River Action                            WQR0096

Additional written evidence from River Action


Founded in February 2021, River Action is a UK registered charity dedicated to campaigning to address the river pollution crisis. Its prime activities at present involve calling on a) food production companies to mitigate the adverse ecological impacts of their supply chains and b) governments to establish the regulatory and legislative frameworks needed to enhance environmental protection and enforcement.

Following our original submission to this inquiry in February (key aspects summarised below), we have discovered further information and wished to make this available to members of the committee ahead of the remaining stages of this crucial inquiry.

The contribution of agriculture to the river pollution crisis

River Wye: the impact of intensive poultry production

1 Parliamentary Office of Science and Technology POST Note No. 478 October 2014 Diffuse Pollution of Water by Agriculture


2 https://www.endsreport.com/article/1696294/bevan-ea-lacks-powers-resources-tackle-farm-pollution

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Wales, the density of poultry farms has reached a level unmatched in Europe, while in Herefordshire and Shropshire over the past decades poultry units have almost doubled in size and more than tripled in number to 1150 housing 38 million chickens (or 70 times the number of people in those counties).3

Inadequate response from major Wye egg producer Noble Foods

River Action formed earlier this year in order to apply direct pressure to major agricultural producers and suppliers to take responsibility for the environmental conduct of their supply chains. There are a number of options available to farms and production facilities to prevent damaging run-off and an experienced network of organisations through the Rivers Trust movement on hand to assist in their implementation.

We have focussed our engagement specifically on Noble Foods. As the UK’s leading egg producer and owner of well-known premium brands such as Happy Egg, and also as the key player in the Wye catchment, Noble should be demonstrating leadership in the fight to save our rivers. We believe that the fact that this major agribusiness is sourcing its eggs from an area where poultry farming has been linked to severe environmental damage is of great public interest.

Despite the high standards of environmental compliance and supply chain integrity now expected by all the UK’s major food retailers, we find it concerning that, to date and despite our repeated engagement over the course of this year, Noble Foods does not appear to have given any detailed information on how it is working with farmers to help mitigate the problem. Furthermore, the issue of river pollution is still not identified as a focus area for Noble’s CSR strategy.

Timeline of engagement



3 https://www.theguardian.com/environment/2021/jun/14/bird-costs-less-than-pint-welcome-to-britains-poultry-capital-hereford- shropshire-powys

4 https://www.brecon- radnor.co.uk/article.cfm?id=112425&headline=The%20nation%E2%80%99s%20%E2%80%98favourite%E2%80%99%20river


5  https://www.theguardian.com/environment/2020/oct/05/river-pollution-leads-to-welsh-demand-for-halt-to-intensive-poultry- units

6  https://riveractionuk.com/wp-content/uploads/2021/04/River-Action-letter-to-Noble-Foods-15.02.2021.pdf

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7  https://riveractionuk.com/wp-content/uploads/2021/04/Letter-from-Duncan-Everett-to-Charles-Watson.pdf

8 https://riveractionuk.com/blog/river-action-urges-noble-foods-to-invest-vast-gu-puds-sale-profits-into-urgent-action-on-farm- pollution/

9 https://riveractionuk.com/wp-content/uploads/2021/07/Charles-Watson-Noble-Foods-letter-July-2021.pdf

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owned agricultural units and those of its third party supply chains, and to reiterate our questions above.

Inability of underfunded Environment Agency to address agricultural pollution

It is our view that action by individual companies is not only a moral duty of businesses operating in the context of a climate and nature crisis, but also makes financial sense given the increasing awareness of and demand for sustainability by investors and customers alike. However, actions at the farm or business level must be enabled and driven by an effective overarching policy environment: it is critical that a strengthened regulatory framework is created which both rewards and incentivises good practice at the farm level and which requires that the food processing industry pays its share in supporting farmers financially in implementing the necessary remedies.

An area of particular concern to us, which has become increasingly clear through the course of our campaigning, is the complete collapse in environmental protection across the UK which means that polluters (agricultural and otherwise) continue to get away with degrading our rivers: without addressing the current lack of enforcement against river polluters we can only tackle the symptoms of the crisis rather than the cause.

The Environment Agency has publicly stated that it lacks the resources to tackle agricultural pollution. Recent evidence of this, which may be of interest to the Committee includes -

10  https://salmon-trout.org/wp-content/uploads/2021/04/Doing-its-job.stc_.pdf

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Agency and the implications this will have for environmental protection. In these letters, Ms Howard Boyd states that:

Conclusion: Give Us Back Our Rivers campaign

In light of the degraded state of our rivers and the collapse of our environmental protection agencies’ capacity to tackle agricultural and other sources of pollution, in June 2021 River Action launched the Give Us Back Our Rivers campaign11 with a public petition calling on the UK and Welsh Governments to double the environmental protection budgets of the Environment Agency and Natural Resources Wales. This petition has so far been signed by other 50,000 people, making it one of the top trending petitions in the UK this year.

While funding alone is certainly not enough to resolve the issue, the reality is that we get the environment we pay for: adequate funds and resources are required immediately or our agencies have no chance of tackling this issue.



September 2021


























11  https://riveractionuk.com/Campaigns/give-us-back-our-rivers/