Friends of the Upper Wye WQR0094

Written evidence from Friends of the Upper Wye

Friends of the Upper Wye

Friends of the Upper Wye (FOUW) formed in July 2020 in response to many media reports documenting the large-scale loss of protected riverine habitat to severe algal blooms occurring all along the river from the headwaters to the coast. We now have over 300 members and have trained around 100 volunteers to become citizen scientists as part of our project monitoring water quality in the catchment twice a week. See FOUW.org.uk.

Executive Summary (Key Points)

Over two thirds of the phosphorus pollution in the Wye catchment comes from agriculture. Nationally, farming is also the sector thought to be responsible for most river pollution.

There are around 20 million chickens in the Wye catchment at any one time.

Arising manures are not well controlled, regulated or their correct disposal/application enforced.

Enforcement of the farming regulations, where statutory, is patchy and insufficient. Most farming regulations are voluntary, and unenforceable.

The cumulative impact of pollution arising from the sudden proliferation of intensive livestock farming in Powys, Herefordshire and surrounding counties has not been documented or researched but some 90% of the globally important Ranunculus habitat in the river has been lost in the last five years.

Failure by the planning authorities involved to properly consider the cumulative effects of agricultural developments is driving the recent surge of diffuse pollution entering the river.

Control measures for river pollution have focussed on waste water and housing development controls which contribute less than 1/3 of all river pollution into the river Wye.

Water protection zones should be used much more widely to clamp down on diffuse sources of agricultural pollution. The regulators will need enhanced budgets and much improved coverage on the ground to enforce any new rules imposed to reduce pollution.

Regulatory discontinuities and failure to cooperate across the England Wales border exacerbates the problem and allows potential pollutants to move around the environment untraced.

Friends of the Upper Wye WQR0094

Agricultural Pollution

The sector responsible for most water pollution in our rivers is farming. National data collection is so poor that figures should be treated with caution.

DEFRA press office says that, in England, 40% of waters are impacted by rural diffuse pollution and 36% of waters are impacted by pollution from wastewater, Sir James Bevan’s official EA figures were both higher.

In urban areas, sewage is likely to be the main polluter but in rural areas it’s likely to be agricultural practice.

In the West Country, where around 80% of the land is actively farmed, intensive dairy production has caused catastrophic pollution incidents when old failing slurry tanks release hundreds of tonnes of slurry into a river causing major fish-kills. West Wales suffers from similar incidents.

Farming operations are so poorly regulated that, on average, in England, a farmer can expect a pollution inspection once every 263 years1. This situation is set to improve because in July the Environment Agency announced that they will recruit an additional 50 Agriculture Regulatory Inspection Officers but we note that these staff are only starting on 18 month contracts. We believe a far larger sustained effort will be required to effectively inspect farms across England. We fear that Wales will lag far behind.

Despite repeated breaches of the new 2018 English Farming Rules for Water, there hasn’t yet been a single penalty issued. There seems to be a cultural aversion to punishing agricultural polluters. The 2021 Welsh Water: Agricultural Pollution regulations only reaching full impact in 2023 contain nitrate but no phosphate provisions and have already been challenged by the NFU.

Without effective enforcement, there is no incentive for farmers to improve their practices. Compliance costs money and puts conscientious farmers at a competitive disadvantage. Farming advice and voluntary schemes are undermined because the carrot needs a stick. Rivers Trusts feel they’re operating with one hand tied behind their backs - they can give support but they need the regulators to wield the stick too.

The Wye Catchment – a case study

The River Wye, once voted the nation’s favourite river, hit national headlines in the summer of 2020 for turning the colour of pea soup due to excessive algal blooms. Suddenly nobody could ignore the ecological crisis that had been brewing in the catchment for years.

1 https://inews.co.uk/news/environment/farmers-pollution-inspection-environment-agency- chemicals-pollutants-659701

Friends of the Upper Wye WQR0094

Algal blooms starve the river of light and oxygen smothering river ecology. The most dramatically visible effect has been the loss of Ranunculus in the river. Ranunculus (water crowfoot or water buttercup) is a beautiful white-flowering plant that has traditionally blanketed the Wye. This special habitat for fish and invertebrates is acknowledged as internationally important in the designation of the Wye as a Special Area of Conservation

All those who know the river best are reporting the same story - over 90% of the precious weed has disappeared in recent years - a frightening loss in a very short time with devastating consequences.

The causes of algal blooms are temperature, low flow, sunlight and excess nutrient. The Wye suffers from excess nutrients and phosphorus is considered to be driving the problem. Given that the temperature, flow, and sunshine conditions for algal blooms are beyond our control it is the excess nutrient concentration that we can and should control to prevent man-made algal blooms from destroying the Wye’s delicate ecosystem.

Aerial photographs taken of the same spot on the Wye, near Foy – the first showing the ranunculus in 2019 and the second showing the complete lack of the plant in 2020.

Friends of the Upper Wye WQR0094

Credit: Angling Dreams (Adam Fisher)

Natural Resources Wales has recently found that more than 60% of the Welsh sections of the Wye Special Area of Conservation failed phosphorus limits, stating that: “Phosphorus pollution is known to cause the process of eutrophication in rivers, a highly problematic issue that causes excessive growth of algae, which smothers and blocks out light for other aquatic plants and animals.”2

Source of the nutrients

The majority of the phosphorus in the Wye catchment - over two thirds - comes from agricultural sources. Environment Agency modelling gives the following percentages for the sources of Phosphate load:

Upper Wye sub-catchment - 66% agriculture, 25% sewage, 9% other. River Lugg sub-catchment - 66% agriculture, 25% sewage, 9% other. Lower Wye sub-catchment - 61% agriculture, 33% sewage, 6% other.

The planned phosphate-strippers for sewage treatment works in the catchment will decrease the proportion of phosphorus coming from sewage thus increase agriculture’s share.

As with all modelling, “rubbish in means rubbish out” applies. We cannot comment on the reliability of the EA input data other than to note that the figures entered for intensive poultry may have been half the true number and illegal combined sewage overflows will presumably not have been included.

2 https://naturalresources.wales/about‐us/news‐and‐events/news/nrw‐issues‐new‐advice‐ to‐safeguard‐the‐river‐wye‐special‐area‐of‐conservation/?lang=en