 million by mid-2029 (ONS 2020). More people more sewage. Discharges from CSOs were killing fish in 1989 and they are still killing fish. Untreated effluent is allowed and indeed permitted by the EA to enter our rivers and the sources of pollution referred in the case studies still present a threat to the ecological status of those rivers.
During the Covid-19 pandemic the Agency only attended Category 1 incidents or incidents of public concern. There was a 63% drop in the number of reported environmental incidents attended by Environment Agency officers. The largest drop in visits in nominal terms was in the agency’s West Midlands region. There, between the start of April and the end of August 2020, the EA attended 129 reported environmental incidents, 81% less than the 679 site visits that were made in the region during the same period in 2019 (ENDS 2021)
Since 2009 the Environment Agency has seen its budget cut by 63% and has lost 25% of its staff. There is an over reliance on operator self-monitoring with a reduction in sampling to a bare minimum necessary to comply with the water framework directive. In the Trent between Willington and Sawley some 25 km apart there has been no fisheries surveys undertaken and only biological samples were taken below the East Midland Airport following a request to do so from the local angling club. Prior to 2016 no biological samples had ever been taken.
Clearly we need more monitoring including 24 hour monitoring of sewage effluents or other permitted discharges to determine diurnal fluctuations in water quality. As a former colleague once told me “If you want to dump something in the river do it at night”. The Agency has become a reactive investigator rather than proactive and its obsession with cutting down on car mileage has resulted in incidents not being properly investigated. Fisheries and Environment Officers are not encouraged to walk the banks and inspect rivers or develop contacts with stakeholders that do. If you don’t look you won’t find.
There is widespread concern that when there is a major Category 1 incident the agency has increasingly relied on Civil Sanctions or Enforcement undertakings rather than enforce the law and push for stiffer fines. It is no wonder that water companies make reactive offers and hand out money to organisations that come up with schemes that do nothing to improve the water quality or indeed have anything to do with water. These types of sanctions should only be used for minor offences. It is also disturbing that even though the EA has a world leading fish rearing unit, it fails to restock rivers where thousands of fish have been killed and the riparian owners receive no compensation.
English water companies have handed more than £2bn a year on average to shareholders since they were privatised three decades ago. The pay-outs in dividends to shareholders of parent companies between 1991 and 2019 amount to £57bn – nearly half the sum they spent on maintaining and improving the country’s pipes and treatment plants in that period.
Most people who have worked in the Environment Agency will point to the major reorganisation in 2002 aimed at introducing modern regulation of waste with the implementation of BRITE (Better Regulation Improving the Environment) and the beginning of the steady decline in monitoring river water quality and in enforcing the laws designed to protect our rivers.
Rivers do not respect county or political boundaries and you can’t manage them that way. We now have a large multifunctional organisation responsible for protecting the environment but now continually failing to protect the water environment. What is needed is a return to a single authority responsible for our rivers that is properly funded and given the powers to improve our rivers , monitor them and enforce necessary legislation to keep them improving.
Most if not all of the experienced staff who previously worked for the National River Authority have left so we need to recruit and train the future Fisheries and Pollution Inspectors and Area Managers and encourage them to be proactive in stopping the deterioration in water quality.
The Angling Trust has called for better monitoring of our rivers, lakes, canals and coastal waters. Proper enforcement of existing laws and regulations. Stricter penalties against polluters to discourage them from polluting again and a review of existing laws to help close loopholes.
The Salmon and Freshwater Fisheries Act (SAFFA) 1975 is designed to protect fish populations. Part 1, Section 4.1. (Poisonous matter and polluting effluent). It is an offence to cause or knowingly permit to flow, or put, into any waters containing fish, any liquid or solid matter to such an extent as to cause the water to be poisonous or injurious to fish or the spawning grounds, spawn or food of fish. Review of this legislation is long overdue. It is astonishing that if you are a polluter but comply with a permit issued by the EA you will not be prosecuted for this offence.
Dimbylow B., O’Neill D.O. and Pearson J.M. (1996) Surface Water Pollution at East Midlands International Airport. Proceedings of the Institution of Civil Engineers – Transport Volume 117, 2, pp. 106-108
Environment Agency (1997). Local Environment Agency Plan: Soar consultation report April 1997 5.7.2
Environment Agency (2014). River Trent Fish Monitoring Report, Analysis and Reporting Team 2014.
Environment Agency 2020 (reference558) https://www.gov.uk/government/publications/environment-agencys-use-of-civil-sanctions/enforcement-undertakings-accepted-by-the-environment-agency-1-june-to-30-september-2020
Policar T, Podhorec P, V. Stejskal V, P. Kozák. Švinger V, Hadi Alavi V.S.M. Growth and survival rates, puberty and fecundity in captive common barbel (Barbus barbus L.) under controlled conditions. Czech J. Anim. Sci., 56, 2011 (10): 433–442
Wild Trout Trust 2016 https://www.wildtrout.org/assets/reports/Tean%20Walkover_comp.pdf