The Present State Of Waters In England
And Wales
4. 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
(paragraph 29).
The Government welcomes the Committee's acknowledgement
that much has been achieved to improve river water quality, principally
through massive water industry investment. Diffuse sources of
pollution are now proportionately much more significant - the
Government's plans to address agricultural sources of diffuse
pollution are dealt with in the Government's response to recommendation
10.
The rationale for the approach written into the Water
Framework Directive of monitoring elements such as fish, invertebrates
and algae is that they each respond to different pressures. Such
broad monitoring is more likely to pick up the impact of more
significant pressures requiring control and mitigation measures.
The Biological GQA remains the best national classification
system for ecological quality. Macro-invertebrates do respond
to a variety of pressures including organic pollution and toxic
metals, however it is recognized that this system is not designed
to detect the impacts of, for example, nutrient pressures.
Methods have been developed using macrophytes and
diatoms to assess the impact of nutrients and nutrient control
measures in rivers. These methods (Mean Trophic Rank and Trophic
Diatom Index) have mainly been applied by the Environment Agency
to determine the impacts of waste water treatment works discharges
for the purposes of the EC Urban Waste Water Treatment Directive.
However this approach is concerned primarily with the impact of
relatively large point sources of nutrients, especially phosphorus.
As the Water Framework Directive is concerned with the impact
of all pressures, both point and diffuse, the Environment Agency
is working with Scottish Environment Protection Agency to develop
operational tools to enable the prediction of the expected (reference
condition) macrophyte or diatom community at any river or lake
site, an assessment of ecological status based on the observed
macrophyte community (expressed in terms of quantitative deviation
from the reference condition), and a diagnosis of the anthropogenic
pressures affecting the observed community.
5. We are very concerned about the eutrophication
of British waters, especially in Sites of Special Scientific Interest
(SSSIs) (paragraph 32).
The eutrophication process is complex, affected by
a range of factors, and measuring its extent in particular waters
can be technically difficult. As part of the overall response
to the Water Framework Directive, improved reference-based methodologies
will have to be developed. Research is in hand to formulate the
new tools that will be required. Notwithstanding these issues,
the risks and undesirable effects of eutrophication are acknowledged
as a significant concern. The Government is in the process of
implementing a range of management measures, particularly the
Urban Waste Water Treatment, Nitrate and Habitats Directives and
(for marine waters) an OSPAR strategy in this area. In addition,
the Environment Agency published a strategy on eutrophication
in 2000, implementation of which is part of the Agency's "Making
It Happen" initiative.
It is important to bear in mind that phosphorus concentrations
in rivers have significantly reduced since 1990, although there
is no similar trend as yet for nitrates. Nutrients from point
sources are increasingly coming under control through the implementation
of the Urban Waste Water Treatment and Habitats Directives. With
regard to diffuse nutrient pollution, the Nitrates Directive,
with recently extended UK designations, is now being implemented
to reduce nitrogen pollution and may also help further to reduce
phosphorus pollution. The potential need for additional measures
on diffuse agricultural nutrient pollution is being looked at
in the current Government review (see responses to recommendations
7 - 10).
Regarding SSSIs, some riverine sites are already
designated as Sensitive Areas (Eutrophic) under the Urban Waste
Water Treatment Directive. There are currently 109 Sensitive Areas
(Eutrophic) in England which are reviewed every four years. The
Environment Agency is also introducing phosphorus standards for
riverine Special Areas of Conservation (all of which are SSSIs)
under the Habitats Directive. These standards will drive action
under the periodic review of water price limits. The potential
to extend those standards to all SSSI rivers will be considered.
The Environment Agency is working with partners to
take forward Habitat Action Plans under the UK Biodiversity Action
Plan which includes addressing key threats to chalk rivers, mesotrophic
lakes and eutrophic standing waters - with priorities for protective
action generally being sites of high conservation status. This
is incorporated in a holistic approach to the improvement of biodiversity
in the aquatic and wetland environment under the biodiversity
strategy for England.
6. 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 (paragraph 34).
The Directive does not cover flooding or land use
planning explicitly, but both can have implications for environmental
water quality. Defra is pursuing integration with the land use
planning system in two main ways:
§ by
ensuring that national and regional land use planning guidance
properly reflects new water priorities - for example the guidance
on planning and pollution control. There is a regular programme
for revising this guidance to reflect new considerations such
as the Water Framework Directive;
§ through
applying the existing system of controls on water pollution, including
the need to consult the Environment Agency on certain categories
of development applications, and the powers which the Agency already
has to control discharges and abstraction (the latter being subject
to amendment in the Water Bill).
6.2 The implications for flood management in England
and Wales are currently being assessed with the Environment Agency,
recognizing that many flood defence measures play a significant
role in protection of the public and property. We are also taking
part in a European working group to develop best practice guidance
on flood prevention and mitigation.
6.3 A review of project appraisal guidance is likely
to be required to ensure that all flood defence projects are consistent
with the application of the Directive, building on current approaches
that are already being developed through shoreline management
planning and catchment flood management plans which will, themselves,
form building blocks in the river basin management plan process.
Defra already actively encourages a wide range of
approaches to flood control and encourages consideration of options
that include managed realignment of defences to create more sustainable
and environmentally acceptable solutions as well as the creation
of flood storage areas on agricultural, amenity and other suitable
land.
Diffuse Pollution and Agriculture
7. 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 (paragraph 46).
The Government takes the view that considerably more
needs to be done to tackle nutrient pollution, from both agricultural
and non-agricultural sources. The extension of the area of nitrate
vulnerable zones from 8% of the agricultural area of England to
55% and the associated action programme measures will go some
way towards reducing agricultural nitrogen loads. As point sources
increasingly come under control diffuse pollution inputs will
become more evident (see recommendations 8-10).
Phosphorus is one of the principal pollutants arising
from diffuse agricultural sources and the Government's strategic
review of diffuse water pollution from agriculture (DWPA) is looking
at cost-effective measures to tackle this, and other nutrient
related pollution issues. Measures adopted now to tackle phosphorus
will take some time to have an impact in the water course, because
of the need to both reduce the amount of phosphorus in reservoirs
such as soil and sediment and restore ecosystems, which may involve
processes such as species reintroduction and biomanipulation.
8. 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 (paragraph 47).
The intensity of land use is clearly an important
factor in assessing and understanding diffuse pollution loads
to water courses. However, particularly in some vulnerable catchments,
the problem could be mitigated by the promotion and better targeting
of existing good practice measures in agriculture and elsewhere.
See recommendations 7 and 9-10 for DWPA.
9. 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 (paragraph 47).
Any changes in agricultural practice proposed in
order to implement the Water Framework Directive will clearly
have to be proportionate and cost-effective if they are to be
successful in reducing diffuse pollution inputs. The Department's
review referred to above is examining a wide range of potential
policy instruments, including regulation, voluntary and advisory
measures as well as economic instruments, and will aim to choose
the most appropriate and cost-effective measures, tailored to
suit local circumstances. What is appropriate in one river basin
district will not necessarily be appropriate in another. The Directive's
RIA is currently being updated but any measures adopted will adhere
to the general principles set out in annex A to the Sustainable
Food and Farming Strategy - Facing the Future, published in December
2002.
The European Commission published its formal proposals
on Reform of the CAP - 'A Long Term Perspective for Sustainable
Agriculture' on 22 January 2003. The Government supports the Commission's
proposals, the central element of which is to decouple agricultural
production from subsidy. If agreed, this would bring farmers closer
to the market, delivering economic, environmental and international
benefits. The Government supports the Greek Presidency in its
aim of reaching agreement in June 2003.
10. The Government should 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 (paragraph 48).
Following a discussion paper[1]
published in June 2002 a further discussion document was published
30 April 2003. By the end of 2003-04 we will have developed an
Action Plan which will include specific policy instruments on
which we will have consulted formally.
The purpose of the review is to identify the most
cost-effective approaches for reducing this pollution, and so
the costs of different options and the principles of sustainable
development will be considered in formulating proposals for consultation.
The choice of policy instruments will have an effect on the distribution
of the costs of reducing diffuse water pollution from agriculture
and the potential impacts on all stakeholders will be carefully
considered as part of the policy development process. Full consultation
with stakeholders is being conducted as part of the process.
11. We urge the Environment Agency and others
to be more aware of the status of lakes and ponds (paragraph 51).
Lakes are a water body category under the Directive,
so their status will be assessed according to the requirements
of the Directive.
In considering which lakes should be considered,
the Directive provides a minimum area cut off value of greater
than 50 hectares. This would in effect mean that many small but
important standing waters might not be considered. To overcome
this the Agency and the UKTAG are proposing a series of significance
tests for smaller water bodies, such as conservation value, to
justify their inclusion.
For lakes and ponds that do not fall within these
either of these criteria, it is expected that the measures taken
to protect other surface water bodies will provide protection
for small lakes and ponds within the same catchment.
1 'Initial Thinking on the Problem and Solutions' Back
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