Timetable for implementing the Directive
12. In its memorandum, the European Commission wrote
that "the Directive is very ambitious both in its declared
objectives and the timetable for its implementation. As from the
end of 2003 the Member States will face key implementation deadlines
on a regular basis".[20]
The timetable is set out below.
Table 1: Timetable for implementing
the Directive
Year
|
|
Article
|
2000
|
Directive came into force
|
25
|
2003
|
Transposition into national legislation
|
24
|
2003
|
Identification of River Basin Districts and Competent Authorities
|
3
|
2004
|
Characterisation of river basins
|
5
|
2006
|
Establish monitoring network
|
8
|
2006
|
Start public consultation
|
14
|
2009
|
Finalise River Basin Management Plans including programme of measures
|
13 and 11
|
2008
|
Present draft river basin management plans
|
13
|
2010
|
Introduce pricing policies
|
9
|
2012
|
Put programme of measures into operation
|
11
|
2015
|
Meet environmental objectives
|
4
|
Implementing the Directive
13. Responsibility for implementation of the Water Framework Directive
within the prescribed timescale ultimately rests with the Government
of each Member State. In England and Wales the Department for
Environment, Food and Rural Affairs (Defra) has lead responsibility
for the implementation of environmental Directives. But other
Departments and bodies will be affected by the Directive, including
the Office of the Deputy Prime Minister,[21]
local authorities, British Waterways, English Nature and the Countryside
Council for Wales.
14. However, the Directive requires that Member State Governments
identify an "appropriate competent authority",[22]
responsible for applying the rules of the Directive. In other
words the competent authority will take day-to-day responsibility
for the Directive and for ensuring the achievement of its objectives.
The Directive does not specify in detail what sort of organisation
the competent authority should be: all that is required of Member
States is that they provide information about the legal status,
responsibilities, membership and institutional relationships of
each competent authority. The competent authority may be a new
body, or it may be an existing organisation: it is envisaged that
it may take on new powers or existing powers may be transferred
to it. In England and Wales Defra and the Welsh Assembly Government
have proposed that the Environment Agency should be appointed
as the sole competent authority.[23]
The Common Implementation Strategy
15. The practicalities of implementing the Directive are to be
determined in large part through a Common Implementation Strategy
(CIS). The aim of the CIS is to develop a common understanding
of the technical and scientific implications of the Directive,
leading to a common approach to it, which will in turn facilitate
consistent implementation of the Directive across Europe.[24]
In its memorandum the European Commission told the Committee that
"given the scale of the challenge, the short-time frame and
the desirability of developing coherent and consistent approaches
to the implementation of the Directive, the Member States and
the Commission, together with other stakeholders, agreed to work
together on a Common Implementation Strategy (CIS). The CIS is
designed to produce technical guidance documents to be used by
all Member States and candidate countries in the implementation
of the Directive".[25]
It is worth recording that guidelines developed through the CIS
will be informal and not legally binding.
16. A common strategy for the implementation of the Water Framework
Directive depends on:
· sharing information between Member States;
· informing and involving the public;
· ensuring coherence with other sectoral and structural policies
and related Directives;
· integrating activities on different horizontal issues for
the effective development of river basin management plans;
· building capacity in Member States;
· involving stakeholders and the civil society;
· promoting a common attitude towards candidate countries
of Central and Eastern Europe; and
· establishing working groups and develop informal guiding
and supporting documents.
The CIS has focussed in working groups on a number of key issues
such as analysing pressures and impacts, the assessment and classification
of groundwaters, best practice in river basins management planning,
the development of a common Geographic Information System, economic
analysis, heavily modified and artificial water bodies, the identification
of river basin districts, intercalibration, monitoring, pilot
river basin networks, public and stakeholders participation, and
typology, reference conditions and classification.
Failing to implement the Directive: infraction
proceedings against the United Kingdom?
17. All Member States appear to be vocal supporters of the way
in which European environmental legislation is formulated and
implemented, but few if any back their words with enthusiastic
action. At different times every Member State has faced infraction
proceedings for failing properly to implement Directives. The
United Kingdom, for example, has had infraction proceedings brought
against it in relation to the Bathing Water, Drinking Water, Shellfish
Waters, Integrated Pollution Prevention Control, Waste, Habitats,
Urban Wastewater Treatment and most recently the Nitrates, Directives.[26]
The lesson from past experience certainly seems to be that it
is better in the long run properly to implement Directives, rather
than to adopt a narrow or minimalist approach to implementation[27]
- and also that full implementation of a Directive after a deadline
is much better than incomplete implementation on time.
18. Past experience suggests that most if not all Member States
will fail to achieve proper and full implementation of the Water
Framework Directive within the timescale set out in the Directive.
That is disappointing, but it is, as we have said, a common problem.
Over time, Member States should address the issue, in particular
by only agreeing to new Directives after the practical and economic
implications of their implementation have been fully assessed
and costed. Being able to do so may be particularly difficult
in the case of last minute changes to Directives, including the
Water Framework Directive, during the conciliation process.[28]
In this case, however, it is sensible for the United Kingdom to
keep the process of implementation marching step-by-step with
that in other major European Union member states to build confidence
that it is not imposing burdens or costs which are not affecting
other countries.
Public participation
19. Article 14 of the Directive requires that "Member States
shall encourage the active involvement of all interested parties
in the implementation of this Directive, in particular the production,
review and updating of the river basin management plans."[29]
To that end the Government published a consultation paper in March
2001 as "the first step in what will be an extensive consultation
process, including discussions with the principal affected parties".[30]
It was aimed particularly at the water industry, businesses which
discharge into, or abstract from, water bodies, navigation authorities,
industry and agriculture in general, local authorities and interested
NGOs, as well as water company customers.
20. The first consultation paper foresaw a second paper, which
was issued in October 2002.[31]
The second paper referred to Article 14, and said that "through
a participative process, sustainable water quality can be enriched
by the aspirations and knowledge of those who care about the water
environment and the concerns of those affected by proposed action".[32]
The principal means by which the view of the public and others
will be taken into account is through consultation exercises conducted
in relation to the drawing up of river basin management plans.[33]
These should also be used to draw attention to the costs and processes
of implementation.
Science and the Directive
21. Implementation of the Water Framework Directive depends on
scientific analysis of current water quality, the extent to which
such quality should be improved, and how that improvement can
be brought about. A wide range of scientific disciplines are involved
in addressing such issues. That diversity of view is reflected
in debate surrounding the Directive, a debate which was aired
in evidence to us, as well as being conducted externally.[34]
We have therefore decided to set out a brief overview of the science
behind the Directive, as well as evidence about the present ecological
status of waters in England and Wales, and apparent gaps in the
evidence.
22. There are a number of predominantly scientific questions
surrounding the Water Framework Directive. It is only by answering
such questions that properly informed decisions can be made about
the strategies and resources needed to implement the Directive.
The questions which recurred throughout our inquiry were:
(a) How should we define water status in ecological terms -
which groups of plants and animals should form the basis of this
definition?
(b) Which groups of plants and animals should be expected in
waters of 'high' ecological status, and what scientific evidence
exists to support this definition of a reference state?
(c) What physical, chemical and biological conditions are required
by these plants and animals, and to what extent can these deviate
from this reference condition in waters of 'good' ecological
status?
(d) In what ways would the definitions of 'high' and 'good'
ecological status vary between different regions of England and
Wales and between different water body types?
(e) How many waters in England and Wales currently fail to
achieve 'high' or 'good' ecological status?
(f) What strategies and resources would we need to protect
waters presently of 'high' or 'good' ecological status?
(g) How might we generate preferred conditions in other waters
to restore these to at least 'good' status within the prescribed
timetable of the Water Framework Directive?
(h) What scientific and financial resources are needed to answer
all the scientific issues raised by the implementation of the
Directive?
Perhaps the most important of these questions, at least initially,
is that which asks what is the current state of water quality
in surface and ground waters in England and Wales. Before decisions
can be made about what policies are needed to meet the objectives
of the Water Framework Directive, it is vital that a clear understanding
is reached of the current status of these waters, as currently
no comprehensive overview exists of the ecological state of waters
in England and Wales.[35]
The present state of waters in England and Wales
23. Of particular concern to a number of our witnesses were optimistic
statements made by Defra and the Environment Agency about the
present state of waters in England and Wales, which they felt
might lead to complacency about the scale of the task involved
in implementing the Directive.
24. The WWF told us that "there has been good news on the
environment with populations of key freshwater species such as
otters rising ¼..However,
DEFRA and Environment Agency press releases suggesting that our
rivers and wetlands are in rude health are misleading. Real problems
remain".[36] In
oral evidence the organisation argued that "the way we are
describing the water environment does not actually reflect what
we believe to be the true state of it in terms of its ecology
and its health".[37]
The RSPB asserted that
whilst a considerable amount has been achieved in
tackling gross organic pollution and controlling some hazardous
substances, our aquatic and wetland ecosystems still face major
challenges.[38]
The RSPB also cited work by Plantlife, which has
"shown that plant species that depend on nutrient-poor water
have suffered, and continue to suffer, substantial long-term declines".[39]
25. Such concerns reflect those raised in the wider
scientific community. For example, the British Ecological Society
held a meeting in September 2002 to discuss the assertion that
"Government spin points to major improvements in river quality,
but it is not widely realised that this applies largely to the
effects of gross organic pollution and the deoxygenation it has
caused in the past. There are many other, equally serious old
and novel ways in which lake, river and wetland systems are being
damaged".[40] Indeed
in June 2002 English Nature and the Environment Agency acknowledged
that "integrated and widespread action to tackle pollution
from agricultural land is urgently required if we are to meet
existing environmental commitments and prepare the farming community
for the more comprehensive demands of new European water legislation".[41]
26. By contrast Defra assured us that "the standard
of our rivers has consistently increased in recent years in terms
of quality standard ... We have made enormous progress in this
country in relation to improving water quality in its broadest
sense".[42] Moreover,
the Department also implied that two-thirds of our rivers are
of good quality at present.[43]
It is apparent that this positive view is based on information
generated by the Biology General Quality Assessment (GQA) based
on a river monitoring programme carried out on a quinquennial
basis by the Environment Agency.[44]
The most recent Biology GQA found that 94 per cent of rivers were
of good or fair quality in 2000 (five per cent were poor and one
per cent were bad).[45]
27. It is, however, widely argued that such classifications
only present a partial picture of the reality. The biology GQA,
for example, is based on the distribution of a range of aquatic
animals termed macroinvertebrates, such as mayflies and shrimps.[46]
They are used as a reference because they are relatively sedentary,
because they spend most of their life cycle within rivers, and
because they are ubiquitous. Macroinvertebrates are acutely sensitive
to the amount of oxygen present in the water body, and the classification
scheme used in the biology GQA is based on this sensitivity. Thus
a river classified as being of 'high' or 'good' status can be
considered to be an oxygen-rich river. The headwaters of any river
in England and Wales would normally fall into this category unless
a large amount of oxygen-demanding pollutant, typically organic
wastes, were to be delivered to the water body from the land.
Lowland reaches of rivers where the flow is more sluggish will
naturally have a lower oxygen status, but again this will drop
if too much organic pollution is delivered to the river.
28. Thus the classification of river water quality
in England and Wales based on the biology GQA is actually reflecting
the oxygen status and the organic pollution status of these rivers.
It is consistent with the evidence only to say that the oxygen
status of British rivers has consistently increased in recent
years in terms of the biology GQA standards, reflecting the fact
the we have made enormous progress in this country in relation
to reducing the organic pollution of our rivers. On that basis
it is worth noting that a third of our rivers still have less
oxygen in them than is desirable to support a natural near-reference
state macroinvertebrate community.
29. We readily acknowledge the improvements in
oxygen status that have been achieved in the rivers of England
and Wales in recent decades and the return of key indicator species
such as salmon to many of our river systems. We are aware, however,
that this has been achieved largely through investment in improving
the quality of effluent discharged from major sewage treatment
works and to a lesser extent the reduction in industrial pollution
resulting from shrinkage in the manufacturing sector and the better
management of animal wastes on farm holdings - sources of pollution
which are relatively easy to identify and, with technological
advances, to treat. We are far less sanguine about the wider picture.
30. There is little reason to assume that waters
in England and Wales are of high quality across a range of criteria
simply because of evidence about the distribution of only one
group of animals in rivers and their sensitivity to oxygen status.
Therefore we are concerned that the Environment Agency "has
taken an initial view that 'good status' may be met by those stretches
of river where the Biology General Quality Assessment class is
A or B in both 1995 and 2000".[47]
This approach does not appear to accord with the principles of
the Water Framework Directive, since it takes no account of the
presence of a wider range of pollutants in British waters, the
fact of a much greater degree of ecological damage in other plant
and animal groups, and the need to tackle diffuse pollution from
agricultural and urban land. Our witnesses raised a number of
wider-ranging concerns about water quality:
· the
WWF[48]
cited evidence from the Environment Agency that more than 30 rivers
in England and Wales suffer from low flows due to over-abstraction,[49]
and that ground- and surface-water abstraction regimes in large
areas of south east England and East Anglia are "unsustainable
and unacceptable".[50]
Over-abstraction leads to fundamental changes in the physical
habitat of water bodies, particularly headwater streams and small
lakes and ponds;
· the
Wildlife Trusts told us that "land drainage and flood defence
have also devastated the character of river corridors with less
than 5 per cent of lowland floodplains now supporting wetland
habitats and around 80 per cent of river channels having been
modified".[51]
Even in upland rivers 60 per cent of river channels have been
modified.[52]
The British Ecological Society has been told that "many lowland
rivers have been dredged, deepened and straightened, resulting
in the loss of most of their physical and biological diversity".
It is also argued that "recent physical restoration efforts
have been small scale with little impact on the ecology of the
rivers";[53]
and
· the
WWF also quoted the assertion of the RSPB that "United Kingdom
Biodiversity Action Plan habitats such as lowland reedbeds, wet
grassland and estuaries cover only a fraction of their former
ranges".[54]
The decline in many native species of birds (such
as the bittern), aquatic mammals (the water vole), crustaceans
(the crayfish), fish (the bullhead) and plants (water crowfoot)
many be blamed in part if not wholly on the impact of these wider
changes to the character of British waters.[55]
Consequently it is argued that implementation of the Water Framework
Directive must take account of these wider issues, rather than
simply focussing on marginal improvements in the very limited
aspect of water quality measured in the biology GQA.
31. Witnesses also reflected and reported the concerns
of the wider scientific community about the extent of other forms
of chemical pollution and ecological damage which do not currently
form part of the Environment Agency's General Quality Assessment
for rivers in England and Wales.[56]
For example it has been said that "many plants that are dependent
on unpolluted water are finding that there is nowhere for them
to go. Evidence for this is provided by stoneworts, highly specialised
and complex algae ¼.Over
one third of lost stonewort populations can be attributed to nutrient
pollution, and of all remaining stonewort populations in the United
Kingdom, over one third are threatened by nutrient pollution".[57]
In addition, there is evidence of an increased presence of endocrine-disrupting
chemicals in the waters of England and Wales, which are having
a significant and detrimental impact on a range of fish and other
animals.[58] Such chemicals
are not apparently included in any routine assessment of water
quality in England and Wales.
32. Another problem is the eutrophication of rivers,
lakes, estuaries and coastal waters, caused by the presence of
plant nutrients, nitrogen and phosphorus. Eutrophication can lead
to excessive plant growth in rivers and the loss of plant communities
in lakes and their replacement by dense populations of single-celled
algae. The result can be a significant deterioration of the ecological
structure and function of waters. It is acknowledged as such a
serious problem in England and Wales that a special forum was
formed in 1998 to bring together the different Government departments,
agencies and NGOs to co-ordinate their various scientific research
initiatives on eutrophication and related issues.[59]
The WWF told us that "eutrophication of fresh and coastal
waters, caused by increased nutrient levels, is widely acknowledged
as the most serious threat to water quality in the United Kingdom
and much of the European Union".[60]
The organisation said that 80 out of 95 wetland Sites of Special
Scientific Interest (SSSIs) surveyed in 1995 were suffering from
eutrophication.[61] English
Nature also reports that 141 out of 190 SSSIs surveyed in 1992
were found to be acidified.[62]
We are very concerned about the eutrophication of British waters,
especially in Sites of Special Scientific Interest.
33. Notwithstanding the Government's assertions about
the good quality of waters in England and Wales, there are in
fact a number of factors which adversely affect that quality when
it is assessed against the criteria set out in the Water Framework
Directive. These include their physical alteration as a result
of flow regulation structures and water abstraction for domestic
and industrial purposes. Also included is the development and
drainage of land within river corridors for urban and agricultural
purposes, frequently ending the natural function of floodplains.
Meanwhile, the reduced rates of flow in headwater streams have
had a significant effect on their fisheries and conservation value,
whilst the alteration of banks through channel dredging, straightening
and reinforcement has led to the loss of habitat for native species
such a crayfish and water voles, with knock-on effects on the
rest of the food web. Waters are also affected by a cocktail of
chemical pollutants from a wide range of sources, some of which
are toxic and hazardous to human and aquatic life. Others, such
as plant nutrients, are not toxic, but are nonetheless damaging
to the natural ecology of our waters.
34. Addressing these wider concerns about water quality
implies that implementation of the Directive will prove complicated.
For example, dealing with the loss of wetland habitat, particularly
in the floodplain, clearly overlaps with the issue of flooding
and flood protection, as well as of land use planning. Thus it
will be necessary to integrate the response to the Water Framework
Directive with domestic flood control and planning policies. And
if the assessment of water quality is to go beyond current measures
a wider range of pollutants and sources of pollution will have
to be taken into account.
Diffuse pollution
35. Pollutants are delivered to water bodies from
either 'point' or 'diffuse' sources. 'Point' sources refer to
the delivery of pollutants to waters via a single point of entry.
Such sources of pollution are usually easily identifiable, and
the harmful material can be prevented from entering water bodies
by the treatment of effluent prior to discharge. Under the Water
Framework Directive there will be no excuse for the continued
presence of pollution from a point source in any water body, unless
it can be demonstrated that it has no immediate or long-term impact
on the ecological status of the water body.
36. A number of our witnesses argued that investment
has already been made in the control of chemical pollution from
point sources, at a considerable cost to water industry customers
and shareholders, and that the industry should not be required
to continue to invest in the face of mounting chemical pollution
from diffuse sources. Severn Trent told us that "one of the
main problems faced in implementing the Directive will be the
impact of diffuse pollution. Such pollution not only adversely
affects the ecological potential of watercourses, but directly
affects water suppliers through the degradation of the quality
of water which we abstract to produce drinking water".[63]
South West Water agreed, and told us that "the overall impacts
on unresolved diffuse pollution sources must become the highest
priority for containment and improvement before further environmental
gains can be justified and cost imposed on South West Water and
its customers".[64]
37. Failure to control the pollution of water supplies
from diffuse sources goes against the widely accepted principle,
reiterated in the Directive,[65]
that the polluter should pay. The Water Framework Directive is
specifically aimed at remedying the deficiency.[66]
However, dealing with diffuse pollution is not straightforward.
It oozes from the landscape and atmosphere at rates and locations
which vary in both space and time, and the sources are not readily
identifiable, so individual polluters cannot easily be held to
account. Typical pollutants which fall into this category include
the major nutrients, such as carbon, nitrogen and phosphorus,
which sustain plant growth, nitrogen and sulphur compounds deposited
from atmospheric sources, and sediments eroded from the land together
with a whole host of other pollutants (pesticides, herbicides,
heavy metals) stuck to the surface of these sediments. The pathways
by which these pollutants might reach a water body, and thus the
reasons why the control of diffuse pollution is clearly going
to be a challenge, are illustrated in Figure 1.
Figure 1: Sources and pathways for
diffuse pollution of waters
38. The importance of controlling pollution from
diffuse sources was highlighted by a number of witnesses. The
Natural Step told us that "legislation and investment in
water quantifiable, and amenable to control by an authorisation
or consenting process. However, pollution arising today from diffuse
sources may equal or exceed the impact of point sources".[67]
The Countryside Council of Wales specifically requested that the
Committee examine "the links between land management, agri-environment
incentives and the requirements to control diffuse pollution".[68]
And the WWF argued that "one of the acid tests of successful
Water Framework Directive implementation will be whether or not
adequate measures are put in place to reduce levels of diffuse
water pollution from agriculture".[69]
39. Despite the ready acknowledgement that dealing
with diffuse pollution is extremely important, it is of concern
that the extent of the problem is not quantified in any of the
documents relating to the Directive released for public consultation
by Defra and the Environment Agency.[70]
Indeed, as we have said, one of the principal difficulties in
formulating policies to deal with diffuse pollution is the difficulty
in determining exactly how severe the problem is. What evidence
does exist, however, again appears to contradict the assurances
given by Defra and the Environment Agency about the 'good' and
'improving' water quality of British waters.
Figure 2: Trends in nitrate concentrations
in the River Thames, 1930-2000[71]
40. A study of nitrate pollution in the River Thames
(see above) revealed that nitrate concentrations have risen threefold,
from 10 mg per litre in 1930 to more than 30 mg per litre in 2000.
Similar patterns emerge in work commissioned by the Environment
Agency in the 1990s, which found that in 80 per cent of sample
lakes across England and Wales nutrient levels had more than doubled
compared to their pre-second World War state. In 46 per cent of
lakes there had been more than a five-fold increase in their nutrient
levels. Whilst a substantial part of these trends has been attributed
to point source discharges from sewage systems in the past, diffuse
sources are now believed to be the primary source of nutrient
enrichment in these waters.[72]
Diffuse pollution and agriculture
41. The primary source of diffuse pollution is agriculture.
The Secretary of State has said that "the increased intensification
of farm production and the great steps made to reduce point source
pollution from factories and sewage works mean that ... agriculture
is now clearly one of the major contributors to the pollution
of water".[73] The
Policy Commission on the Future of Farming and Food said more
baldly that "agriculture is now the number one polluter of
water in the country".[74]
The Commission attributed the damage to the intensification and
expansion of agricultural production, which has taken place in
both upland and lowland regions in response to the economic levers
of the Common Agricultural Policy (CAP).
42. More than 40 per cent of the land surface of
the European Union is currently used for agricultural production.
In some member states, notably those lying within lowland, temperate
regions of Europe, agricultural land occupies a substantial majority
of the land mass and little natural or semi-natural vegetation
now remains. In Belgium and Germany almost half of the land surface
is under agricultural production; cultivated land in the Netherlands
occupies more than two-thirds of the land surface; and in the
United Kingdom more than three-quarters of the land surface is
cultivated and a substantial proportion of the remainder upland
areas, whilst not cultivated, is used for sheep grazing.
43. In the early part of the last century, however,
far less land was used for agricultural production. Wetlands were,
generally, wet; steep slopes might have been grazed but were rarely
ploughed or fertilised; and far less land was used for arable
cultivation, particularly around lakes and alongside rivers where
the risk of flooding from unregulated channels was high. Land
in agricultural production was also used far less intensively
that is the case today, with little use of inorganic fertilisers,
lower stocking rates, and much greater on-farm recycling of animal
manures and crop residues. These were viewed as valuable resources
for the improvement of soil fertility.
44. Following the Second World War public policy
moved towards the promotion of self-sufficiency in the production
of food, reflected in the Agriculture Act 1947 and later the Common
Agricultural Policy. The result has been a significant impact
on the movement of soil, nutrients and other agricultural chemicals
from the land to adjacent water bodies. For example, large areas
of grazing marsh, fenlands and river floodplains were drained,
bringing fragile wetlands into agricultural cultivation. Grassland
was ploughed to make way for arable crop production in many areas,
releasing nitrogen and phosphorus that was previously locked up
in the soil. Fertiliser application rates to all crops and grassland
rose at an extraordinary rate, notwithstanding the nutrients already
present in the soil. Nutrient additions in the form of livestock
wastes either directly voided to grazing land or spread as a slurry
on arable crops also contributed to a progressive saturation of
agricultural soils with nutrients.
45. As more land has been brought into arable cultivation
the remaining area of grazing land has diminished, and yet livestock
numbers have increased. With more livestock being produced on
less land, natural grazing has been supplemented by concentrated
feeds. One impact of this practice has been to increase the per
capita nutrient content of manures and urine voided onto the fields.
This has increased the rate of diffuse nutrient loss to adjacent
water over and above the increased nutrient loading resulting
from the expansion in farm livestock numbers on the land.
Table 2: Changes in land use in the
United Kingdom between 1931 and 2000[75]
|
1931
|
2000 |
% change
|
Cereal crop area (ha)
Fertilised grassland (ha)
Cattle (head)
Sheep (head)
Pigs (head)
Poultry (head)
|
1,835,307
8,361,332
5,912, 661
16,803,371
2,835,324
57,009,189
|
3,103,765
4,661,000
7,391,019
30,145,302
5,473,083
117,841,982
|
69 %
- 44 %
25 %
79 %
93 %
107 %
|
Cattle stocking (head/ha)
Sheep stocking (head/ha)
|
0.71
2.01
|
1.59
6.47
|
124 %
222 %
|
Figure 3: nitrogen load exported from land to water
in England & Wales[76]
[Units: Kilogrammes of nitrogen exported per hectare of agricultural
land]
Figure 4: phosphorus load exported from land to
water in England & Wales[77]
[Units: kilogrammes of phosphorus per hectare of agricultural
land]
46. It has been estimated that nitrogen loading on British
waters is nearly three times higher now than it was in the first
half of the last century, and that phosphorus loading is more
than twice as high now as it was then. And it has been estimated
that in the 1990s 75 per cent of the nitrogen load and 60 per
cent of the phosphorus load delivered to British waters derived
from diffuse rather than point sources. As is highlighted on these
maps there are few if any areas of England and Wales which have
bucked the trend. Diffuse pollution from these agricultural and
atmospheric sources is affecting all waters in England and Wales
to a certain extent, from upland tarns and streams in the Lake
District and North Wales to lowland rivers and lakes like the
Thames and the Norfolk Broads, to chalk streams like the Frome,
Piddle and Kennet. It is important that the Government defines
what will be an acceptable level of nitrogen and phosphorus for
each of our rivers so we can assess in clear terms the order of
pollution reduction that will be needed for successful implementation
of the Directive.
47. The extent of the diffuse pollution problem in the water
bodies of England and Wales is symptomatic of the intensity with
which we use the landscape. Diffuse pollutants, because they
affect all British waters, because they cannot be attributed to
single sources of origin, and because they are the inadvertent
by-product of other social and agricultural policies within Britain
and Europe, will be the most difficult and costly to control under
the Water Framework Directive. If intensive agricultural practices
have led to diffuse pollution it is clear that in order to deal
with the problem wholesale changes in such practices will be needed.
Limiting diffuse pollution will be a costly and expensive undertaking,
and will impact on an agricultural industry which is already under
severe pressure. It is likely to require changes in agricultural
practice - perhaps even to the direction and ethos of the CAP.
As such it is emblematic of the significance and wide-ranging
impact of the Water Framework Directive.
48. In June 2002 Defra set up a strategic review of diffuse pollution
from agriculture in England and Wales.[78]
The Government should be now clarify the timetable for completion
of the strategic review of diffuse pollution from agriculture.
We trust that the review will consult as widely as possible about
the scale of the problem, and the strategies and resources needed
to bring this most intractable of pollution sources under control.
Given the likely impact that dealing with diffuse pollution will
have on the agriculture industry we recommend that the review
assess carefully the financial implications of the Directive for
the agricultural industry to ensure that the costs of implementation
for this sector are proportionate in respect of its present ability
to pay.
20 Ev 1. Back
21 See
J28, para.10; Q 131. Back
22 See
Article 3(2) of the Directive. Back
23 See
Defra and the Welsh Assembly Government (2001) First Consultation
Paper on the Implementation of the EC Water Framework Directive
(2000/60/EC), and Defra and the Welshe Assembly Government
(2002) Second Consultation Paper on the Implementation of the
EC Water Framework Directive (2000/60/EC). Both documents
can be viewed at
http://www.defra.gov.uk/environment/consult/waterframe/. Back
24 Q
215. Back
25 Ev
2. Back
26 See,
for example, Ev73a, and an English Nature press release (EN/02/35)
dated 28 June 2002: English Nature and the Environment Agency
are disappointed at the proposal for 55% coverage of Nitrate Vulnerable
Zones in England. Back
27 Ev
219, para.3.1; Q 272. Back
28 Qq
532 ff. Back
29 Directive
2000/60/EC Article 14, para. 1. Back
30 Defra
and the Welsh Assembly Government (2001) First Consultation
Paper on the Implementation of the EC Water Framework Directive
(2000/60/EC), para.1.2.. Back
31 Defra
and the Welsh Assembly Government (2002) Second Consultation
Paper on the Implementation of the EC Water Framework Directive
(2000/60/EC). Back
32 Second
Consultation Paper, para.14.1. Back
33 Second
Consultation Paper, paras.14.1 ff. Back
34 See,
for example,
http://www.britishecologicalsociety.org/publicaffairs/meetings.php,
and http://www.fwr.org.uk. Back
35 See
for example Q 252. Back
36 Ev
25. Back
37 Q
125. Back
38 Ev
243. Back
39 Ev
243; see also Duckworth, J., Davis, R., and Costley, J. (2001)
Junk Food for Plants: how nutrient pollution is threatening
the UK's wild flora (report for Plantlife). Back
40 See
http://www.britishecologicalsociety.org/publicaffairs/meetings.php
Back
41 English
Nature Press Release EN/02/35, 28 June 2002. Back
42 Q
510. Back
43 Q
511. Back
44 Ev
73. Back
45 See
the river quality section of
http://www.environmentagency.gov.uk. Back
46 Macro-invertebrates
are small animals that can be seen with the naked eye. They include
insects such as mayflies and caddis-flies, together with snails,
shrimps, worms and many others; see Environment Agency Biology
GQA Method, which can be seen at
http://www.environment-agency.gov.uk. Back
47 Ev
74, para.5. Back
48 Ev
26, para.2.2. Back
49 Environment
Agency (1998) The State of the Environment of England and Wales:
freshwaters, The Stationery Office, Norwich. Back
50 Environment
Agency (2001) Water Resources for the Future: a strategy for
England and Wales, Environment Agency, Bristol. Back
51 Ev
204. Back
52 Ev
25. Back
53
http://www.britishecologicalsociety.org/publicaffairs/meetings.php. Back
54 See
Ev 26, para.2.2; RSPB (2002) Wetlands in the Water Framework
Directive: report to Defra's Stakeholder Sounding Board. Back
55 For
example, the mink has had a significant impact on populations
of aquatic mammals and birds. Back
56 See:
http://www.environment-agency.gov.uk,
and Environment Agency (1998) The State of the Environment of
England and Wales: Fresh Waters, the Stationery Office, Norwich. Back
57 Duckworth,
J., Davis, R., and Costley, J. (2001) Junk Food for Plants:
how nutrient pollution is threatening the UK's wild flora
(report for Plantlife). Back
58 See
http://www.fwr.org.uk. Back
59 See
http;//fwr.org.uk; see also http://www.defra.gov.uk/environment/water/index.htm.
Back
60 Ev
27, para.2.6 Back
61 Ev
26, para.2.2; see Carvalho, L. and Moss, B. (1995) 'The current
status of a sample of English Sites of Special Scientific Interest
subject to eutrophication', Aquatic Conservation: marine and
freshwater ecosystems, 5, 191-204. Back
62 Rimes,
C. (1992) Freshwater acidification of SSSIs in Great Britain
- overview. English Nature Science No.1. Back
63 Ev
80. Back
64 Ev
197. Back
65 Paragraph
11 of the preamble to the Directive. Back
66 Article
11(h) of the Directive. Back
67 Ev
226. Back
68 Ev
183. Back
69 Ev
27, para.2.6. Back
70 Defra
(2002) Second Consultation Paper on the Implementation of the
EC Water Framework Directive (2000/60/EC), Defra Publications,
London, and Environment Agency (2002) The Water Framework Directive:
guiding principles on the technical requirements, Environment
Agency, Bristol. Back
71 Based
on data presented by Onstad and Blake (1980) 'Thames basin nitrate
and agricultural relations, in proceedings of a symposium on watershed
management, American Society of Civil Engineers, 961-973, and
data extracted from the Environment Agency archive for the River
Thames at Walton-on-Thames.] Back
72 Johnes,
P. J., Curtis, C., Moss, B., Whitehead, P., Bennion, H. and Patrick,
S. (1998) Trial Classification of Lake Water Quality in England
and Wales: a proposed approach. Environment Agency R&D
Technical Report E53, Environment Agency, Bristol; and Moss, B.,
Johnes, P. J. and Phillips, G. L. (1996) 'The monitoring and classification
of standing waters in temperate regions - a discussion and proposal
based on a worked scheme for British waters', Biological Reviews,
71, 2, 310-339. Back
73 HC
Deb, 27 June 2002, col.1001W. Back
74 Policy
Commission on the Future of Farming and Food (2002) Farming
& Food: A sustainable future, p.68. Back
75 Data
for fertilised grassland are for 1999. Data were extracted from
the Parish summaries of the Annual Agricultural Census, 1931,
and from the summary statistics for 2000 published at
http://www.defra.gov.uk/esg/m_natstats.htm. Back
76 Johnes,
P. J. and Butterfield, D. (2002) Landscape, regional and global
estimates of N flux from land to sea: errors and uncertainties.
Biogeochemistry, 57/58, 429-476. Back
77 Johnes,
P. J., Fraser, A., Harrod, T., Butterfield, D. and Withers, P.
J. (2000), Quantification of National P Loss from Agriculture
to Water. Environment News, MAFF; and Johnes, P. J.,
Fraser, A., Harrod, T., Butterfield, D. and Withers, P. J. (1999),
Quantification of National P Loss from Agriculture to Water.
Final Report and Annex, MAFF research programme NT1036. Back
78 See
Nitrate controls to spearhead long-term strategy to improve
water quality, Defra Press Release, 251/02, 27 June 2002. Back
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