Strategic Evidence & Partnership Project Report (Defra, 2011) by Westcountry Rivers Trust

Defra Strategic Evidence and Partnership Project

(Component A) Establishing strategic partnerships and obtaining local catchment evidence Contents Acknowledgements..........................................................3 Main report authors.........................................................3 Trust report authors.........................................................3

Executive Summary______________________7 1.0 Introduction_________________________8 1.1 Project objectives.......................................................9 1.2 Project deliverables....................................................9 1.3 Test trusts...................................................................9 1.4 What is the WFD problem?........................................9 1.4.1 Case example..................................................... 9 1.5 Methodology............................................................10 1.5.1 Tools available to rivers trusts......................... 10

2.0 Summary of trust assessments_________11 2.1 Overall waterbody classification..............................11 2.2 Tools used in rivers trust investigations....................12 2.3 Mitigation recommendations...................................13

3.0 Matrix comparison of measures and delivery bodies_____________________15 4.0 GIS and Data Sharing for Integrated Catchment Management______________17 4.1 Data Access Introduction.........................................17 4.2 Data access issues and solutions..............................17 4.2.1 LAND USE AND LAND COVER........................... 17 4.2.2 Agricultural Statistics....................................... 19 4.2.3 BASEMAPS....................................................... 20 4.2.4 TERRAIN / HEIGHT DATA.................................. 20 4.2.5 ENVIRONMENTAL MONITORING DATA............ 20 4.2.6 FLOOD PLAINS................................................. 21 4.2.7 SOILS................................................................ 21 4.3 Data Access Summary..............................................21 4.4 Web Mapping Portal................................................22 4.4.1 Web GIS Screenshots....................................... 22 4.4.2 User Guide....................................................... 23 4.5 Visualisation Tools Workshop...................................23

Appendix 1: River Lugg Demonstrating the use of Local Catchment Evidence to Meet Good Ecological Status in the River Lugg Catchment. Wye & Usk Foundation

Appendix 2: River Ottery Developing a catchment management framework for the delivery of â&#x20AC;&#x2DC;Goodâ&#x20AC;&#x2122; Water Framework Directive status at a sub-catchment scale. Westcountry Rivers Trust

Appendix 3: River Rea Strategic evidence and partnership report. Severn Rivers Trust

Appendix 4: Matrix comparing information from RBMP and trust investigations. All appendices appear at the end of the document after page 86

Acknowledgements The authors would like to thank the three rivers trusts for the hard work that they put into these investigations on top of their normal project delivery work. Without it, there would be no report. Thanks must also be extended to the local area staff of the Environment Agency and other organisations that assisted with data and knowledge to enable these investigations to report accurately. The future of delivery is in this partnership.

Main report authors Alistair Maltby MSc CEnv FIFM, The Rivers Trust Michelle Walker BSc, The Rivers Trust

Trust report authors Emma Buckingham, Severn Rivers Trust Nick Paling, Westcountry Rivers Trust Hazel Kendall, Westcountry Rivers Trust Caroline Sherrott, The Wye and Usk Foundation

5.0 Conclusions________________________25 6.0 Recommendations___________________26 References____________________________27 3

(Component B)

5.0 Catchment Sensitive Farming Programme Review____________________________56

A Review of current policy tools and funding mechanisms available to address water pollution from agriculture In England

Executive Summary

30-37

1.0 Introduction________________________38 2.0 Objectives And Methodology.................. 39 2.1 Objectives ................................................................39 2.2 Methodology ...........................................................39 2.2.1 A Multi-Stage Approach................................... 39 2.2.2 Confidentiality................................................. 40

3.0 The Problems And Reasons Why The Problems Occur....................................... 41 3.1 Key Problems Identified By Stakeholders ................41 3.2 Soil Pollution Processes ...........................................42 3.3 Phosphorus Pollution Processes ..............................43

4.0 Current Policy Instruments ___________44 4.1 Overview Of Current Regulatory And Financial Mechanisms Available ............................................44 4.2 Assessment Of Current Regulatory And Financial Mechanisms Relevant To Soil Pollution .................45 4.2.1 Addressing The Growing Of Crops In Certain High Risk Fields Without Appropriate Soil Management Practices In Place....................... 45 4.2.2 Addressing Overstocking Of Livestock In Certain Grassland Fields At Certain Times Causing Poaching And Compaction............................... 51 4.2.3 Addressing Animals Poaching And Breaking Down River Banks............................................ 52 4.2.4 Addressing Farm Tracks Funnelling Water Into Fields................................................................ 53 4.2.5 Addressing Mechanical Compaction............... 53 4.3 Assessment Of Current Regulatory And Financial Mechanisms Relevant To Phosphorus Pollution......54 4.3.1 Addressing Phosphorus Transfer To Watercourses Via Soil Erosion.................................54 4.3.2 Addressing The Build Up Of Phosphorus Levels In The Soil ...............................................................54 4.3.3 Addressing The Timing And Method Of Phosphorus Application..........................................55

5.1 Targeting Of CSF Activity..........................................56 5.2 Reaching Farmers.....................................................57 5.3 Grant Funding..........................................................57 5.4 Developing On-Going Working Relationships With Farmers....................................................................58 5.5 Integration Of CSF And The Environmental Stewardship Programme.........................................58

6.0 Overarching Observations_____________59 6.1 Lack Of Consensus Of The Problem..........................59 6.2 Land Ownership Dynamics.......................................60 6.3 Enforcement Of GAEC1 Within Cross Compliance...60 6.4 Farmers Attitudes Towards Regulation.....................60 6.5 Roles And Responsibilities........................................61 6.6 Skills Need Within The Environment Agency...........62 6.7 Working Practices OF Environment Agency Enforcement Officers...............................................62 6.8 Reform Of Anti Pollution Works Notices.................62 6.9 Need For Different Incentive Packages....................62

7.0 Required Policy Changes______________64 7.1 Better Governance Arrangements Needed.............64 7.2 Clearer Regulation And Enforcement Needed........65 7.3 More Advice Provision Needed...............................66 7.4 Better Strategic Design Of Agri-Environmental Payments System Needed.......................................68 7.4.1 Targeting Area Payments................................. 68 7.4.2 Targeting Capital Payments.............................. 69 7.5 Clarity Needed Regarding The Management Of Phosphorus.............................................................70

8.0 Current Common Agricultural Policy Reform Proposals____________________71 9.0 Potential For Private Sector Investment In Catchment Management______________73 9.1 Paid Ecosystem Services Markets............................73 9.2 Investment From The Water Industry.....................75 9.3 Investment From Other Sectors..............................76 9.4 Paid Ecosystem Services Mapping...........................77

10.0 Conclusions And Recommendations___79

Annex A Enforcement Cost Estimates And Assumptions (5 Year Period)............................................................83

Annex B Advice Provision Cost Estimates And Assumptions (5 Year Period)............................................................85

References____________________________86 Tables Table 1. Summary Of Problems Encountered And Underlying Causation....................................................................41 Table 2. Coverage Of Buffer Strips In Lugg & Rea Catchments.47 Table 3. Uptake Of HLS Erosion Management Measures In Lugg And Rea Catchments...................................................49 Table 4. HLS Fencing Options Adopted In Rea Catchment.......52 Table 5. CSF Capital Items Funded In Study Area Catchments.57 Table 6. Indicative Enforcement Resources & Costs (5 Years)..66 Table 7. Indicative Advisory Resources And Costs (5 Years) ....67 Table 8. Cost Estimates To Achieve Necessary Arable Reversion/ Buffer Strips................................................................68

Disclaimer This report has been produced under contract by Alex Inman (Consulting), an independent consultant, on behalf of Defra and The Rivers Trust. All analysis and observations contained within have been derived from verbal information provided by project participants, complemented by quantitative data provided by participants where possible. Much of the analysis is based on opinions expressed by individuals which may not necessarily represent those of the organisations they represent. Whilst the author has taken all due care to interpret and collate participant input accurately, any party relying on the results of the analysis shall do so at their own risk and neither the author, Defra or The Rivers Trust shall be liable for any loss or damages (excluding personal injury) arising there from.

Maps Maps displaying Environmental Stewardship options kindly produced by Natural Englandâ&#x20AC;&#x2122;s Geographical Information and Analysis Team, Telford. Reproduced by permission of Ordnance Survey on behalf of HMSO. Crown Copyright and database right 2011.

Table 9. Estimated Capital Investment Required In Study Catchments.................................................................69

Figures Figure 1. Rea SCIMAP Analysis And ELS Cultivated Land Buffer Distribution.................................................................48 Figure 2. Distribution Of HLS Soil Protection Measures HJ3, 4, 5 In The Lugg..................................................................50

Figure 3. Map Illustrating Potential Target Areas For PES Payments....................................................................78

Rivers trusts are a network of local community-led river stewardship initiatives covering 70% of river catchments in England and Wales. The Rivers Trust is their national umbrella body. The movement is probably the fastest growing environmental initiative in the UK with growth throughout the British Isles. The focus of rivers trusts is the delivery of on-the-ground improvement measures, thereby filling an important niche at the practitioner level. Rivers Trusts are incorporated, and they are charities, therefore they are independent, responsible and exist for public benefit. Component A investigates the potential role of rivers trusts in identification of failures to meet Good Ecological Status (GES) as classified by the Water Framework Directive (WFD) system, and good ecological status as defined by local stakeholders. Rivers trusts are also asked to propose community-led mitigation measures to increase co-delivery of WFD. Component A also explores what role The Rivers Trust might play in order to best support the delivery of WFD mitigation measures by local rivers trusts. Three rivers trusts of different characteristics, Westcountry Rivers Trust, the Wye & Usk Foundation, and the Severn Rivers Trust, were asked to make an initial assessment of waterbodies in their catchments, and identify from waterbody data, the areas where they might be able to provide additional evidence in terms of classification. The trusts then used basic tools and knowledge available to them to undertake investigations which would lead to mitigation recommendations that could be delivered by the third sector, thereby increasing the delivery of WFD objectives.

Rivers trusts have access to quite a broad range of tools which they can use. In this case, the use of existing data not used in WFD classification, local knowledge (including walk-over surveys), and the use of bespoke Geographic Information System (GIS) models and mapping tools, dominated the investigation.

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Executive summary of a DEFRA Strategic Evidence & Partnership project (component A)

The rivers trust investigation ended up challenging the GES classification of many waterbodies. This is important in that WFD classification must match local aspirations if the community is to deliver on behalf of government, and that these waterbodies represent a significant risk of showing deterioration in future assessments. Rivers trusts were able to propose mitigation measures which tended to be structured on a catchment, or units of catchment scale, rather than on a WFD waterbody scale. Trusts were confident that delivery of these measures would result in achievement of good ecological status. The Rivers Trust has a significant role to play in facilitating access for trusts to complex data held in statutory organisations, developing investigative tools, mapping and monitoring achievements. Rivers trusts are capable of providing a substantial resource in the delivery of WFD good ecological status, from investigation of failures, through to implementation of measures. Full engagement with the rivers trust movement will substantially improve WFD ambition. In order to achieve this, rivers trusts need: 1. Funding structured so that measures can operate over sensible catchment units, as opposed to that which is restricted to specific measures, or waterbodies. 2. Ability to contribute biological data and knowledge to the classification process. 3. Support with, and access to catchment data, maps, and investigative tools. 4. Strong delivery by statutory bodies of regulatory measures outside the scope of the third sector.

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Establishing strategic partnerships and obtaining local catchment evidence 1.0 Introduction The EU Water Framework Directive (WFD) is the most significant piece of legislation effecting rivers in more than a generation and is widely welcomed by the rivers trust movement. The legislation centres on the achievement of Good Ecological Status (GES) for rivers, a departure from previous standards centred on easily measurable chemical determinants. The rivers trust movement is a network of communityled river improvement and management initiatives. These initiatives are legally incorporated such that they may undertake work with full liability, and are registered charities such that they must demonstrate public benefit. The charitable objectives, and hence work, of these bodies are typified by the following statements, with some local variation dictated by the characteristics of catchments and communities: 1. To advance the education of the public in the management of water and environmental protection, conservation, rehabilitation and improvement. 2. To advance the education of the public in the understanding of rivers, their basins, fauna and flora. 3. To protect, conserve, rehabilitate and improve the rivers, streams, watercourses and river basins, including adjacent coastal waters and water impoundments, of England and Wales or any part or parts thereof for the public benefit. Within the scope of these broad charitable objectives, rivers trusts are essentially delivery organisations, and involve people referred to as having ‘wet feet’. Rivers trusts do not normally achieve their objectives by lobbying or campaigning, they do not own their own land or manage reserves, but achieve them by ‘doing’ work with people who own and manage river and water resources. The Rivers Trust (RT - formally the Association of Rivers Trusts) is the umbrella body for the rivers trust movement, founded and governed by the local trusts. RT is not a management hierarchy for local trusts, but works in servitude of these local community-led initiatives. Essentially, RT provides a model and support whereby any community-led organisation with charitable objectives in line with those of the movement, can operate legally, and for public benefit on their local rivers. Rivers trusts are almost unique amongst the conservation charities in that they work almost exclusively on other people’s land. Based on the charitable objectives and delivery work of rivers trusts, by their very nature, rivers trusts are delivering work to achieve good ecological status at a 8

catchment scale. It has therefore been surprising and frustrating that in many instances, objectives set by the classification of waterbodies for achievement of Good Ecological Status under WFD do not reflect priorities set by local community initiatives. For Government, this restricts the opportunity to capture the delivery resource, and additional funding resource, which is already operating to deliver similar objectives. For the charitable, and in particular the rivers trust sector; alternate priorities set by the current classification restrict the financial resources available, both in amount and geographic area, and reduce public support for WFD when these priorities are outside of their understanding of the river and its ecological problems. This project looks to demonstrate that the situation as described exists, and provide evidence that rivers trusts can be given responsibility to deliver good ecological status in their catchments, which reflects GES as recognised by the WFD. It is hoped that this will give confidence to Government in giving responsibility and resources to rivers trusts for the delivery of the WFD without constraint by the current classification system, with the benefit that this will result in ramped up public support, ambition, delivery, and attract further funding to achieve GES within the required timescale. The following report is a summary and analysis of three detailed reports (Appendix 1, 2, 3) made by the trusts involved in the project. The trusts are broadly representative of the capability of the rivers trust movement in 2011. This includes one very new trust, faced with all the associated problems. Their reports reflect their individuality and are given in the appendices.

Figure 1: Growth of the rivers trust movement reflected by number of trusts and the coverage of the currently proposed 100 WFD river catchments. Conservative figures based on current full membership of RT. If all initiatives engaged with RT are included, coverage of WFD catchments is at least 73%, and RT is confident that the whole country is covered by community groups who have yet to engage with the movement but who could use the rivers trust model provided by RT.

1.3 Test trusts The scale of the rivers trust operations engaged in this project work are summarised in Table 1 by the number of people they employed at the beginning of the project, and their income from their last published accounts.

1. Demonstrate that Rivers Trusts are able to collect additional information to either support or challenge waterbody ecological classifications. 2. Demonstrate that Rivers Trusts are able to collect additional information to assign a reason and, or geographic location to good ecological status failures. 3. Demonstrate that Rivers Trusts are able to recommend a solution for ecological status failures where measures are currently considered infeasible or disproportionately expensive. 4. Test simple investigative methodologies available to Rivers Trusts for informing waterbody ecological status and reasons for failure. 5. Test the feasibility for RT to provide a central mapping and database service to assist Trusts in carrying out waterbody investigations and delivering informed measures.

1.2 Project deliverables 1. Report on catchment investigations by individual trusts. 2. Matrix of analysed waterbodies to include existing measures from the River Basin Management Plan (RBMP) and measures proposed by rivers trusts in light of investigation. 3. Report on GIS & data sharing issues to include the potential role of a national mapping tool and database.

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1.1 Project objectives A review by Rivers Trust personnel of the WFD RBMP waterbody assessments within three study catchments to:

1.4 What is the WFD problem? Following national classification by the Environment Agency (EA), there are a number of classifications that are acting as a barrier to implementation of works to meet the Directive by rivers trusts and the third sector. These may be summarised into three categories: 1. Failing waterbodies where there is no attributable cause. 2. Failing waterbodies where the cause is suspected but the mitigation solution is classified as infeasible or considered financially disproportionate. 3. Passing waterbodies where the classification is considered contrary to local knowledge. By embracing waterbodies in the first two categories, rivers trusts can potentially increase both the scale and efficiency of delivery of WFD measures, and hence the ambition for GES by 2015 and 2027. The third category of waterbody is perhaps more controversial, but none the less, very important in order for the third sector to be able to embrace the objectives of WFD in their daily work on the river.

Table 1: Comparison of trusts involved in project, and respective rivers of focus. Income and staff complement are used to distinguish the capacity of the operation. 1 Severn Rivers Trust employed their first member of staff to deliver this project. Two of these trusts are well established, with strong professional teams, and a relatively high income. SRT is a younger trust and is important in this analysis to represent the current capabilities of trusts that might have started within the last two years. It should be noted that despite the relatively high income of the two more established trusts, this income is principally delivery project derived, and the staff liabilities are subsequently also very high. Loss of project delivery income would lead to a very rapid decline in the staff resource available to deliver in otherwise remote rural locations. 9

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1.4.1 Case example West Cumbria Rivers Trust (WCRT) is a relatively new trust, and although the trustees have been active as a community group for a couple of years, the rivers trust was only incorporated under the RT model this year (2011). WCRT employ one member of staff who is an ex-Environment Agency project officer, and have worked up a suite of four projects designed to bring the River Derwent catchment into good ecological status, in full co-operation with the local EA Area team. These four projects all addressed complete barriers to fish migration existing in tributaries of the River Derwent, and all agree that this was compromising good ecological status. The projects subsequently all failed technical assessment for WFD funding because the waterbodies were already classified as being in GES. The reason for this is that the monitoring points are in the main river which means that adjoining tributaries are classified using the same data. This clearly leads to an incorrect assumption on the ecological health of these significant tributaries, detaches WFD priorities from local community priorities, and is a significant risk of showing deterioration based on future investigation.

1.5 Methodology The only prescribed methodology for this piece of work involved the identification and selection of waterbodies where there is likely to be opportunities for rivers trusts to increase ambition in terms of GES achievement. This involves a quick method of identifying waterbodies from the data given in the River Basin Management Plan (RBMP), which at the current time is the only data source available outside of the EA for working on WFD delivery. By sorting the waterbody data sheets using standard spreadsheet tools, the following areas of opportunity for rivers trusts can be quite easily identified within catchments: • Waterbodies with no biological monitoring. • Waterbodies with single categories of failure where all other parameters appear in good status. • Fish failures, where all other parameters appear in good status • Other biological failures, where all other parameters appear in good status. • Measure decision codes that describe the water body as ‘technically infeasible’ or ‘disproportionately expensive’.

The next stage of review is to analyse these waterbodies in a spatial way. This is a little harder in that mapping tools are not available equally over the rivers trust network at the current time. It is also helpful when mapping waterbody classification to have knowledge of the corresponding monitoring network, data that is not usually accessible to trusts. The mapping situation is another aspect explored later on in this report and is another opportunity to increase the capacity for WFD delivery over the rivers trusts sector. Mapping waterbody classification helps to identify the following features: • Failing waterbodies downstream of a network of passing waterbodies • Lone passing waterbodies in a network of failing waterbodies • Very large waterbodies, or waterbodies with a large network of tributaries • Very small waterbodies • Waterbody classifications which do not correspond to the priority work of the local rivers trust. If data on the monitoring network is also available, this helps identify the following features: • Monitoring points outside of classified waterbodies • Monitoring points below features within waterbodies Obviously, waterbodies that have strong data for failures on multiple parameters, and mitigation measures that are well identified, need no immediate input from rivers trusts in order to increase the delivery ambition.

1.5.1 Tools available to rivers trusts The project then asked the rivers trusts to explore the range of tools that are currently easily available, or transferable to them to identify the cause of failure, and the appropriate mitigation measure for selected waterbodies. Tools which were suggested in the first instance included: • Local knowledge of current and historic problems with suitable investigation and audit trail. • Walk-over surveys including wet weather surveys looking for inputs to streams, habitat surveys, both linear or point based (e.g. River Habitat Survey (RHS) or a simplified version of this developed by Tyne Rivers Trust), or just general stream reconnaissance. • SCIMAP, a fine sediment hydrological connectivity Geographic Information System (GIS) model developed in partnership with Eden Rivers Trust. • Aerial photographs • Water quality assessment using invertebrate proxies or collected directly either as a sample or using electronic logging devices. • Statutory & third party data sources not used in WFD classification. • Electrofishing & other fisheries surveys.

2.1 Overall waterbody classification In each of the three rivers, trusts identified serious disparity between the classification and local knowledge. This is of course partly biased as the selection process identified waterbodies where there was a lack of biological data used in the classification, but this in itself represents a large proportion of waterbodies nationally, and represents the difficulties that trusts might encounter in incorporating WFD measures into catchment management. The WUF investigation was slightly different, in that because they worked on a much larger catchment, they picked a number of waterbodies that represented issues for the foundation, and worked

on these. So although there was disparity, the overall proportion of the waterbodies they assessed, did not change. 23% of waterbodies in the Lugg catchment did not have biological data, and based on experience, the majority of these might be expected to fail GES if this data is incorporated. The figure is fairly similar in the River Rea with 37% of waterbodies not having biological data, however, the proportion of waterbodies having no biological data that meet GES is much higher, 60% in the Rea. If these figures are consistent around the country, this reflects a big possible deterioration based on monitoring alone. The earlier Eden assessment gives a more conservative figure over a larger catchment of 10% of all waterbodies not having biological data and 22% of waterbodies meeting GES (Maltby, 2009). Though this is nearly a quarter of passing waterbodies not having the appropriate data. Wye & Usk is 40% of all waterbodies overall (Evans, 2009).

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2.0 Summary of trust assessments

Figure 2: Comparison of rivers trust opinion on investigated waterbodies against current classification. Percentage is proportion of waterbodies with biological data. For the River Lugg, WUF investigated a number of named waterbodies rather than the whole catchment. Their conclusions resulted in different results for some waterbodies, but the overall split did not change and so one pie chart is shown. 11

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2.2 Tools used in rivers trust investigations Of particular interest from the investigations, is the amount of assessment that has been possible from existing sources and local knowledge. Even where scientific tools are used in the case of WUF, this is to confirm assessment rather than to inform it. This was somewhat of a surprise and more technical investigation was expected to be needed, but makes the development of a GIS data sharing and analysis platform for the rivers trust movement an even bigger priority, and one which will have direct consequences for the delivery of wider WFD objectives. From the reports, it is clear that it would

only require a very small series of steps to trace many of the problems back to individual sources or priority areas, using these more technical tools, which will help produce a series of mitigation measures that are as affordable as might be achievable. Further work will need to assess and refine the available tools based on the key environmental problems being identified by trusts consistently in waterbody assessment. RT should also work to add to the simple suit of scientific field tools, or refine protocols, such that rivers trusts can provide a solid audit trail back to the competent authority based on their conclusions on waterbody status so that mitigation decisions can be agreed and waterbody recovery monitored.

Table 2: Range of investigative tools used by the trusts in analysis of selected waterbodies. Items in italics are proposed by WRT but yet to be implemented. 12

Very significant to the achievement of good ecological status on a catchment and national level, are the recommended mitigation measures from each study. Re-interpretation of a number of fairly non-descript parameters, application of local knowledge, and on the ground interpretation, has lead the rivers trust in each case to come up with a suite of measures which could be applied over the whole catchment area of interest. This treatment of WFD, not on a waterbody level, but on sensible management units based on the character of the catchment is representative of the way that trusts work, and is at odds to the current way in which trusts can access specific WFD funding. Controversial for The Rivers Trust, is that other organisations can access WFD funding outside of waterbody restrictions, which would facilitate meeting GES in a holistic way, but this does not seem to be being used with this objective. The rivers trusts feel that this approach to meeting good ecological status is more likely to show improvement of the critical biological parameters, and is likely to result in management changes that will be preserved within future catchment management.

It is not a great surprise to see that the more established trusts have current mechanisms based around existing projects and funding for delivering many of the capital works required to improve the ecological condition of the study waterbodies. This has led to less defined capital cost estimates in those catchments because they are tied up with broader measures, for example based around oneto-one farm advice. This is likely to represent good value for money as the trust works on specific problems and use existing funding mechanisms as much as possible. As the newest trust, SRT has been able to be quite definitive on the costs of riverside fencing, and those of the fish pass capital works already known. There are further fish passage works required in the waterbodies so a total capital funding estimate of perhaps £800k would not be unreasonable for bringing these eight waterbodies into good ecological status. Based on the experiences of established trusts, some of these capital works (fencing, buffer strips, stock reduction etc) might be delivered by signposting to, or facilitation of agri-environment schemes available in the catchment. This might reduce the capital bill by perhaps £200k, but could end up ‘costing’ more with the additional expense of paying for other activities required to make a Higher Level Scheme

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2.3 Mitigation recommendations

Table 3: Mitigation recommendations, estimated costs and external funding sources.

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(HLS). This might not be good value for money if the additional environmental works were non-functional from an ecosystems services perspective, or non-priority from a conservation perspective. If the regulators were more active in this catchment in enforcing cross compliance and other regulations, funding may also be reduced in that the landowner would be more likely to make a share of the investment. Match funding of at least 50% has been common in many such areas, and much more could be expected with no additional funding required. The WUF cost estimate is interesting as their approach would concentrate on refining the identification of the particular phosphate sources in the catchment, leading directly to the parcels of land and farms to work on. This has been estimated at ÂŁ90k for the three waterbodies identified for improvements, but would be supplemented by the use of agri-environment schemes where possible, and improvements to management made by both the water company and the Inland Drainage Board (IDB). There is perhaps an outstanding question on the whether the source of phosphate is derived from septic tanks, water treatment works or diffuse pollution; but this does

not take away from any of the works required due to the clear ecological impact of sediment in these rivers, which if not showing up in GES phosphate failures, would certainly show up in biological parameter failures. The value for money in investment in the WUF catchment investigation and works programme is likely to be very good because the result will be more efficient use of existing funding already available for mitigation work. Best value for money from all the studies in this project are likely to come from the WRT work on the Ottery as at the current time, the works and land management agreements necessary are being funded by the water company through the Upstream Thinking project. The reason for this is the importance of the Tamar catchment to the South West Water supply network. It is important to realise that neighbouring catchments that are not part of the water supply network will not have access to this level of funding support, where the WRT approach might be better combined with some effort as in the WUF example to further identify the individual farms and problem parcels of land. In these catchments, new sources of funding will need to be identified.

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3.0 Matrix comparison of measures and delivery bodies

Table 4: Comparison of measures from RBMP and trust investigations. Full matrix is shown in Appendix 4. Measure comparison is only possible for the waterbodies already classified as failing, as there is obviously no measure prescribed for waterbodies that are already meeting GES.

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The trusts reported that for all the waterbodies assessed, there were no specific measures, just cross cutting measures covering a variety of issues representative of the river basin. This means that on the face of it, appropriate measures may be being prescribed, such as the CSF initiative, cross compliance enforcement and so on, but there is no way of telling where these initiatives will be applied, and what effort will be put into them. This leaves potential co-deliverers in a very difficult position as it seems that there are no gaps in delivery for other sectors to fill. This situation encourages apathy and measures need to demonstrate their true geographic extent to empower other organisations like rivers trusts. It is likely that the same cross â&#x20AC;&#x201C;cutting measures exist in the South West RBMP, even though they are not identified in the matrix by WRT, and this is probably because these broad measures are difficult to identify in the plan, and impossible to assign to any particular waterbody. It is encouraging that some of the measures prescribed by trusts in the investigated waterbodies match measures already within the plan. In this instance, the opportunity provided by trust information might be to target these schemes within the waterbodies to individual farms, and perhaps give an opportunity for the trust to use tools available within those schemes which would represent a huge efficiency. For example, rivers trust staff working in these waterbodies might work with farmers to make applications for capital funding available through the England Catchment Sensitive Farming Initiative (CSF), or assist in designing environmental measures for application in an agri-environment scheme. This is already the way that many trusts operate, including those within this study. Trust investigations also give a good opportunity for accurate costing of landscape, watershed or multiple waterbody scale initiatives to groups or even individual farms.

The WUF investigation has given responsibility for some measures to other organisations, specifically important to these waterbodies. In the context of the last RBMP process, and liaison panel process, this is a very important finding, where it has been difficult to engage many industries as co-deliverers. WUF provides evidence that the sewage treatment works is a phosphate source that needs addressing by the water company through the water companyâ&#x20AC;&#x2122;s Asset Management Plan (AMP), and suggests that ecological habitats could be improved by the Inland Drainage Board (IDB) taking a less aggressive approach to stream drainage, and in so doing reduce costs by approximately ÂŁ4k per year for that waterbody alone. WUF also provided evidence that there are cross compliance enforcement issues in these waterbodies, an area of work that it is very important that rivers trusts stay completely detached from, and this might help prioritise limited resources available to the regulators across large catchments. In all cases, the trusts are identifying themselves as key to the delivery of on-the-ground measures in these waterbodies. This may either be as direct implementers in the case of migratory fish barriers, habitat improvements and mitigations, informers in the case of pollution and ecology assessments, or facilitators to direct other initiatives. This natural position for rivers trusts needs to be supported and formalised in WFD delivery mechanisms to recognise the resource, the information, and the reporting potential of trusts in RBMPs, and the regulators need to take a strong line on compliance which is important for the rivers trusts to remain detached from.

4.1 Data Access Introduction Much of the analysis work underpinning catchment management set out in this report, is heavily dependent on spatial data, which can be time consuming and costly to acquire. The Rivers Trust have spent many months negotiating and co-ordinating a national data sharing agreement between the Environment Agency and the 39 Rivers Trusts in England and Wales, which has secured access to many core datasets, largely driven by the EU INSPIRE Directive. However, the EA / RT agreement does not cover third party data, which includes a significant number of datasets fundamental for integrated catchment analysis and planning. NGOs struggle to afford much of this data unless they are able to draw on sub-contractors’ license agreements via public sector partners. However partnership status is not generally recognised under these license agreements, with the exception of the Ordnance Survey’s Public Sector Mapping Agreement (PSMA). If third sector organisations cannot use the core datasets which private and public sector bodies base their management decisions on, either because costs are prohibitive, or because legal or technical issues prevent access, then this presents a major obstacle to effective third sector involvement in WFD, and to the wider ideals of the ‘Big Society’. Table 5 (overleaf) details the indicative annual data costs for a representative rivers trust with a catchment area of 3000km2, wishing to undertake a program of analysis work similar to that which has been undertaken for the SE&P project. The estimates are also given for the whole of England and Wales to show the scale of the costs for national involvement of the third sector in WFD. Each NGO involved in WFD and wishing to access the data would be liable for these fees, and they are largely annual license costs, so they would be payable every year, in perpetuity. Clearly this is not something that a typical NGO can finance, and so for WFD work, the third sector would be looking to the public sector to subsidise this cost, which in most cases would mean the public purse is paying twice for the same data. The Rivers Trust believe this is an unacceptable waste of public money, and so are committed to exploring every possible avenue to reduce or remove data license costs to third sector organisations who are working to support public sector core business. The goal which RT are pursuing is to reduce the licensing costs from a potential £180k per catchment per annum to only around £4.5k ‘startup’ cost, and around £1.5k per annum thereafter. The first figure would be the full cost of licensing Detailed River Network, Flood Zones, Land Cover Map 2007 raster, Nextmap 5m DEM, Mastermap,

1:10k basemaps, 1:25k basemaps and soils vector data. The reduced figure is based on an assumption that EA provide OS data under the PSMA, that Nextmap DEM data are made available at reduced cost and under a perpetual license, and that LCM2007 data are made provided by Defra under a sub-contractors license agreement. The most valuable of these is the PSMA saving.

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4.0 GIS and Data Sharing for Integrated Catchment Management

4.2 Data access issues and solutions In this section, we set out the key issues regarding the main datasets required for effective catchment management planning, along with our recommendations for how we think they might be tackled. This is a fast moving field – RT have been diligently pursuing and lobbying the various parties for improved access and reduced cost, which is starting to reap results. Therefore this summary is likely to be rapidly out of date, so please contact RT to be kept apprised of developments.

4.2.1 LAND USE AND LAND COVER Up to date and spatially detailed land cover and land use are essential baseline datasets, used for modelling diffuse pollution risk, mapping ecosystem service provision, and for ‘what if’ scenario modelling of potential WFD measures. LandCoverMap2007 – (Centre for Ecology and Hydrology / NERC) This is the most up to date national land cover map for the UK, released July 2011. Available as a 25m raster product and a detailed vector product (prices quoted here are for raster data) Annual Cost: National £12,400: Catchment £390 (includes £150 CEH admin fee) Issues: The CEH administration fee adds considerably to the cost for small trusts. Annual costs quickly become prohibitive for those with large areas. Defra part-funded the development of LCM2007, and can supply data to sub-contractors, although Defra would be liable for a £100 administration fee per license. It is not yet clear whether this option is available for RTs who are not under contract to Defra. Solutions: Defra and RT should investigate whether existing funding vehicles, such as the River Improvement Fund would enable Defra to provide the data to all RTs. We recommend that CEH are pushed to waive the £100 administration fee per subcontractors license, or at the very least to combine the fees for all 39 trusts, to minimise the administrative burden on all parties. RT can co-ordinate the administration of licensing for the trusts, as they have with the EA / RT data sharing agreement. In a separate approach, RT have also asked CEH to make their data free of charge, as they do for academic users, or at the very least waive their administration fees applied to every purchase. We are much less hopeful of this approach delivering a satisfactory result unless some high-level pressure is applied to NERC.

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Table 5: Breakdown of Indicative Annual Data Costs for NGOâ&#x20AC;&#x2122;s wishing to undertake catchment analysis and planning

*We are awaiting confirmation from Intermap that this discount will apply to all Rivers Trusts, and that the license will be granted on a perpetual basis, so no annual fees would apply. Figures in bold are based on actual quotations requested by RT, figures in italics are estimated from comparable information. Where national coverage is quoted for a single user, this would only cover one user in a single organisation and would not indicate the cost of each individual local NGO holding a copy of the data.

Held by Defra and Rural Payments Agency for England, WAG for Wales, Edina and ADAS These are the most comprehensive agricultural land use statistics for England and Wales, based on the annual June survey. Held at community level by WAG, farm holding level by Defra, field level by the RPA, summarised at 1km level by ADAS and 2km level by EDINA. This is a critical dataset for modelling current and future agricultural land use impacts on water quality and WFD ecological status, and therefore for selection of most appropriate programmes of measures. Annual Cost: £900 per user for national coverage (Edina 2km dataset). ADAS would usually charge a fee for data provision, but we are exploring options with them – for example they have been able to provide their 1km data free of charge for the pilot web mapping portal project, covered by a Defra license. Defra, WAG and RPA have no charges set – summary stats at county level are available online free of charge. Issues: Use of statistics is restricted by the Agricultural Statistics Act, covering appropriate use and ensuring data protection. This makes any data request complex to assess, and requires director level sign-off within Defra. Data are only available when working on specific Defra projects, so are not available to RTs out with the SE&P project. This meant that we had to make two versions of the web mapping portal available, covered by separate licenses. In addition, the holdings-level data can provide wildly inaccurate statistics on land use at sub-catchment level (holdings can be spread across many catchments and stats are reported at a nominal centre point of the entire holding). 1km data are heavily processed by ADAS to remove much of this inaccuracy, which is why they

charge a ‘value-added’ fee. Field-level data are the only spatially accurate data reflecting actual land use and livestock numbers within catchments, but access is restricted to RPA and NE. Solutions: RT have requested access to historical and current holdings level and 1km summary data, but the latter are developed by ADAS under license from Defra, so the licensing and cost implications are complex. We will continue to explore options for reducing or removing the cost with ADAS, but it is not yet clear whether they would make the data freely available to RTs even if we continue to contract them to host the web mapping portal. Based on feedback from a survey of RTs and SE&P project partners, we established that there is a clear need for agricultural statistics to be made available beyond the SE&P project, and we set out a range of possible solutions, including licensing trusts for the ADAS 1km data and providing holdings level data to RT who could generalise this to remove any data protection issues. We are awaiting a response from Defra regarding the licensing situation.

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4.2.2 Agricultural Statistics

RT have also written to the RPA to request field level statistics as well as farm boundaries. We have proposed that the field level statistics could be summarised at WFD waterbody catchment level to protect confidentiality. RPA have promised to consider the request. We would recommend that the planned EA Catchment Data Sharing Forum should address this as a matter of priority.

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4.2.3 BASEMAPS Essential for setting RT work in context, from catchment management planning and field work preparation to detailed referencing of survey and monitoring data Detailed River Network and topographic basemaps (EA and Ordnance Survey) The DRN is the new core dataset on which WFD is based – it is critical that all WFD partners have access to this data so that survey and monitoring work is referenced to a common spatial framework. Annual Cost: Free for access under the Public Sector Mapping Agreement, otherwise national costs for DRN are £10k, Mastermap is £5.9m, 1:10k basemaps are £220k and 1:25k basemaps are £28k Issues: If RTs cannot access the DRN, they will simply use a different frame of reference for digitising and collecting information, which would mean their data would be very difficult to integrate with public sector datasets, representing a missed opportunity for ‘The Big Society’. Solutions: RT have requested that EA set up an End User License under the Public Sector Mapping Agreement, which would allow EA to share these Ordnance Survey datasets with organisations who support delivery of their core business. These datasets would include the DRN and the majority of OS topographic basemaps. RT have offered to coordinate the licensing process for each trust, as this has worked successfully under the EA / RT data sharing agreement. EA are currently investigating. RT believe that it is critical that this is resolved by start of the pilot catchments intiative in 2012.

4.2.4 TERRAIN / HEIGHT DATA Critical for modelling of detailed hydrological processes, such as diffuse pollution runoff and hydrological connectivity, which are essential for gaining an accurate risk assessment across catchments. Nextmap 5m DEM – (Intermap PLC and Getmapping) RT have been in discussion with Getmapping, and are awaiting final confirmation that they will match academic discount and offer a perpetual license. One-off Cost: National £150,000; Catchment £3000 (provided we get agreement, otherwise an annual cost of £610,000 for national coverage at full price) Issues: Data costs are still prohibitive for smaller trusts so RT will explore options for central funding. Solutions: If Getmapping agree to this discount, RT could bid for one time funding from public sector to purchase national data which would then be available on a perpetual license to all Rivers Trusts.

4.2.5 ENVIRONMENTAL MONITORING DATA Essential for understanding and critically appraising the WFD assessments and assessing the most appropriate measures. Water Quality, Flow and Biological Monitoring Data (EA, Water Companies, Rivers Trusts) Costs: None for EA or RT data. No information on Water Company charges. EA data are available from local EA teams, and EA are now bound by the INSPIRE directive to respond to reasonable requests within 20 days. Issues: Locations and content of water company monitoring datasets are commercially sensitive, so

Land use Slope Rainfall

4.2.6 FLOOD PLAINS Essential for identifying ‘wetted land’ with potential for wetland habitat creation – a key component of sustainable catchment management planning. Flood Zones 2 & 3 (Environment Agency and Centre for Ecology and Hydrology / NERC) These show the 100yr and extreme 1000yr flood plains for rivers in England and Wales. Annual Cost: National £2,200; Catchment £280 (Royalty payable to CEH) Issues: Annual costs are steep for smaller trusts with limited budgets. Flood zones were modelled using CEH data, so use of any derived product must gain approval from CEH licensing team. For example, Wetland Vision future potential wetlands data, or anything derived from it, cannot be used without CEH approval, which can take several months as CEH are slow to respond. Solutions: RT could bid for annual funding from public sector to subsidise the cost. Central government could direct NERC / CEH to release IPR restrictions and charges on derived data products, and/or impose a 20 day service level agreement for resolving license requests.

4.2.7 SOILS

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access is restricted for non-public sector bodies. Local provision of data requests by EA has been patchy, but the national data team have been very helpful in providing guidance for directing future requests, so it is hoped that these problems are now largely solved. Rivers Trusts are beginning to amass monitoring and survey datasets, which are currently held piecemeal by each individual trust. This will pose challenges for sharing the information efficiently with public sector bodies. Solutions: RTs should direct all reasonable data requests to local EA External Relations teams, and insist that 20 day service level agreement is adhered to. RT will collate any issues to report to national EA data sharing team. EA Catchment Data Sharing forum should engage with water companies to investigate options for opening up access to water quality monitoring data. RT will continue to evaluate options for efficient central storage of datasets – using existing systems where possible to avoid duplication of effort. RT will also investigate the option for EA to store and manage RT data.

Essential for characterising catchment runoff and underpins many models such as PSYCHIC, and NEAP-N Soils Vector and Series data (National Soils Resources Institute) Vector dataset contains spatial extent of soil series, supplementary datasets contain detailed hydrology and runoff information. Annual Cost: Catchment £1000 (Includes £375 Administration Fee) Issues: Annual costs are steep for smaller trusts with limited budgets. Hydrology of Soil Types (HOST) data underpin many ADAS models, so output from these requires a license from NSRI. Solutions: RT are meeting with NSRI to discuss options for reducing costs, including partnership and development of value added services. NSRI waived license fees and responded very promptly to the license request in respect of PSYCHIC output available on the web mapping portal.

4.3 Data Access Summary Whilst much progress has been made with respect to widening data access for the third sector, there is still much work to be done. We fully support the EA’s proposal to set up a catchment data sharing forum, and have provided recommendations for priority issues which the forum could tackle. Solving the access to Defra agricultural statistics remains the biggest challenge in terms of complexity, and yet the data are proving to be a critical information source that could underpin effective selection of measures for WFD. The time and effort involved in this data gathering and licensing task should not be underestimated. Each NGO wishing to obtain data to support their catchment management work will need to engage with Defra, the Rural Payments Agency, the Centre for Ecology and Hydrology, the National Soils Resources Institute and the Ordnance Survey at the very least. We would therefore recommend that Government consider funding a national data sharing post, hosted by an NGO, with responsibility for negotiating and co-ordinating national data sharing agreements between public, private and third sector organisations.

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4.4 Web Mapping Portal The previous section discussed the licensing restrictions and costs of data, but data sharing is also about the technical challenges of providing data to multiple users, and of turning datasets in to information that can be readily interpreted and widely understood by all stakeholders. Both of these are big challenges. RT have started to address these challenges by commissioning ADAS to set up a Web GIS pilot at a cost of £12k, to run until the end of November, which will be used to elicit user feedback from SE&P partners, but also a wider range of WFD co-deliverers (RT successfully negotiated temporary data licenses to allow a wider range of end users to evaluate the system). User feedback from the pilot stage will be used to design the next phase, which could be rolled out to other rivers trusts in 2012. RT believe that this tool could offer a good solution for information sharing between WFD stakeholders for the pilot catchments, but there is still some considerable work to do to agree data licenses across the wide range of WFD co-delivery organisations. RT are fully prepared to help and advise other NGOs wishing to access this information, and will be joining the EA’s planned catchment data sharing forum, which we hope will start to address these issues. It will certainly require some drive and determination on the part of the public sector to make this happen, and RT are currently

Web GIS Screenshots

negotiating and petitioning a wide range of public and private sector data suppliers to keep this agenda moving forward. RT are also exploring with the EA’s economics and statistics team the potential for using this and other existing platforms to develop a solution for evaluating and comparing costs of measures within catchments, so the pilot project has already provided a focus for solving some of the key data and information sharing challenges which face WFD co-deliverers. Longer term, such a platform could also include a central data storage solution for NGOs undertaking data collection and monitoring, thus enabling them to share their data efficiently with other stakeholders, something which is a challenge for very small organisations with limited IT budgets. To be fully effective, this approach would need co-ordination between NGOs and the public sector – to ensure that IT resources are used most effectively, and that large IT and database projects do not duplicate effort and waste resources.

4.4.1 Web GIS Screenshots The RT Web Mapping Portal can be accessed at: http://web1.adas.co.uk/rt. Please contact The Rivers Trust for login details (info@theriverstrust.org ).

A user guide has been prepared to show the functionality of the system, outline data contents, and give a more detailed explanation of some of the key information. The aim of the guide is to translate metadata (data about data), which is a key requirement under the INSPIRE directive, in to a human-readable form, and to ensure that end users are made aware of the limitations of the data.

4.5 Visualisation Tools Workshop

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4.4.2 User Guide

A workshop involving The Rivers Trust and Westcountry Rivers Trust was held in August 2011, to evaluate a range of visualisation tools that are available, both for communication with stakeholders, but also for catchment planning and management. The workshop explored the idea of using different tools at different scales, and Figure 3 (overleaf) shows a conceptual model of the different models and approaches, along with some of the key data requirements. A tiered approach to using spatial data and models could be applied at different scales. At the catchment and regional scale, ecosystem services mapping (see Westcountry Rivers Trust’s report) can help to inform policy, by identifying broad areas where ecosystem services and food production are in competition, and also can help to identify potential funding sources when seeking to adopt a paid ecosystem services approach. At a sub-catchment scale, more detailed data, mapping and modelling can start to prioritise issues and target intervention – for instance using Scimap to identify risk areas for fine sediment erosion. Finally at the most detailed scale, field work and farm advice can be targeted, using detailed information such as farm and field level land use, large scale basemapping and the most detailed hydrological network data. The workshop also tested some free and low cost software options for exploring and visualising catchment information. Figure 4 (overleaf) shows some of the output from these tools. 3D models, such as ArcScene (part of ArcGIS Desktop) are very powerful, as they allow the user to drape aerial photography, imagery or basemaps over a 3D model of the catchment, providing an instantly recognisable framework for other layers, such as modelled erosion risk data, and allow the user to ‘grab’ the model and move it around, creating a very interactive experience. RT plan to test some of these tools in future stakeholder engagement work.

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Figure 3: Conceptual model of catchment planning and visualisation tools

Figure 4: 3D visualisation tools

Rivers trusts are able to collect additional information to either support or challenge waterbody ecological classifications, and recommend achievable solutions that can be applied locally. In the case of this project, three rivers trusts of varying size and resource were able to assess their test catchment for waterbodies where there was a gap in knowledge relating to the problem or the solution. They were able to make strong arguments based on existing knowledge and data, and collect supporting information, which on the balance of probability would result in mitigating for the failure to meet GES. In addition, the trusts identified waterbodies where GES was being shown to be met, contrary to local knowledge. Addressing this category of waterbodies is important in order to align WFD and stakeholder delivery to maximise ambition and available funding, and critical in preventing future deterioration. In this respect, rivers trusts represent a major opportunity to increase the achievement of GES and tackle problems previously considered infeasible or disproportionately expensive. In order to capitalise on this opportunity, the waterbody classification which as with any national reporting methodology designed for reporting upwards, needs to be detached from assessment of delivery measures which are best implemented on appropriate management units which reflect the catchment and its monitoring network. Rivers trusts have identified varied funding opportunities to meet their ecological objectives, and this might be used for the achievement of GES if objectives are better aligned in catchment units, and WFD funding to rivers trusts is broadened to wider areas of implementation than, for instance, just fish passage.

This project tested simple investigative methodologies in use at rivers trusts. In every case, basic local knowledge has been critical to waterbody assessment for ecological condition and mitigation measures by the trusts, whether this has been collected by new walk-over survey or historically. Building professional capacity and experience at the catchment level will be critical to future rivers trust delivery. Mapping and modelling tools developed and used by the rivers trust movement are useful for targeting work, and providing an evidence base for proposed mitigation measures. Though it is important to recognise that these tools do not take away the need for local ground truthing and identification of unpredictable land use or behaviour. The Rivers Trust has a role to play to formalise some of these methodologies, provide training, and perhaps a records or data analysis service. The Rivers Trust needs to employ or develop new tools for the apportionment of sediment to land use types or river bank erosion, for the apportionment of phosphate and faecal coliforms to agricultural or human sources, and for the field tracing of sources of chemical pollution parameters. This will further improve the evidence base for WFD measures and reduce the implementation cost to exactly where it is needed.

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5.0 Conclusions

In terms of The Rivers Trust providing a central mapping and database service; this seems to be both feasible, and increasingly relevant for the delivery of third sector contribution to WFD. This project has made considerable headway on the issue of third sector access to data held in public organisations, and giving subsequent access to this data to external co-deliverers is perhaps easier through The Rivers Trust than trying to achieve this through the public sector. Providing support in mapping and modelling through RT has been very important to the individual trusts engaged in this project, and lessons learned from this will help develop a platform for supporting rivers trust delivery of GES throughout the country.

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6.0 Recommendations The Rivers Trust acknowledges and supports the Environment Agency as DEFRAs competent authority in determining waterbody classification, regulation and its enforcement. Many of the following recommendations concern the analysis, classification and treatment of waterbodies as shown in the RBMP. These points are made not to be critical about the current classification system, but hopefully to show where rivers trusts might be able to provide supporting information and increased capacity for future classifications, and more importantly, where rivers trusts might be able to deliver appropriate mitigation measures, and what changes would facilitate this in the way the classification is used to report downwards on mitigation priorities and delivery. 1. Waterbodies which default to GES based on absence of biological monitoring data need to be treated differently within the classification system in order to enable re-classification, or at least WFD funded mitigation works to take place on the presentation of suitable evidence. This might take the form of a ‘pending’ classification. This needs to occur not least as these sites represent a barrier to engagement with catchment based restoration work by the trust movement, but also as these sites are at very high risk of showing deterioration based on future monitoring and evidence collection. These waterbodies could indeed be prioritised for works to prevent deterioration as suggested by WUF. 2. Physico-chemical parameters, which form the basis of the majority of WFD classifications do not appear to reflect ecological condition, or give support or evidence for failures in biological parameters, in particular where acute changes in water quality are suspected. Changes need to be made either to the way that this data is collected, or the suite of parameters used to determine ecological status. 3. The rivers trusts approach to waterbody failures was to treat the problems and solutions on a watershed basis, which often meant combining multiple waterbodies whether the failing parameters were

in those waterbodies or not. Tying measures to individual waterbodies may prevent treatment of an upstream or downstream cause. It is recommended that prescription of WFD measures to meet GES be re-targeted on catchment or sub-catchment basis with the waterbody classification reserved as a mechanism for reporting upwards on a national basis. 4. Waterbodies should reflect the monitoring network rather than using extrapolated data from outside the classified waterbody. Extrapolation leads to unnecessary errors and mitigation works are targeted to the wrong locations. 5. Biological data is the most important parameter for determining ecological status and the current suite of physico-chemical parameters (or the method of their collection) is not a suitable proxy. Rivers trusts can fill some of these gaps in knowledge and there should be a way for this knowledge to be taken into account in determining measures to meet GES. 6. WFD funding to enable co-deliverers to achieve GES needs to give the freedom to act holistically for the achievement of good ecological status over sensible catchment management units which reflect the communities aspiration for the river. It is important that work is not restricted to just failing waterbodies where the cause of these failures may be inaccurate or much more extensive than the waterbody in question. 7. The Rivers Trust should aim to formalise some of the investigative methodologies, and identify or develop new methodologies for some of the sediment and diffuse pollution issues identified by trusts in this report. Training and formalisation of some of these methodologies might help in providing the necessary audit trail for WFD measures, and monitoring of waterbody recovery. 8. The Rivers Trust needs funding to develop WFD mapping resources accessible to the entire third sector, and modelling and database services to the rivers trust movement. This will facilitate a considerable increase in targeted achievement of GES, and provide a possible basis for providing audit trail and evidence base for tackling reaches of river not covered by the current classification system, either because monitoring is outside of the waterbody, or monitoring is downstream of ecological failures within waterbodies. An ‘informing-down’ mechanism to complement the ‘reporting-up’ classification. 9. Measures in the RBMP should be linked to specific waterbodies, or their geographic extent shown across the management area to show gaps in delivery suitable for co-deliverers to take action.

Appendices

RSPB Three Rivers Study:

Appendix 1:

Critical analysis of the draft RBMP for the Wye and Usk. S. Evans. Wye & Usk Foundation, 2009. Review of the RBMP for the River Kennet. J. D. Lawson. Action for the River Kennet, 2009. Detailed analysis of the draft RBMP for the River Eden, Cumbria. A. M. Maltby. Association of Rivers Trusts, 2009.

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References

Demonstrating the use of Local Catchment Evidence to Meet Good Ecological Status in the River Lugg Catchment. Wye & Usk Foundation.

Appendix 2: Developing a catchment management framework for the delivery of â&#x20AC;&#x2DC;Goodâ&#x20AC;&#x2122; Water Framework Directive status at a sub-catchment scale. Westcountry Rivers Trust.

Appendix 3: Strategic evidence and partnership report. Severn Rivers Trust.

Appendix 4: Matrix comparing information from RBMP and trust investigations.

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A Review Of Current Policy Tools And Funding Mechanisms Available To Address Water Pollution From Agriculture In England (component B)

Alex Inman, Independent Consultant October 2011

Acknowledgements The author would like to thank the many individuals from the farming community, the Environment Agency, Natural England, the Water Industry, The National Farmers Union and FWAG who gave up their time to provide knowledge and evidence for this report. Thanks is also due to Laurie Smith (SOAS), Allan Buckwell (CLA), Michael Winter (Exeter University) and Kaley Hart (IEEP) for helping to provide strategic policy insights relevant to the findings developing from the case study fieldwork. Disclaimer This report has been produced under contract by Alex Inman (Consulting), an independent consultant, on behalf of Defra and The Rivers Trust. All analysis and observations contained within have been derived from verbal information provided by project participants, complemented by quantitative data provided by participants where possible. Much of the analysis is based on opinions expressed by individuals which may not necessarily represent those of the organisations they represent. Whilst the author has taken all due care to interpret and collate participant input accurately, any party relying on the results of the analysis shall do so at their own risk and neither the author, Defra or The Rivers Trust shall be liable for any loss or damages (excluding personal injury) arising there from. Maps Maps displaying Environmental Stewardship options kindly produced by Natural Englandâ&#x20AC;&#x2122;s Geographical Information and Analysis Team, Telford. Reproduced by permission of Ordnance Survey on behalf of HMSO. Crown Copyright and database right 2011.

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Executive Summary

This report contains findings from ‘Component B’ of a Defra Strategic Evidence and Partnership project (DSEPP) designed to assess the ability of current policy tools (regulation, agri-environment incentive payments, advice) to address water quality impacts from agriculture. The potential for private sector funding to compliment public funded agri-environmental payments targeted at water quality improvement was also explored. Evidence and analysis provided in this report originates from participatory research with on-the-ground practitioners and farmers in three case study catchments on the western side of England: the Caudworthy Water (Tamar), the Lugg (Wye) and the Rea (Severn). The research was undertaken between January and September 2011. Across the study catchments, diffuse soil and phosphorus pollution were considered by project stakeholders to be the key agricultural pollution issues requiring attention. Whilst sediment and nutrient pollution is often referred to as a ‘diffuse’ or ‘non-point source’ problem, stakeholders were largely of the view that the problem is the result of ‘multiple point source’ pollution incidents from specific fields, tracks, gateways and stretches of river bank which can be identified and systematically addressed. Specific instruments evaluated included Cross Compliance, Anti-Pollution Works Notices, Environmental Stewardship and the Catchment Sensitive Farming advice and grants programme, these mechanisms representing the key policy instruments currently available to address agricultural pollution. The EA has at its disposal Section 85 of the Water Resources Act 1991 (‘Knowingly causing pollution’) which enables prosecution for various offences where pollution of surface and/or groundwater occurs. The limitation of this mechanism is that it tackles the effect rather than cause of a problem and can only be invoked once a pollution incident has occurred. It cannot be used to prevent water pollution taking place and has not, therefore, been evaluated within this project.

Assessment of current Regulatory and Financial Mechanisms Relevant to Soil Pollution Cross Compliance The identification of soil erosion risk and the adoption of suitable control measures is a fundamental feature of cross-compliance, most notably within the revised Soil Protection Review (SPR) which all farmers receiving the Single Farm Payment must have completed by December 2010. However, whilst it is too early to evaluate the impact of the revised SPR, views expressed by EA Enforcement Offers and farm advisors suggest the mechanism is unlikely to provide adequate protection against soil erosion. Firstly, it is possible that many farmers will not correctly identify risk levels on high risk fields; and secondly, EA Enforcement Officers believe the SPR is an unenforceable mechanism because provided a farmer has completed his SPR, identified a risk level for each field and allocated the appropriate number of optional measures, he cannot be deemed non compliant even if he is causing a significant soil erosion problem on his farm. Whilst there is provision within the cross compliance enforcement process to prevent farmers from failing to take action once an issue has been pointed out to them, this process is not a standard operating procedure at the current time. There are currently no mandatory requirements within cross compliance for farmers to prevent degradation of river banks from livestock, a common cause of soil erosion. There is an option within the SPR grassland management measures to ‘minimise damage to riverbanks by providing managed access to water for livestock’ but farmers do not have to select this option. Aside from the workability or otherwise of the SPR as an enforcement tool, interviews with farmers showed that the SPR processes has not engaged them in a broader sense regarding the importance of soils to their business and the negative consequences of soil erosion to the environment.

APWNs The EA has the ability to issue Anti Pollution Works Notices (APWNs) served under Section 161 of the Water Resources Act to deal with soil related water pollution. The difficulty with APWNs is that they can be time consuming to prepare and deliver with recent EA guidance specifying APWNs should only be issued where it is possible to demonstrate a category 1, 2, or 3 level incident. Because of the resource implications surrounding the issuing of APWNs for soil pollution, the EA has been extremely reluctant to make widespread use of this instrument to date. However, new guidance information provided to Enforcement Officers and acquired during the fieldwork for this project outlines that the process of issuing APWNs has recently been 30

streamlined. EA staff believe these reforms will make the use of APWNs far more practical for tackling soil and nutrient run-off problems, albeit APWNs should only be used as a last resort where a farmer refuses to take appropriate action.

Environmental Stewardship The Environmental Stewardship programme in the form of the Entry Level and Higher Level Schemes offer sources of funding to farmers to adopt changes in land use which can, in certain situations, protect watercourses from soil erosion. In recent years new ELS buffer strip options have been introduced with a resource protection focus. However, land management experts interviewed across the case study catchments were of the view buffer strips, unless very wide (12m+) are not capable of preventing soil reaching watercourses from fields with anything greater than a 7-10 degree slope. The new ELS options that are potentially capable of dealing with the problem are unlikely to be taken up by farmers because the loss of income from implementing these measures is perceived as too high due to the extensive loss of productive land involved. The evidence suggests farmers will tend to sight buffer strips on marginal land which is not necessarily at greatest risk from soil erosion. Under the current programme, several individuals were of the view that a way to engage farmers to adopt effective resource protection measures within ELS would be to re-weight the allocation of points away from hedgerow management options towards resource protection measures. Currently, the majority of farmers derive most of their points from hedgerow management and do not need to undertake broader land management options. However, farmer opinion pointed towards a scenario where they would choose not to enter the scheme at all if they were required to undertake measures involving taking productive land out of agricultural production.

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Feedback from farmers within this project has reaffirmed a commonly held view within the farming community that ELS payments are effectively a way of recouping modulated funds to top up the Single Farm Payment. In other words, ELS is seen as an entitlement payment for delivering basic environmental standards under cross compliance, not a payment which is sufficient to warrant adopting additional activities which involve taking land out of production. To do this, farmer respondents were adamant that payment rates will need to be considerably higher than current levels. Alternatively, farmers pointed out land reversion obligations would need to be tied to receipt of the Single Farm Payment. Higher Level Stewardship is targeted at specific areas of countryside considered to be particularly important for a range of Biodiversity, Landscape, Historic Environment and Resource Protection delivery objectives. According to Natural England personnel engaged with the project, HLS currently covers 10% of agricultural land across England and is increasingly focusing on SSSI sites and Habitats Directive designated areas. An examination of the HLS scheme demonstrates there are a small number of appropriate measures with the potential to combat soil erosion from high risk arable land. The difficulty with these measures in terms of providing effective soil erosion protection is that many arable farmers do not consider the financial payments available a sufficient incentive to stimulate adoption. Discussions with Natural England HLS officers also suggest they view HLS as a multi-outcome scheme and tend not to focus on resource protection accordingly. As a result, the evidence points to a situation where HLS officers rarely concentrate on resource protection outcomes or working up HLS applications on farms where biodiversity or heritage outputs are unlikely.

Capital Grants Capital grants exist through the Environmental Stewardship Programme and the Catchment Sensitive Farming initiative to facilitate the adoption of farm infrastructure improvements (fencing, tracks, hard standing areas for livestock) which can lead to significant reductions in soil erosion. However, take up of these options has not been high thus far and there is evidence grants require greater targeting. It is noteworthy that there are no agri-environmental payments currently available for winter housing, considered by many farm advisors as extremely important for keeping animals away from vulnerable fields during the wetter (winter) months of the year.

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Assessment Of Current Regulatory And Financial Mechanisms Relevant To Phosphorus Pollution Cross Compliance At the current time, there are no requirements within cross compliance for farmers to limit the application rates of phosphorus on their land and there are no requirements regarding the timing and method of phosphorus applications. Farmers within Nitrate Vulnerable Zones (which includes much of the Lugg catchment) must adhere to nitrogen limits which involve monitoring the application levels and timing of slurries and manures. Whilst this process is likely to indirectly result in a limit on phosphorus applications, NVZ rules do not specifically target phosphorus applications.

APWNs APWNs are not suitable for tackling excessive phosphorus levels in soils or for specifying requirements for timing and methods of application due to the need for establishing source, pathway and receptor impact which is very difficult for phosphorus. Other than indirect measures as outlined above, there are no statutory measures designed to enforce phosphorus limits.

Environmental Stewardship Reducing phosphorus levels in soils is not an explicit objective of the Environmental Stewardship programme but there are measures within the schemes which stipulate a reduction of cessation in the application of manures. For example the ELS maize management options (EJ2 and EJ10) require appropriate rates and timings of manure applications both to the maize crop and the subsequent crop planted. The difficulty with these measures is that they tend to be adopted by farmers who are already extensive in their operations and are unlikely to have high phosphorus indices on their farms.

Capital Grants For livestock farmers, applying phosphorus at appropriate time windows (when crops require nutrients for growth) very largely depends on the availability of sufficient storage capacity. Since the creation of the CSF capital grants programme, there has been a valuable introduction of grant aid to fund the construction of manure storage (CSF023) and slurry storage (CSF026) roofing areas. However, CSF and other advisory personnel on the ground are of the view many farms require fundamental increases in storage capacity, necessitating the building of new stores for which CSF grants are not available. South West Water is investing significant funding to increase on-farm slurry storage which is providing much needed private funds to boost the money available through the CSF grant pool for store roofing. 32

Catchment Sensitive Farming Programme Review Feedback from Catchment Sensitive Farming Officers (CSFOs) suggests targeting CSF grants and advice has proved difficult to deliver on the ground due to incomplete data sets and uncertainty regarding the nature and scale of water quality problems in their respective catchment areas. The level of information (data) exchange between the CSF programme and EA ‘data gatekeepers’ regarding water quality monitoring and assessment analysis appears to vary between catchments. Observations from CSFOs suggest there are often strong differences of opinion between national and local EA staff regarding which water quality issues should be targeted for WFD compliance which, in turn, is leading to confusion amongst CSF delivery teams. Based on observations from the CSFOs interviewed, it does not appear the CSF programme has been successful at reaching the ‘difficult to engage’ farmers i.e those farmers who tend not to proactively seek advice and who are often believed to have significant pollution issues on their farms. Lack of time and a reluctance on the part of CSFOs to cold-call these farmers are cited as reasons for lack of engagement with this cohort of the farming community. Cold-calling training is being provided to CSFOs to equip them with the confidence to undertake this difficult activity more widely. Revisions to the CSF grant application process have resulted in applicants standing a better chance of receiving funding if they have already engaged with CSF (e.g attended a CSF clinic) or become involved in the Environmental Stewardship Programme. The difficulty with this approach is that ‘difficult to reach farmers’ by definition have not engaged with these programmes. By reducing the likelihood of these farmers to obtain CSF grant, it is possible they will become even more marginalised and isolated from the programme and its broader objectives. An examination of the measures eligible for CSF funding within the three study areas suggests these measures are broadly appropriate for dealing with the soil and phosphorus problems identified. However, whilst the measures eligible for grant appear well conceived, the evidence suggests the grant has not been targeted effectively so far. Feedback from CSFOs indicates they have limited time available to visit farms to identify measures for funding and the scoring of CSF applications has historically been undertaken by a centralised administrative team in Nottingham who are not necessarily best placed to judge optimal grant allocation. However, it appears CSF managers have recognised this shortfall in the current system because from 2012, CSFOs will be given much greater opportunity to score applications.

Following on from this, there are a large number of extension providers operating at various levels across the farming sector, seemingly with different remits and modes of operation. Not surprisingly, the end customer i.e the farmer, is often receiving different messages regarding what is expected from them; which is leading to confusion and often disillusionment with the environmental agenda. It is crucial, therefore, that all deliverers sing from the same hymn sheet. This will require leadership from Defra to bring the various providers together to agree a common objective and working practices.

Overarching Observations A reoccurring theme that emerged across all three study areas was a clear lack of consensus regarding the nature and extent of local water quality problems. Almost without exception, the farmers engaging with this project were of the view the farming community must be presented with evidence that a problem exists before they will be willing to take action. Farmers do not appear to have been adequately involved by the catchment management community in jointly understand the problems. Consequently, this has led to many farmers remaining disengaged from the subject and, in some cases, becoming overtly hostile to the agencies involved. There was universal agreement amongst the farmers that regulation to protect water quality is needed and justified. Farmers were quick to point out, however, that it is vital they understand what constitutes an offence and the regulatory process must be perceived as fair. A warning or series of warnings followed by prosecution through failure to act on these warnings is deemed a balanced way forward.

new ideas and working practices. For this reason, it seems the EA is not well placed to act as a first port of call for farmers seeking advice on pollution issues. Not surprisingly, farmers have an inherent fear of the EA due to its regulatory and enforcement function.

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It is uncertain at the current time how well integrated the CSF programme and its staff are with the Natural England Environmental Stewardship initiative. Rather than having separate staff delivering CSF, ELS and HLS schemes, some CSFOs questioned whether it would make more sense to merge the various schemes under a single delivery team to promote internal co-ordination and allow a single point of contact with farmers to facilitate relationship building.

Whilst the EA should not necessarily be precluded from maintaining an advisory capacity, there is a clear need for a confidential arms length highly skilled extension advice service capable of helping farmers tackle water pollution issues within the context of running profitable farm businesses. Given the CSF programme is already established, it would make sense to develop the skills base and capacity of this initiative, complimented where available by independent organisations such as ADAS, The Rivers Trusts etc. With an effective and trusted extension service in place, this would leave the EA with a clear regulatory focus. Based on feedback from EA local managers, there appears to be a skills shortage within the Agency regarding knowledge of farming systems and the farming sector in general. EA managers believe this is a major problem regarding the ability of Enforcement Officers to correctly identify pollution issues, understand the causes of these problems, and command the respect of farmers when engaging with them on these matters. When asked to express their views on the EA staff they have dealt with, farmers were impressed with their professionalism but, with one exception, were of the opinion they lacked sufficient knowledge of the industry over which they were regulating. It appears the EA is planning to address this issue by developing a training system designed to produce Enforcement Officers who are specialists in agricultural systems although it seems this is currently planned to happen in the Midlands region only. Feedback from EA Local Managers suggests Enforcement Officers spend considerable amounts of time â&#x20AC;&#x2DC;processing paperwork rather than undertaking on-farm visitsâ&#x20AC;&#x2122;. The view from managers is that a considerable volume of paperwork could be dealt with by administrative staff, freeing up Enforcement Officers to work on-the-ground.

A fundamental finding of this project generated from stakeholder feedback is a need for clear demarcations between the roles, responsibilities and operating practices of the statutory agencies and advice providers (public, private, NGO) operating within the catchment management space. Each organisation involved in the mix should have a defined and well communicated terms of reference and be experts in their respective fields of operation to generate trust amongst themselves and wider stakeholders. Evidence from a plethora of research studies (strongly reaffirmed by farmer opinion expressed in this project) highlights the need for farmers to develop an on-going confidential relationship with a trusted farm advisor before they are willing to voluntarily discuss pollution problems on their landholdings and be receptive to 33

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Current Common Agricultural Policy Reform Proposals

Potential For Private Sector Investment In Catchment Management

It is clear from the EU Commissions ‘CAP towards 2020’ communication that the share of the CAP budget allocated to Pillar II is not envisaged to expand further which has disappointed many environmental groups who see Pillar II as an efficient mechanism of targeting payments to farmers to deliver specific environmental outcomes. Rather the Commission’s proposal is to introduce a ‘greening’ element to Pillar I involving 30% of Pillar I funds being ring fenced to fund a range of green measures including crop diversification, maintenance of permanent grassland and the establishment of Ecological Focus Areas (at least 7% of the farm, excluding permanent pasture, must be left fallow or put into extensive management).

An effective combination of regulation, advice and CAP derived funds (both Pillar I and II) should be able to bring about many of the necessary changes but it is likely that more money will be required, particularly for capital infrastructure payments and land retirement in specific areas of ecological and/or drinking water importance.

In terms of helping to mitigate the types of soil and nutrient run-off issues highlighted within the study areas for this project, it would appear the Ecological Focus Areas (EFA) offer the best opportunity. Given a need in some cases for the strategic arable reversion of land , the EFA measure potentially offers a valuable tool to protect water resources and deliver WFD outcomes. Importantly, it has the potential within a given catchment to protect specific land areas at risk of soil erosion and run-off and, importantly, reduce the budget needed to fund the uptake of these measures from the agri-environmental pot (Pillar II or private funds) which can, therefore, be diverted to delivering other environmental outcomes. However, the success of this measure will entirely depend on the detail of how it is implemented. In particular, it will be vital to ensure farmers position their EFAs on areas of their farm which are likely to produce greatest resource protection outcomes. For this reason, farmers should not be left to their own devices when selecting this land but should be required to refer to some form of catchment risk map which stipulates areas where EFAs should be selected.

In recent years, a growing interest has developed in what have generically become known as Paid Ecosystem Services (PES) models for environmental protection’ defined as involving a voluntary transaction where a well-defined environmental service (or a land use likely to secure that service) is ‘bought’ by a (minimum one) service buyer from a (minimum one) service provider if, and only if, the service provider delivers appropriate levels of service provision. A review of the literature has identified a small but growing number of instances where private (non-government) entities have funded payments direct to landowners to deliver specific environmental outcomes. In some cases, these markets have been initiated and managed completely independently of the state whilst in most cases, the state has played a major role in their development, funding and on-going administration. Indeed, private funding contributions have, thus far, been relatively small compared to the other sources of funding such as donors or public resources. A key problem with PES markets is the potential for high transaction costs, highlighting the importance of good intermediaries who can reduce transaction costs to an economically efficient level. Water companies in the UK are increasingly being seen as a potential source of private sector investment for catchment management initiatives. During the fieldwork for this project it has been possible to identify different trajectories within the water industry regarding water company involvement. A small number of water companies are already working with landowners to deliver improved water quality at the farm level. For example, during the PR09 funding round, South West Water is spending £9m on moorland and farmland projects and £1m on catchment investigation projects which totals 1% of total CAPEX between 2010-2015. In PR14, South West Water plans to spend between £30-£50m on catchment management projects, split approximately 66% on moorland rehabilitation projects and 33% on wider farmland. The majority of water companies have not invested in catchment management thus far, but are currently investigating the likely efficacy of on-farm measures to mitigate water quality pollution issues and the likely propensity of farmers to take up the requisite measures on a voluntary basis. It is interesting to note that both South West Water and Severn Trent Water whose operational regions overlap with the DSEPP project study areas have chosen to work with local Rivers Trusts who act as neutral brokers

Ultimately, the key issue that will determine the geographical scale of water company investment in catchment management is commercial selfinterest. Based on discussions with water company representatives, it is clear that water companies will only invest in catchment management where this approach will provide value to their customers and shareholders. The role of OFWAT, the Water Industry Regulator, is also vitally important regarding water industry investment in catchment management as it is ultimately OFWAT which sanctions this investment through the Periodic Review process. Discussions with OFWAT representatives for this project suggest OFWAT is broadly very supportive of catchment management as an approach but is cautious regarding whether catchment initiatives will work and, therefore, whether water customer money can be spent in this way. It will also be vital from the point of view of both OFWAT and the individual water companies, that a clear regulatory baseline is established for farm environmental compliance standards, underpinned by effective enforcement. This will give the water industry confidence that investment made in farm level activities will not be delivering outcomes which should already be being delivered to comply with legal requirements. And importantly, this appears to be a necessary prerequisite before water customers can be asked to pay land managers for the delivery of additional ecosystem services. As part of the DSEPP project, interviews were conducted with a small number of companies from outside the water industry in each of the three study catchments to determine their attitudes towards a conceptual PES model for catchment management and whether they could foresee their respective company’s funding catchment management initiatives in the future. In general, there was a very positive response to the principle of investing in a locally based catchment management scheme. For example, one company interviewed currently supplies Marks & Spencers with food items and explained M&S is increasingly examining the sustainability of its own food and drink supply chain. If the company could demonstrate to M&S it was investing in a food supplier network which was delivering multiple environmental benefits, it was felt this might well provide a competitive advantage over other food processing businesses.

Paid Ecosystem Services Mapping

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between the water company and local stakeholders particularly farmers. This arrangement closely resembles the ‘trusted intermediary’ model referred to in the academic literature as being a prerequisite for successful PES market formulation and delivery.

To deliver both food and multiple other ecosystem services within a catchment, there is a need for a variety of land uses capable of delivering these outputs. Some areas will be more suitable for growing food and some more suitable for providing other services including water quality, flood alleviation, recreation and biodiversity. Where a farmer is producing food from a unit of land likely to cause soil erosion but where this unit of land is crucial for the provision of multiple other ecosystem services, an argument exists to divert land use away from food production toward the provision of these other services. If a market can be developed where beneficiaries of multiple ecosystem services derived from the land unit are prepared to pay the farmer more for these services than he is currently deriving from using that land for food production, it is possible to envisage an optimal societal outcome. If suitable market mechanisms could be established, it is possible that funds from beneficiaries could be targeted at land parcels causing water quality pollution problems where these parcels have a high multiple ecosystem service value. These private markets could be used to supplement payments made from Common Agricultural Policy or other public funds thereby producing a significant incentive for landowners to divert land away from agricultural production activities with a high probability of causing pollution problems. Farmers will need to be convinced, however, of the merits of PES markets. Indeed, becoming suppliers of a wider range of ecosystem services remained an esoteric concept for many members of the farming community interviewed during this project. The governance and management of these funds would need to be co-ordinated to deliver maximum benefit, with international experience suggesting a ‘neutral broker model’ is likely to be the best institutional arrangement for achieving this outcome.

However, respondents were quick to point out that unless existing tax systems are modified to allow these schemes to be funded or unless businesses are required by law to invest in them, the funding for these schemes generated organically is likely to remain very low. As demonstrated by international experience, it seems fiscal and regulatory intervention will be required by government if localised PES schemes capable of delivering water resources protection are to become a widespread reality. 35

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Conclusions and Recommendations Improved Governance Of The Catchment Management Planning Process Is Required There is a need to co-ordinate understanding surrounding the state of waterbodies, for uncertainties to be clearly communicated and agreed on, and for solutions and delivery plans to be developed which have a mandate from the farming community, delivery agencies, the water industry and other catchment stakeholders. Clear problem definition will allow development of targeted mitigation solutions. To facilitate the development of a co-ordinated catchment plan, information flow between stakeholders must be transparent and accessible. This requires the development of open access catchment scale data repositories which become the one-stop-shop for all parties involved in the delivery of WFD objectives. There is a need to clarify the roles and responsibilities of the various parties involved (public, private, third sector) in the delivery of WFD objectives to avoid institutional conflict, encourage efficiency, and ensure the whole is greater than the sum of the individual parts.

Transparent, Equitable And Enforceable Regulation Of An Environmental Baseline Is Needed Farmers are currently confused, both about their legal responsibilities and about the enforcement process that accompanies the regulation of environmental compliance matters. Conversely, there also appears to be confusion amongst the regulatory authorities regarding process and application of regulation relevant to the agricultural sector. There is a clear need for this situation to change. The evidence suggests that an unambiguous enforcement process needs to be established and, most importantly, clearly communicated to the agricultural sector. Cross compliance measures should not be increased in number. What is needed is for the existing requirements to be adhered to and for a process of stepped enforcement (repeat visits) to be implemented to ensure pollution problems are successfully mitigated once identified.

Similarly, outside the cross compliance process, EA enforcement procedures also need to be capable of identifying problems on a catchment scale and able to follow through a problem from identification to successful mitigation. Walkover surveys and follow up farm visits offer a route to achieve this, backed up by an appropriate monitoring. Increased resource will be required for the EA to implement walkover and follow up visits but the evidence suggests the costs of doing this will not be orders of magnitude greater than existing resource availability. A distinct advantage of a proactive walkover approach undertaken by the EA is that those farmers which the CSF programme has struggled to engage with thus far will very likely be identified by the EA and referred to CSF advisors for assistance. To improve the effectiveness of EA delivered regulation, consideration should be given to a national roll out of the specialist training currently being provided to agricultural Enforcement Officers in the Midlands region.

Investment In Agricultural Extension Is Required There is an urgent need to invest in the expansion and skills base of extension providers in England. The Catchment Sensitive Farming initiative should be invested in by government, to provide a highly skilled and credible hub for future extension provision, working with other delivery partners (including the third sector) where these are available, locally accepted and have the requisite skill sets. Focussing on the three study catchments for this project, with the exception of the Caudworthy catchment, current CSFO capacity would need to be increased; from 0.3 to 0.6 FTE in the Rea and from 0.5 to 2.4 FTE in the Lugg. Whilst representing increased costs, numerous research projects focusing on farmer behavioural change have identified a central role for one-to-one advice delivered by a trusted and skilled advisor, often over an extended period of time. The importance of this issue has been formally recognised by the EU Commission in relation to forthcoming reforms of the Common Agricultural Policy which is stressing the need for member states to put in place enhanced advice provision. Farmers must play a central role in the design and constitution of locally delivered advice to ensure provision is tailored to need. Consideration should also be given to fully integrate CSF, ELS and HLS advice provision within Natural England to avoid the dangers of fragmented advice delivery and encourage a common vision for the delivery of support to the rural landscape.

Need For A Participatory Phosphorus Management Strategy

It is possible that targeted Ecological Focus Areas (EFAs) under the proposed greening of the Common Agricultural Policy could deliver many of the necessary land use changes from Pillar I (Single Farm Payment) without the provision of Pillar II agri-environment payments. However, should targeted EFAs not be possible, or where these would not be sufficient within a given catchment, additional payments to farmers will be needed. In this case, it is recommended that the current ELS scheme is fundamentally reshaped to focus payments on targeted resource protection measures. Where income forgone rules limit the payment levels that can be offered to farmers to adopt bespoke land use change options, additional financial resources should be sought from the private sector through the development of PES markets.

It is understood that Defra has agreed not to propose the implementation of new measures within Water Protection Zones before first a) developing a catchment approach that targets the use of existing regulatory, advice and incentive mechanisms b) determining the efficacy of this approach; and c) assessing whether additional measures are required. This would appear to be a balanced approach in line with the government’s better regulation agenda. However, there has been no clear roadmap and timetable presented to farmers setting out an overarching process for addressing agricultural impact on the water environment; a much needed set of milestones which should be communicated to all stakeholders. A clear plan is required setting out basic compliance measures together with additional incentivised measures that will be available in certain areas – while making it clear that if farmers do not engage with the process, additional regulation will become a necessity. This certainty is needed for farmers to understand what is required of them and to plan effectively for the future.

The capital works budget under the CSF programme, if targeted and if continued at current levels, appears to have the potential to deliver many of the needed changes by the end of the second WFD cycle. However, it is very unlikely significant infrastructure improvements such as new slurry stores or cattle housing either can be, or will be, funded under RDP funding streams. As with selective land use change above, it appears, therefore, that private sector money – either as lump sum grants or in the form of low/no interest loans – will be needed to deliver the necessary scale of change required. There is a need for the co-ordination of different funding streams to deliver one set of targeted objectives at a catchment scale, set out in a single integrated management plan agreed by all parties.

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Financial Support To Deliver Water Resource Protection Needs Reform

Should phosphorus restrictions be implemented, it will be crucial to ensure a very long lead time is given (at least 5 years) for farmers to be able to make appropriate financial plans surrounding their businesses, which, in many cases may require significant structural adjustments. Financial assistance to farmers to put in place storage capacity should also be given serious consideration. Whilst it is probably not possible for public money to be made available in England - due to a combination of state aid rules and a precedent of no financial assistance being offered with NVZs - this should not preclude assistance being made available from the private sector through Paid Ecosystem Service markets where feasible to establish.

Rea Lugg

Tamar

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1.0 Introduction Solving the problem of water pollution from agriculture and meeting the requirements of the EU Water Framework Directive (WFD) represents a significant challenge; particularly in an era of growing food demand world-wide, changes in climate patterns, global financial instability and pressures on public finances. Indeed, for Defra, the issue of agricultural pollution of water represents a ‘wicked problem’ (Rittel and Webber 1973) involving technical uncertainties, a diverse range of interest groups often with different values, a lack of definitive problem formulation and a need for a multistakeholder response at a local level which precludes a top-down centrally managed process. It is no surprise a solution to this problem has been slow to emerge thus far. This document contains the findings from ‘Component B’ of a Defra Strategic Evidence and Partnership project (DSEPP)1 designed to assess the ability of current policy tools and funding mechanisms to address water quality impacts from agriculture and offer policy relevant recommendations for any changes required to the current system. It is envisaged that the outputs from the project will have relevance to Defra’s ongoing WFD policy agenda in addition to the implementation of objectives outlined in both the Natural Environment and forthcoming Water White Papers. Readers should note the information presented in this report should be distinguished from the activities of Component A of the DSEPP which focussed on matters relating to waterbody assessments, data management and collection of information relevant to the development of river basin management plans. The outputs of Component A have been reported separately by Alistair Maltby of The Rivers Trust.

The evidence and analysis provided in this report originates from participatory research with on-the-ground practitioners and farmers in three case study catchments on the western side of England: the Caudworthy Water (Tamar), the Lugg (Wye) and the Rea (Severn). It is, therefore, important to note that the analysis and conclusions from this project have been derived from a sample of predominantly livestock and mixed farming catchments, albeit with arable farming having a significant presence in particular sections of the Lugg and Rea catchments. An assessment of particular problems associated with intensive arable catchments, where agro-chemical pollution can predominate, has not been the focus of this project. However, many if not all of the overarching conclusions from the project have generic policy relevance to the management of all catchments in England irrespective of their geographical location. Section 2.0 briefly outlines the Objectives and Methodology used for the project whilst Section 3.0 details the main water quality problems reported in the study areas together with the underlying reasons behind these problems. Sections 4.0 and 5.0 provide an assessment of the current policy instruments available to address the problems encountered whilst Section 6.0 presents an overview of a number of observations relevant to the governance of these policy instruments. Section 7.0 offers a discussion on required changes to current policy instruments, followed by Sections 8.0 and 9.0 which assess how Common Agricultural Policy reform and private investment in catchment management might best be leveraged to deliver WFD objectives. Finally Section 10.0 contains conclusions and recommendations emanating from the project findings.

DSEPP is a co-funded project with funding sources provided by Defra, The Rivers Trust and WWF UK

2.1 Objectives The overarching objective of Component B of DSEPP was to bring Defra, The Rivers Trust and other key stakeholders together in three case study catchments to seek a pragmatic and cost effective strategy for meeting Water Framework Directive water quality goals. Specific objectives were effectively two-fold: Primary objective: • To assess the ability of current policy instruments (regulation, agri-environment incentive payments, advice) to deliver water quality improvements within the three catchments selected for the study Secondary objective: • To assess the potential for private sector funding to compliment publicly funded agri-environmental payments targeted at water quality improvement

2.2 Methodology 2.2.1 A Multi-Stage Approach From the outset, it was agreed that the information needed to meet these objectives would be collected via primary research with ‘on-the-ground’ stakeholders in three study catchments: the Caudworthy Water (Tamar), the Lugg (Wye) and the Rea (Severn). These catchments were chosen due to their association with agricultural pollution problems (all three are within Catchment Sensitive Farming priority areas), the existence of local Rivers Trusts at different stages of development and the presence of water companies involved with a range of catchment management initiatives. Further details relating to the physical characteristics of the three study catchments can be found in the Component A report. A bottom up approach was adopted to ensure information was obtained from either individuals directly involved in the delivery of current policy instruments or individuals on the receiving end of these policies (currently or potentially), most notably members of the farming community. A summary of individuals engaged by the project are outlined below:

• Local farmers, many of whom had engaged with the Environmental Stewardship (ES) and Catchment Sensitive Farming (CSF) programmes. Several had experience of cross-compliance visits • Environment Agency personnel: Local Team Leaders, Enforcement Officers, Land Use Experts • Natural England Personnel: ES Officers, CSF Officers • Water Company Catchment Managers • Farming and Wildlife Advisory Group advisors (FWAG) • National Farmers Union (NFU) representatives • Wildlife Trust and Area of Outstanding Natural Beauty (AONB) representatives • Local businesses representing potential sources of funding for Paid Ecosystem Services (PES) schemes

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2.0 Objectives and Methodology

Information gathering was achieved through the following four-stage process undertaken between January and September 2011: Stage 1 Initial kick-off workshops in each of the three study catchments to explain the objectives of the project and gain buy-in to the initiative These one day meetings enabled a discussion around a number of topics including: attitudes towards current public funded agri-environment schemes; attitudes towards the role of regulation in tackling diffuse pollution from agriculture (inc. cross-compliance); attitudes towards actual and potential water company lead catchment management schemes; catchment governance and the role of the public, private and NGO sectors Stage 2 Problem identification and solutions workshops These one day workshops were structured to gain a collective understanding of the nature and scale of water quality problems in each study catchment and a steer from stakeholders on how best to deal with these problems. This discussion was facilitated by focussing debate on whether sources, pathways or receptors should be targeted and how this might be done. Large scale catchment maps were used to provide a vehicle for capturing opinion and determining where effort should be focussed.

2 The ECM+ model has been developed by Tobias Krueger at the University Of East Anglia under RELU Project RES-229-25-0009 to enable an understanding of the effects of land use and land management changes and changes in sewage treatment options (inc septic tanks) on water quality. At the current time, the model is capable of forecasting Nitrogen and Phosphorus loadings, not all water quality parameters.

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To assist stakeholders in their thinking, the ECM+ Model2 was applied (Caudworthy and Rea catchments) to enable a quantitative analysis of the levels of change required within the study catchments - both in terms of cross compliance adherence and take up of agri-environment measures â&#x20AC;&#x201C; to reduce Phosphorus loadings to WFD compliant levels. The ECM+ Model provides stakeholders with an opportunity to construct different land use and management scenarios within a given catchment, thereby facilitating a discussion around the trade-offs that might be required to meet WFD Good Ecological Status (GES). Stage 3 Assessment of current policy tools A series of interviews were subsequently undertaken in each of the three study catchments to determine the ability of the current suite of regulations and agri-environment schemes (public funded and water company funded) to deal with the problems identified at Stage 2. In total, 47 interviews were undertaken across the three catchments with representatives of the farming community, Environment Agency, Natural England Water Companies and FWAG. Stage 4 Assessment of Potential Private Sector Funding In order to gain an idea of whether private sector funding might be leveraged to fund catchment management activity, a small number of exploratory interviews (n=7) were undertaken across the three study areas with private sector businesses; comprising energy intensive businesses interested in carbon management or food and drink businesses with an interest in sustainable food chains. Environment managers from these businesses were interviewed to assess the potential for their organisations to invest in land management schemes designed to deliver multiple ecosystem benefits including water quality improvements.

In addition to the four stages outlined above, a series of four interviews were also held with academics known to the author specialising in the field of Common Agricultural Policy reform and agri-environmental policy design. These interviews were helpful in providing a strategic context to assist in the interpretation of the on-the-ground evidence coming from stakeholders in the case study catchments.

2.2.2 Confidentiality In order to encourage candid dialogue in open meetings and one-to-one interviews, individuals taking part in the case study level research were assured that their specific comments would remain confidential to the author. This report, therefore, presents synthesised findings and does not directly attribute individual comments or points of view made.

3.1 Key Problems Identified By Stakeholders As outlined in Section 2.0, Stage 2 of the project involved convening workshops in the case study catchments to identify key factors impacting on water quality and the underlying reasons behind these factors. A revealing finding from these workshops was a lack of concrete evidence regarding the nature and extent of water quality problems in the study catchments which made building a consensus opinion of the problems very difficult. A further discussion of this issue is provided in Section 6.1. However, through dialogue between workshop participants, stakeholders reached broad agreement across all three study areas that sedimentation and excessive phosphorus entering watercourses were the two key problems that need to be addressed. Table 1 below summarises the problems and underlying reasons cited.

It should be noted that whilst the relative weighting of reasons behind the problems appears to vary between the study catchments, all catchments involved with this project were considered to exhibit all of the reasons outlined in Table 1 to a certain degree. It should also be noted that the reasons cited for pollution problems in Table 1 is not an exhaustive list with stakeholders mentioning several other issues including, for example, strip grazing of winter fodder crops (e.g stubble turnips) which can cause poaching, compaction and runoff problems. However, it was felt by project participants that the items summarised in Table 1 represent the main issues requiring attention and likely to yield the greatest benefits if put right. On a positive note, it appears some significant problems within the study catchments have been addressed in recent years; for example, soil erosion from soft fruit grown under pollytunnels in the Lugg where infrastructure improvements made by growers have significantly reduced pollution problems historically associated with these sites.

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3.0 The Problems And Reasons Why The Problems Occur

Sediment pollution and nutrient enrichment from phosphorus have been cited in numerous WFD evaluations as representing a problem across large areas of the UK3. Indeed, â&#x20AC;&#x2DC;diffuseâ&#x20AC;&#x2122; phosphorus pollution is considered a significant problem for nearly 50% of rivers and 25% of lakes in England and Wales. Sediment (from eroded soil) pollution has been identified as posing a risk for 21% of rivers, with a 75% contribution expected from agricultural sources4. In terms of standards required to meet

Table 1. Summary of problems encountered and underlying causation

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WFD requirements, there is a prescribed standard for phosphorus but not for sediments. With the exception of the Lugg where 30% of waterbodies are officially failing the WFD phosphate standard of 0.06mg/l, WFD waterbody classifications do not flag phosphorus as being a problem in the other waterbodies across the three study areas. This stimulated significant debate amongst stakeholders regarding the sampling method used by the EA to measure phosphorus which is undertaken once each month and is likely to miss peak rainfall events when the majority of phosphorus movement occurs. By applying a probability to the EA data in the Caudworthy and the Rea5 waterbodies, phosphorus levels move from a WFD pass to a fail which, therefore, corroborated local stakeholder opinion that phosphorus levels are likely to be a problem. It is interesting to note that whilst sediment and nutrient pollution is often referred to as a ‘diffuse’ or ‘non-point source’ problem, stakeholders were largely of the view that the problem is often the result of ‘multiple point source’ pollution incidents from specific fields, tracks, gateways and stretches of river bank which can be identified. This view is of fundamental importance when considering policy approaches to dealing with sediment and nutrient pollution and is directly relevant to the debate surrounding the appropriate targeting of measures to deliver optimal cost:benefit outcomes (see Section 4.0).

3.2 Soil Pollution Processes Soil erosion is a naturally occurring process involving the mobilisation and deposition of soil particles, mainly by water and air. However, whilst soil erosion is a feature of any natural ecosystem, the rate at which it is taking place has been significantly accelerated by anthropogenic influences, often associated with inappropriate land use activities associated with agriculture. The volume of erosion can be striking. For example, in the Tamar catchment, a gross erosion rate of 5.3 t/ha/year has been estimated (Quine and Walling 1991). In terms of associated key impacts on freshwater ecosystems, excessive sediment entering watercourses can smother gravels preventing fish eggs and invertebrates from accessing sufficient oxygen to survive. As outlined above in Table 1, soil erosion is often caused by a combination of activities which leave the land unprotected and vulnerable. During erosive rainfall events, soil may be detached, transported, and deposited into watercourses which, in turn, compromises the health of freshwater fish,

invertebrates and macrophytes. Sediment eroded from the top of a field may become deposited where the gradient slackens until a subsequent erosion event remobilises this material. Soil eroded from agricultural land will often find its way into a main river channel from where it can be transported downstream as far as the sea. In terms of ecological service provision, soil performs many ecological functions including nutrient cycling, regulating water and nutrient flows, filtering toxic compounds and supporting the growth of a variety of animals and soil micro-organisms by providing a diverse physical, chemical and biological habitat. Crucially, it provides a medium in which crops are grown for human consumption. As such, it is a vital natural resource and forms a key building block upon which life on earth depends. The effects of soil erosion can be sub-divided into on-farm and off-farm impacts. On-farm impacts are predominantly borne by the farmer and are essentially related to loss of production capacity. As soil erosion takes place, the ability for cereal crops and grass to flourish is reduced which, in turn, has a direct impact on the productivity of the land. The upper soil horizon or ‘top soil’ is the most productive component of any soil series and it can take upwards of 150 years for 1cm of topsoil to develop. Off-farm impacts of soil erosion are largely borne by wider society and take a number of forms such as flooding, declining water quality and pollution of air; involving emissions of greenhouse gases such as carbon dioxide, methane and nitrous oxide.

The Protection of Waters Against Pollution from Agriculture. Defra Consultation on diffuse sources in England, August 2007 The Protection of Waters Against Pollution from Agriculture. Defra Consultation on diffuse sources in England, August 2007 5 Probability calculations are undertaken within the ECM+ Model. Five-year average SRP concentrations were calculated from EA monitoring data for the period 10/2005-09/2010, i.e. the Water Years 2006-2010. The uncertainties around these average figures were estimated using Bayesian Inference 3 4

Phosphorus has been identified as a nutrient which should be prevented from reaching surface water bodies in excessive amounts as biological productivity in watercourses is usually limited by P availability. Too much P input can contribute to algal blooms (often toxic to both aquatic animals and humans) and watercourse oxygen deficiency which can be fatal for fish and other aquatic fauna. Phosphorus entering watercourses from agriculture does so in two forms a) attached to soil particles and organic matter including animal manures (Particulate phosphorus which usually comprises over 75% of Total Phosphorus) and b) dissolved in water run-off (dissolved P, approximately 25% of Total Phosphorus). Fine textured soils (e.g clay loams, silty clay loams) have a particularly high risk of generating phosphorus transport to watercourses due to their high affinity to phosphorus combined with a high erosion potential. These soils typify much of the land covering the three study areas chosen for this project. The proportion of total phosphorus (comprising both dissolved and particulate phosphorus) available to plants at a given moment in time is known as reactive phosphorus (or bioavailable phosphorus) which is made up primarily of dissolved phosphorus plus a small proportion of the particulate form. Some observers have commented that given the particulate form of phosphorus makes up a small proportion of reactive phosphorus, it should not be the focus of attention from policy makers concerned about water quality objectives. However, although not immediately available to plants, particulate phosphorus represents a major reservoir of potential reactive phosphorus which can become soluble over time through natural transformation processes in rivers, lakes and estuaries, particularly when dissolved phosphorus levels are depleted.

To reduce phosphorus transport to watercourses, it is imperative to ensure mobilisation of mineral soil and organic matter is minimised (prevents Particulate phosphorus transport). Methods to reduce soil mobilisation have been outlined in Section 4.2 and include contour cultivation and sowing, the planting of cover crops and arable reversion. Whilst these methods prevent mineral soil and organic matter mobilisation and therefore Particulate phosphorus, they are less likely to prevent dissolved phosphorus loads.

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3.3 Phosphorus Pollution Processes

To prevent dissolved phosphorus loads, it is important to ensure that phosphorus build up in the top-soil is kept to a minimum to prevent this being dissolved in water passing over and through the top-soil e.g through drains. Where excessive application of animal manures occurs, high concentrations of phosphorus accumulate in the top layer of the soil which provides higher risk of dissolved phosphorus loads occurring during periods of run-off. When the spreading of manure is immediately followed by rainfall and runoff, then incidental transport can lead to loss of fresh manure-bound phosphorus. Loss of phosphorus in runoff is influenced by the rate, method, and the timing of phosphorus application, source of phosphorus used, amount and duration of rainfall and the type of crop being grown. For example, the dissolved phosphorus concentrations can be considerably reduced if manures can be applied a few inches below the soil surface. Phosphorus is far less likely to run off the land if it is given time between application and rainfall events to be absorbed into the soil profile. Phosphorus loads are also likely to vary considerably from farm to farm and field to field. High erosion risk land which is intensively farmed with high levels of manure application is likely to yield more phosphorus to water courses that a low intensity farm on flat land.

Phosphorus entering watercourses has multiple sources including agriculture, sewage treatment works, septic tanks, naturally decaying plant materials, stream bank erosion and wildlife excreta.

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4.0 Current Policy Instruments This section of the report revisits each of the underlying causes of pollution identified in Section 3.0 and systematically assesses whether currently available policy tools are appropriate and capable of dealing with these issues. A brief overview of relevant regulatory6 and financial incentive mechanisms is provided first before going on to assess the efficacy of each tool to address each problem identified. An assessment of the current advice service available to farmers on pollution matters in the form of the Catchment Sensitive Farming (CSF) initiative is dealt with separately in Section 5.0.

4.1 Overview Of Current Regulatory And Financial Mechanisms Available The following mechanisms represent the main policy tools currently available in England to address soil and phosphorus pollution from agriculture:

Cross Compliance Since 2005, all farmers receiving the Single Farm Payment must adhere to a set of Statutory Management Regulations (SMRs) and Good Agricultural and Environmental Condition (GAEC) practices across their landholdings. Whilst there are a large number of SMRs and GAECs within crosscompliance, it is only the Soil Protection Review (GAEC1), Ground Water Regulations (SMR2), Sewage Sludge Regulations (SMR3) and Nitrate Vulnerable Zones (SMR4) that have relevance to the problems identified by stakeholders in the study areas for this project and of these, it is only really the Soil Protection Review that is directly targeted at managing soil and phosphorus pollution. Under EU regulations, 1% of farmers claiming the Single Farm Payment receive a cross-compliance inspection each year with compliance failures incurring losses of between 1% up to100% for extreme and persistent failures. In England and Wales, The EA currently carries out cross-compliance inspections for Ground Water Regulations (SMR2), Sewage Sludge Regulations (SMR3) Nitrate Vulnerable Zones (SMR4) and Water Abstraction (GAEC18) with The Rural Payments Agency (RPA) inspecting compliance with the other land management cross-compliance requirements including the Soil Protection Review (GAEC1).

Anti-Pollution Works Notices (APWNs) The EA has at its disposal Section 85 of the Water Resources Act 1991 (‘Knowingly causing pollution’) which enables prosecution for various offences where pollution of surface and/or groundwater occurs. The limitation of this mechanism is that it tackles the effect rather than cause of a problem and can only be invoked once a pollution incident has occurred. It cannot, therefore, be used to prevent water pollution taking place. In addition to Section 85 of the Water Resources Act 1991, there is a plethora of environmental legislation on the statute books relevant to the protection of freshwater water systems including, but not limited to: The Nitrate Vulnerable Zone (NVZ) Regulations 1998; Anti- Pollution Works Notices, Section 161A, Water Resources Act 1991; Water Protection Zones, Section 93, Water Resources Act 1991; The Control of Pollution (Silage, Slurry and Agricultural Fuel Oil) ‘SSAFO’ Regulations 1991; Groundwater Regulations 1998; The Waste Management (England and Wales) Regulations 2006; Environmental Protection Act 1990; Pollution Prevention and Control Regulations 2000; EU Environmental Liability Directive 2003; Wildlife and Countryside Act 1981; Salmon and Freshwater Fisheries Act 1975; The Sludge (Use in Agriculture) Regulations 1989; and the Town and Country Planning Act 1990. Whilst a wide variety of legislation exists as outlined above, it is only Anti-Pollution Works Notices (APWNs) that are currently available to address soil and phosphorus pollution issues on open farmland in any location. APWNs served on a person require that person to carry out works and operations to prevent, or remediate the consequences of the entry of any poisonous, noxious or polluting matter or any solid waste to controlled waters and have been used to a limited extent within the agricultural sector (see below). Water Protection Zones Section 93, Water Resources Act 1991 are also available in principle to target soil and nutrient run-off and in a similar way to APWNs, Water Protection Zones can be applied anywhere they are necessary. This mechanism goes one step further than APWN legislation by having the potential to specify area based designations within which all farmers must undertake mandatory activities. However, due to the complexities of setting up WPZs including the need for the collection of robust evidence that justifies imposing costs on one group of land owners over others7, only one WPZ has been designated to date on the Dee catchment, largely to deal with industrial pollution. EA personnel consulted within this project did not consider WPZs to be a practical policy instrument for use in the foreseeable future.

The scope of this project focused on statutory law and not common law rights developed through precedents e.g “A riparian proprietor is entitled to have the water of the stream on the banks of which his property lies, flow down as it has been accustomed to flow down to his property, subject to ordinary use of the flowing water by upper proprietors, and to such further use, if any, on their part in connection with their property as may be reasonable under the circumstances.” (John Young & Co. v. Bankier Distillery Co. 1893 Appeal Cases 691). 7 WPZ designation also requires ministerial approval

The Environmental Stewardship Scheme (ES), incorporating the Entry Level Scheme (ELS), Organic Entry Level Scheme (OELS), the Uplands Entry Level Scheme (UELS) and Higher Level Scheme (HLS) provides payments to farmers to undertake specific management practices or capital works designed to deliver environmental public goods. These schemes are offered to farmers on a voluntary basis and are promoted as multi-objective schemes covering a range of biodiversity, heritage and natural resource protection objectives, including soil and water protection. The ELS, OELS and UELS are noncompetitive schemes and are open to all farmers whilst the HLS is a competitive scheme within which farmers must effectively bid for a share of a finite budget. According to Natural England personnel engaged with the project, HLS currently covers 10% of agricultural land across England and is increasingly focusing on SSSI sites and Habitats Directive designated areas. In addition to ES, the CSF programme also provides grants to farmers within priority catchments (currently totalling 50 in England) to install capital items specifically targeting pollution from farmyards, intensive grassland and cultivated fields. The annual budget for 2011 totals ÂŁ10.5m and is awarded to farmers on a competitive basis who must fill out an application form. Financial assistance is provided for a variety of works including clean and dirty water separation infrastructure, track maintenance, watercourse fencing, roofing of manure storage areas and the resurfacing of gateways.

4.2 Assessment Of Current Regulatory And Financial Mechanisms Relevant To Soil Pollution Having provided a brief overview of the main policy mechanisms currently available to address soil and phosphorus pollution, this section of the report reviews the capability of these mechanisms to address the soil pollution issues outlined in Section 3.0.

4.2.1 Addressing The Growing Of Crops In Certain High Risk Fields Without Appropriate Soil Management Practices In Place

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Agri Environmental Schemes

Growing crops such as maize, potatoes and winter cereals can be a high risk exercise, particularly on sloping land in fields with soils sensitive to capping and erosion. The late harvesting of maize and potatoes means bare earth can be exposed to autumn and winter rainfall events resulting in significant mobilisation of soil from land to nearby water courses8 . If winter cereals or cover crops are not established early enough in the autumn to establish sufficient root growth and land cover, similar outcomes can become manifest.

Cross Compliance The identification of soil erosion risk and the adoption of suitable control measures is a fundamental feature of cross-compliance, most notably within the revised Soil Protection Review (SPR) which all farmers receiving the Single Farm Payment must have completed by December 2010. Farmers must classify each field in terms of erosion risk (scale of low, medium and high) and then select a prescribed number of management options from a list of measures (Part 3 of the SPR) to manage this risk. Precisely which options the farmer selects is up to him. There is already, therefore, a toolkit in place to address the issue of high risk cropping in the form of the SPR. However, whilst it is too early to evaluate the impact of the revised SPR, views expressed by EA Enforcement Offers and farm advisors suggest the mechanism is unlikely to provide adequate protection against soil erosion. Two main reasons were given. Firstly, it is up to the individual farmer to assess the risk of his fields; the higher the risk identified, the more measures he must put in place to manage the risk. Given most farmers are not trained soil scientists, it is possible that many farmers will not correctly identify risk levels on high risk fields, thereby under scoring risk (e.g scoring a high risk field a medium or low risk field) and adopting a sub-optimal profile of measures to manage the risk. Secondly, EA Enforcement Officers believe the SPR is an unenforceable mechanism because provided a farmer has completed his SPR, identified a risk level for each field and allocated the appropriate number of optional measures, he cannot be deemed non compliant even if he is causing a significant soil

There are, however, a number of management practices that can be adopted to reduce erosion risk such as rough ploughing after a maize harvest to improve rain infiltration rates and reduce overland flow

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erosion problem on his farm. Whilst it is true a farmer cannot be initially deemed non-compliant provided he can demonstrate he has completed his SPR and adopted the appropriate number of measures, discussions with the RPA highlighted there is provision within the cross compliance enforcement process to prevent farmers from failing to take subsequent action. On encountering a soil erosion problem, RPA inspectors have the option to refer the case to Natural England land management specialists who will visit the site to make an assessment. If considered a serious enough case, Natural England will then refer the case back to the RPA who will write to the farmer with guidance on how to rectify the problem. Whilst no further action will be taken, it is understood from RPA inspectors that the probability of that farm being selected for subsequent cross compliance inspections will increase although this is not guaranteed. If the farmer is selected for re-inspection and it is found he has not adopted the guidance issued by the RPA, the RPA will then request action is taken and levy a financial penalty. However, whilst this referrals system does appear to be in place, consultation with the RPA reveals very few referrals are made by RPA inspectors to Natural England suggesting the process is not a standard operating procedure at the current time. In addition to the above, observations made by both farm advisory staff and farmers themselves suggests RPA staff check for the existence of the SPR booklet when making a cross compliance inspection but not whether the measures within it have been applied. It is uncertain whether this is due to RPA inspectors being aware of the lack of enforceability cited above, a lack of resources or whether RPA inspectors lack confidence in being able to identify soil related non-compliances. Given the revised SPR and related enforcement process is still relatively new, it is difficult to make a definitive judgement on whether this instrument is an effective mechanism to improve soil management in high risk fields. However, the evidence presented by respondents within this project suggests it is not For the process to have credibility and purpose, it will be important to ensure inspectors have the skills and resources to check measures identified within a farmers cross compliance booklet have been implemented. Clearly, where soil management problems still prevail, it will be necessary for inspectors to have sufficient expertise to identify these problems and for a referrals process to be put in place which ensures farmers take appropriate action where current measures are proving ineffective. Aside from the workability or otherwise of the SPR as an enforcement tool, interviews with farmers showed that the SPR processes has not engaging them in a broader sense regarding the importance of soils to their business and the negative 46

consequences of soil erosion to the environment. When asked whether the SPR had raised awareness of the importance of soil management, one farmer dryly commented his â&#x20AC;&#x2DC;awareness was raised for the time it took to fill out the book and put it in the drawerâ&#x20AC;&#x2122;. In many cases, it transpired respondents have employed land agents and advisors to fill out their SPR booklet and have played no active role at all in its development. The emergence of specialist cross compliance consultants (e.g Cross Compliance Solutions Ltd in Hereford www.cxcs.co.uk) is testament to this hands-off approach.

Anti Pollution Works Notices As introduced in Section 4.1 and informed through discussion with EA staff, the EA does have the ability to issue Anti Pollution Works Notices (APWNs) served under Section 161 of the Water Resources Act to deal with soil related water pollution. APWNs can be issued when a) the EA can apportion responsibility to the source(s) contributing to the soil erosion that leads to pollution (a person has caused or knowingly permitted the pollutant to enter controlled waters) and b) specific land management actions are available to the land holder in order to achieve the desired environmental outcomes written into the APWN. To serve an APWN, the EA must identify the source of the pollution, the pathway of the pollution to the receptor (the watercourse) and they must also demonstrate the pollution is causing an impact on the receptor. Details of which management activities are causing the problem need to be listed together with the specific improvements required to address the pollution risk. EA guidance to Enforcement Officers states that Officers should avoid unsuitable or unreasonable actions which may leave the Agency open to legal action. The guidance suggests SPR measures from the Cross Compliance Manual are recommended for use unless these are likely to be insufficient to deal with the issue at hand. The difficulty with APWNs is that they can be time consuming to prepare and deliver with recent EA guidance specifying APWNs should only be issued where it is possible to demonstrate a category 1, 2, or 3 level incident. Clear identification of the source of pollution is required which makes APWNs unsuitable if there are multiple holdings contributing to the polluting load. Because of the resource implications surrounding the issuing of APWNs for soil pollution, the EA has been extremely reluctant to make widespread use of this instrument to date. Indeed, all bar one of the EA enforcement staff engaged in the three study areas had never issued a works notice to a farmer. Notwithstanding the resource implications, there appears a clear case that APWNs represent an existing tool which could be applied more widely to pollution incidents arising from the inappropriate

Agri-Environmental Payments The Environmental Stewardship programme in the form of the Entry Level and Higher Level Schemes9 offer sources of funding to farmers to adopt changes in land use which can, in certain situations, protect watercourses from soil erosion.

The Entry Level Scheme The Entry Level Scheme has been criticised historically for being too focussed on biodiversity and habitat measures at the expense of soil erosion and water pollution management options. However, in recent years new measures have been introduced with a resource protection focus, most noticeably Measure EJ5 In-field grass areas to prevent erosion and run-off (New in 2010), Measure EJ9 12m buffer strips for water courses on cultivated land (New 2009), Measure EJ13 Winter Cover Crops (New in 2010), Measure EE9 6m buffer strips on cultivated land next to a watercourse (New 2010) and Measure EE10 6m buffer strips on intensive grassland next to a watercourse (New 2010). These new measures add to the existing suite of 2m-6m buffer strip options under Measures EE1 to EE6. Whilst the ELS scheme now contains a broad spectrum of resource protection measures, land

management experts interviewed across the case study catchments were of the view buffer strips, unless very wide (12m+) are not capable of preventing soil reaching watercourses from fields with anything greater than a 7-10 degree slope. This view is backed up by the guidance in the Cross Compliance Guidance for Soil Management 2010. Most buffer strips within ELS are, therefore, not capable of preventing the type of soil erosion cited as emanating from sloping potato, maize and cereal fields across the three study catchments. If the ELS options referred to above are considered in this light, only the new options EJ9 (buffer from 12m minimum up to 24m) and EJ5 (up to a third of any given field can be sown to grass) are likely to offer adequate protection from soil erosion in anything other than very low risk fields. The difficulty with relying on these options as a mechanism for solving soil erosion is that the evidence suggests from numerous farmer interviews undertaken that voluntary take up of these options will be low because the loss of income from implementing these measures is perceived as too high due to the extensive loss of productive land involved. Given the recent introduction of these two measures it is too early to provide any quantitative analysis of actual take up rates. However, if we examine the take up rates for the buffering options which have been in ELS for some time (which involve taking land out of production), these have been very low across all three study areas as demonstrated in Table 2.

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management of high risk crops. Clearly identifiable gully or rill erosion leading from a potato or wheat field directly into a watercourse is one such example.

1. Data based on ELS and HLS Agreements current at March 2011. Source: NE Geographical Information & Analysis Team 2. NE ES staff estimate only 20% of buffers occupy watercourse bank locations 3. DRN online lengths are Lugg 1936651m and Rea 405270m (Source: EA Directives Reporting Services Team) 9

OELS and UELS are not focussed on within this report due to the very low uptake of these schemes within the study areas

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Where farmers have been prepared to enter land into buffer strip management, evidence from the farmer interviews shows they have only been prepared to give up marginal land which is difficult to farm anyway and produces low outputs from an agronomic perspective. Prime intensively farmed agricultural land is not being volunteered but it is precisely from this type of land that many of the soil erosion problems cited by stakeholders in the study areas appear to arise. Indeed, it is possible to infer from the current geographical distribution of ELS buffer strips within the project study areas that buffer strip options are not necessarily situated in areas at greatest risk from soil erosion. As can be seen in Figure 1 with regard to a SCIMAP risk analysis for the Rea catchment , ELS buffer strip options on cultivated land are either absent or very thinly spread on many areas considered to represent a high erosion risk. Conversely, there is a relative concentration of ELS buffers on cultivated land in the bottom left hand corner of

the catchment which the SCIMAP model and expert opinion on the ground suggest is a lower risk area. This strongly suggests ELS resource protection measures are not delivering targeted outcomes which has implications for the cost effectiveness of the scheme going forward. Under the current programme, several individuals were of the view that a way to engage farmers to adopt effective resource protection measures within ELS would be to re-weight the allocation of points away from hedgerow management options towards resource protection measures. Currently, the majority of farmers derive most of their points from hedgerow management and do not need to undertake broader land management options. However, farmer opinion pointed towards a scenario where they would choose not to enter the scheme at all if they were required to undertake measures involving taking productive land out of agricultural production.

Figure 1. Rea SCIMAP Sediment Source Risk Analysis And ELS Cultivated Land Buffer Distribution

1. Insert in above risk map demotes key cereal growing areas 2. ELS buffer locations relate to 2,4 and 6m buffers on cultivated land as at March 2011 â&#x20AC;&#x201C; Source: NE Geographical Information & Analysis Team 48

Higher Level Stewardship is targeted at specific areas of countryside considered to be particularly important for a range of Biodiversity, Landscape, Historic Environment and Resource Protection delivery objectives. According to Natural England personnel engaged with the project, HLS currently covers 10% of agricultural land across England and is increasingly focusing on SSSI sites and Habitats Directive designated areas. Both the Lugg (Target Area Statement WM18 Wye and Lugg River Valleys Target Area) and Rea (Target Area Statement WM10 River Teme Target Area) fall within HLS prioritised areas and have attracted a fair amount of HLS funds accordingly. The Caudworthy is just outside the HLS Target Area for the North Tamar Catchment and is characterised by only one HLS agreement focussed on a very small SSSI site in the northern fringes of the catchment. Priorities in each target area are defined by a Targeting Statement which specifies farmers must undertake at least one of a number of land management activities, depending on the objectives for the Target Area. The River Teme, Wye/Lugg and North Tamar Catchment targeting statements all include soil erosion protection as one activity farmers can choose to deliver in return for HLS payments. An examination of the HLS scheme demonstrates there are a small number of appropriate measures with the potential to combat soil erosion from high risk arable land. These include measures HF14 Unharvested, fertilser free conservation headlands with a width of 6m-24m (£440/ha), measure

HJ3 Arable reversion to unfertilised grassland to prevent erosion or run-off (£280/ha) and HJ4 Arable reversion to grassland with low fertiliser input to prevent erosion or run-off (£210/ha). The difficulty with these measures in terms of providing effective soil erosion protection is that many arable farmers do not consider the financial payments available a sufficient incentive to stimulate adoption, particularly with high projected prices for cereals over the medium to long term. By way of an example, a farmer interviewed in the Lugg catchment described how he had recently entered the HLS scheme and had adopted arable reversion but only because this suited his farm business plans to increase livestock production and reduce his arable acreage. He stated categorically that he would not have selected arable reversion had he planned to maintain his focus on arable production.

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The Higher Level Scheme

Other farmers within more of a mixed farming system do appear to view the HLS reversion payments as sufficient provided they are not asked to give up their prime agricultural land. The costs of reverting marginal arable land are considered to be offset by the overall income from the HLS agreement and the value of the new grazing land created. This is not perceived to be the case where prime arable land is concerned. In all, the evidence shows the take up of HLS soil protection measures has not been widespread across the study catchments as indicated in Table 3 below11 :

Table 3. Uptake of HLS Erosion Management Measures in Lugg and Rea Catchments

1. Data based on HLS Agreements current at March 2011. Source: NE Geographical Information & Analysis Team 2. Figures based on area of land in arable rotation (Lugg 29,000 ha / Rea 5,600 ha). Source: June 2010 Agricultural Census

No take up of these measures exists in the Caudworthy catchment 49

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An illustration of the spatial distribution of these measures within the Lugg is provided in Figure 2. Aside from payment levels, it appears HLS option uptake can be strongly influenced by the preferences of individual HLS advisors who may or may not prioritise resource protection measures within a given HLS application, depending on their technical backgrounds and conservation interests. Given HLS advisors explained persuading farmers to adopt resource protection measures â&#x20AC;&#x201C; particularly arable reversion â&#x20AC;&#x201C; can be difficult and sometimes unpopular, it was also possible to detect a lack of enthusiasm to promote resource protection through fear of losing farmer buy-in and, therefore, failing to hit HLS scheme adoption targets. Discussions with Natural England HLS officers also suggest they view HLS as a multi-outcome scheme and tend not to focus on resource protection accordingly. As a result, the evidence points to a situation where HLS officers rarely concentrate on resource protection outcomes or working up

HLS applications on farms where biodiversity or heritage outputs are unlikely. A noticeable exception was encountered in one of the study areas where a specific HLS officer has focussed on resource protection outcomes due to a personal commitment to reduce the soil erosion problem in the locality. In the round, feedback from HLS officers in the three study areas suggests that whilst HLS target statements can theoretically permit an HLS application to focus on resource protection outcomes, it is unlikely such an application will be successful. Where resource protection focussed HLS applications have been successful is in the Clun catchment (near neighbour to the Rea) where Habitats Directive targets to protect the freshwater pearl mussel have necessitated HLS agreements to focus on water quality protection measures. Here, the driver for resource protection measures has been species protection rather than improvements in water quality per se.

Figure 2. Distribution Of HLS Soil Protection Measures HJ 3, 4 & 5 In The Lugg

Large numbers of livestock on grassland fields can at times (particularly when wet) cause poaching and associated mobilisation of soil to rivers. Poaching tends to take place, although not always, on intensive livestock farms where animal densities can be high.

Cross Compliance Under the SPR, there is an optional measure specifying that farmers should ‘remove grazing livestock from grassland when the soil is too wet and poaching occurs’ (Measure I7). Measure I8, also optional, specifies that if it is necessary to out winter livestock, farmers should ‘locate any sacrificial fields on freely drained soils and not on fields that will lead to erosion’. There are, therefore, provisions within cross compliance to manage soil erosion caused by poaching. A difficulty arises, however, regarding enforcement thereof because if a farmer does not select option I7 above in his SPR for a given field, he cannot be deemed non compliant if poaching occurs on that field. Similarly, if he selects option I8 but causes an erosion problem on a given sacrifice field, it is very difficult for an enforcement officer to judge whether a farmer has selected an inappropriate field through negligence or through a genuine mistake. Movement of livestock to prevent soil erosion is, therefore, not technically mandatory under cross compliance on improved grassland fields. Potentially, RPA inspectors can refer a case to Natural England and follow the enforcement process outlined in Section 4.2.1 but, according to RPA personnel consulted, this practice is not carried out in reality.

Anti Pollution Works Notices EA personnel confirmed that APWNs could potentially be used to stop farmers poaching fields. However, as outlined in Section 4.2.1, the cause, the pathway and receptor damage would need to be determined in each instance which can be a resource intensive process. As a consequence, APWNs have not been used for this purpose thus far. For further details on the mechanics of serving APWNs, see Section 4.2.1.

Agri-Environmental Payments There are currently no ELS measures targeting the alleviation of poaching on intensive livestock farms. There are, however, a selection of HLS measures that have the ability to achieve this outcome; specifically HJ6 Preventing erosion or run-off from

intensively managed improved grassland (£280/ha) which requires restricted supplementary feeding and HJ7 Seasonal livestock removal on grassland with no input restriction (£40/ha) which applies on a whole field basis. There are also HLS measures which seek to reduce the grazing intensity on certain fields, particularly HK7 Restoration of species-rich, semi natural grassland (£200/ha) which precludes any heavy poaching by livestock.

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4.2.2 Addressing Overstocking Of Livestock In Certain Grassland Fields At Certain Times (Particularly Winter) Causing Poaching And Compaction

Despite their existence, the evidence shows the coverage of these measures has been very low. No uptake can be found at all for HJ6 Preventing erosion or run-off from intensively managed improved grassland and HJ7 Seasonal livestock removal on grassland with no input restriction across any of the study catchments. Regarding HK7 Restoration of species-rich semi natural grassland, there are 205 hectares registered under this option in the Lugg catchment but none in the Rea or Caudworthy. As outlined in Section 4.2.1 when assessing HLS soil erosion measures for arable land, it appears insufficient payments are the key reason why so few intensive livestock farms have adopted HLS measures capable of preventing soil erosion from their livestock operations. Feedback from HLS officers also suggests it is difficult for intensive livestock farms to meet the necessary criteria to qualify for entry onto the HLS scheme. Poaching and compaction of land can often be particularly acute around drinking and feeding areas. The CSF grant scheme provides two funding options to tackle this problem, CSF07 Hard bases for livestock drinkers and feeders and CSF010 Livestock troughs with associated pipework. However, take up of these options has not been high thus far. For example in the Tamar catchment for the 2011/12 wave of CSF applications, only 7 out of 166 applicants applied for option CSF07 Hard bases for livestock drinkers and feeders. It is also noteworthy that there are no agrienvironmental payments currently available for winter housing, considered by many farm advisors as extremely important for keeping animals away from vulnerable fields during the wetter (winter) months of the year. Insufficient housing means farmers are often forced to place their stock in fields at times when a heightened risk of poaching and compaction exists. South West Water is currently funding winter housing, with a proviso that the farmer has enough land and manure/slurry storage to accommodate the nutrient flows from the number of animals owned. Subject to state aid rules, there would appear to be an argument for adopting this mechanism within the CSF grant scheme to fund winter housing where private funding sources (e.g water companies) are not available. 51

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4.2.3 Addressing Animals Poaching And Breaking Down River Banks Animals gaining direct access to river banks can severely damage bank structure, causing banks to collapse and soil to enter the river channel.

Cross Compliance There are currently no mandatory requirements within cross compliance for farmers to prevent degradation of river banks. There is an option within the SPR grassland management measures to ‘minimise damage to riverbanks by providing managed access to water for livestock’ but farmers do not have to select this option. Evidence from farm advisors suggests farmers only select this option if they already have their watercourses fenced off and therefore do not have a problem with bankside poaching. As with the crop risk management and in-field poaching issues already referred to, RPA inspectors can potentially refer riverbank degradation cases to Natural England and follow the enforcement process outlined in Section 4.2.1 but it does not appear RPA personnel have adopted this procedure thus far.

Anti Pollution Works Notices According to EA personnel consulted, APWNs could be used to stop farmers allowing their animals to overgraze and destabilise riverbanks. However, as in outlined in Section 4.2.1, the cause, the pathway and receptor damage would need to be determined in each instance which can be a resource intensive process. EA staff explained there is not a ‘culture’ to do this at moment due to the perceived scale of the riverbank poaching problem.

Agri-Environmental Payments An obvious solution to the riverbank degradation problem is precluding animals from accessing watercourses with stock fencing. This, however, is expensive to erect and maintain which is why many farmers do not voluntarily adopt this management option. In terms of financial assistance for fencing off watercourses, there is currently no grant available under the ELS scheme for new fencing although financial assistance is possible to obtain through the ELS scheme for fencing maintenance12. There is grant funding available for sheep fencing (£1.80/m) and post and wire fencing (£1.20/m) for farmers managing to get into the HLS scheme but this fencing is mainly used for keeping animals out of hedgerows and other non-riparian habitat restoration projects and is rarely used as a water protection measure. To give an indication of HLS fencing available, a listing of the fencing options currently funded under HLS contracts in the Rea catchment is provided below in Table 4: The HLS fencing itemised in Table 4 totals 123,539m (123.5km) but it is estimated that only 10%, or 12km, of this fencing will be alongside watercourses13. Whilst this makes a valuable contribution to watercourse protection in the catchment, HLS fencing is not in place for the majority of the 405 km of on-line watercourses which makes up the Rea catchment14. In recent years, the Catchment Sensitive Farming Initiative has provided funding for capital items including watercourse fencing (measure CSF003). Funding rates available are £2.50/m for sheep netting, £1.25/m for high tensile fencing and £2.50/m for post and wire fencing. This has been a valuable additional source of finance for

Table 4. HLS Fencing Options Adopted In Rea Catchment

Data based on HLS Agreements current as at March 2011. Source: NE Geographical Information & Analysis Team

There is provision for new fencing against watercourses under the UELS scheme Estimation derived from HLS Officer assumption 14 On-line figure from DRN data provided by EA Directives Reporting Services Team 12 13

Fencing grants to farmers in the three study areas have been made available through private sources, particularly the Rivers Trusts. The Westcountry Rivers Trust, The Wye and Usk Foundation and Severn Rivers Trust have been extremely successful at raising money to fund watercourse protection but these sources of funding are sporadic and not guaranteed on an on-going basis.

4.2.4 Addressing Farm Tracks Funnelling Water Into Fields Farm tracks can be the cause of significant soil mobilisation as they provide a channel for runoff to gain velocity. If water from tracks flows directly into a field, the force of the water can cause significant soil erosion.

Cross Compliance There are no measures within cross-compliance which place a responsibility on the farmer to manage run-off from tracks.

Anti Pollution Works Notices APWNs can be used to stop tracks acting as sources and pathways for soil pollution of watercourses according to EA enforcement staff. However, whilst APWNs have been used to mitigate soil erosion from tracks in the quarrying industry, they have not been applied thus far to the farming sector. As with other pollution sources highlighted previously, sufficient evidence must be accumulated in order to serve a APWN which can be a resource intensive process. See Section 4.2.1 for further detail on APWNs.

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farmers but feedback from both farmers and local farm advisors suggests very little fencing has been installed under CSF thus far. An examination of the 2011/12 contract data confirms this with the length of watercourse fencing contracted being 600m in the Lugg, 556m in the Teme and 868m in the Tamar. Indeed, when the estimated required fencing coverage for each of the study catchments is taken into consideration (see Section 7.4.2), it appears uncertain at the current time whether the ES and CSF programmes are sufficient to deliver the necessary quantity of installations.

Grant assistance is currently available to remedy erosion problems from tracks under both the CSF programme and the HLS scheme. Measure CSF011 funds cross drains on or in farm tracks whilst Measure RDD within the Higher Level Scheme capital grants section also provides financial assistance for putting in track drains. There is also funding available under the CSF programme to build swales and check dams (CSF013) to manage run off from existing tracks and to build new tracks which can circumvent pollution pathways caused by existing track pathways (Measure CSF021A/D). Given that both the HLS and CSF grant pools are competitive schemes, farmers are not guaranteed access to the funds which means an individual with an erosion problem caused by a farm track may well not be able to gain sufficient funding to fix the problem. Take up of measures under CSF and HLS to manage farm tracks has not been widespread across the study catchments thus far (<20 farms adopting relevant options under the CSF 2011/12 funding round across the entire Lugg, Teme and Tamar area). It is uncertain whether this is due to lack of demand from farmers or lack of availability of funding for these measures.

4.2.5 Addressing Mechanical Compaction It is widely agreed by soil scientists, agronomists and farm advisory personnel that compaction of soils from mechanical operations is a major cause of erosion and is a widescale problem. Compacted soils prevent infiltration of rainfall resulting in increased overland flow and associated erosion and run-off.

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Cross Compliance Theoretically, the SPR provides a regulatory vehicle to address compaction from mechanical operations in that farmers should identify fields at risk of being compacted and then adopt appropriate measures to manage this problem. The difficulty here is that the SPR process assumes farmers are able to diagnose they have a compaction problem and it assumes they have the necessary knowledge to put in place effective management measures. There is also a question over whether it is possible for an RPA inspector to determine whether a farmer has taken adequate precaution to manage compaction. This assumes the inspector is capable of identifying compaction and able to make a judgement on appropriate management practices. Given that the identification of compaction often requires inspection holes to be dug with a spade, it does not appear RPA cross compliance Officers have a sufficient remit to detect compaction effectively as they do not have the authority to undertake ‘invasive’ investigations i.e dig holes on farmers land. It, therefore, seems likely that EA walkover surveys offer a better opportunity to identify soil compaction issues and engage with farmers accordingly (see Section 7.2). There is also a requirement within the SPS for farmers to note any mechanical operations undertaken on waterlogged soils and then take actions to repair any compaction caused. Again, the difficulty here is that farmers may fail to recognise when a field is waterlogged and they may not take appropriate actions to rectify a problem even if they identify one. Accurately identifying a farmer has caused a problem on waterlogged land without having performed appropriate restoration is extremely difficult, making meaningful enforcement of this element of the SPR almost impossible.

Anti Pollution Works Notices APWNs could theoretically be used to address pollution caused by underlying soil compaction. However, due to the scale of the problem and the difficulties involved in assessing both the cause and the remedy, EA staff were of the view a regulatory approach to tackling soil compaction represents a major challenge.

Agri Environmental Schemes Mechanical compaction is not specifically targeted within the Environmental Stewardship Scheme. However, within the CSF grant scheme, there is financial assistance for farmers to roof over slurry and manure stores, which can increase storage capacity thereby reducing slurry/manure spreading frequency. This in turn reduces machinery traffic across fields which reduces the likelihood of these fields becoming compacted. There is also funding within CSF to put in place hardcore farm tracks which has the potential to reduce compaction from 54

farm traffic by diverting machinery movements away from vulnerable soils, particularly in wetter weather when compaction is most likely to occur. Given the apparent lack of awareness of soil compaction expressed by many farmers, there is a distinct need for extensive advice and training on this issue, both in terms of compaction recognition but also management of the problem post recognition. The EA’s Think Soils manual is available to farmers, together with the Codes of Good Agricultural Practice and supporting literature to the SPR. Evidence from farmers, however, suggests face-to-face and hands-on training is the best form of knowledge transfer which has considerable cost implications in terms of providing sufficient training and demonstration resource.

4.3 Assessment Of Current Regulatory And Financial Mechanisms Relevant To Phosphorus Pollution This section of the report reviews the capability of current policy mechanisms – cross compliance, APWNs and the Environmental Stewardship Scheme to address the phosphorus pollution issues outlined in Section 3.0.

4.3.1 Addressing Phosphorus Transfer To Watercourses Via Soil Erosion An analysis of current policy mechanisms relevant to tackling soil erosion is presented in Section 4.2.

4.3.2 Addressing The Build Up Of Phosphorus Levels In The Soil Surface Cross Compliance At the current time, there are no requirements within cross compliance for farmers to limit the application rates of phosphorus on their land. Within the Sewage Sludge Regulations (SMR3) there is a stipulation that farmers should ‘take account of the nutrient needs of plants when applying sewage sludge’ but there are no mandatory limits for sewage sludge application rates per se. The Code of Good Agricultural Practice and RB209 recommendations exist for farmers to apply appropriate application rates but these are advisory documents and are not accompanied by any regulatory requirements. Farmers within Nitrate Vulnerable Zones (which includes much of the Lugg catchment) must adhere to nitrogen limits which involve monitoring the application levels and timing of slurries and manures. Whilst this process is likely to indirectly result in a limit on phosphorus applications, NVZ rules do not specifically target phosphorus applications. Obviously, outside NVZ areas, the NVZ legislation has no influence over phosphorus usage.

APWNs are not suitable for tackling excessive phosphorus levels in soils due to the need for establishing source, pathway and receptor impact which is very difficult for phosphorus. Other than indirect measures as outlined above, there are no statutory measures designed to enforce phosphorus limits.

Agri Environmental Schemes Reducing phosphorus levels in soils is not an explicit objective of the Environmental Stewardship programme but there are measures within the schemes which stipulate a reduction of cessation in the application of manures. For example within the Entry Level Scheme, there are habitat improvement measures which prohibit manure applications including the buffer strip options, measures EK1 Take field corners out of management, EK2 Permanent grassland with low inputs, EK3 Permanent grassland with very low inputs and EK4 Management of rush pastures. There are also stipulations within the ELS maize management options (EJ2 and EJ10) which require appropriate rates and timings of manure applications both to the maize crop and the subsequent crop planted. Within the HLS scheme, there are a range of measures specifying a reduction or cessation of manure applications including HJ6 Preventing erosion or run-off from intensively managed, improved grassland and HK6 Maintenance of species-rich, semi-natural grassland. The difficulty with these measures is that they tend to be adopted by farmers who are already extensive in their operations and are unlikely to have high phosphorus indices on their farms. As already noted in Section 4.2.1, the HLS scheme is not available to the majority of farmers who either lie outside the HLS target areas or do not have sufficient habitat or heritage interest on their farms to qualify for entry into the scheme.

4.3.3 Addressing The Timing And Method Of Phosphorus Application

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Anti Pollution Works Notices

Cross Compliance As is the case with levels of phosphorus application, there is no requirement within cross compliance specifying the timing and method of phosphorus application. As with application rates, the Code of Good Agricultural Practice and RB209 recommendations provide guidance on timing and methods but these are advisory documents and carry no regulatory standing. Farmers within NVZs must adhere to nitrogen limits and spreading windows which have an indirect control on the timing of phosphorus applications.

Anti Pollution Works Notices APWNs are not suitable for tackling inappropriate timing and methods of phosphorus application in soils due to the need for establishing source, pathway and receptor impact which - as already pointed out above - is very difficult for phosphorus. Other than indirectly through NVZ legislation, there are no statutory measures designed to enforce the timing or method of phosphorus applications.

Agri Environmental Schemes For livestock farmers, applying phosphorus at appropriate time windows (when crops require nutrients for growth) very largely depends on the availability of sufficient storage capacity. Since the creation of the CSF capital grants programme, there has been a valuable introduction of grant aid to fund the construction of manure storage (CSF023) and slurry storage (CSF026) areas. These capital works prevent rainwater entering these stores, thereby increasing the capacity of existing farm infrastructure to house more manure and slurry material, improve timing of applications and reducing the chance of leakage of nutrients from the farmyard.

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Evidence suggests grant funding for storage roofing has been welcomed by farmers with over 80 projects being funded across the three study areas during the 2011/12 CSF funding period. Whilst the CSF roofing grants are delivering significant benefits, CSF and other advisory personnel on the ground are of the view many farms require fundamental increases in storage capacity, necessitating the building of new stores for which CSF grants are not available15. In the Caudworthy catchment, South West Water is investing significant funding to increase on-farm slurry storage which is providing much needed private funds to boost the funds available through the CSF grant pool for store roofing16. This innovative project presents a model which may well have application much more widely across the UK and is addressed in more detail in Section 9.0. There are provisions within a small number of Environmental Stewardship measures to influence the timing of manure application to land. For example in ELS, measures EJ2 Management of maize crops to reduce soil, EJ10 Enhanced management of maize crops to reduce soil erosion and run-off, EK2 Permanent grassland with low inputs and EK3 Permanent grassland with very low inputs specify manures should be applied at appropriate times as part of the ELS management agreement. The difficulty with these measures is that very few farmers appear to have adopted the maize management options (mainly because of the 01 October harvesting deadline) and those farmers adopting the grassland management options tend to place these options on fields which are being farmed extensively and are unlikely to have high phosphorus indices.

5.0 Catchment Sensitive Farming Programme Review During the fieldwork for this project, a number of opportunities arose to engage with staff involved with the delivery of the Catchment Sensitive Farming (CSF) initiative within and outside the three study catchments. Given delivery of advice to farmers in the form of CSF is a key plank in the current policy toolbox to combat agricultural pollution, CSF officers and managers were consulted to obtain their views on the strengths and weaknesses of the current operational aspects of the programme. Farmers interviewed during the project who had come into contact with CSF were also asked to comment on their experiences.

5.1 Targeting Of CSF Activity In each CSF target catchment, CSF activities are shaped by a process that begins with an examination of WFD waterbody classifications and supporting data, followed by the development of an action plan to identify target areas and specific groupings of landholdings. This process is overseen by a panel of local stakeholders (including farmers) and supported by access to nutrient models such as PSYCHIC to further assist the targeting of effort. Feedback from Catchment Sensitive Farming Officers (CSFOs) suggests this targeting exercise has proved difficult to deliver on the ground due to incomplete data sets and uncertainty regarding the nature and scale of water quality problems in their respective catchment areas (see Section 6.1). For example, CSFOs feel ill equipped to communicate the relative contribution of agriculture and other sectors to the phosphorus problem due to a lack of source apportionment data being available. There also appears to be variations across the study catchments regarding the level of information (data) exchange that exists between the CSF programme and EA ‘data gatekeepers’ regarding water quality monitoring and assessment analysis. Some CSFOs believe they have poor access to data which they perceive to be ‘centrally controlled’ whilst other respondents felt data sharing between the EA and CSF was relatively good due to the initiative being a joint delivery programme which is fostering closer collaboration between the two organisations. Access to data appears, in some cases, to depend on the strength of personal contacts. Observations from CSFOs suggest there are often strong differences of opinion between national and local EA staff regarding which water quality issues should be targeted for WFD compliance which, in turn, is leading to confusion amongst CSF delivery teams. CSFOs on the ground are of the opinion the EA needs

In any event, even if CSF grants were available, a funding ceiling of £10,000 is not considered high enough for the building of new stores 16 South West Water has projected a 65:1 payback ratio for the investments it is making in catchment management activities, resulting from reduce water treatment costs 15

5.2 Reaching Farmers Evidence from CSFOs indicates that between 30%-50% of farmers within each of the three study catchments have come into contact with the CSF programme thus far 17. Contact has mainly been achieved through clinics, arranged by CSFOs to introduce the programme to local farmers and, in particular, to promote the CSF grants available. Farmer motivations to attend these events have very largely been driven by a wish to obtain grant rather than a wish to gain knowledge on pollution mitigation techniques and the broader ethos behind the CSF initiative. Based on observations from the CSFOs interviewed, it does not appear the CSF programme has been successful at reaching the ‘difficult to engage’ farmers i.e those farmers who tend not to proactively seek advice and who are often believed to have significant pollution issues on their farms. The reasons for lack of engagement with these farmers appears two-fold: firstly, CSFOs believe they have not had time thus far to ‘seek out’ these farmers and secondly, there appears a reluctance on the part of CSFOs to cold-call farmers who they believe are unlikely to be welcoming or receptive to the CSF message. Lack of cold-calling has been recognised by CSF managers who have recently initiated cold-calling training at a national level to provide CSFOs with the skills and confidence to undertake this difficult activity more widely.

Revisions to the CSF grant application process have resulted in applicants standing a better chance of receiving funding if they have already engaged with CSF (e.g attended a clinic) or become involved in the Environmental Stewardship Programme. The difficulty with this approach is that ‘difficult to reach farmers’ by definition have not engaged with these programmes. By reducing the likelihood of these farmers to obtain CSF grant, it is possible they will become even more marginalised and isolated from the programme and its broader objectives.

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to establish a coherent centralised data repository for WFD classification and targeting planning which is not disputed by EA staff and other WFD delivery organisations.

5.3 Grant Funding An examination of the measures eligible for CSF funding within the three study areas suggests these measures are appropriate for dealing with the problems outlined in Section 3.0. However, whilst the measures eligible for grant appear well conceived, the evidence suggests the grant has not been targeted effectively so far. Feedback from CSFOs indicates they have limited time available to visit farms and identify optimal measures for funding, leading to sub-optimal grant allocation e.g manure stores receiving roofing grant in catchment locations where there is a low risk of nutrient run-off. This issue has been exacerbated by funding uncertainties. For example CSFOs in the Rea catchment reported they were not informed CSF grant would be available for 2010/11 until one month prior to the application window closing. This did not leave sufficient time for them to identify optimal measures and target the best spend profile for the grant. Contacting farmers during the application window (March/April) was also made

Table 5. CSF Capital Items Funded In Study Area Catchments

Source: CSF Capital Grants Scheme Funding Priority Statements 2011/12

CSF has operated in the Tamar and Lugg since 2006 but only started in the Rea in 2010 57

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difficult due to this being the prime lambing season for sheep farmers. On a positive note, it now appears that CSF programme money has been secured from RDP funds, at least until March 2013, which means CSFOs can plan ahead and have greater opportunities to identify best value grant funding opportunities prior to the grant application window in March/April 2012. Whilst compressing all applications within a short application window requires co-ordinated preparation by both CSFOs and farmers, this approach allows applications to be processed extremely cost effectively with only 5% of the total grant allocation of £10.5m pa being spent on administration costs. CSFO’s also expressed concerns that the scoring of CSF applications has historically been undertaken by a centralised administrative team in Nottingham who are not necessarily best placed to judge optimal grant allocation. This concern was substantiated by feedback from the farmer interviews which highlighted several examples of inappropriate measures being funded. For example, one farmer cited an example where a neighbouring farm had received CSF grant to cover a manure store where this farm is almost entirely focussed on arable production. However, it appears CSF managers have recognised this shortfall in the current system because from 2012, CSFOs will be given much greater opportunity to score applications. In addition, they will be given discretion to award grant assistance to ‘special cases’ where a farmer fails to meet the grant criteria but where the allocation of grant has the opportunity to achieve considerable environmental outcomes. Care will also be needed to ensure CSFOs have sufficient time to ensure contracted works under the grant programme have been undertaken. Feedback from CSFOs highlights they have not always had the resource to ensure farmers have undertaken work contracted under the scheme. Observations made by local farm advisors suggest contracted works have not always been carried out which has implications for the credibility of the CSF grant allocation process.

5.4 Developing On-Going Working Relationships With Farmers The availability of grant assistance from the CSF programme has undoubtedly helped to act as a hook to engage with farmers. However, evidence from farmer interviews and feedback from CSFOs suggests the CSF programme has not always been able to use this initial ‘way in’ to develop on-going working relationships capable of dealing with fundamental problems. One farm advisor likened the CSFO/farmer relationship as being characterised by ‘payment for

services rendered without the development of any love’. It appears lack of time available to CSFOs is a major reason why the establishment of continued working relationships have not been established. It is also likely that the use of private contractors in some areas to deliver CSF outputs has reduced the level of direct contact between CSFOs and the farming community. CSFOs also commented that the quality of advice delivered by private contractors and, therefore, the value of the CSF brand may have been compromised due to private contractors often being selected on price due to limited CSF budgets. One further barrier to building strong relationships with farmers appears to be due to poor timing of service delivery. For example in the Rea catchment, some farmers receiving CSF grant had subsequently signed up for CSF delivered manure tests to be undertaken, designed to promote the optimal use of nutrients and reduce run-off. Unfortunately, it appears these tests were undertaken in the winter when nutrient levels in stored manures are different than in the spring when the farmers concerned planned to spread the majority of the tested material. Consequently, these tests were not well received by those farmers involved.

5.5 Integration Of CSF And The Environmental Stewardship Programme It is uncertain at the current time how well integrated the CSF programme and its staff are with the Natural England Environmental Stewardship initiative. It is the perception of CSFOs that Natural England Managers are not particularly interested in the CSF initiative which results in a lack of co-ordination between the two grant pools. For example, CSFOs cited examples where farmers have received grant under both CSF and HLS for fencing where CSF money might have been better spent on additional farm infrastructure such as slurry store roofing or alternative drinking points. Rather than having separate staff delivering CSF, ELS and HLS schemes, some CSFOs questioned whether it would make more sense to merge the various schemes under a single delivery team to promote internal co-ordination and allow a single point of contact with farmers to facilitate relationship building. To encourage better programme coordination, it appears since April 2011 that some CSFOs have began occupying office space within Natural England’s Land Management Teams where ELS/HLS officers reside. It is not clear whether this happens across all regions but would appear to be a positive move to foster collaboration.

The fieldwork for this project enabled extensive interaction with a broad range of individuals either directly involved in the delivery of regulation, advice and financial incentives or those directly involved with managing the land on a day-to-day basis i.e the recipients of regulation, advice and financial incentives. From this exercise, it has been possible to make a number of overarching observations which have direct relevance to the policy debate surrounding WFD implementation. This section of the report provides a synthesis of these observations, providing context for the suggested policy instrument changes which follow in Section 7.0.

6.1 Lack Of Consensus Of The Problem A reoccurring theme that emerged across all three study areas was a clear lack of consensus regarding the nature and extent of local water quality problems. In particular, farmers have an interest in understanding the relative contribution agriculture is making to the problem as a whole, for example in relation to phosphate loads. The evidence suggests this source apportionment data has not been made available thus far across the study areas. Feedback from farmers strongly suggests they have received little if any information explaining the current state of waterbodies in their area and they remain sceptical about the information they have received. As outlined in Section 6.1, a lack of agreement within the EA and the scientific community more widely over ‘the problem’ has prevented clarity of message which has prevented a common understanding amongst stakeholders on the ground of what the water quality concerns are in their area and what to do about them. The impacts of soil erosion in particular are hard for farmers to grasp as soil entering a river is often ‘washed away’ without causing obvious damage. As one conservation minded farmer put it, ‘if there was a road at the bottom of every farm which became blocked by soil, farmers would very quickly acknowledge there is a problem’.

‘ I began noticing that my cows wouldn’t drink from a particular stretch of the stream and felt there had to be something nasty going into the water there. Then I twigged our farmhouse septic tank is situated in the field near to that spot so I put two and two together. We’ve put some buffers in there now and that seems to have done the trick’

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6.0 Overarching Observations

The difficulty thus far is that farmers do not appear to have been adequately involved by the catchment management community in jointly understand the problems. Consequently, this has led to many farmers remaining disengaged from the subject and, in some cases, becoming overtly hostile to the agencies involved. The need to present the problems in a clearer manner and develop methods for determining appropriate solutions has been recognised by the scientific community in recent years which has responded through the production of a plethora of computer models designed to model effects of land use change and farm management practices on pollutant loads18. Based on evidence derived from extensive academic research and farmer feedback within this project, it will be crucial to ensure farmers are involved in the choice, on-going development and scrutiny of these models to ensure they become a trusted decision support tool going forward. Simply presenting farmers with a ‘black box’ and expecting them to believe the results is unlikely to generate this outcome. The need to involve farmers in defining problems and solutions has been formally recognised within the Catchment Approach formally launched in March 2011. The CSF programme is already piloting a participatory method for jointly working with farmers to collect and monitor water quality in local water courses and has allocated a budget (£85,000 in 2011) for local groups to carry out bespoke research designed to collect evidence and assess appropriate mitigation strategies. Farmers contacted within the DSEPP project welcome these developments but several were sceptical how seriously farmer input will be taken.

Almost without exception, the farmers engaging with this project were of the view the farming community must be presented with evidence that a problem exists before they will be willing to take action. Interviews with farmers uncovered numerous examples of situations where they had identified for themselves that a problem exists and had subsequently taken appropriate action:

Inman, A. and Cook, H. Reviewing Vulnerability Assessment And Modelling Tools For Pollutant Source Identification. SAIN Working Paper 4, April 2011 18

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6.2 Land Ownership Dynamics It became apparent during the project that many land parcels in the study areas are increasingly not being farmed by owner occupiers. Numerous farmers and farm advisors interviewed were of the strongly held view that farmers renting ground, particularly on short term Farm Business Tenancy agreements, do not have a sufficient incentive to make infrastructure investments on items such as watercourse fencing, farm tracks and slurry stores which are the route cause of many of the water quality problems cited in the study catchments. In addition, short term tenancies do not encourage the development of a long-term farm plan, a necessary prerequisite for embedding environmental protection measures within the farming system, particularly where fundamental land use or land management changes may need to be made which cannot be delivered overnight. The corollary of this observation is that land owners need to be engaged on the water quality agenda in addition to their tenants to determine whether more satisfactory resource protection outcomes can be achieved to the mutual benefit of both tenant and landlord. It is likely this requires a third party capable of brokering such an arrangement, a theme that will be further expanded on in Section 10.0.

6.3 Enforcement Of GAEC1 Within Cross Compliance

At the current time, the Rural Payments Agency (RPA) is responsible for the enforcement of GAEC1 which includes issues pertaining to the Soil Protection Review. The EAâ&#x20AC;&#x2122;s remit is restricted to auditing farmer compliance with the Groundwater Regulations, The Sewage Sludge Regulations, the Nitrates Directive and water abstraction rules. Feedback from EA Enforcement staff reveals that when making cross compliance inspections, they are under instructions not to investigate soil related issues and do not have sufficient time within their cross compliance visit schedule to perform this activity anyway. Given the EA is responsible for WFD delivery, it would appear more efficient if EA Officers could check compliance with GAEC 1 when they are already on farm checking Groundwater, Sludge and Nitrates SMRs. Given detection of SPR non-compliances requires specialist skills, there is also an argument that these skills should be developed within the agency with a specific remit for catchment management more widely (i.e the EA) rather than within the RPA which has a different focus. This does not, however, appear to be current government policy as it is understood the RPA is currently in the process of taking over all cross compliance regulatory visits. Irrespective of which Agency monitors GAEC1, it will be important that inspections are mainly carried out during the autumn and winter months when detection of soil and nutrient run-off related problems can be achieved accurately. Evidence from EA Enforcement staff suggests cross compliance inspections by both the RPA and EA are often carried out in dry weather when identification of soil pollution problems is difficult.

6.4 Farmers Attitudes Towards Regulation Farmer attitudes towards regulation were explored in detail during interviews and workshops across the three study areas. There was universal agreement amongst the farmers that regulation to protect water quality is needed and justified. In some cases, farmers felt regulations did not currently go far enough particularly in relation to run off from crops such as potatoes and maize where mandatory buffer strips were called for by some respondents. Farmers were quick to point out, however, that it is vital they understand what constitutes an offence. At the current time, farmers appear confused and uncertain about exactly where the boundary is which has led to a continuation of bad practice in the absence of a clearer regulatory framework. In order for regulations to be accepted by the farming community, feedback from respondents also underlines a need for the regulatory process to be perceived as fair. In particular, for soil pollution and cases of nutrient run-off from fields, farmers do not perceive immediate prosecution for a first offence to be appropriate, arguing lack of awareness or lack of control over events due to bad weather are often at play. Rather, a warning or series of warnings followed by prosecution through failure to act on these warnings is deemed a balanced way forward. During the fieldwork, cases were encountered of farmers who had been prosecuted for run-off offences, in their view unfairly as they did not be perceive they had been causing a problem. It is testimony to the professionalism of the EA personnel involved that the farmers harboured no bad feeling to these Officers personally, simply the system under which they were operating. Linked to the issue of fairness is the need for farmers to understand and recognise the impact of bad practice on the water environment. It follows that regulations to prevent an environmental harm will be more likely to be accepted and adhered to if that harm is perceived as real. In the case of cross compliance, several farm advisors interviewed were of the opinion many farmers perceive the SPR to be â&#x20AC;&#x2DC;unnecessary bureaucracyâ&#x20AC;&#x2122; because they do not recognise the harm that can be caused by soil pollution.

A clear finding of this project generated from stakeholder feedback is a need for clear demarcations between the roles, responsibilities and operating practices of the statutory agencies and advice providers (public, private, NGO) operating within the catchment management space. Each organisation involved in the mix should have clearly defined and well communicated terms of reference and be experts in their respective fields of operation to generate trust amongst themselves and wider stakeholders. It is understood Defra has recently initiated a joint working group project to directly address this issue, a timely and needed initiative based on the findings from this project. Evidence from a plethora of research studies (strongly reaffirmed by farmer opinion expressed in this project) highlights the need for farmers to develop an on-going confidential relationship with a trusted farm advisor before they are willing to voluntarily discuss pollution problems on their landholdings and be receptive to new ideas and working practices. For this reason, it seems the EA is not well placed to act as a first port of call for farmers seeking advice on pollution issues. Not surprisingly, farmers have an inherent fear of the EA due to its regulatory and enforcement function which is why nearly all farmers interviewed stated they would be nervous to invite EA staff onto their farmers to discuss a pollution matter openly. Only one farmer interviewed had ever voluntarily contacted the EA over a pollution issue, having prevaricated over this decision for several days: ‘I was worried if they came out to discuss one matter they may see two or three other things and pick me up on those as well’ This fear of the EA is recognised by the majority of CSF advisors interviewed who purposefully distance themselves from close association with the EA in order to facilitate the building of trust with farmers: ‘The last thing I want to do is begin working with a farmer, maybe successfully obtain some CSF grant for him and then find the EA have prosecuted him the day after I’ve been there.’ The wish by CSF Officers to build a confidential working relationship with farmers is the reason why information exchange on farm specific pollution issues is very much one sided between the EA and the CSF Programme (information flows from the EA to CSF but not the other way round), much to the frustration of some EA Enforcement staff. Westcountry Rivers Trust has worked with farmers in the South West of England for 15 years and adopts the same confidential policy for the purposes of building trust with, and access to, the farming community.

Whilst it is unlikely farmers will approach the EA for advice on a voluntary basis, it is possible that the EA can provide an advisory function where they have encountered a pollution event on a farmers land i.e it is no longer voluntary for the farmer to seek advice. Indeed, the EA already performs this role in some cases where EA staff have sufficient agricultural expertise. The difficulty here, based on farmer feedback, is that they find it very difficult to be receptive to advice from an organisation which also has the potential to prosecute them. Aside from the issue of farmer perception, dealing with pollution mitigation will increasingly require integrated agronomic and farm business advice and it is questionable whether this can best be provided by a regulatory agency such as the EA.

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6.5 Roles And Responsibilities

Whilst the EA should not necessarily be precluded from maintaining an advisory capacity, there is a clear need for a confidential arms length highly skilled extension advice service capable of helping farmers tackle water pollution issues within the context of running profitable farm businesses. Given the CSF programme is already established, it would make sense to develop the skills base and capacity of this initiative, complimented where available by independent organisations such as ADAS, The Rivers Trusts etc. Given the CSF programme is currently a joint initiative between NE and EA, it is questionable whether this is the best arrangement based on the observations made above. Indeed, the evidence would suggest that CSF extension provision should remain entirely separate from the EA and should aim to build links with other independent advice providers. There is already close collaboration between the CSF Programme and the Westcountry Rivers Trust (WRT) in the Tamar catchment where WRT is co-ordinating CSF grant applications. This is effectively a pilot exercise in CSF/Third Party partnership delivery which, if successful, could be rolled out elsewhere where suitable external technical capacity exists. With an effective and trusted extension service in place, this would leave the EA with a clear regulatory focus. Evidence from interviews with EA operational staff strongly indicates there is no clear consensus amongst senior management regarding how consistently regulations should be enforced and how much presence the EA should have on-theground. This lack of clarity is resulting in confusion amongst staff at the coal face. One example was given where local Enforcement Officers have recently been instructed to step back from operating in a particular catchment to make way for CSFOs to begin working with farmers there. This points to a situation where there appears to be a blurred picture regarding how regulation should be used, where the level of baseline environmental performance of farmers should be, and where advice and financial support should be applied.

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Aside from the public sector agencies, there are a number of third sector organisations involved with catchment management delivery in England and Wales, most noticeably the Rivers Trusts, FWAG, the Wildlife Trusts, the AONB network and other NGOs such as the RSPB. Interviews with respondents from both statutory agencies and third sector organisations revealed an element of confusion over respective roles and responsibilities, with different working practices, cultures and pressures appearing to threaten optimal partnership working in some cases. International experience has demonstrated that partnership working between public and third sector organisations is not always easy, but if marshalled correctly, can yield powerful results. Establishment of roles and responsibilities, and formal recognition of these by all concerned, appears to be a key prerequisite for success. Providing sufficient financial resources to the third sector to leverage delivery potential is also regarded as crucial given these organisations often suffer from precarious funding streams, holding back the building of capacity.

6.6 Skills Need Within The Environment Agency Based on feedback from EA local managers, there appears to be a skills shortage within the Agency regarding knowledge of farming systems and the farming sector in general. In contrast to previous policy, Enforcement Officers are no longer recruited by regional offices for specific skill sets but are recruited through a national pool – the ‘boot camp’ - which tends to yield candidates with very little if any understanding of farming systems. EA managers believe this is a major problem regarding the ability of Enforcement Officers to correctly identify pollution issues, understand the causes of these problems, and command the respect of farmers when engaging with them on these matters. It appears the EA is planning to address this issue by developing a training system designed to produce Enforcement Officers who are specialists in agricultural systems although it seems this is currently planned to happen in the Midlands region only. Views were mixed as to whether the training will be suitably in-depth to equip recipients with sufficient knowledge. In addition to the perceived need to recruit and train Enforcement Officers with agricultural knowledge, EA managers are also of the opinion the status, pay structure and career progression of these officers will need to be enhanced in order to attract sufficient numbers of high calibre individuals. Working with the farming sector is regarded by local EA managers as a complex job requiring highly skilled people who need to be suitably incentivised. When asked to express their views on the EA staff they have dealt with, farmers were impressed with their professionalism but, with one exception, were of the opinion they lacked sufficient knowledge of the industry over which they were regulating.

6.7 Working Practices OF Environment Agency Enforcement Officers As outlined above, enforcement of regulations in the agricultural sector requires people with technical specialist skills to be on-the-ground interacting with the farming community on a daily basis. Long serving EA staff referred back to the days of the National Rivers Authority when it was felt more time was available for face-to-face contact with farmers. It was perceived Key Performance Indicators (KPI) have worked against EA officers ‘getting to know their patch’ as the time involved in doing this is not necessarily attributable to direct KPI outputs. Feedback from EA Local Managers suggests Enforcement Officers spend considerable amounts of time ‘processing paperwork rather than undertaking on-farm visits’. The view from managers is that a considerable volume of paperwork could be dealt with by administrative staff, freeing up Enforcement Officers to work on-the-ground. In one of the study catchments, the local office has managed to secure funding to recruit two administrators to support the Enforcement Officers to achieve this outcome. Whilst this situation is improving the ability of EOs to step up enforcement visits, it has only been possible to employ the administrators on two-year short term contracts so longer term support is not guaranteed.

6.8 Reform Of Anti Pollution Works Notices As referred to in Section 4.2.1, The EA has traditionally been resistant to using APWNs because of the resource intensive nature of these regulatory instruments. However, new guidance information provided to Enforcement Officers and acquired during the fieldwork for this project outlines that the process of issuing APWNs has recently been streamlined. In particular, there has been a reduction in necessary supporting documents from eleven to one and the removal of a need for a formal risk assessment and cost benefit analysis. EA staff believe these reforms will make the use of APWNs far more practical for tackling soil and nutrient run-off problems, albeit APWNs should only be used as a last resort where a farmer refuses to take appropriate action.

6.9 Need For Different Incentive Packages As outlined in Section 4.2.1, evidence from both farm advisors and farmers strongly indicates the current suite of agri-environmental schemes do not provide sufficient incentives to encourage many of the land use changes needed to solve water quality problems. Feedback from farmers within this project has reaffirmed a commonly held view within the farming community that ELS payments are effectively a way of recouping modulated funds to top up the Single Farm Payment. In other words, ELS is seen as an entitlement payment for delivering basic environmental standards under cross compliance, not a payment which is

‘In relation to the Entry Level Scheme criteria we have adopted the options which have had the least impact on our productive farming system ie. we don’t want to be taking land out of production by having buffer strips when we can adopt options which are more easily achievable, in our case mixed stocking and low input fertiliser. Virtually all of our points are achieved in these options without any real disruption to our systems, even if we weren’t in ELS we would be doing this anyway……. with regard to HLS, if they want farmers to take up options which takes land out of production they need to offer a premium over and above achievable margins. I realise you are asking me to put a figure on this but it is really a ‘how long is a piece of string’ question, and I am only a simple farmer’ For farmers with relatively small field sizes, incorporating buffer strips (particularly 6m-12m) is perceived as giving up too much field area to make management of the remaining plot practical. In addition, farmers with relatively small farms (typifying the Caudworthy and Rea catchmnents) believe buffering watercourses on their farms will involve giving up too much land relative to the total size of their landholdings, rendering their farming systems (e.g crop rotations, stocking rates etc) unviable. The crucial point here is that the majority of farmers interviewed did not perceive a different vision for their farm, involving specific locations taken out of production, as being financially viable based on current ES payment rates. As an aside, it is also important to remember that the majority of farmers see their primary role as - and derive their self-respect from - being producers of food produce. Becoming suppliers of a wider range of ecosystem services remained an esoteric concept for many members of the farming community interviewed. In reality, it is likely that in some cases, the current buffer strip/arable reversion payments offered under both ELS and HLS do adequately reflect income forgone (plus a ‘hassle/profit/risk’ margin) whilst in other cases they do not. Academic research has produced mixed conclusions in the past on this

subject. Studies based on farmer opinion (e.g Moss, 1994; Falconer, 2000; ADAS, 2002) have suggested that agri-environment payments do not fully compensate the income foregone whilst empirical studies that have attempted to assess the direct financial implications (e.g Jones, 2006; Wallis and Jones 2007) suggest income foregone is more than covered and that farmers are able to profit from these schemes.

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sufficient to warrant adopting additional activities which involve taking land out of production. To do this, farmer respondents were adamant that payments rates will need to be considerably higher than current levels which are, firstly, not considered to accurately reflect income forgone; and, secondly, are not considered high enough to take into account - as one farmer put it the ‘additional inconvenience and hassle of managing buffer strips and messing about putting awkward bits of ground into grass and weeds’. Furthermore, several respondents mentioned current payments do not warrant ‘the risk of taking land out of production for the five year duration of these schemes’ i.e a reduction in production potential might significantly compromise farm profitability if commodity prices significantly rise during the term of an ES agreement. The following response from a farmer in the Lugg catchment neatly summarises how many farmers feel about current payments:

Whatever the reality of the situation, observations from the research undertaken for the DSEPP project suggest it is what the farmer thinks that is the all important factor as this determines his Willingness To Accept (WTA) payment threshold. Estimates from respondents suggest an average farmer WTA is two to three times the payment rates currently on offer under the ES programme which, therefore, presents a significant policy challenge. Two potential responses are possible. Firstly, policy makers could choose not to increase payments but to go for a ‘voluntary coercion’ approach. As one farmer himself pointed out, ‘the only way Defra will get us farmers to take up these actions without paying us more is to tie these undertakings to the Single Farm Payment’. The other potential option is to significantly increase the payment rates under the agrienvironmental measure but this is unlikely to be feasible given the income foregone rules imposed by Europe. Also, as one of the policy experts interviewed for this project put it, there is also a question regarding ‘why should a farmer be paid more than the opportunity cost of his land and efforts for diverting land from a market good to a public environmental good?’ To answer this last question, it is possible to construct a strong argument that a farmer should be paid more than the opportunity cost of converting land out of production if the alternative public goods he is producing have a value which is worth more than the value that can be derived from the same land for producing food. In short, under agri-environmental payments, farmers are currently paid for the opportunity costs of diverting land out of production. They are not paid for the value of the ecosystem services they produce. This leads into the realms of the need to develop effective valuation methods for ecosystem goods and services which will always generate levels of uncertainty. However, if a pragmatic evaluation can be arrived at which is acceptable to a group of willing providers (farmers) and payers (public, private or third sector), it is feasible to conceive a market could be developed which would generate payments commensurate to farmers’ WTA, thereby delivering the resource protection goals society needs. It is possible to envisage a mechanism where CAP funds could used to deliver payments for ecosystem services provided rather than payments for income foregone; but this will take time to broker at a European level. In the short to medium term, more localised schemes between farmers and private sector payers operating independently - yet complementary to – existing state run agri-environmental schemes, might offer a more pragmatic way forward. This topic 1s further explored in Section 10.0. 63

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7.0 Required Policy Changes The analysis and observations outlined in Sections 4.0, 5.0 and 6.0 indicate there are already a number of mechanisms in place that are helping to restore water quality across the study catchments. The evidence suggests, however, that there are several gaps or dislocations within current policy design that need to be addressed in order to improve water quality standards further and meet WFD requirements. This section of the report synthesises some of the key learning points from previous sections which have relevance to policy makers tasked with WFD implementation at a national scale i.e at a scale beyond the three case studies selected for this project. An assumption is made here that the issues encountered in the case study catchments are common to many other catchments in England . Firstly, an assessment of necessary governance or catchment management institutional changes is provided, followed by a summary of specific instrument changes required to address the types of water quality problems outlined in Section 3.0. Estimates for delivery costs over a notional five year planning period (case study level) are also provided to offer an indication of the financial implications inherent within the suggested delivery framework.

7.1 Better Governance Arrangements Needed Feedback from respondents across a variety of different interest groups strongly indicates there is a need for clarity regarding the nature and scale of water quality problems at a catchment scale and how best to address this problem. As pointed out is Section 6.1, there is confusion and lack of consensus both between and within the governmental agencies and within the farming community on these crucial issues which is making joined up planning and delivery of actions on-the-ground very difficult. Current initiatives underway to address these factors are encouraging. In particular, The EA is addressing information gaps in many failing waterbodies (those failing WFD Good Ecological Status GES) by undertaking catchment investigations which are due to be completed during the second half of 2012. It will be crucial, however, to ensure EA led investigations are transparent about uncertainties and benefit from the knowledge of national and local EA staff in addition to outside delivery partners. It will also be vital to ensure the farming community is fully involved in

the interpretation of results to build trust in the data collection, monitoring and analysis methodologies used. There remains a distinct problem with regard to waterbodies classified as currently meeting WFD GES (not currently earmarked for investigations) where classifications are disputed by local stakeholders on the ground including local EA and Natural England staff and third sector environmental groups. This is leading to confusion and lack of trust, particularly, amongst the farming community. For example, both the Caudworthy catchment and most of the River Rea is currently classified as GES yet these catchments are the focus of advice and grant activities by the Westcountry Rivers Trust and Catchment Sensitive Farming respectively. Not surprisingly, this disjuncture does not breed faith in the current WFD classification system and delivery mechanism amongst the farming community. The case is clear, therefore, for the need for a single catchment scale data portal which is open to all stakeholders involved with the delivery of WFD objectives; government agencies, non governmental delivery partners, water companies, farmers etc. Access by non delivery entities (including members of the public) should also be enabled, although these users will be likely to require less detailed information. This portal should include clear communication of water quality problems, levels of uncertainty, WFD classifications and supporting data and should form a central data repository for use by all parties involved with, or interested in, cathment management delivery. Where current WFD classifications are disputed or under review and may require re-classification, this requires clear communication. A further discussion on data sharing can be found in the report outputs from Component A of the project. It is suggested that each catchment data portal should be managed by the proposed host organisations envisaged under the Catchment Approach, albeit in partnership and with technical support from the EA. The current Catchment Approach pilot approach scheduled for 2012 is a very welcome initiative which should help to galvanise and build consensus on problem identification and required solutions. As a policy development to facilitate WFD implementation, the Catchment Approach appears particularly well conceived and timely. The need for improving participatory catchment planning design, consensus (trust) building and knowledge transfer, as envisaged within the Catchment Approach, has been overtly highlighted by the findings of this report.

As pointed out in Section 6.0, it appears current baseline requirements for the management of soil erosion and nutrients are often poorly understood by farmers and are not being adequately enforced by regulatory authorities. The evidence suggests there is a clear need for land management failures to be identified and logged across a catchment and for the legal responsibilities and consequences for noncompliance to be clearly communicated to farmers. Ultimately, regulations need to be both enforceable and enforced, but with sanctions only used as a last resort following a sequence of awareness raising and warning steps, complimented with advice and financial assistance where possible. The evidence from farmer interviews during this project is that farmers will regard this process as equitable and they welcome clarity on what is required from them regarding the environmental protection agenda. At the current time, it appears the SPR element within Cross compliance is not accompanied by an effective enforcement process. Firstly, it is unclear whether RPA inspectors posses sufficient experience to identify whether risk management measures entered into farmer SPR booklets have been appropriately selected and implemented. Secondly, where farmers are deemed by the RPA to be either non-compliant under the SPR or compliant but still causing pollution problems, there is no systematic procedure to ensure farmers take subsequent action to rectify a problem. Such farmers may be written to by the RPA with guidance on what to put right, and may be more likely to receive a future inspection under cross compliance, but there is no guarantee of repeat inspection to insure action has been taken. Of vital importance, there is no guarantee currently that such farmers will be given access to sufficient advice and/or financial support to help them rectify the problem. Under the current cross compliance enforcement regime, whilst the EA has no responsibility to enforce the SPR, the EA does have the latitude to refer farms to the RPA where the EA suspects an SPR breach has taken place. These farms will be subject to an increased probability of a cross compliance inspection but there is no guarantee a farm identified by the EA will be inspected. Feedback from EA staff suggests they are referring very few cases to the RPA at the current time due to a lack of confidence amongst EA staff that referrals to the RPA will lead to ‘environmental outcomes being delivered’ i.e that action will be taken by the RPA. Given only 1% of farms are inspected annually under cross compliance, some stakeholders within the case study areas look to a need for greater usage of regulatory measures by the EA. However, as pointed out in Section 4.1.2, the EA has thus far been extremely reluctant to use its powers to enforce action, for example through the use of APWNs. There

appears to have been no systematic on-the-ground identification of site-specific issues at a catchment scale by the EA in recent years; partly due to resource limitations and partly due to a lack of consensus within the Agency over how rigorously enforcement of the legislation should be applied.

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7.2 Clearer Regulation And Enforcement Needed

In the round, it appears for soil and nutrient management practices to be effectively regulated in a given catchment, a systematic process of identification and enforcement of management failures is required ensuring a balanced and equitable system prevails at all times. As outlined in Section 3.0, respondents across the case study catchments were largely of the view soil erosion is a ‘diffuse point source’ issue, with a significant proportion of the problem emanating from a relatively small area of land. To deal with this issue, therefore, identification of problem fields can be achieved through a combination of modelling tools and walkover surveys . By targeting walkovers and subsequent farm visits at specific high risk catchment zones determined initially from desk studies and local knowledge, costs of enforcement can be minimised. During the fieldwork for this project, it appears that the EA has begun to undertake a series of walkovers across specific catchments with the aim of identifying pollution problems . It would seem appropriate that this process should be rolled out as a matter of course within all catchments to form the basis of an on-going enforcement policy. Specifically, walkovers could be used to determine problem sites (focused on Category 1, 2 and 3 issues) which could stimulate subsequent visits to farms associated with specific problems identified. It is envisaged EA staff could explain the problem to the farmer, agree action is required but leave the precise nature of the action up to the farmer. A return visit and timetable would be agreed. Upon a revisit, if the problem has not been rectified, a formal warning could be issued requiring further action to be taken together with another return visit timetable. If the problem was found to be persistent at the next visit a formal ‘code B’ could be issued and proceedings initiated to serve an APWN. It is understood the EA is currently developing a ‘walkover handbook’ to help staff identify and deal with point source runoff problems from agricultural land causing pollution. The guidance outlined in the handbook envisages a process similar to that described above but it is uncertain whether this process has been officially adopted thus far. As an addendum, for this system to work on a practical level, it will be necessary for the EA to have access to the Rural Land Registry (RLR) mapping system which provides field scale land ownership data (currently only available to NE and the RPA). At the moment, EA officers have to ‘knock on doors’ to identify owners of a particular land parcel which they regard as an extremely inefficient and time consuming process. In order to provide the cross compliance process with a level of enforceability, a similar stepped process of revisits could be implemented to ensure appropriate 65

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mitigation procedures are adopted by farms either with technical breaches of SPR compliance or identified problems. As pointed out in Section 6.3, the RPA currently inspects the SPR and according to RPA staff consulted as part of this project, it is likely the RPA will take over the inspection of all GAECs and SMRs from 2012 leaving the EA with no cross compliance inspection responsibilities at all. However, based on observations accrued during project fieldwork, it is questionable whether the RPA is necessarily the most appropriate entity to be carrying out the SPR inspections, particularly if the EA were to begin carrying out extensive walkover surveys. Identifying run-off problems requires skills and experience and it would seem to make sense to house and develop these skills in the Agency directly responsible for WFD implementation i.e The EA. Additionally, if the EA were to begin a process of identifying problem sites from walkovers and then monitoring actions taken by farmers through a process of revisits, it would be efficient to add cross compliance visits and subsequent revisits within one overall monitoring and surveillance process.

The current combined annual resource expended on farm visits in the Rea and Lugg, for example, is estimated at between 0.5 and 1.5 FTE per year which covers a myriad of activities including cross-compliance inspections, GW authorisation compliance visits, PPC poultry site compliance, abstraction licence compliance, pollution response, pre-application visits for PPC, SSAFO compliance and occasional miscellaneous activities including planning consultations. The resource needed for walkovers and repeat visits outlined in Table 6 would be additional to that which exists already. However, whilst obviously an extra cost, the additional resources required do not seem orders of magnitude greater than that which is already in place

7.3 More Advice Provision Needed

With reference to the pollution issues identified within the three study catchments for the project (Section 3.0), the walkover and subsequent follow up visit approach outlined above would be capable of identifying and taking action on all these issues. Whilst problems associated with insufficient slurry and manure storage may not necessarily be identifiable at the walkover stage, the follow up farm visits stemming from this exercise would be able to cover this base22. Indicative estimates for the resources required by the EA to undertake a comprehensive walkover and enforcement programme as outlined above in each of the three study catchments over a 5 year period are presented in Table 623.

A distinct advantage of a proactive walkover approach undertaken by the EA is that those farmers which the CSF programme has struggled to engage with thus far will very likely be identified by the EA. These farmers could then be referred to the CSF programme by the EA for help and assistance to rectify the on-farm problems encountered. Ultimate sanctions on farmers (i.e Single Farm Payment reduction or issue of a Works Notice) should be used as a last resort and should be seen as a failure to engage farmers effectively on the water quality improvement agenda. As pointed out earlier, it is essential the enhanced enforcement process outlined above is complemented by both an enhanced system of farm advice and greater access to targeted agri-environmental payments to address specific requirements.

Table 6. Indicative Enforcement Resources And Costs (5 Years)

1. Number of days based on walkover of entire catchment (5km/day) and follow up visit to 30% of farms in catchment 2. Costs based on salary and overhead figures provided by EA Finance Business Partner and EA Team Leader For details of the assumptions and calculations behind the above estimates please see Annex A.

22 It is assumed many of the farms with manure and slurry storage problems will be included in the 30% of farms identified for follow up visits from the walkovers 23 Please note these estimates are designed to provide a ballpark indication of costs and have not been verified by EA financial managers

Very importantly, farmer feedback suggests extension advisors must have expertise in farm business economics. This will be necessary to help farmers adopt practical solutions which make sense from a business perspective whilst at the same time deliver environmental protection. Advisors should also have the ability to influence where and how grant money is spent within a given catchment to achieve best value for money. To a certain extent, this autonomy is beginning to happen within the CSF programme which the evidence suggests is the correct direction of travel. As pointed out in Section 6.5, it is important advisors remain one-step-removed from the regulatory bodies to develop a trusted working relationship with farmers. It is also crucial CSF advisors are appropriately resourced to be able to spend sufficient time with farmers who may require significant ‘handholding’. An estimation of the advisory resource and costs necessary to deliver appropriate levels of service for the three study catchments over a 5 year period is provided in Table 724. For details of the assumptions and calculations behind the above estimates please see Annex B.

This analysis suggests that with the exception of the Caudworthy catchment, current CSFO capacity would need to be increased; from 0.3 to 0.6 FTE in the Rea and from 0.5 to 2.4 FTE in the Lugg. Whilst representing increased costs, numerous research projects focusing on farmer behavioural change have identified a central role for one-to-one advice delivered by a trusted and skilled advisor, often over an extended period of time. The importance of this issue has been formally recognised by the EU Commission in relation to forthcoming reforms of the Common Agricultural Policy which is stressing the need for member states to put in place well resourced advice systems to help farmers adopt more sustainable farm business practices. All four policy advisors consulted for this project were also universally in agreement that a highly professional well funded extension system is a fundamental building block for successfully delivering the agri-environmental agenda in the UK. This point of view has not always been shared by public authorities who have tended to view the provision of advice as an administrative cost rather than a long-term investment in the sustainability of the agricultural sector 25 . Long-term investment in expert agricultural advisors is, however, exactly what many observers have been calling for to help farmers meet the growing challenges of producing more food within a more sustainable production system 26.

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Farmers identified as having a pollution problem by The EA and RPA should have access to a confidential advisory service with sufficient resources and expertise to provide on-farm guidance relevant to the needs of the individual. As pointed out by EA and Natural England staff in the study catchments, it is important farmers are provided with appropriate risk management tools to enable them to understand how to ‘carry on farming but without losing soil and nutrients into the river’. One such risk management tool is currently being developed through a collaborative project between the EA, Natural England, Cranfield University and a farmer in the Lugg catchment, the plan being to roll this tool out to other farmers in the area once it is completed.

In terms of external delivery entities, it would appear to make sense to continue to outsource some CSF functions to third party partners where appropriate resources exist. However, to avoid delivery fragmentation, to facilitate consistency of message and to ensure a sufficient advisory skills base is available in all areas, there is a strong argument in favour of ensuring greater resources are channelled to developing the current CSFO human resource base. If external contractors are to be recruited, steps must be taken to ensure highly skilled individuals are used and that contract management does not divert CSF Officer time away from on-the-ground delivery. It is understood CSF is already beginning to explore a

Table 7. Indicative Advisory Resources And Costs (5 Years)

1. Number of days based on NE focussing effort on 30% of farmers identified through EA walkover surveys 2. Costs based on salary and overhead figures provided by NE CSF Project Manager 3. Existing FTE figures provided by NE CSF Project Manager Please note these estimates are designed to provide a ballpark indication of costs and have not been verified by CSF financial managers Hart, K. and Baldock, D. Greening The CAP: Delivering Environmental Outcomes Through Pillar One. Institute for European Environmental Policy, July 2011 26 See for example Improving agricultural extension: A reference manual, FAO, 1997 24 25

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‘partnership delivery’ model although the details of this are unclear. In any event, care must be taken to ensure the transaction costs of managing external delivery partners do not outweigh the potential value external partners might bring. The evidence also suggests it takes time for farm advisors to develop the necessary ‘local knowledge’ (technical and cultural) to perform their role effectively and for trust to develop between an individual advisor and the local farming community. Steps should, therefore, be taken to ensure advisor continuity is maintained which is another argument in favour of a well resourced core CSF delivery team, complemented by local external providers where these demonstrate strong social capital and credibility within the local farming community. The issue of a fragmented advice network in England leading to mix messages to farmers and inefficient extension delivery is not new (e.g Winter, 1995). Since the break up of ADAS in the late 1980’s, many observers have called for the need for a co-ordinated extension effort, delivered through expert farm advisors capable of delivering financially viable environmental advice to farmers. The variety of advisory organisations developing over the last three decades can be seen as a valuable development in as much as farmers have a choice over who they use and new approaches to advice, most noticeably pioneered by the Westcountry Rivers Trust, have lead to notable innovations being made 27. There is, however, a need to make sure all advisory organisations are sending the same message to the farming community which will require collaboration and may require formal agreement. As pointed out in Section 6.4, confusion amongst farmers over what is expected from them appears to be an underlying cause for inaction in many cases.

7.4 Better Strategic Design Of AgriEnvironmental Payments System Needed The evidence accrued during this project suggests the current structure of agri- environmental payments is not appropriate for solving the resource protection problems identified by stakeholders within the three study catchments and summarised in Section 3.0.

7.4.1 Targeting Area Payments Protection of water resources will sometimes require specific areas of high risk land to be taken out of production, either in the form of robust buffer strips or infield reversion of arable land. As they stand at the moment, both the ELS and HLS schemes do not offer sufficient payment levels to incentivise the majority of farmers to take up appropriate resource protection measures. If mandatory buffering and reversion is not introduced (see Section 8.0 on greening of the CAP), higher per hectare payment levels will need to be offered to farmers. Simply re-weighting the ELS points system away from hedgerow options towards resource protection measures will not work as many farmers may choose to withdraw from the scheme. The need to significantly increase payment rates presents a significant problem, however, due to EU income forgone rules which place a cap on payment rates below the level which most farmers will find attractive. Without income forgone restrictions being reformed which is very unlikely, it will be necessary to identify additional private sources of funding, a subject which is explored further in Section 9.0. To gain maximum cost:benefit from such payments it will be vital to ensure they are focussed where they can make most impact. An estimate of the financial resources required to achieve appropriate targeted arable reversion in the study catchments for a 5 year period is presented in Table 8. A total cost of £5.5m in payments appears a high figure. However, if the total current ELS budget for the three catchments is taken into account,

Table 8. Cost Estimates To Achieve Necessary Arable Reversion/Buffer Strips

1. Estimates provided by farm advisors 2. Payment rates derived from interviews with farmers Integrated Whole Farm Plans (promoting ‘win-win’ solutions) incorporating 130 best farm practice advice sheets developed by Westcountry Rivers Trust are one such example 28 Estimate based on £30/hectare x eligible ELS area across the study areas 27

Irrespective of funding streams and payment levels, there seems little argument that resource protection payments should be targeted at those farms where most protection is likely to be delivered. This in turn requires the involvement of local scheme administrators with on-the-ground knowledge (e.g CSF Officers) of where best to allocate funds. To facilitate the optimal allocation of agri-environment spend it is also likely that better co-ordination between CSF, ELS and HLS staff within Natural England is required. As pointed out in Section 5.5, it appears actions are being taken to address this issue although it is uncertain how much integration will result from the current changes. One CSF Officer interviewed suggested that CSF, ELS and HLS programmes and operational staff should be fully integrated into one operational unit, an idea which may well warrant further consideration within Natural England management circles.

7.4.2 Targeting Capital Payments

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estimated at £13m 28 over the same timeframe, it is possible to suggest these more targeted arable reversion payments could achieve greater gain at less cost than ‘broad and shallow’ ELS payments which appear to be delivering marginal additionality at the current time.

Many of the pollution problems identified in Section 3.0 are caused by underlying deficiencies in farm infrastructure. Table 9 outlines estimates for the level of capital investment required by farmers to solve these infrastructure related issues. Clearly, investment in infrastructure represents a major financial challenge for the farming industry going forward and it will be vital to ensure grant funding is targeted where it can best make an impact. The current grant pool available does appear to be able to make a significant contribution to the necessary investments in the study catchments. For example, funding the required fencing works for the Lugg as outlined in Table 9 at a rate of 50% could have been achieved by dedicating approximately 40% of the CSF grant available in the Lugg for the 2011/12 period to that purpose 29. As with area payments discussed in the previous section, it will be crucial to ensure individual CSFOs are able to identify where best the money should be spent. This in turn will necessitate the development of a well informed targeting plan informed by best available data backed up by local knowledge.

Table 9. Estimated Capital Investment Required In Study Catchments

1. Estimates provided by farm advisors 2. Cost estimates derived from farm advisors and interviews with farmers

29 £462,000 grant allocation made for the Lugg Catchment 2011/12

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7.5 Clarity Needed Regarding The Management Of Phosphorus Applying excessive levels of phosphorus to land, particularly at times where risk of run-off is high, represents a significant pressure on the health of freshwater ecosystems. As pointed out in Section 4.3, outside NVZs, there is currently no restriction on the application rates and timing schedules for manures and slurries and even within NVZs, application limits are specified for nitrogen not phosphorus levels. If it is assumed, however, that the current NVZ restrictions represent de facto a restriction on phosphorus applications as well as nitrogen, there remains a question over whether the remaining 40% of farmland lying outside NVZ designations should be subject to some form of phosphorus application restrictions. With regard to the three study areas for this project, most of the Lugg catchment is within an NVZ whilst neither the Caudworthy nor the Rea contain any NVZ designated land. This is a very complex policy question and one which raised significant debate with stakeholders throughout this project. There seems little doubt from an ecological perspective that raising bioavailable phosphorus levels in watercourses is a major cause of eutrophication which in turn can have serious negative consequences on a range of organisms including macrophytes, invertebrates and fish. Bioavailable phosphorus becomes more plentiful when excessive amounts of manure and slurry are applied to a given area of land. Phosphorus is especially likely to become available when manures and slurries remain near the soil surface where connectivity with run off is greatest.

A strong argument exists, therefore, to restrict both the total volume of phosphorus applied and also when it is applied to increase the chance of crop nutrient take up and reduce the risk of run off from rainfall events. The ability of a farmer to spread manures and slurries at an appropriate time window depends on him having sufficient slurry storage capacity. The ability of a farmer to not overload a given land holding with phosphorus also depends on him having access to sufficient land. The difficulty this presents is that many farmers outside NVZs do not have sufficient storage and/or land to accommodate the volume of phosphorus generated by their livestock. This has major financial viability implications for these farms should restrictions on application rates and storage capacity be introduced. Should phosphorus restrictions be implemented, it will be crucial to ensure a very long lead time is given (at least 5 years) for farmers to be able to make appropriate financial plans surrounding their businesses, which, in many cases may require significant structural adjustments. It will also be crucial to ensure that phosphorus restrictions on agriculture are not introduced without assessing alternative options which may place disproportionately less costs on society e.g phosphate stripping at water treatment works, reducing phosphorus loads in detergents etc. Financial assistance to farmers to put in place storage capacity should also be given serious consideration. Whilst it is probably not possible for public money to be made available in England - due to a combination of state aid rules and a precedent of no financial assistance being offered with NVZs - this should not preclude assistance being made available from the private sector through Paid Ecosystem Service markets where feasible to establish (see Section 9.0).

Since its inception, the European Common Agricultural Policy (CAP) has exerted a huge influence on the way the natural environment is managed across the UK and Europe more widely. Dating back to the MacSharry reforms of 1992, there has been a slow but gradual increase in European funds dedicated to the delivery of specific environmental outcomes under Pillar II of the CAP although Pillar I (direct farm support subsidy) has continued to maintain the lions share of the total CAP budget. It is clear, however, from the EU Commissions ‘CAP towards 2020’ communication that the share of the CAP budget allocated to Pillar II is not envisaged to expand further which has disappointed many environmental groups who see Pillar II as an efficient mechanism of targeting payments to farmers to deliver specific environmental outcomes. Rather the Commission’s proposal is to introduce a ‘greening’ element to Pillar I involving 30% of Pillar I funds being ring fenced to fund a range of green measures. In summary, it is proposed farmers must perform three greening measures in addition to adhering to cross-compliance regulations to receive an additional annual payment on top of a basic annual entitlement, all funded from Pillar I. At the moment, farmers receive the equivalent of the additional annual payment and the basic annual direct payment without having to undertake these greening options. The three greening measures currently proposed are: • Crop diversification: arable farms must grow at least three different types of crop each covering at least 5% and no more than 70% of the farm area. This would prevent, for example, 50% wheat 50% oil seed rape rotations practiced on some farms • Maintaining permanent grassland: Grassland over 5 years old must be retained • Ecological Focus Areas: at least 7% of the farm (excluding permanent pasture) must be left fallow or put into extensive management for the purposes of enhanced environmental protection

There is currently significant debate as to whether the proposed greening measures will yield any genuine environmental outcomes or whether they represent ‘greenwash’ with little likelihood of delivering any meaningful ecological benefits. In terms of helping to mitigate the types of soil and nutrient run-off issues highlighted within the study areas for this project, it would appear the Ecological Focus Areas (EFA) offer the best opportunity. Given details from the Commission have been rather vague thus far, it is difficult to gain much clarity at the moment regarding the scope of this particular measure. However at this stage, it is understood farmers would be required to allocate 7% of their ‘non permanent pasture land’ to an extensive management regime which might involve the creation of fallow land (land with no productive purpose) buffer strips, flower strips, beetle banks, skylark plots or grass margins.

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8.0 Current Common Agricultural Policy Reform Proposals

Given a need for the strategic arable reversion of land identified in Section 7.4, the EFA measure potentially offers a valuable tool to protect water resources and deliver WFD outcomes. Importantly, it has the potential within a given catchment to protect specific land areas at risk of soil erosion and run-off and, importantly, reduce the budget needed to fund the uptake of these measures from the agri-environmental pot (Pillar II or private funds) which can, therefore, be diverted to delivering other environmental outcomes. In fact, if 7% EFA was focussed on arable land in the three study catchments for this project, this would more than cover the estimated arable reversion area needed to protect the catchments and would, therefore, save considerable agri-environment budget which would otherwise be required to incentivise farmers to take this land out of production. However, the success of this measure will entirely depend on the detail of how it is implemented. In particular, it will be vital to ensure farmers position their EFAs on areas of their farm which are likely to produce greatest resource protection outcomes. For this reason, farmers should not be left to their own devices when selecting this land but should be required to refer to some form of catchment risk map which stipulates areas where EFAs should be selected. This map would need to be constructed through a catchment management planning exercise, such as the Catchment Approach initiative envisaged by Defra. Provision needs to be made, therefore, at an EU Commission level, to ensure local priorities can be incorporated within the greening legislation.

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It will also be important to ensure EFAs are robust enough (e.g dimensions, width) to deliver sufficient protection of watercourses and that the farmer is given enough flexibility to design, if necessary, a matrix of EFA land capable of delivering a specific purpose. For example, managing asparagus or other high erosion risk land is likely to require infield grass strips positioned in a variety of configurations to prevent overland flow. Both in-field and field margin options should, therefore, be made available to the farmer. To provide farmers with assistance in selecting and implementing their EFA requirements, it will also be important they have access to appropriate advice, reaffirming the need for a skilled extension service outlined in Section 7.3.

Aside from the need to target the proposed EFA measure, some more overarching principles need to be put in place regarding the greening of Pillar I. In particular, to ensure wide-scale adoption of the proposed greening measures, it will be important to make access to the entire direct payment entitlement dependent on delivery of these measures not just the 30% additional payment. It is not clear yet within the Commissions proposals whether farmers will have to adopt the greening measures to obtain their â&#x20AC;&#x2DC;coreâ&#x20AC;&#x2122; entitlement payments. Secondly, there is a significant need to put in place effective monitoring and evaluation methods to assess the on-going effectiveness of both the green payments scheme and the cross-compliance mechanism under Pillar I. There is currently an absence of any requirement to monitor the impacts of these policy instruments which presents a major barrier to assessing their effectiveness 30. Lack of monitoring may well be a reason why the apparent shortcomings of the cross-compliance process outlined in Section 4.0 have not been formally identified and evaluated thus far.

See Hart, K. and Baldock, D. Greening The CAP: Delivering Environmental Outcomes Through Pillar One. Institute for European Environmental Policy, July 2011 30

The final section of this report provides an assessment of the potential for private sector money to contribute towards water quality protection outcomes through investment in catchment management. As outlined in earlier sections, delivering WFD obligations will require significant investment, primarily to achieve a combination of targeted land use changes and farm infrastructure improvements. As has been demonstrated, an effective combination of regulation, advice and CAP derived funds (both Pillar I and II) should be able to bring about many of the necessary changes but it is likely that more money will be required, particularly for capital infrastructure payments and land retirement in specific areas of ecological and/or drinking water importance.

9.1 Paid Ecosystem Services Markets In recent years, a growing interest has developed in what have generically become known as Paid Ecosystem Services (PES) models for environmental protection. Wunder (2008) defines PES as involving a voluntary transaction where a well-defined environmental service (or a land use likely to secure that service) is ‘bought’ by a (minimum one) service buyer from a (minimum one) service provider if, and only if, the service provider delivers appropriate levels of service provision. A review of the literature has identified a small but growing number of instances where private (nongovernment) entities have funded payments direct to landowners to deliver specific environmental outcomes. These payments form part of the development of private markets characterised by ‘individual buyer, individual seller transactions’ (Brown et al, 2006). In some cases, these markets have been initiated and managed completely independently of the state whilst in most cases, the state – usually in the form of a natural resources management agency – has played a major role in their development and on-going administration. Indeed, the literature reveals a majority of PES schemes are not self-organised between buyers and sellers but managed by a government agency. Notably, the government in Costa Rica has pioneered the use of formal PES mechanisms by establishing the Pago por Servicios Ambientales (PSA) in 1997 (Brown et al, 2006). This is a nationwide scheme which targets a number of services including carbon sequestration, water quality and quantity (for drinking, irrigation supply and hydropower), biodiversity conservation and scenic beauty (Turner and Daily, 2008). Since 2000, a growing number of PES mechanisms have emerged throughout other Meso-American and South American countries and also in North America.

As demonstrated in Costa Rica, a closer examination of many of the state led PES schemes reveals that payments made by ecosystem service recipients often form only a part of the total payments received by providers; the balance being made up from a variety of other sources (Porras et al, 2008). These include the re-allocation of (national and local) government general budgets, the reallocation of water revenues or surcharges on domestic or agricultural user fees and donor funds in the form of international grants and loans ( e.g from the World Bank).

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9.0 Potential For Private Sector Investment In Catchment Management

There is insufficient evidence across the board to assess the relative contribution of the various funding sources. However, in cases where information does exist, private contributions are relatively small compared to the other sources of funding such as donors or public resources. This raises questions about the financial sustainability of these initiatives over the long-term (Porras et al, 2008). In several cases, it has been necessary for the state to intervene by enacting the enforcement of payments, the Philippines government, for example, introducing a mandatory requirement for water users to finance watershed management activities. Such interventions involve significant up-front and on-going transaction costs paid for from the public purse. In addition to the state led PES schemes outlined above, a smaller number of privately led or ‘user ’ schemes have also started developing, usually on a reduced scale when compared to the state led schemes and usually concerned with the provision of a small number of ecosystem services (normally one in particular). For example, ‘scenic landscape’ markets involving self-organised private transactions can be found in the USA. These have involved the purchase of conservation easements from private landowners by private land trusts keen to protect scenic landscapes from development. Prices of conservation easements are negotiated directly between the trust and the landowner. Other examples from the USA include Trout Unlimited financing private landowners to improve fish habitat (Brown et al, 1993). In the Philippines, the Kanla-on Spring Water Plant (KSWP) company depends on the maintenance of high water quality within the watershed it is operating in, which is being negatively impacted by unsustainable forestry operations. Consequently, the company is funding a reforestation and training programme to protect its assets (Porras et al, 2008). There are also increasing examples in Europe of water companies paying farmers to undertake management practices that protect raw water quality at source. In the Weser-Ems Administrative District of Lower Saxony in Germany, voluntary land management contracts have been established between land managers and the water supply companies whereby farmers are paid compensation for economic loss which may arise. In the UK, private water companies (see below) have also started incentivising landowners to bring about 73

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changes in land management practices. Perhaps the most widely cited European example of a private entity paying landowners to protect water quality at source relates to Perrier-Vittel, the bottled water company. Whilst the exact payment levels are not known, this business has spent several million dollars on incentive payments in the catchments where it abstracts its water (Daily and Ellison, 2002). In terms of evaluating the overall efficiency of privately funded payment schemes, this is very difficult at the current time given a lack of quantifiable data on environmental improvements and only a few exante studies of costs (Porras et al, 2008). Based on developing country Payments for Watershed Services (PWS) schemes which represent the majority of PES schemes currently in existence, there is still a lack of evidence that investing in PES land-management measures upstream has advantages over other measures to address downstream water-related problems and effectively change farmer behaviour. A fundamental difficulty with ecosystem services when considering market mechanisms is that they are largely non-excludable services i.e it is difficult to exclude those who don’t pay for these services from benefiting from them (known as the free-rider problem). Potential purchasers of these services are also deterred from paying if they know other people will not pay. Free riding is particularly likely where multiple water users share the same catchment. It is noteworthy that most payment agreements with water users have been established in watersheds where there is a single dominant user (Pagiola, 2002). Because of the free-rider problem, it may become necessary for the state to step in to enforce payments otherwise the market will fail 31. For example, the state in Costs Rica has had to introduce mandatory water payments to finance PES activity. In Bolivia, it has been difficult to get individual users to pay for ecosystem provision with an NGO supplying nearly all the money so far (Asquith et al 2008). The difficulty with state intervention is that high transaction costs are likely to result, leading to the scheme becoming inefficient.

• Communication between farmers and downstream users. Their participation could be transitory. The dialogue will help to identify the environmental services expected by downstream users • Programme design. Feasibility studies, designing the payment mechanism, developing management plans and establishing monitoring systems to ensure the delivery of watershed services • Support to suppliers. This helps create the technical, social and institutional capacities to implement the land-management practices required by buyers • Administration of the scheme. Draw up contracts, collect and manage funds, transfer payments to suppliers, coordinate overall monitoring and technical capacity • “Wholesale” managers. In these cases, a facilitator will take the risk of the intermediation process by buying the environmental services (usually bundled) from landowners. They try to sell these services to different users by pooling demand from local and international sources. This type of intermediary in practice becomes a “first-stage” demand for environmental services. Because of the risk involved, the role of “wholesale” manager is usually taken by a government agency, particularly for national-level schemes Landell- Mills and Porras (2002) argue that the successful development of markets depends on their ‘counterpart’; meaning strong cooperative arrangements capable of facilitating trading relationships. Intermediaries have often been criticised in the past for taking too much cash out of the schemes for themselves – leading to distrust and conflict between providers and intermediaries. Intermediaries need to be trusted and provide transparency over their role and the benefits the scheme is providing for providers and payers (Vatn, 2010). PES Schemes will only work where trust can be generated.

A key theme emerging from the literature maintains that high transaction costs can cancel out any of the theoretical efficiencies proposed by PES advocates. This has led several observers to conclude that the key to successful PES schemes is having good intermediaries who can reduce transactions costs to an economically efficient level. To date, a wide range of entities, governmental and nongovernmental, academic and financial, have been involved in facilitating the development and operation of schemes, performing a broad range of roles. In relation to PWS schemes, Porras et al (2008) classifies intermediary activities under the following headings:

31 PES market establishment may not be compatible with ‘slim government’ or lack of state intervention. See Defra Evidence and Analysis Series Paper 4 Payments for Ecosystem Services, 2011

• Actively involved: A small number of water companies are already working with landowners to deliver improved water quality at the farm level. For example, within the Caudworthy catchment and the Tamar catchment more widely, South West Water (SWW) is funding farm infrastructure improvements such as increased slurry store capacity and farm track improvement. During the PR09 funding round, SWW is spending £9m on moorland and farmland projects and £1m on catchment investigation projects which totals 1% of total CAPEX between 2010-2015. In PR14, SWW plans to spend between £30-£50m on catchment management projects, split approximately 66% on moorland rehabilitation projects and 33% on wider farmland. Costs to the customer appear very small, totalling £0.60/year/ household during PR09 and an estimated £2.00/ year/household for PR14.

When examining ways of minimising transaction costs within PES schemes, some authors have emphasised a need to generate a reciprocal relationship between provider and society. Central to this relationship is the need for farmers to perceive the payments they receive as a reward for providing a good service rather than an incentive to behave well. This sense of worth leads to a lower likelihood of farmers failing to adhere to contractual obligations, necessitating less monitoring and enforcement and resulting in correspondingly lower transaction costs (Gintis et al, 2003).

• Undertaking investigations: The majority of water companies have not invested in catchment management thus far, but are currently investigating the likely efficacy of on-farm measures to mitigate water quality pollution issues and the likely propensity of farmers to take up the requisite measures on a voluntary basis. At the current time, it appears these companies may choose a number of routes in the future ranging from farm interventions (i.e financial payments to farmers and provision of advice) to a continuation of end-of-pipe treatment. Where water companies feel pollution levels have reached a plateau in a given catchment, it is likely they will be able to continue blending poorer quality sources with high quality resources, reducing the pressure to invest in a catchment management approach.

The existing evidence also suggests that, as with government incentive schemes, PES schemes need to involve better targeting so that payments reach those providers of ecosystem services most capable of delivering maximum outputs. When considering PWS schemes for example, Porras et al (2008) suggest differential payments are required that reflect (1) the risk of loss of watershed services (2) the geographical location of the provider and (3) the opportunity cost involved with the provider taking action. Porras et al suggest grading systems can be used to identify areas capable of delivering most environmental benefits; involving the use of hydrological and risk mapping together with socio-economic analysis of farmers by location, willingness to engage and required compensation levels.

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Transaction costs are also dependent on the complexity of the scheme in question including the number of ecosystem services being traded and the volume of entities involved. Wunder at al (2008) have reviewed various PES schemes and make a distinction between ‘user’ and ‘government’ funded schemes. User schemes are characterised by small numbers of entities focussing on one ecosystem service only; whereas government schemes involve many entities and multiple services. Because of their smaller and simple structure, user schemes generate far lower transaction costs. As the number of agents involved grows, markets become costly due to the increased number of deals to manage (Vatn, 2010). At a certain point, it becomes cheaper and easier to deliver the ecosystem services in question through taxes or some other charge which involve simplified interaction with providers.

It is interesting to note that both South West Water and Severn Trent Water whose operational regions overlap with the DSEPP project study areas have chosen to work with local Rivers Trusts who act as neutral brokers between the water company and local stakeholders particularly farmers. This arrangement closely resembles the ‘trusted intermediary’ model referred to in section 9.1 as being a prerequisite for successful PES market formulation and delivery.

9.2 Investment From The Water Industry Water companies in the UK are increasingly being seen as a potential source of private sector investment for catchment management initiatives. During the fieldwork for this project it has been possible to identify different trajectories within the water industry regarding water company involvement.

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Ultimately, the key issue that will determine the geographical scale of water company investment in catchment management is commercial selfinterest. Based on discussions with water company respresentatives, it is clear that water companies will only invest in catchment management where this approach will provide value to their customers and shareholders. South West Water, for example, wishes to invest significant resources in Bodmin Moor and Dartmoor as these areas are strategically vital to SWWs business, supplying nine reservoirs, three river abstractions and two hydro electric installations which are becoming increasingly important to SWWs energy supply. The company believes retaining water on the moors and reducing nutrient pollution from wider farm land will help to improve water quantity in times of low flow, reduce water quality problems during drought conditions, reduce pump storage in reservoirs during dry periods and delay the investment in water treatment works which represent huge CAPEX and OPEX commitments. The role of OFWAT, the Water Industry Regulator, is also vitally important regarding water industry investment in catchment management as it is ultimately OFWAT which sanctions this investment through the Periodic Review process. Discussions with OFWAT representatives for this project suggest OFWAT is broadly very supportive of catchment management as an approach but is cautious regarding whether catchment initiatives will work and, therefore, whether water customer money can be spent in this way. Where a specific water pollution problem can be attributed to a specific farm activity, a case for sanctioning remedial payments was regarded by the OFWAT representatives as relatively straightforward. However, where the cause/effect relationship is less clear cut, the case for funding becomes more difficult. For this reason, OFWAT appears to be concerned about funding land use change payments where these may not result in reduced pollution and has asked water companies to identify the risk associated with various land use change options not working. During PR09, OFWAT has only been prepared to sanction capital works (where a cause/effect relationship is easier to prove) but the view from SWW is that OFWAT will approve land management expenditure for the PR14 period provided sufficient outcomes and cost/benefit ratios can be demonstrated. It will also be vital from the point of view of both OFWAT and the individual water companies, that a clear regulatory baseline is established for farm environmental compliance standards, underpinned by effective enforcement. This will give the water industry confidence that investment made in farm

level activities will not be delivering outcomes which should already be being delivered to comply with legal requirements. And importantly, this appears to be a necessary prerequisite before water customers can be asked to pay land managers for the delivery of additional ecosystem services. In short, the overarching issue focussing OFWAT’s position on catchment management is that of customer benefit. On this subject, OFWAT representatives were of the view water company customers must be further engaged regarding their willingness to pay for ecosystem services through their water bills when agri-environmental payments through Defra managed schemes are already in existence. This raises a much greater need for a societal debate regarding ecosystem provision from the landscape; who should pay for this, who should be paid to provide these services, and how much? Orchestrating this debate is possibly beyond the remit of the water companies but is a task which could be taken up by the host organisations facilitating the Catchment Approach initiative going forward. Importantly, Defra policy and technical teams (e.g water, biodiversity, air quality and soils) should also aim to closely collaborate on this initiate to ensure a common vision is developed across the Department.

9.3 Investment From Other Sectors As part of the DSEPP project, interviews were conducted with a small number of companies from outside the water industry in each of the three study catchments to determine their attitudes towards a conceptual PES model for catchment management and whether they could foresee their respective company’s funding catchment management initiatives in the future. The model presented included the following features: • Land managers would receive payments from local businesses for putting in place long-term land management changes and/or infrastructure improvements which would deliver multiple ecosystem benefits including carbon sequestration, improved water quality, flood mitigation and biodiversity gains 32 • The scheme would be established and managed by a local not-for-profit entity • Local businesses would contribute funds to a catchment funding pool which would be managed and distributed by the not-for-profit entity

32 For example creation of wetlands can lock up carbon from the atmosphere, remove nitrogen from run-off through denitrification and reduce flooding by slowing down the process by which overland flow reaches river channels

With one exception, respondents interviewed also felt investment in local catchment management would be a positive Corporate Social Responsibility outcome. Others felt a distinct marketing advantage could be derived from such an investment, with one company already donating proceeds from one of its product lines to the Wildfowl and Wetlands Trust for this reason. Companies within the food and drink sector appeared to envisage a particularly strong marketing advantage from being associated with such a scheme, due to the wish to link their brand identities to a sustainable ‘countryside’ supply chain delivering positive environment outcomes. One company interviewed currently supplies Marks & Spencers with food items and explained M&S is increasingly examining the sustainability of its own food and drink supply chain. If the company could demonstrate to M&S it was investing in a food supplier network which was delivering multiple environmental benefits, it was felt this might well provide a competitive advantage over other food processing businesses. Three of the companies interviewed had explored carbon-offsettng schemes (all outside the UK) but had been unconvinced of the legitimacy of these schemes and ‘whether they actually lock up carbon’. The idea of being able to invest in a local scheme ‘which you can actually see’ and which can be constantly monitored and scrutinised was appealing to respondents. They also liked the idea of a not-for-profit scheme administrator, given a perception that existing schemes are presided over by ‘profiteering middlemen’. A potential limitation of a local catchment management scheme was perceived to be a likely low threshold for carbon sequestration capacity. In particular, one respondent interviewed explained his business produces 40,000 tonnes of carbon each year and questioned how much of this could realistically be absorbed through a local catchment management programme. Local schemes would also need to achieve recognised accreditation standards for companies to be able to invest in them.

In summary, attitudes were very positive towards a catchment based PES model. However, respondents were quick to point out that unless existing tax systems are modified to allow these schemes to be funded or unless businesses are required by law to invest in them, the funding for these schemes generated organically is likely to remain very low. As demonstrated by international experience (see Section 9.1), it seems fiscal and regulatory intervention will be required by government if localised PES schemes capable of delivering water resources protection are to become a widespread reality.

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Across the companies interviewed, there was a very positive response to the principle of investing in a locally based catchment management scheme. All companies interviewed bar one were involved in the Carbon Reduction Commitment programme and one was large enough to be part of the ETS trading scheme. Respondents were of a view that if they are required by government to pay what they see as an environmental tax on carbon emissions (e.g CRC), they would rather a proportion of this money be spent on a local environmental initiative which would be of benefit to their staff and the local community rather than channelled into ‘general Treasury coffers’. Alternatively, they proposed that their CRC payments could be reduced subject to them investing resources in a local catchment scheme.

9.4 Paid Ecosystem Services Mapping The previous sections have outlined multiple sources of funding which could potentially be raised to fund catchment management delivery. The scope of this report precludes a full discussion on the potential for embedding an ecosystem services approach into a catchment management framework. However, a brief example of practical application is given here. To deliver both food and multiple other ecosystem services within a catchment, there is a need for a variety of land uses capable of delivering these outputs. Some areas will be more suitable for growing food and some more suitable for providing other services including water quality, flood alleviation, recreation and biodiversity. Where a farmer is producing food from a unit of land likely to cause soil erosion but where this unit of land is crucial for the provision of multiple other ecosystem services, an argument exists to divert land use away from food production toward the provision of these other services. If a market can be developed where beneficiaries of multiple ecosystem services derived from the land unit are prepared to pay the farmer more for these services than he is currently deriving from using that land for food production, it is possible to envisage an optimal societal outcome. The farmer generates a better return from the unit of land and society benefits from the production of beneficial ecosystem services from the land which is now no longer likely to produce negative environmental externalities.

33 For further information see Palin, N., Walker, M. and Couldrick, L. Mapping Multifunctional Land Important For The Provision Of Ecosystem Services At A Catchment Level. Westcountry Rivers Trust, September 2011

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Figure 3. Map Illustrating Potential Target Areas For PES Payments

Source: Westcountry Rivers Trust

To illustrate this point, Figure 3 outlines a map of four catchments in SW England (Tamar, Torridge, Taw and Exe) highlighting areas of land in red which provide multiple regulating and supporting ecosystem services but are also used for intensive food production (approximately 7% of the land area) 33. Such land represents zones where beneficiaries of these nonfood provisioning services might choose to offer payments to farmers to take these land parcels out of agricultural production.

If suitable market mechanisms could be established, it is possible that funds from beneficiaries could be targeted at land parcels causing water quality pollution problems (see Section 7.4.1) where these parcels have a high multiple ecosystem service value. These private markets could be used to supplement payments made from Common Agricultural Policy or other public funds thereby producing a significant incentive for landowners to divert land away from agricultural production activities with a high probability of causing pollution problems. The governance and management of these funds would need to be co-ordinated to deliver maximum benefit, with international experience suggesting the â&#x20AC;&#x2DC;neutral broker modelâ&#x20AC;&#x2122; is likely to be the best institutional arrangement for achieving this outcome (see Section 9.1).

Based on the evidence and analysis set out in the previous sections of this report, it is possible to draw the following overarching conclusions and recommendations.

Improved Governance Of The Catchment Management Planning Process Is Required Based on the case study catchment areas selected for this project, it appears significant confusion and disagreement regarding the nature and scale of water quality problems can exist at the catchment level; with current WFD delivery plans demonstrating insufficient detail to enable focussed effort. There is a need to co-ordinate understanding surrounding the state of waterbodies, for uncertainties to be clearly communicated and agreed on, and for solutions and delivery plans to be developed which have a mandate from the farming community, delivery agencies, the water industry and other catchment stakeholders. Clear problem definition will allow development of targeted mitigation solutions. Of utmost importance, trust in the process and in those involved with delivery must be established. To facilitate the development of a co-ordinated catchment plan, information flow between stakeholders must be transparent and accessible, within limits laid out in the Data Protection Act. This requires the development of open access catchment scale data repositories which become the one-stop-shop for all parties involved in the delivery of WFD objectives. Management, coordination and ownership of this facility requires careful consideration by Defra; at this stage it would appear the host organisation model envisaged within the Catchment Approach will be the correct vehicle to deliver such an undertaking. Leading on from this, it is recommended there is a need to clarify the roles and responsibilities of the various parties involved in the delivery of WFD objectives to avoid institutional conflict, encourage efficiency, and ensure the whole is greater than the sum of the individual parts. Given the emergence of an active third sector within the sphere of water resources management in recent years, it is suggested the relationship and dynamics between the third sector and the statutory agencies is reviewed and formalised to ensure all parties are able to realise their full potential.

Transparent, Equitable And Enforceable Regulation Of An Environmental Baseline Is Needed

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10.0 Conclusions And Recommendations

Farmers are currently confused, both about their legal responsibilities and about the enforcement process that accompanies the regulation of environmental compliance matters. Conversely, there also appears to be confusion amongst the regulatory authorities regarding process and application of regulation relevant to the agricultural sector. This is particularly true of the Rural Payments Agency and The Environment Agency over the issue of enforcing the Soil Protection Review within Cross Compliance. The result is a situation where all parties â&#x20AC;&#x201C; farmers, regulatory personnel, conservation groups appear demoralised and often frustrated with the current regulatory process. There is a clear need for this situation to change. The evidence suggests that an unambiguous enforcement process needs to be established and, most importantly, clearly communicated to the agricultural sector. Cross compliance measures should not be increased in number as there are already a myriad of obligations within the GAEC and SMR requirements. What is needed is for the existing requirements to be adhered to and for a process of stepped enforcement (repeat visits) to be implemented to ensure pollution problems are successfully mitigated once identified. Similarly, outside the cross compliance process, EA enforcement procedures also need to be capable of identifying (and mapping) problems on a catchment scale and able to follow through a problem from identification to successful mitigation. Walkover surveys 34 and follow up farm visits offer a route to achieve this. Identification of problems and subsequent constructive liaison with farmers is a highly skilled job which requires technical expertise and practical on-the-ground experience. It is suggested that walkovers are, therefore, undertaken by EA enforcement staff who are able to develop indepth knowledge of their local area and refine the skills necessary to interact with the farming community in a knowledgeable, equitable and informed manner. Given the need for developing clear roles and responsibilities within the catchment management space and given the need to develop specialist skills within EA Enforcement Officer personnel (see Section 6.6), the use of private sector consultants to undertake walkover surveys for the purposes of identifying pollution problems should be reviewed.

Walkover is defined here as an â&#x20AC;&#x2DC;on footâ&#x20AC;&#x2122; visual survey undertaken by Environment Agency staff for the purposes of identifying pollution problems and should be distinguished from bespoke chemical or biological monitoring surveys 34

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Increased resource will be required for the EA to implement walkover and follow up visits but the evidence suggests the costs of doing this will not be orders of magnitude greater than existing resource availability. Focusing attention on particular high risk sections of a given catchment, through the use of modelling tools and local EA knowledge, is an obvious way of reducing the resource load required. Cost efficient enforcement also depends on the development of an appropriate monitoring system capable of pinpointing problems, enabling source apportionment and tracking the efficacy of mitigation measures over time. It is hoped the Defra Test Catchment programme will provide suitable guidance on the best monitoring protocols to meet these objectives.

Investment In Agricultural Extension Is Required The need to apply regulatory enforcement action on a farm business should be regarded as a policy failure. As highlighted in Section 5.0, there is an urgent need to invest in the expansion and skills base of extension providers in England, capable of helping farmers with the technical, business and, in some cases, emotional support they will need to deliver the multifunctional farmed landscape society is increasingly demanding from them. As pointed out in Section 6.2, land is increasingly farmed on a rented basis which has complicated the picture with regard to long-term husbandry of, and investment in, issues such as soil health and farm infrastructure relevant to sustainable land management. Brokers will increasingly be needed to help both landlords and tenants understand their responsibilities pertaining to the resource protection agenda, and develop appropriate solutions whereby both parties share the costs and the benefits of enhanced environmental measures undertaken. There are a large number of extension providers operating at various levels across the farming sector, seemingly with different remits and modes of operation. Not surprisingly, the end customer i.e the farmer, is often receiving different messages regarding what is expected from them; which is leading to confusion and often disillusionment with the environmental agenda. It is crucial, therefore, that all deliverers sing from the same hymn sheet. This will require leadership from Defra to bring the various providers together to agree a common objective and working practices. It is suggested that the Catchment Sensitive Farming initiative should be invested in by government, to provide a highly skilled and credible hub for future extension provision, working with other delivery partners (including the third sector) where these are available, locally accepted and have the requisite skill sets.

Farmers must play a central role in the design and constitution of locally delivered advice to ensure provision is tailored to need. It is recommended the Affiliated Regional Advisory Training Service model (Winter, 1996) originally proposed in the 1990â&#x20AC;&#x2122;s is reviewed by Defra as a possible framework for delivery of integrated advice and training of advisors and is considered within the context of the Defra Integrated Advice Pilot work currently being undertaken. Consideration should also be given to fully integrate CSF, ELS and HLS advice provision within Natural England to avoid the dangers of fragmented advice delivery and encourage a common vision for the delivery of support to the rural landscape. On a broader level, a review of Natural Englandâ&#x20AC;&#x2122;s remit may be required to ensure natural resource protection is fully incorporated within its statutory responsibilities alongside habitat and species (biodiversity) protection.

Financial Support To Deliver Water Resource Protection Needs Reform The evidence from this project suggests the current Environmental Stewardship package of Entry Level and Higher Level schemes is unlikely to deliver WFD objectives unless fundamental reforms are made. Neither scheme is resulting in the sufficient take up of selective buffering, arable reversion and capital investment measures needed to adequately protect watercourses from soil and nutrient run off problems and prevent underlying ecosystem functions from continued degradation. As pointed out in section 8.0, it is possible that targeted Ecological Focus Areas (EFAs) under the proposed greening of the Common Agricultural Policy could deliver the desired outcomes from Pillar I (Single Farm Payment) without the provision of Pillar II agri-environment payments. However, should targeted EFAs not be possible, or where these would not be sufficient within a given catchment, additional payments to farmers will be needed. In this case, it is recommended that the current ELS scheme is fundamentally reshaped to focus payments on targeted resource protection measures. The analysis derived from the case studies for this project suggest an ELS scheme focussed purely on targeted resource protection measures (land use change measures) could deliver required resource protection goals using a proportion of the current ELS budget, releasing the remaining ELS budget to enhance current HLS funds available for focussed delivery of biodiversity, heritage and broader landscape objectives. Where income forgone rules limit the payment levels that can be offered to farmers to adopt bespoke land use change options, additional financial resources should be sought from the private sector through the development of PES markets.

It is recommended that very careful consideration is given to planning how multiple sources of finance, both public and private, might best be managed to deliver optimal land use change and farm capital works investment at the catchment scale. Without effective co-ordination between funding streams, there is a very real danger that resources will not be targeted effectively to deliver optimal outcomes. Worse still, fragmented funding streams might deliver counter productive results. Within the Catchment Approach framework currently being piloted by Defra, it is recommended there is a need to explore the development of a ‘catchment delivery funding mechanism’ capable of pooling multiple funding sources within the context of delivering a single integrated catchment plan. It is understood that the current Catchment Restoration Fund recently established by Defra exists in parallel to the CSF grant pool, the Environmental Stewardship pool, The Nature Improvement Area pool and emerging private sector funding streams developing via the water companies. It is also worth noting that the phasing of the Common Agricultural Policy budget, the Water Framework Directive delivery cycle and the Water Industry Periodic Review process is not synchronised which makes co-ordinated budgeting of catchment planning particularly difficult. All of this points towards a need for the co-ordination of different funding streams to deliver one set of targeted objectives at a catchment scale, set out in a single integrated management plan agreed by all parties.

Need For A Participatory Phosphorus Management Strategy

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As pointed out in Section 7.4, capital investment will be required to solve many of the problems associated with phosphorus and soil run off stemming from compaction of soils, poaching by livestock, river bank degradation etc. Based on an analysis within the three case study catchments for this project, the capital works budget under the CSF programme, if targeted and if continued at current levels, appears to have the potential to deliver many of the needed changes by the end of the second WFD cycle. However, it is very unlikely significant infrastructure improvements such as new slurry stores or cattle housing either can be, or will be, funded under RDP funding streams. As with selective land use change above, it appears, therefore, that private sector money – either as lump sum grants or in the form of low/no interest loans – will be needed to deliver the necessary scale of change required.

As highlighted in Section 3.0, excessive phosphorus loads were regarded as a problem in all three study areas selected for this project and are considered a problem in nearly 50% of all surface waters in England and Wales. Changes with regard to the volume and/or timing of phosphorus applications were considered needed if phosphorus levels in soils are to be reduced to a level that poses low risk to the health of aquatic ecosystems. Water Protection Zone (WPZ) legislation has been put in place (amended in 2009) which has the power to place mandatory restrictions on the volume and timing of phosphorus applications. Findings from the fieldwork for this project suggest, not unsurprisingly, that farmers are hostile to the idea of WPZs, questioning whether they are necessary and whether mandatory measures will work. These are fair enough questions. It is understood that Defra has agreed not to propose the implementation of new measures within WPZs before first a) developing a catchment approach that targets the use of existing regulatory, advice and incentive mechanisms b) determining the efficacy of this approach; and c) assessing whether additional measures are required. This would appear to be a balanced approach in line with the government’s better regulation agenda. However, there has been no clear roadmap and timetable presented to farmers setting out an overarching process for addressing agricultural impact on the water environment; a much needed set of milestones which should be communicated to all stakeholders. A clear plan is required setting out basic compliance measures together with additional incentivised measures that will be available in certain areas – while making it clear that if farmers do not engage with the process, additional regulation will become a necessity. This certainty is needed for farmers to understand what is required of them and to plan effectively for the future. For a process leading up to WPZ designation to have legitimacy, it would need to be underpinned by sound transparent science. Care must be taken to ensure phosphorus monitoring is sufficiently robust to detect changes in phosphorus levels in both soils and watercourses in response to farm management and land use changes. It will also be vital to make sure source apportionment analysis (proportion of P coming from agriculture, septic tanks, sewage treatment works etc) is sufficiently accurate to determine how much agriculture in a given catchment is contributing to total phosphorus loads.

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It is understood that various monitoring and modelling methods (e.g ADAS) are currently being constructed to provide sufficient data to answer these important questions. It is recommended that the final development and use of these tools is undertaken with full involvement and scrutiny from the agricultural community at a national, regional and local scale to facilitate trust in the methods used. Engagement with farmers at a catchment scale must be undertaken on an on-going-basis to design monitoring approaches, analyse data results, assess potential mitigation solutions and evaluate results. This process should be fully embedded within the Catchment Approach envisaged by Defra.

There remains the outstanding question of how farmers needing to invest in farm infrastructure to improve phosphorus management should fund this investment when they may not have adequate financial resources available. As pointed out in Section 7.4, in the absence of sufficient RDP funding, this is a need which could be met from private sector contributions. Failing this, it is likely that farm businesses without sufficient access to investment funds would be forced to leave the industry should mandatory phosphorus limits be applied, a situation which has social and indeed economic consequences for both the farming families themselves and also the rural communities in which they reside.

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Annex A Enforcement Cost Estimates And Assumptions (5 Year Period) Note: Cost estimates designed to provide indicative guidance only. They do not take into account wage inflation and have not been verified by EA Financial Managers

Caudworthy Catchment

Rea Catchment

component B

Lugg Catchment

Notes On Assumptions: Number of farms in catchment: Caudworthy = 22, Rea = 235, Lugg = 879 Length of WFD waterbodies: Caudworthy = 14km, Rea = 67km, Lugg = 452 km Costs (inc 50% overhead) of employing EO = £52,000 (£240/day) Costs of employing support staff (inc 50% overhead) = £31,104 (£140/day) Walkovers wet weather and dry weather (assume 5km/day and 33% of waterbodies covered p.a): Caudworthy = 6 (2) days, Rea = 27 (9) days Lugg = 180 (60) days Initial visit (1st Repeat Visit): assume 33% of farms require visit: Caudworthy = 2 farms/year, Rea = 26 farms/year, Lugg = 97 farms/year Initial visit (1st Repeat Visit): assume each initial visit takes 0.5 days/farm 2nd visit: assume 20% of farms initially visited require revist: Caudworthy = 1 farm/year, Rea = 5 farms/year, Lugg = 19 farms/year 2nd visit: assume each visit takes 0.5 days/farm Warning letter (Issue Code B. Evidence Gather): assume 10% of farms receiving second visit: Caudworthy = 1 farm/year, Rea = 1 farm/year, Lugg = 2 farms/year Warning letter (Issue Code B. Evidence Gather): assume 2 days for EO and 7 days for support staff per farm Issue APWN: assume 7 days for EO, 7 days for support staff and 5 days Legal Support per farm

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Annex B Advice Provision Cost Estimates And Assumptions (5 Year Period) Note: Cost estimates designed to provide indicative guidance only. They do not take into account wage inflation and have not been verified by NE Financial Managers

Caudworthy Catchment

Rea Catchment

Lugg Catchment

Notes On Assumptions: Costs (inc overhead) of employing a CSFO = ÂŁ42,000 (ÂŁ190/day) Farms to be engaged from EA walkovers across 5 years (Caudworthy = 7 farms, Rea = 78 farms, Lugg = 290 Assume 7 days needed with each EA referred farm engaged (inc developing a whole farm plan) Engagement with other farms (non-EA referred) in catchment across 5 years e.g telephone advice (Caudworthy = 15 farms, Rea = 157, Lugg = 589) Assume 1 day needed with each non-EA referred farm 85

component B

References ADAS (2002). Pilot agri-environment scheme targeting in the Chilterns: farmer questionnaire analysis. Report by ADAS Consulting Ltd for English Nature Asquith, N.M., Vargasa, M.T. and Wunder, S. (2008). Selling two environmental services: In-kind payments for bird habitat and watershed protection in Los Negros, Bolivia. Ecological Economics 65, 675-684 Brown, T. C., Brown, D. and Binkely, D. (1993). Laws and programs for controlling non-point source pollution in forest areas. Water Resources Bulletin 29(1): 1-13. Brown, T.C., Bergstrom, J.C. and Loomis, J.B. (2006). RMRS-RWU-4851 Discussion Paper. Ecosystem Goods and Services: Definition, Valuation and Provision Daily, G. C. and Ellison, K. (2002). The new economy of nature: the quest to make conservation profitable. Washington, D. C.: Island Press. Defra (2007). The Protection of Waters Against Pollution from Agriculture. Defra Consultation on diffuse sources in England Falconer, K. (2000). ‘Farm-level constraints on agrienvironment scheme participation: a transactional perspective’, Journal of Rural Studies, 16, pp379 – 394 FAO (1997). Improving agricultural extension: A reference manual Gintis, H., Bowles, S., Boyd, R. and Fehr, E. (2003). Explaining altruistic behavior in humans. Evolution and Human Behaviour 24, 153–172. Hart, K. and Baldock, D. (2011). Greening The CAP: Delivering Environmental Outcomes Through Pillar One. Institute for European Environmental Policy Inman, A. and Cook, H. (2011). Reviewing Vulnerability Assessment And Modelling Tools For Pollutant Source Identification. SAIN Working Paper 4 Jones, J.V.H. (2006). ‘A case based investigation of the financial implications of agri-environment Landell-Mills, N. and Porras, I.T. (2002). Silver Bullet or Fools’ Gold. A Global Review of Markets for Forest Environmental Service and their Impact on the Poor. Report. IIED, London

Moss, J. (1994). ‘A baseline assessment for a new ESA – The case of the Mourne Mountains and Slieve Croob’. In, Whitby, M. Incentives for Countryside Management - The Case of Environmentally Sensitive Areas. CAB International: pp153 - 178 Pagiola, S. (2002). Paying for water services in Central America: learning from Costa Rica. In: Pagiola, S. et al (eds) Selling forest environmental services. Earthscan, pp 37–62 Palin, N., Walker, M. and Couldrick, L. (2011). Mapping Multifunctional Land Important For The Provision Of Ecosystem Services At A Catchment Level. Westcountry Rivers Trust, Cornwall Porras et al. (2008). All that glitters: A review of payments for watershed services in developing countries. Natural Resource Issues No. 11. International Institute for Environment and Development. London, UK Quine, T. A. and Walling, D.E. (1991). Rates of soil erosion on arable fields in Britain: Quantitative data from Caesium 137 measurements. Soil Use and Management 7(4) Rittel, H. and Webber, M. (1973). Dilemmas in a General Theory of Planning. Policy Sci 4:155-169. scheme participation: pre- and post-decoupling’, Journal of Farm Management, 12(7), pp477 – 498 Turner, R. K. and Daily, G.C. (2008). The Ecosystem Services Framework and Natural Capital Conservation. Environ Resource Econ (2008) 39:25–35 Vatn, A. (2010). An institutional analysis of payments for environmental services. Ecological Economics 69 (2010) Wallis, J.R. and Jones, J.V.H (2007). ‘The Financial Impact of the Entry Level Scheme in the uplands – A case study assessment on farms in Teesdale’. Paper delivered to the RICS ROOTS Rural Research Conference 2007 held at RICSHeadquarters, London 17th April 2007 Winter, M. (1995). Networks of Knowledge, Godalming. WWF Winter, M. (1996). The Working of an Affiliated Regional Advisory and Training Service (ARATS) for Environmental Land Management in England. Unpublished Consultancy Report to FWAG and WWF, Exbourne, Devon. (available from the author d.m.winter@ex.ac.uk) Wunder, S., Engel, S. and Pagiola, S. (2008). Taking stock: A comparative analysis of payments for environmental services programs in developed and developing countries. Ecological Economics 65, 834-852

Defra Strategic Evidence and Partnership Project Component A Appendix 1 Demonstrating the use of Local Catchment Evidence to Meet Good Ecological Status in the River Lugg Catchment.

Component A - Appendix 1

Strategic Evidence & Partnership Project

Demonstrating the use of Local Catchment Evidence to Meet Good Ecological Status in the River Lugg Catchment

Component A - Appendix 1

Contents Page Contents Summary 1. Introduction

2 4 5

1.1 The River Lugg catchment description 1.2 Water quality pressures

5 5

2. Assessment of current WFD classification for the River Lugg

2.1 WFD monitoring network 2.2 Chemical monitoring network 2.3 Biological Monitoring network 2.4 Fish classifications 2.5 Invertebrate classifications 2.6 Phosphate classifications

7 7 8 9 11 12

3. Waterbodies selected for additional investigation

4. The Tippets Brook

4.1 Introduction 4.2 Catchment description 4.3 Assessment of waterbody classification 4.3.1 Physico-chemical elements 4.4 Catchment walk-over survey 4.5 Waterbody investigations 4.5.1 Study aim 4.5.2 Chosen investigations 4.5.3 Sampling sites 4.6 Macro-invertebrate survey 4.6.1 Methodology 4.6.2 Results 4.6.3 Discussion 4.7 Electro-fishing survey 4.7.1 Methodology 4.7.2 Results 4.7.3 Discussion 4.8 Diatom survey 4.8.1 Methodology 4.8.2 Results 4.8.3 Discussion 4.9 Conclusion 4.10 Achieving GES in the Tippets Brook- An Holistic Approach 4.10.1 The problem

14 14 15 16 17 18 18 18 19 21 21 22 23 23 23 23 23 23 24 25 26

27 27

Component A - Appendix 1

4.10.2 The holistic approach to land managers 4.10.3 Case studies illustrating the holistic approach 5. The River Lodon 5.1 Introduction 5.2 Catchment description 5.3 Assessment of waterbody classification 5.3.1 Physico-chemical classification 5.3.2 Fish 5.3.3 Invertebrates 5.3.4 Phosphate 5.4 Waterbody investigations 5.4.1 Study aim 5.4.2 Chosen investigations 5.5 Land use mapping and modelling 5.5.1 Land use mapping 5.5.2 SCIMAP to identify diffuse pollution sources 5.6 Catchment walk-over survey 5.6.1 Methodology 5.6.2 Gravel embeddedness survey 5.6.3 Riparian bank erosion 5.6.4 Shading 5.6.5 Barriers to fish migration 5.7 Conclusions 5.8 Achieving GES in the River Lodon 5.8.1 Action undertaken by the Foundation following the WB investigations 5.8.2 Case studies illustrating WUFâ&#x20AC;&#x2122;s holistic approach to tackling agricultural phosphate and sediment sources in the River Lodon References

27 29

32 32 33 33 34 36 36 37 37 37 38 38 39 41 41 41 42 42 42 43 44 44 45 48

Appendix: Table 1: Showing classification and justification of waterbodies selected for desk based study Table 2: Full macro-invertebrate sampling results for all sites in the Tippets Brook Table 3: Full diatom sampling results for the Tippets Brook site 4 (Upstream A4112 Bridge) Table 4: FCS2 Diagnostics River Lodon Table 5: Walk-over survey results for the Lodon catchment

Component A - Appendix 1

Summary In this study the Wye & Usk Foundation (WUF) conducts a systematic review of Water Framework Directive (WFD) classification for waterbodies in the River Lugg catchment, using local knowledge of the catchment to ground truthing in the current waterbody classifications. Following this desk based exercise, the Tippets brook (a waterbody classed as Good (in the absence of biological monitoring) and River Lodon (failing WFD targets with unknown cause) catchments were selected for additional investigation to explore how, with the use of proven methodologies, Rivers Trusts may further inform the WFD assessment process and guide appropriate mitigation measures. The desk based study identified limitations with the current biological monitoring network which is likely to be creating an unrealistically positive picture of the current state of the waterbodies in the catchment. In the absence of appropriate assessment data, increased emphasis needs to be placed on the status of adjacent biological classifications and less on Physico-chemical indicators. The Foundation is concerned by the lack of ambition displayed in the plan, with only one waterbody that is currently failing being predicted to attain ‘good’ status by 2015. The Tippets Brook catchment was selected for additional biological monitoring to test the current WFD classification. Results from invertebrate, diatom and fish sampling indicates the catchment to be suffering from the effects of diffuse agricultural pollution and casts serious doubt over the current classification of ‘good’ status in the absence of biological monitoring. WUF recommend this classification is revisited to ensure targeted mitigation measures can be delivered to reduce the effects of agricultural diffuse pollution and ensure the delivery of WFD targets. Investigations conducted in the River Lodon catchment aimed to attribute a cause to the unknown elemental failures. Utilising results from computer modelling and a catchment walk-over survey, WUF were able to identify agricultural sediment and phosphate as a being a major pressure with additional impacts from barriers to in stream movement of fish populations. Sources and pathways for agricultural phosphate were also identified and likely to be contributing to phosphate failure. Full phosphate apportionment following the extension of the monitoring network is recommended to assess impacts from waste water treatments and industrial sites. To deliver WFD targets in the River Lodon and Tippets Brook catchment, WUF recommends the use of a ‘holistic approach’ to land managers through the use of an integrated combination of advice, incentivisation, compliance and enforcement measures on a sub-catchment scale. This approach was further illustrated through case studies highlighting work completed by the Foundation to tackle sources of agricultural diffuse pollution.

Component A - Appendix 1

1. Introduction 1.1 The River Lugg catchment description: The River Lugg is the major tributary of the River Wye, rising at its upland source in the Radnor Forest, Powys it flows in a south easterly direction, joining with the River Wye near to Mordiford, having drained a total area of 1,077km2. Until the mid’80s the river Lugg was a major part of the Wye Salmon fisheries’ spawning area, with recorded annual redd counts in excess of 1,000. This was brought to an abrupt end with the construction of several barriers to migration – driven by a combination of the demand for agricultural intensification and weak regulation1. Over the last 20 years a wide range of other issues and pressures have been brought to bear on the ecology of the river. In recognition of its wildlife and geomorphological importance the main stem of the River Lugg is designated as a Site of Special Scientific Interest (SSSI), with the river below Hampton Court (the furthest downstream barrier to salmon migration) forming part of the River Wye Special Area of Conservation (SAC) designation.

Figures 1: Left: Position of the River Lugg within the River Wye catchment.

Land use within the catchment compromises mixed arable and livestock production. Grassland and woodland dominate the upper regions and the Bodenham massif with arable cropping increasing through the middle reaches to become the prevailing land use in the lower part of the Lugg. Livestock production is dominated with sheep in the headwaters and cattle in the middle and lower sections of the catchment. Pig and poultry units are also present, with a large number located within the River Arrow and Pinsley brook sub-catchments. 1.2 Water quality pressures: Major pollutants enter the River Lugg through point and diffuse sources. Discharges from agriculture, sewage treatment works, industry and residential sites combine in the watercourse with damaging effects. In 1994, water quality concerns lead to the Lugg being designated as a ‘eutrophic sensitive area’ under the Urban Wastewater Treatment Directive. There are approximately 40 recognised inputs of STW effluent to the River Lugg and its tributaries, and at least an additional 50 inputs from private and trade effluents, notably Cadbury’s large chocolate crumb factory in Marlbrook (figure 2). Environment Agency modelling has attributed 50% of the Lugg’s Phosphate 1

Since the implementation of the Salmon and Fresh Water Fisheries Act in 1975 it is now a requirement that fish passes be constructed to any new or rebuilt impounding structures.

Component A - Appendix 1

loadings to industrial point sources (including STW’s), with phosphate loadings increasing downstream along the length of the catchment.

Figure 2&3: Left: Cadburys factory situated on the Lugg at Marlbrook. Right: Evidence of IDB channel modification in the Lugg catchment. Draining a predominantly rural catchment, many of the Lugg’s water quality pressures can be attributed to agricultural land use pressures. In the lower catchment, the last 10 years has seen a shift from livestock production to highly profitable cash crops including, soft fruit, asparagus and potatoes. These land use changes have had a major impact on water quality through the associated pollution of sediments, nutrients, pesticides and herbicides and high levels of unlicensed abstraction. In an attempt to reduce agricultural pollution, the River Lugg has been a priority catchment for the Defra’s Catchment Sensitive Farming Delivery Initiative since 2007. Large sections of the river have been physically modified through the construction of weirs (>100 in the catchment) and a flood defence by-pass channel in Leominster. In addition, much of the lower catchment comes under the management of River Lugg Internal Drainage Board (IDB). Covering 11,130 ha of land and 176 km of scheduled watercourses, past IDB work has seen many tributaries channelised and cleared with the intention of maximising agricultural productivity and to protect agricultural land from flooding. IDB modifications and clearance have transformed stretches of the Lugg waterbodies from meandering streams with riffles and pools, to straight, uniform depth channels and an artificially low bed height. These channels are over widened and prone to filling in with vegetation so are annually flailed or sprayed resulting in limited bankside vegetation (see figure 3). Figure 4: Current WFD waterbody classification in the River Lugg. 6

Component A - Appendix 1

Classifications for the River Lugg catchment published in the Severn Basin Management Plan (2010) highlight that 71% of Waterbodies (WB’s) are currently failing to meet WFD water quality targets, with 27% of WB’s currently rated as being in bad or poor condition (see figure 4). There is a concerning lack of ambition, with only one WB (Gilwern brook) that is currently failing being predicted to attain GES by 2015. This is one of the WB’s currently failing on fish due to barriers to migration that are in the process of being removed but WUF and EAW. It begs the question why some of the other WB’s potentially able to benefit from this work are not forecast to improve.

2.0 Assessment of current WFD classification for the River Lugg 2.1 WFD monitoring network: The Lugg catchment is divided into 40 individual WB’s, with a total of 150 WFD monitoring sites. Most WB’s are considered as being at an appropriate scale to allow accurate assessment and the effective implementation of remedial measures. However, the delineation of WB 42030 (R Lugg: Conf Norton- conf R Arrow [42030]) shown in figure 5, is of concern as land use undergoes a significant change around this WB’s mid-point. To ensure accuracy in the WFD classification it would be more appropriate to split this WB at the mid-point, into two distinct management units.

Figure 5: WFD monitoring sites in the River Lugg catchment

2.2 Chemical monitoring network: In the Lugg, WFD Physico-chemical element monitoring is comprehensive with 97% of WB’s sampled. The most common Physico-chemical failure is for phosphate, with 30% of WB’s failing WFD Phosphate targets. 42% of these WB’s are also failing targets for dissolved oxygen. The number of WB’s measured for the full suite of chemical pollutants is much more limited, with a full range of polluting substances only monitored in the lower reaches of River Frome, at its confluence with the River Lugg and lower main stem at Mordiford. In-line with extensive published research, the Lugg WB’s often show discrepancies between Physicochemical and ecological elemental results. Only 25% of WB’s displaying ecological parameter failures are also 7

Component A - Appendix 1

failing on chemical parameters. This is indicative of two factors. Firstly, the fluctuations in water quality are often not effectively identified through monthly monitoring and there is also a tendency to sample during dry weather flows, which often negates the true assessment of loadings from storm water and combined sewage outflows. Secondly, many parts of the catchment are suffering from elevated levels of fine sediment which impact severely on the salmonid fish stocks, causing multiple failures for fish. 2.3 Biological Monitoring network: The four principle biological element coverage across the 40 waterbodies in the Lugg Catchment is shown in Table 1. Element

No of WB’s with data

% of WB’s with data

Fish

Inverts

Phytoplankton/ benthos

2.5

Macrophytes

Any biological data

Table 1: Biological monitoring coverage

18 16 14 12 10 8 6 4 2 0 Fish

Phosphate

Inverts

Flow

Phytobenthos

Figure 6: Summary of failing elements in the River Lugg catchment. 23% of WB’s are currently lacking inclusion of biological monitoring in their assessments. Where biological monitoring is absent, the WB status has been estimated based on the classification of adjacent WB’s and Physico-chemical classifications (where available). This is of concern, as there is a notable difference in the rate of attainment of good status for Physico-chemical standards of ammonia, phosphate, pH with those for biological elements (see table 2). It is also noted that the two WB’s rated as bad are currently passing all other Physico-chemical parameters.

Component A - Appendix 1

Biological data (lowest determinant)

35%

Physico-chemical data (lowest determinant)

69%

Table 2: % Attainment of good status for WBâ&#x20AC;&#x2122;s in the River Lugg Of particular concern to WUF is the classification of the Tippets brook as at GES in the absence of biological monitoring data, WUF and EA surveys have identified the WB as being heavily impacted by agricultural diffuse pollution and channel modifications (see section 3.0).

100 90 80 70 60

(1)

(22)

40 30 20

(22)

10 0

Phytobenthos

Fish

Invertebrates

Figure 7: % failures for biological elements, (including total sample size)

2.4 Fish classifications: Fish monitoring is an effective indictor of WB health, most sensitive to the effects of morphology, barriers to migration and sediment. In the Lugg catchment 55% of WB classifications contain fish monitoring results. Fish are responsible for the largest number of WB failures (figure 6) and in total accounting for 70% of all the biological element failures (figure 7) Note that this is in the absence of comprehensive phytobenthos monitoring which we anticipate to incur an even higher failure rate. Figure 8 shows current fish classifications in the River Lugg catchment; the map highlights a trend between fish failures, and decreasing water quality along the length of the catchment. Other monitored elements do not display a similar trend, which could further indicate the sensitivity of fish to subtle changes in water quality and habitat often missed with monthly chemical and invertebrate monitoring. Several WBâ&#x20AC;&#x2122;s draining the Western flank of the Leominster flood plain are not currently assessed for fish. Temporary cropping, including large amounts of winter cereals and contract potato production dominate this area, associated high risk soil management practises on the light, friable soils has lead to high levels of soil erosion. IDB modifications have also reduced the streams natural ability to buffer pollutants and as such, salmonid spawning and nursery habitats in these reaches are inundated by high levels of fine sediment. It is WUFs opinion that most of these WBâ&#x20AC;&#x2122;s are also failing to meet WFD fish targets. 9

Component A - Appendix 1

Figure 8: Fish WFD classification in the River Lugg (Source EA, 2011) The EA’s Fish Classification Scheme assesses the status of a waterbody by comparing the number of species found with what would be expected to have been found in a similar pristine location. A WB displaying an anomaly in its FCS classification is the R. Arrow (source to conf. Gladestry brook). Situated in the upper catchment, with relatively pristine habitats we would expect to see very healthy populations of brown trout and salmon. However, this is not the case due to the presence of a series of sizeable weirs along the Arrow catchment, which were acting as a barrier to fish migration at the time of classification. The likely error in the FCS classification is as a result of the samples being used co-inciding with a period when salmon were artificially stocked in the catchment, a practice now discontinued and does not reflect the true natural populations of fish. In contrast, there are cases where streams are known to be supporting healthy population of fish, but are currently classified as failing. One such example is the Pinsley Brook, a small tributary that joins the Lugg north of Leominster. The Pinsley displays many characteristics of a Southern chalk stream and contains a healthy population of brown trout and an increasing population of salmon following the removal of a barrier in its lowest reaches. WUF habitat work has further improved the stream, and as such we are confident that the waterbody is now meeting WFD targets for fish. Another WB likely to be showing an overly negative classification is the Hindwell brook (conf. Knobley Bk to conf. R Lugg). The site is classified as poor for fish, and not predicted to reach GES until 2027 with justification detailed as ‘disproportionately expensiveknown physical barrier to fish migration’. Over the past 4 years WUF and EAW have been progressively working on the weirs downstream and this year completed the construction of two fish passes on the final impassable weirs located in the middle of this WB. As a result, the WB is more accessible to migratory fish. Salmon were first recorded in 2009 and populations have increased in our 2011 survey. We expect this WB to be demonstrating GES for fish by 2015. Justification for non-attainment of GS for fish is summarised in figure 9. ‘Disproportionately expensiveknown physical barrier to fish migration’, is the most prevalent justification for non attainment of GES for fish. In the last 5 years WUF in partnership with EA has completed 33 fish passes on impassable weirs in the Lugg catchment, opening an additional 224 km of juvenile habitat. This highlights the important role Rivers Trust can play in directly influencing WFD classifications, especially where mitigation measures are deemed to be infeasible or too expensive.

Component A - Appendix 1

Technically infeasible (S2b)

Technically infeasible ( S3b)

Technically infeasible (B2a)

Disproportionately expensive (M5a)

Disproportionately expensive (B1a), 0

Figure 9: Summary of WB fish failures 2.5 Invertebrate classifications Freshwater invertebrate families vary in their sensitivity to pollution; their relative abundance can be used as a good indicator of water quality, displaying greatest sensitivity to organic enrichment and pesticides. 43% of sites have been monitored for invertebrates. In total invertebrates are responsible for 25% of all biological elemental failures. 66% of WBâ&#x20AC;&#x2122;S meeting WFD targets for invertebrates are failing on fish, which reflects the fish access problems at point of classification (2002) and elevated sediment loadings. WFD Invert classifications do not always conform to other elemental classifications, for example 4 WBâ&#x20AC;&#x2122;s passing on invertebrates are failing to meet phosphate standards. This is likely to be a consequence of infrequent sampling, or the method of assessment which does not take into account the relative abundance of taxon species and is less likely to detect the effects of chronic, low level diffuse pollution.

Figure 10: Invertebrate WFD classification in the River Lugg (Source EA 2011)

Component A - Appendix 1

2.6 Phosphate classifications Phosphate (P) monitoring is comprehensive with all but one WB monitored. Of all the river WB’s assessed as failing to meet good ecological status, the failure of the phosphate quality element accounted for 38%. 80% of these are classified as moderately failing; these sites could represent ‘quick wins’, with the implementation of targeted remedial measures it would not be a massive leap to bring these sites up to GS for Phosphate by 2015. However lack of ambition is again of concern, all sites showing single elemental failures for phosphate are not predicted to reach GS by 2015.

Stretford WB’s

Figure 11: WFD Phosphate classification in the River Lugg, and the location of major sewage treatment works and the Stretford Brook sub-catchment (Source EA 2011) Of notable concern to WUF are the phosphate classifications in the Stretford sub-catchments (shown in figure 11), both WB’s are failing for phosphate with the upper WB rated as poor and the lower WB as moderate. The catchment contains the highest mean concentrations of total P in the whole of the Lugg catchment, with orthophosphate levels regularly exceeding 0.5mg/l in the upper catchment. The P failure can be attributed to outflow from a STW situated in the town of Weobley, one of the 5 largest STWs in the Lugg catchment it is designed to serve a population of 2935. The outflow from the STW discharges into the upper Stretford catchment. The STW has no provision for phosphate stripping, which is concerning, considering the population size and the proportionate loading of P entering the catchment where it is less than a metre in width. Action to install additional P treatment to the site could have a major impact on P levels in the Stretford WB’s; however, disappointingly, no remedial action is planned during this WFD planning cycle as action is deemed, ‘disproportionately expensive- total phosphate unknown’. 12

Figure 12: Weobley STW outflow into the upper Stretford waterbody

Component A - Appendix 1

3.0 Waterbodies selected for additional investigation: During the process of determining which WB’s would be the focus of more detailed desk based study and additional investigation, WUF’s main objective was to choose WB’s where confidence in the current classification was low, or where additional investigations had the potential to identify appropriate mitigation measures to raise current WFD ambition. The process involved a systematic review of all WFD classifications in the River Lugg using the WB data sheets contained in Annex B of the Severn Basin Plan and knowledge of the catchment to produce a shortlist of suitable WB’s for additional investigation. Shortlisted WB’s and reasons for selection are provided in table 1 of the appendix. To allow a desk based study to be completed full WFD chemical and biological datasets were requested from the Environment Agency on the 12th January 2011. Using established contacts in the local EA area office, our request was handled very timely. Physico-chemical datasets were supplied 26 days after the initial request and provided in a very user friendly format, with a separate worksheet for each waterbody and overall summary work sheet. Our request for ecological data went through a more convoluted chain of people, but once with the right person, the request was dealt with efficiently. The team leader for the local biological monitoring department requested a meeting so she could fully understand our requirements and project objectives. The meeting took place on the 10th February and the data was submitted on the 14th February, 33 days after the initial request was submitted, again in a very helpful format. After more detailed analysis of this data, the Tippets brook and River Lodon were the WB’s selected for additional investigation. Occupying different areas of the catchment, both presented a different set of issues and opportunities for investigation. The location of the selected WB’s is highlighted in figure 13, full waterbody descriptions, methodologies and results are provided in the following sections.

Figure 13: Showing the location of the Tippets Brook and River Lodon WB’s 13

Component A - Appendix 1

4. The Tippets Brook: 4.1 Introduction: The assessment of WB classifications in the Lugg catchment has highlighted just how significant the biological monitoring parameters are in determining waterbody health, bringing into sharp focus waterbodies that are passing simply because ecological health has not been assessed. The WFD also makes it clear that Member States must apply the necessary measures to prevent deterioration in the condition of surface WB’s. With public funding of remedial measures focused at failing WB’s, it is imperative that classifications are accurate and based on a broad set of both chemical and biological indicators. A WB classification of notable concern to the Foundation was the Tippets Brook, where known watercourse pressures have resulted in a serious lack of confidence in the current classification. The Foundation selected this watercourse for additional biological investigations to ground truth the current classification and highlight where additional remedial measures may be required to prevent ‘deterioration’ when WFD biological monitoring is extended. WUF also query the approach which necessitates a WFD ‘downgrade’, solely on the basis of additional monitoring information. This reflex response provides a skew in the real picture of water quality trends.

Figure 14&15: Left: View of the Tippets brook, showing evidence of IDB modification. Right: Tippets brook in spate conditions.

4.2 Catchment description: The Tippets Brook is a tributary of the River Arrow, rising from a spring in Broxwood, crossing approximately 11km of agricultural land before joining the Stretford Brook. Synonymous with other WB’s draining Leominster’s highly fertile western flood plains; the catchment is dominated by a mixture of temporary pasture and arable cropping with large amounts of winter cereal and contract potato production. The middle and lower reaches of the brook comes under the management of IDB - the resultant heavy modification to maintain land drainage has lead to significant habitat degradation, with large sections of the catchment displaying uniform channel morphology, artificially low bed height and limited bankside vegetation (figure 14). In spate flows the stream transports large volumes of sediment and associated nutrients (see figure 15). Soil types along the catchment are predominately fertile clay loams prone to impeded drainage which increases the risk of water logging and compaction. 14

Component A - Appendix 1

4.3 Assessment of waterbody classification: The WFD assessment currently rates the Tippets Brook as good, in the absence of biological monitoring data (see table 3). The classification comprises water chemistry samples taken by the Environment Agency between 2006-2008, at a single monitoring point located at the confluence with the Stretford Brook. Table 4 shows frequency in WFD Physico-chemical monitoring. The majority of sampling is conducted on a monthly basis in dry conditions, although there are notable gaps. In total, the WFD classification compromises approximately 36 collected water samples, giving 499 individual chemical measurements.

Table 3: Summarised WFD Classification for the Tippets Brook Overall Status Good

Biological data Phys-chemical elements

Current status

Absent

High Good High Good High High High High Supports good Supports good

Ammonia (phys-chemical) Dissolved Oxygen pH Phosphate Temperature Copper Zinc Ammonia (Annex 8) Quantity and dynamics of flow Morphology

Table 4: Frequency of WFD water sampling of the Tippets Brook with weather conditions where available (right of grey column indicates data collected post WFD classification). Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

2006 • • (D) • (D) • • • •• (*/D) • •• (D/*) • (HR)

2007 • • (D) •• (D/*) • •(D) • •• • (D) • (OC) •

2008 • (OC) •• (OC/D) • (OC) • (D)

2009 • (D) • (D)

2010 • (D) •• (D/D) • (D)

• (D) • • •• •• (*/D)

• (D) •• (D/D) •• (R/D) • (F)

Key: D= Dry OC= Overcast R= Rain HR= Heavy rainfall F= Frost

Component A - Appendix 1

4.3.1 Physico-chemical elements: The Tippets Brook is currently passing on all Physico-chemical elements. Summarised results for the period 2006-mid 2010 are provided in table 3, and show that all elements are rated as high, with the exception of phosphate and BOD which are both achieving good status. Nearly all samples were collected during dry conditions, as discussed earlier in the report this may negate the effects of fluctuations in P levels, likely to occur during storm flows. The validity of single-point measurements in describing the full catchment also gives some concern when the impact on loading may be temporally and spatially more transient. Table 5: Mean levels of Physico-chemical elements (including standard deviation and WFD classification boundary standards). Mean

Std Dev

WFD High Std

WFD Good std

WFD Mod std

WFD poor std

0.04531

0.0505

0.3

0.6

1.1

2.5

1.79

1.07

6.5

88.98

15.07

pH lower Phosphate (mg/l)

7.909

0.209

4.7

4.2

0.097

0.0616

0.05

0.12

0.25

pH upper

7.909

0.209

100

Temperature (:c)

9.24

3.92

Element Ammonia (mg/l) BOD (mg/l) DO (% saturation)

Figure 16: Orthophosphate and dissolved oxygen levels in the Tippets Brook

Orthophosphate phosphorus concentration (mg/l)

0.3 0.25 0.2 0.15 0.1 0.05 0

Dissolved Oxygen (% saturation)

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 120 100 80 60 40 20 0

16 Jan Feb Mar Apr May Jun

Jul Aug Sep Oct Nov Dec

Component A - Appendix 1

4.4 Catchment walk-over survey: In 2006, a walk-over survey completed by the Foundation, highlighted the Tippets Brook as being in particularly poor condition with large areas of the catchment heavily modified and suffering from the impacts of sediment and nutrient run-off from arable cropping and uncontrolled livestock access. In addition, point source pollution from two farms, a cider and a crisp factory was also detected. The farm pollutions were corrected by WUF in 2009 and 2011, and both companies prosecuted by the Environment Agency (figure 17&18). These findings were supported by an APEM sediment tracing survey, conducted in the River Lugg catchment in 2010. The survey highlights the Tippets Brook as being in particularly poor condition, with the largest number of Grade 1 Sediment Sources in the Lugg catchment (see figure 21), with the majority of substrate found to be covered by fine sediment and deleterious algal growth despite the correction of the identified point source pollutions (APEM, 2010).

Figure 17&18: Pollution from a crisp and cider factory identified during WUF walk over survey of the Tippets Brook

Figure 19&20: Examples of agricultural diffuse pollution and habitat destruction in the Tippets Brook catchment

Component A - Appendix 1

Figure 21: Map showing the location of fine sediment sources identified during an APEM river walkover survey completed in 2010.

4.5 Waterbody investigations: 4.5.1 Study aim: The following investigations were selected to test the current WFD classification, through the assessment of biological health. Utilising the Foundationâ&#x20AC;&#x2122;s understanding of known pressures affecting the catchment the study will identify targeted mitigation measures to ensure that the WB meets WFD biological targets. In addition, following the 2006, walk-over survey, the Foundation has completed over 1.98km of watercourse fencing work in the middle catchment (at site 2 shown in figure 22). The study also aims to quantify the effectiveness of these actions though an assessment of biological parameters and comparison with unimproved areas of the catchment. 4.5.2 Chosen investigations: Marco-invert sampling Semi quantitative electro-fishing surveys Diatom survey

Component A - Appendix 1

4.5.3 Sampling sites: Waterbody investigations were conducted on all, or at a selection of the following sites within the Tippets Brook. Located in upper, middle and lower regions of the catchment, the sites were chosen as representative of typical habitat characteristics in the locality. Site 1- Dovecote: Representing the Upper catchment the stream here is around 1m in width, flows over gravel with a well established pool riffle sequence and large amounts of woody debris in the channel. It is outside the control of the Internal Drainage Board Site 2- Downstream of Bridge in Luntley: This is the section where WUF has excluded livestock. Under the control of the IDB but as part of their BAP plan and agreed with WUF they have agreed to cease managing this section as an experiment. Three of the pollution sources that have been corrected are upstream of this site. Site 3- Bidney Farm: Representing the catchment in its mid-section, the sampling site is located downstream of Bidney farm and transects a large arable field. The channel displays the effects of extensive channel modifications, with an artificial bed depth and minimal bankside vegetation. Flow is uniform and slow, with sediment the dominant bed substrate. Site 4- Upstream A4112 Bridge: A slow flowing section of the Tippets Brook situated upstream of the A4112 Bridge. Substrate is inundated with high levels of fine sediment. Surrounding land is in temporary grassland. This site represents the catchment in its mid-lower region. Site 5- Tyrrellâ&#x20AC;&#x2122;s Court: Situated in the lower reaches of the catchment, the sampling site is located downstream of the Tyrrellâ&#x20AC;&#x2122;s crisp factory where the stream runs along the edge of an arable field. The channel is heavily modified and also displaying an artificial bed depth with minimal bankside vegetation. Flow regimes are more diverse with stretches of riffles and glides, gravels are present but with heavily embedded fine sediment).

Figure 22: Location of sampling sites in the Tippetâ&#x20AC;&#x2122;s brook

Site 4: Upstream A4112 Bridge

Component A - Appendix 1

4.6 Macro-invertebrate survey: 4.6.1 Methodology: Macro-invertebrate sampling was completed at all of the monitoring sites, excluding site 4. The sampling procedure was compliant with the Environment Agency's operational instruction manual produced in 2008 (Technical reference material: freshwater macro-invertebrate sampling in rivers). A one minute manual search was initially carried out at each site, followed by kick sampling using the three minute, pond, net sampling method. The net used was a standard 1mm mesh sampling net. The kick sampling technique involves disturbing the substrate by foot and capturing any displaced invertebrates as they drift downstream with the flow into the sampling net. All available habitat types at each site were sampled proportionately and for a total time of three minutes. Collected samples were placed into a container and then preserved using IMS (industrial methylated spirits). All samples were first examined on the bank side for dead invertebrates. The physical characteristics of each site, including depth, substrate and flow type, a subjective assessment of turbidity and any other relevant observations were recorded. Estimates of algae and macrophyte cover were also recorded. At a later date, the samples were sieved using a 500-micron sieve and placed into a sorting tray. Where possible, macro-invertebrates were identified to species level with the exception of Oligochaeta which were identified to class, and Simuliidae, Sphaeridae and Chironomidae which were identified to family level. Factors making it impossible to identify other macro-invertebrates to species level include size or crucial identification features missing. The families present in a sample contribute to the derivation of a biological (BMWP) score for each site. This scoring system was developed as a way of assessing the biological quality of rivers and streams. The method assigns a score to each taxon ranging from 1 to 10 depending on their capacity to tolerate pollution. Those most tolerant to pollution have a low score, whilst those least tolerant have a high score. The sum of the taxa scores from a sample is the Biological Monitoring Working Party (BMWP) score. The BMWP score, and ASPT (average score per taxon) were calculated for each sample.

Figure 23: Macro-invertebrate sampling at Bidney Farm (Site 3).

Component A - Appendix 1

4.6.2 Results: Table 2 of the appendix shows the number of each species of macro-invertebrate recorded in each sample. Where a species was very abundant, the total number was estimated. Table 6 shows summarised macro-invertebrate results for each site. Populations of invertebrates sampled in the upstream sites are indicative of very good water quality. The sites display a good range of species, with high numbers of total individuals present. Results for Tyrrellâ&#x20AC;&#x2122;s Court display good water quality, with a good range of invertebrates found to be present. But considering the diversity of habitat at the sampling site, a higher score was anticipated. Macro-invertebrates sampled at Bidney Farm scored almost the same as the Tyrrell's site, but contained the least diverse range of species and overall total populations. Based on the BMWP scores of 157 and 160 at the upstream sampling sites, the Bidney and Tyrrellâ&#x20AC;&#x2122;s sites have the potential for higher macro-invertebrate diversity. Table 6: Summarised macro-invertebrate sampling results (full results are provided in Table 2 of the appendix). BMWP TAXA ASPT

Site 1 157 26 6.04

Site 2 160 28 5.71

Site 3 106 21 5.04

Site 4 111 22 5.04

Figure 24: Vaucheria algae at the Bidney Farm site indicating enrichment at the site.

Figure 25: Silt and algae stream substrate at Bidney Farm providing poor fish habitat.

Component A - Appendix 1

4.6.3 Discussion: Macro-invertebrate levels were indicative of good water quality, and support previous efforts by WUF and EA to correct the known point pollutions. A particularly diverse range of species was identified in the upper catchment. The site where habitat restoration work has been completed scored the highest in terms of BMWP and total number of TAXA, indicating the beneficial impact of the habitat work in providing improved conditions for macro-invertebrates. The results obtained in the two sites in the upper catchment would suggest that the lower sites also have the capacity to support increased macro-invertebrate populations, which may currently be restricted as a result of reduced habitat diversity and water quality. Vaucheria algal identified during the biological sampling at Bidney farm indicates that this section of the watercourse is suffering from nutrient enrichment. It would be of interest to know whether this would have resulted in WFD water chemistry failure, had sampling been conducted in this region.

4.7 Electro-fishing survey: 4.7.1 Methodology: Electro-fishing surveys were conducted in September 2011, to obtain a representative sample of the fish assemblage at Site 1 and Site 4. The sites were sampled using a single pass, semi-quantitative method over a 50m length. Two trained operatives were required to complete the survey, one responsible for operating the battery powered back pack equipment and the second netting fish into a bucket. After the survey was completed the fish were recorded and returned along the length of the survey area. The survey assessments conformed to EA and WFD protocol and could potentially be used in the WFD classification of the Tippets brook. 4.7.2 Results: Results from the survey are shown in table 7. In total six species were identified at Site 2 and two species identified at Site 4. With the absence of trout at either of the sampling sites, the WB would not be meeting WFD targets for fish. Table 7: Summary of electro-fishing surveys conducted in the Tippets brook. Site 2: 68m2 fished Site 4: 130m2 fished Species Number Species Number Roach 1 Bull head 10-50 Eel 2 Minnow 5 Bull head 10-100 Minnow 10-100 Stoneloach 10-100 Stickleback 10-100

4.7.3 Discussion: In the absence of salmonids at either sampling sites, the Tippets Brook is highly unlikely to be meeting WFD targets for fish with the population in the lower reaches being particularly impoverished. Results for both sites were disappointing, but the greater diversity in species

Component A - Appendix 1

observed at Site 2 could be indicative of the more favourable habitat conditions as a result of WUF habitat restoration works. To substantiate these results, additional monitoring is recommended. The failure of the Tippets Brook to support a healthy fish population is attributed to the limited availability of suitable in-stream habitats, as a result of extensive channel modifications and agricultural diffuse pollution, causing elevated levels of in-stream sediment and nutrients.

Figure 26: Semi-quantative electro-fish survey at Tyrrellâ&#x20AC;&#x2122;s Court, using battery powered back pack equipment.

4.8 Diatom survey: 4.8.1 Methodology: Diatoms samples were collected and analysed By Ingrid JĂźttner, National Museum of Wales on the 16th September 2011 at Site 4. Sampling conformed to WFD sampling protocol with full implementation of the UKTAG Diatom Assessment for River Ecological Status (DARES) method statement. A sample of the thick biofilm (algae bloom) which covered the fine sediment and silted stones was removed using a thin wooden stick. The sample was preserved in ethanol and processed using standard methods (hot hydrogen peroxide oxidation) and mounted in Naphrax (Krammer & LangeBertalot, 1986-1991). Diatoms were identified and a minimum of 500 valves counted at x1000 magnification using a Nikon Eclipse E600 microscope equipped with differential interference contrast (DIC). The relative abundances of species were calculated. Identifications were based on Krammer & Lange-Bertalot (1986-1991), Krammer (1997a, b, 2002), Reichardt (1999) and LangeBertalot (2001). To assess the ecological status of the site a recently revised and new metrics for rivers were calculated. They included the Trophic Diatom Index (TDI) and Ecological Quality Ratios (EQR),

Component A - Appendix 1

methods developed to monitor trophic status and ecological status in U.K. rivers (Kelly et al., 2007, 2008; DARLEQ - Diatom Assessment of River and Lake Environmental Quality). EQRs were calculated to assess the deviation of diatom assemblages from reference conditions and to determine ecological status classes as defined by the WFD (Council of the European Communities, 2000; Kelly et al., 2007). Uncertainty analysis to assess the risk of misclassification was performed on DARLEQ following Ellis & Adriaenssens (2006).

Figure 27: Showing bed substrate at the diatom sampling location.

4.8.2 Results: Summarised results from the diatom survey at site 4 are shown in table 8. Full species counts and % relative abundance are provided in table 3 of the appendix. Ecological quality ratio (EQR) indicates by how much the diatom assemblage found differs from the assemblage one would expect in this particular type of river if it was not subject to anthropogenic pressures. The sample taken at the Tippets Brook scored a EQR of 0.44, a small value (range 0-1) indicates a large difference, and implies a strong impact. Based on the EQR results the sample indictaes a Poor status under the WFD diatom classification scheme. Trophic diatom index score (TDI) can also be used as an indication of the impacts of elevated nutrients, higher values of the TDI (max. 100) indicate higher trophic status, with a TDI of 73.39 the Tippets Brook diatom assembledge is showing the effects of nutrient enrichment. 12% of the diatom assambledge was compromised of motile diatoms which are more common in streams with fine sediment as the dominant substratum. Less than 3% of the sample compromised of diatom species tollerant to the effects of organic pollution.

Component A - Appendix 1

Table 8: Summarised diatom sampling results (full results are provided in Table 3 of the appendix). TDI eTDI EQR Class CoC poor CoC moderate CoC bad CoCMPB RoM>G/M % Motile % Organic tolerant

Trophic diatom index score Expected TDI score Ecological quality ratio Ecological status class based on EQR Confidence that site belongs to class 'poor'

73.39 40.15 0.44 Poor 72.83

Confidence that site belongs to class 'moderate' Confidence that site belongs to class 'bad' Confidence that the site is moderate or worse class Risk of misclassification above the good/moderate boundary Percentage of motile diatoms

24.24 2.89 99.97

Percentage of organic pollution tolerant diatoms

27.17 11.51 2.37

4.8.3 Discussion: Results from the diatom sampling at site 4, show the Tippets Brook to be failing WFD diatom targets. The results indicate, with high confidence that the site is currently meeting Poor WFD ecological status criteria for diatoms and impacted by nutrient enrichment and elevated levels of fine sediment. With only one sample completed it is important to remember that nutrient concentrations measured in the water are subject to potentially large and rapid variations, diatoms indicate average conditions over a few weeks, nutrients can be taken up very quickly by primary producers (algae, macrophytes) and lead to algae blooms such as observed at Tippet Brook. To further substantiate these results additional monitoring is recommended.

Component A - Appendix 1

4.9 Conclusion: Accepting the limited nature of this study the Tippets Brook is not considered by WUF to be in a good ecological status and therefore should not be regarded as WFD target- compliant. The current system of classification which provides an automatic downgrade to failing status on the accumulation of adverse biological data is potentially unhelpful. Full use of all data sources at the incept should beneficially inform the classification process. The results suggest that fish and invertebrate health is greatest in the upper sites and declines markedly in the lower and middle reaches. There is an indication that fencing at Luntley Farm may have a beneficial impact on macroinvertebrates and fish. It would be useful to revisit the sampling points in order to achieve greater confidence in these results.

4.10 Achieve GES in the Tippets Brook- An Holistic Approach: 4.10.1 The problem: Although important, habitat restoration alone is insufficient to address all the issues identified in the Tippets Brook, the shift in farming in this area from pastoral to intensive arable cropping provides greater challenges. Nutrient and sediment levels in the Tippets Brook are more frequently a consequence of soil and fertiliser management under intensive cropping in the vicinity of the brook. A secondary issue in this area is the presence of intensive livestock systems and organic nutrient loss from hard surfaces and waterlogged fields. Pathways of transport and connectivity are not simple and require a level of investigation to establish risk. In addition, historic channel modification reduces the ability of the Tippets Brook to self remedy. 4.10.2 The Holistic approach to land managers: Awareness in this farming community of the problems has been raised over recent years and we are now at the stage where actions need to be influenced. Risky soil management under increasingly unpredictable climatic scenarios needs to be addressed. Nutrient management and pesticide planning needs to be strategic and safe. Infrastructural provision for housed livestock needs to keep pace with intensification. These aspirations can be best met through an integrated combination of measures ranging through advice, incentive, compliance and enforcement and WUF can make significant contribution to the first three of these at this local level:-

Component A - Appendix 1

Advice provision: This can be provided directly or achieved through signposting to relevant sources of sound soil, nutrient, pesticide and buildings advice. Rivers Trust staff, with detailed local knowledge have a good track record in targeting this advice to maximum benefit, whether or not advice is supplied internally. Incentivisation: Incentives and support for improved land management can provide major benefit as long as these measures are targeted to appropriate recipients. They provide maximum benefit where strategically applied to known problem areas. This need for local knowledge and familiarity with frequently complex pollution pathways and connectivity is best met from strong local knowledge. Again Rivers Trust Staff are well placed to ensure maximum environmental return for investment and can play a significant role in both administration of and signposting of existing and novel funding streams. The most severe pollution found in the walk over survey was corrected this way. Compliance & Enforcement: Whilst working with the Tippetts Brook Land Managers, the maintenance of trust is vital. Farmers need to recognise the confidentiality and impartiality of advice given if they are to remain receptive to diffuse pollution ambitions. However the raft of compliance measures required from EU support mechanisms provide useful tools in reducing diffuse pollution. It is our belief that increased enforcement by the Environment Agency and RPA would significantly increase the uptake of advice, and build confidence with the great majority of compliant farmers. WUF recommend full use of all the levers as identified above to bring about satisfactory reduction in diffuse pollution and achievement of WFD targets in the Tippets Brook.

Component A - Appendix 1

4.10.3 Case studies illustrating the holistic approach: The following case studies highlight work that has been completed by the Foundation under its successful Lugg and River Arrow (LARA) Project, which has restored biodiversity, species richness and variety in rivers within 10 miles of Leominster. Focussing on fish, the 3-year project is funded by the SITA Trustâ&#x20AC;&#x2122;s Enriching Nature Programme and completed in September this year.

Case Study 1: Large Livestock unit in the Tippets Brook catchment: During the 2006 walk-over survey, WUF identified a large section of the upper catchment as being seriously impacted by uncontrolled livestock access. The land manager was contacted and agreed to an advisory visit from the Foundationâ&#x20AC;&#x2122;s catchment officer. The farmer recognised that the current management was unsatisfactory, but regarded the required investment in watercourse fencing as being of little benefit to his business. Incentivised by the offer of WUF grant aid, 2km of watercourse fencing was erected, with the provision of designated livestock drinking bays. Before and after photos are shown below, highlight the benefit of this targeted action. Bankside vegetation has re-established reducing erosion and providing additional instream cover for fish and invertebrates.

Livestock poaching was not the only source of watercourse pollution on the farm. During the visit the officer also identified a source of nutrient rich run-off, from a fouled yard. The absence of roof guttering and down pipes was significantly increasing the volumes of nutrient-charged run-off across the yard. With WUF grant aid, replacement guttering and downpipes were installed, significantly reducing leachate from this site.

Component A - Appendix 1

Case study 2: Catchment officer advice: Large arable farm in the Tippets Brook catchment In November 2010, WUFâ&#x20AC;&#x2122;s Catchment officer visited a large arable farm in the Tippets catchment. In addition to the management over 500ha of intensive arable land, the farmer also operates as the catchments main contract sprayer. During the catchment officerâ&#x20AC;&#x2122;s visit, the farmer was offered practical and economically sound advice, covering all aspects of soil, nutrient and infrastructure management. Of particular concern to the officer was the location of the farms pesticide filling area. Wash- off from the hard surface area was at risk of reaching a drainage ditch located less than 10m away. The officer highlighted the risk of watercourse pollution and the risk of penalties if a pollution incident was identified. The farmer agreed that this was unsatisfactory, and took up the offer of grant aid for the construction of a covered filling area with linked bio-bed treatment system. Utilising links with the local CSF officer WUF were also able to provide the farmer with a free advisory visit from a bio-bed expert, who produced a detailed site specific report advising on the bio-bed construction. The construction of the bed was then part funded by a wider WUF biodiversity project running in the area.

Component A - Appendix 1

4.10.4 In-channel restoration measures: In addition to tackling sources of diffuse agricultural pollution, actions are also needed to ameliorate the effects of extensive channel modification of the Tippets Brook in its middle and lower reaches. The following cases studies highlight suitable remedial measures applied by WUF to other parts of the Lugg catchment: Case Study 3: Check weirs in the Wellington Brook The Wellington Brook, which flows into the river Lugg near the Herefordshire village of Marden, was once an important spawning stream for fish species such as salmon and trout. As with the Tippets Brook, years of heavy modification, including the dredging of gravels to improve land drainage has drastically reduced its ability to support fish species and other wildlife. Following approval from the Lugg IDB, the Foundation created areas of riffles using check weirs, backfilled with alluvial gravel to increase flows and provide suitable spawning sites to maximise egg survival. Tarmac supplied the machinery and gravel with WUF contributing other materials, staff and environmental expertise.

Component A - Appendix 1

5. The River Lodon 5.1 Introduction: WUF is concerned by the lack of ambition displayed in the current classification of failing WBâ&#x20AC;&#x2122;s in the Lugg Catchment. Where causes of failure have been identified, often the sources or extent of the problem are unknown leading to the prescription of broad and extensive remedial measures, resulting in low ambition for WB improvement. This is often a consequence of WB assessments being remote from local knowledge or investigations. A WB demonstrating distinct lack of ambition as a result of unidentified causes of elemental failure is the River Lodon which is currently failing on fish and phosphate and not predicted to meet WFD targets until 2027. The Foundation selected this watercourse for additional investigations to identify the causes of the elemental failures and using case studies, highlight how targeted remedial measures can be used to raise ambition in the current WB classification. 5.2 Catchment description: The River Lodon is located in the eastern Lugg catchment, rising from woodland in Grendon Bishop it transects approximately 18km of agricultural land before joining the River Frome. The character of the Lodon catchment varies considerable between the upper and lower reaches. The upper Lodon cuts through a sloping valley, the river is reasonably fast flowing with series of deep pool and riffles, and should provide an ideal habitat for brown trout and salmon. Uncoppiced alders line much of the banks, causing dark tunnelling of long sections of the river channel. Higher grain prices have lead to an increase in temporary cropping on sloping land that would have historically been permanent pasture. As the gradient declines below Stoke Lacy, and through the Lodonâ&#x20AC;&#x2122;s lower reaches, the river slows and has a more uniform depth and flow rate with increased levels of silt accumulating in the bed substrate. Banks are steep and increasingly vulnerable to erosion. Land use is increasingly a mix of temporary grassland with intensive arable cropping. Below Stoke Lacy Bridge the catchment falls within the Lugg, IDB drainage district with large sections of the catchment displaying uniform channel morphology, artificial bed height and limited bankside vegetation.

Figure 28: Representative views of the River Lodon in its upper (left) and lower reaches (right). 32

Component A - Appendix 1

5.3 Assessment of waterbody classification: The River Lodon is currently rated as poor, with fish poor (very certain) and phosphate moderate (quite certain) the failing elements (see table 8). Macro-invertebrates and all other Physico-chemical elements are rated as high. The waterbody is predicted to fail to meet good status by 2015, with fish and phosphate the elements preventing target achievement. On inception of the WB investigation, EA classification of the Lodon WB attributed unknown causes to the elemental failures. Reassessment of the WFD classification by the EA in the spring of 2011 resulted in the WB being afforded sediment as the suspected cause of fish failure. Full justification codes are provided in table 9. Table 8: Summarised WFD Classification for the River Lodon Overall Status Poor

Biological data Current status

Physico-chemical elements

Current status

Fish Invertebrates

Ammonia (phys-chemical) Dissolved Oxygen pH Phosphate Temperature Copper Zinc Ammonia (Annex 8) Quantity and dynamics of flow Morphology

High High High Moderate High High High High Supports good Supports good

Poor High

5.3.1 Physico-chemical classification: Physico-chemical classification comprises water chemistry samples taken by the Environment Agency between 2006- 2008, at one monitoring at Stoke Lacy Bridge. Table 10 shows WFD sampling in the River Lodon, highlighting that the majority of sampling is conducted on a monthly basis in dry conditions, although there are notable gaps. In total, the WFD classification compromises approximately 37 collected water samples giving 512 individual chemical measurements. The validity of single-point measurements in describing the full catchment also gives some concern when the impact on loading may be temporally and spatially more transient. Table 9: Decision codes for non-attainment of GES by 2015 in the River Lodon Decision Reason for failure code S2b Biological element Suspected â&#x20AC;&#x201C; sediment from diffuse source P1b

Phosphate or Total Phosphorus Unknown uncertain there is a failure / impact

Justification for alternative objective The source (sector or general activity) of the sediment impacting on biology is not yet confirmed There is not sufficient weight of evidence to confirm the need to control eutrophication risk

Reason

Sub-reason

Technically infeasible

Cause of adverse impact unknown

Disproportionately Significant risk expensive of unfavourable balance of costs and benefits

Component A - Appendix 1

Table 10: Showing frequency of Physico-chemical WFD water sampling of the Lodon with weather conditions where available (right of grey column indicates data collected post WFD classification).

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

2006 • • (D) • (D) • •(D) • •(D) • (D) • (R) • (HR) • • (D)

2007 • (D) • •(D) • (D) • (D) • • • • •• (D) • •(D)

2008 • (D) •(D) • (D) • • • • • • • • • (D)

2009 • (D) • (D) •(D) •(R) • (D)

2010 •• (D) • (D) • (D) Key: D= Dry R= Rain HR= Heavy rainfall

•• ••

5.3.2 Fish: The fish assessment comprise four sample locations, with 21 individual assessments made between the period 1992-2010, individual site classifications are shown in table 11. The main driver for the classification of poor is the low numbers of brown trout. FCS2 also predicts that Atlantic salmon should be present at W064M (Site FCS classifications are included in table 3 of the appendix). The most dominant species within the waterbody is brown trout. Other species present include bullhead at all sites with the addition of minnow and stoneloach at W064L, W064M and W171K. Classification of site W171K as good is based on data from 2003 which appeared to be a satisfactory year for brown trout with all sites seeing higher than average sample numbers. The site has not been sampled since, so based on population trends at the other sites, this is potentially a skewed assessment. Additional monitoring is required at this site to increase confidence in the current classification.

Table 11: WFD fish classifications for monitoring sites in the Lodon Site name NGR Year used for classification W064D SO6060054400 2008 W064L SO6130052500 2008 WO64M SO6184449376 2008 W171K SO6130052500 2003

Site Classification Poor Poor Poor Good

35 2007 2008 2009 2010

2008

2009

2010

2002

2001

2000

1999

1998

1997

1996

1995

1994

1993

1992

1991

2007

2006

2005

2006

2005

2004

W171K 2003

Brown Trout

2003

2002

2001

2000

1999

1998

1997

1996

1995

1994

1993

1992

1991

Brown Trout

Figure 29: Trout numbers in the River Lodon (Source EA, 2010) 2010

2009

2008

2007

2006

2005

2004

2003

2002

2001

2000

1999

1998

1997

1996

1995

1994

1993

1992

1991

2010

2009

2008

2007

2006

2005

2004

2003

2002

2001

2000

1999

1998

1997

1996

1995

1994

1993

1992

1991

Component A - Appendix 1

W064D

14 12 10 8 6 4 2 0

Brown Trout

W064L

30 25 20 15 10 5 0

Brown Trout

W064M

Component A - Appendix 1

5.3.3 Invertebrates: Invertebrates were monitored in 2000, 2003 and 2006, with all data taken at the same sampling site in the lower reaches of the tributary at Covender (SO624 432). BMWP and ASPT scores are indicative of high water quality, and up until 2006, when sampling ceased were displaying an upward trend (figure 30). Sites are displaying a good range of species with high numbers of total individuals found. 180

160

5.8

140

5.6

120

5.4

100

5.2

60 40

4.8

4.6

4.4

BMWP ASPT Linear (BMWP) Linear (ASPT)

Figure 30: BMWP and ASPT scores at Covender (with trend lines)

5.3.4 Phosphate: Physico-chemical monitoring has highlighted elevated phosphate levels within the River Lodon, resulting in a moderate classification for this element (figure 31). Monthly samples collected between 2006 and 2008 compromise the current WFD classification, sampling past 2008 has been less frequent, but TP levels still show a moderate status. 0.35 0.3 0.25

Orthophosphate mg/l

0.2 0.15

WFD Good status

0.1

Moderate

0.05 0 05/01/2006

05/01/2007

05/01/2008

05/01/2009

05/01/2010

Figure 31: Orthophosphate levels at Stoke Lacy bridge with WFD, showing good and moderate status standard levels, over period 2006-2010. (Source: Environment Agency, 2011). 36

Component A - Appendix 1

Infrequent sampling and lack of rainfall data makes it impossible to link the peaks in phosphate with non-point sources; however the overall trend shows that peak levels occur during summer months and are possibly a result of reduced dilution of point source discharges occurring during low flows. Currently, the apportionment of point and diffuse source P loading is uncertain, with more work underway. Known potential point source contributions occur at Pencombe STW, The Wye Valley Brewery and numerous private, septic tank systems within the catchment. Ecologically significant loads of P and suspended sediment (SS) are also likely to be originating from surrounding agricultural land, with a combination of landscape morphology and land management practice, generating the highest pollution risk. Sediment has already been identified as the suspected cause of fish failure and is known to be impacting on the ecological health of the WB. Agricultural diffuse P in rivers originates from residual P in soil or from manure or fertilisers applied to agricultural land. Phosphorus becomes mobilised, either in particulate form or soil solution by surface runoff, splash detachment, dissolution and desorption processes. Once mobilised, it is transported via several hydrological pathways where it will interact with the environment before being delivered to rivers.

5.4 Waterbody investigations: 5.4.1 Study aim: At inception, WFD failure in the Lodon for fish and phosphate were attributed as ‘unknown causes’ On turning our attention to the Lugg system, WUF were concerned by this lack of attributable cause to what we perceived from our local knowledge as a known problem and decided to investigate the failure causes further. The following investigations were chosen to identify possible sources and allow assessment of the most appropriate remedial measures likely to raise ambition in the current WB classification. It was apparent that unravelling the Phosphate issue would require significant scientific input, beyond the scope of our ‘in-house’ resources. Subsequently EA have extended chemical monitoring in the Lodon with the specific intention of increasing the understanding of phosphate sources and water quality impacts within the catchment. With EA’s acknowledged expertise in this area, WUF were keen not to replicate this work, choosing rather to focus on methodologies to improve specific awareness of the catchment and its pressures, thus identifying cost effective and targeted mitigation measures.

5.4.2 Chosen investigations: Land use mapping and SCIMAP to identify fine sediment delivery risk from non-point sources Catchment walk-over survey

Component A - Appendix 1

5.5 Land use mapping and modelling: The aim of this investigation was to conduct a desk-based study using GIS mapping, and hydrological modelling to identify potential diffuse pollution sources, and delivery pathways, likely to be impacting on water quality in the Lodon catchment. 5.5.1 Land use mapping: Land use maps were created in ARCMAP using interpolated agricultural statistics from Defra 2010 ag-census. Data have been interpolated using Inverse Distance Weighted algorithm and a cell size of 1000m. Figure 32 shows that arable cropping is spread widely throughout the catchment; with a significant amount of winter cereals grown in the upper regions where cultivation land gradient increases the risk of diffuse run-off. Soil conservation advice would be best targeted in these upper regions.

Horticulture

Cereals

Maize

Figure 32: Arable cropping in the Lodon catchment

KEY: Highest intensity Lowest intensity

Dairy Cattle

Total Cattle

Figure 33: Livestock number in the Lodon catchment 38

Pigs

Component A - Appendix 1

Livestock numbers are shown in figure 33. Cattle are distributed throughout the catchment, with notable ‘hot spots’ in the mid section and in the upper catchment. Indoor pig units are concentrated in the North West regions of the catchment will be generating large volumes of slurry. These farms would potentially be priorities for the delivery of nutrient management advice and assessments of slurry storage capacities.

Figure 34 & 35: Left: Poor winter wheat establishment and impeded infiltration providing a run-off pathway for sediment and nutrient in the upper catchment. Right: Maize production in the upper catchment. 5.5.2 Scimap to identify diffuse pollution sources: A step on from simple catchment scale land use mapping, was the application of a more sophisticated hydrological model- Scimap, in the Lodon catchment. Scimap is a particularly powerful tool combining land use risk, slope and rainfall data to produce a map showing areas of the catchment which generate diffuse pollution and which are hydrologically connected to a watercourse and thus present a high risk of diffuse pollution to water. Scimap does not provide definitive answers but assists with targeting across broad spatial scales by assigning a risk probability framework to a landscape and can be powerful tool in directing mitigation measures most effectively. WUF are well placed to use Scimap data for a targeted campaign of contact with risky management practices within the Lodon. Scimap works by: (1) Assessing the risk of pollution generation at a location through the use of land cover data and the apportioned ‘risk’ of soil erosion. (2) Identification of sources most likely to deliver pollution to the channel based on connectivity to the channel network by surface flow pathways during storm events (the hydrological connectivity risk or surface flow index). (3) Calculating in-stream risk by integrating risk from all sources contributing to that point. It is important to remember that Scimap results will only be as accurate as the data incorporated into the model. WUF ran the model using 10m resolution DTM data and freely available CORINE land cover data from 2000. Problems were encountered when modelling surface flow pathways and

Component A - Appendix 1

hydrological connectivity risk in low-lying areas of the catchment, as the model was not able to resolve correct drainage at this resolution. After a large amount of time spent investigating these anomalies, it was resolved that the model would need to be re-run with finer resolution DEM data (probably 5m), and most likely the catchment would need to be modelled in smaller sections. Whilst the in-channel sediment concentration was found to be unreliable, the sediment source risk maps were still found to be reliable, as the risk is primarily located on steeper ground where the model resolves drainage more accurately. WUF were able to use the data and Scimap model to produce maps showing the risk of fine sediment delivery on a catchment scale. These results, provided in figure 36 indicate the highest risk of fine sediment delivery in the North West region of the catchment, an area that has been of concern to the Foundation following catchment inspections, due to the large amounts of maize and winter cropping on steeply sloping fields. Severe erosion from a maize field was witnessed in this area of the catchment in October 2010 (figure 36). WUF are eager to start using the Scimap model across the entire catchment and are currently in the process of attaining quotes for Nextmap Britain 5m DTM data and Land Cover Map 2007 from the Centre of Ecology and Hydrology. Initial quotes suggest that this will cost in the region of ÂŁ8,400 (ÂŁ1077 for Nextmap 5m DEM2, and ÂŁ277 for LCM 2007).

Figure 36: Scimap results showing fine sediment erosion risk in the Lodon catchment and the location of overland run-off from a poorly sited maize field

Figure based on a provisional quote

Component A - Appendix 1

5.6 Catchment walk-over survey: Catchment walk-over survey provides an additional and powerful tool for identifying more specific catchment pressures along the riparian corridor. The walk-over survey, conducted by an experienced surveyor, allows risky practices to be mapped and indications of sediment contribution investigated. The walk-over survey is at its most powerful when used in conjunction with previous desk-based risk assessments, allowing for ground truthing and subsequent targeting of remedial input. 5.6.1 Methodology: The walk-over survey in the Lodon catchment was completed in November 2010, and recorded features to include levels of in-stream sediment, channel shading by riparian trees, occurrence of riffles and pools, watercourse fencing, bank erosion, sources of fine sediment and potential barriers to fish migration. Photographs were taken at regular intervals to illustrate identified pressures and in-stream habitats. In-stream sediment was measured using a visual assessment of gravel embeddedness, under the following categories: Heavily embedded gravel (HEG): Sediment filling gravel matrix Medium embedded gravel (MEG): Sediment visible between gravel. Some gravel still visible. Low embedded gravel (LEG): No sediment in gravel. The catchment walk-over survey results appear in the appendix, and the following observations are made:5.6.2 Gravel embeddedness survey: Waterbody substrate was found to be heavily embedded with sediment throughout, with additional high levels of deleterious algal growth, see figure 37&38. Limited availability of suitable spawning sites and juvenile areas is likely to be having a major impact on spawning success. A number of specific sites were identified where significant sediment and nutrient impact was recorded. One such site was an organic dairy unit, located in the mid-section of the catchment which was noted as a target for further WUF activity (see case study 3).

Figure 37 & 38: Showing in-steam gravels heavily embedded with fine sediment and deleterious algal growth.

Component A - Appendix 1

5.6.3 Riparian bank erosion: Much of the upper catchment is grazed by cattle and sheep, with approximately 70% of the river bank upstream of Stoke Lacy currently unfenced. Unrestricted livestock access and resultant over grazing and trampling of bankside vegetation has lead to extensive poaching and is contributing large quantities of silt into the river channel. High levels of sediment within in-stream gravels is likely to be seriously restricting juvenile habitats for salmonid species.

Figure 39 &40: Poached banks and faecal contamination from uncontrolled stock access. 5.6.4 Shading: 90% of the catchment was found to be heavily shaded, with un-coppiced alders causing dark tunnelling of long sections of the river channel. Where over shading is accompanied by uncontrolled livestock access this is likely to be having a detrimental impact on fish populations, through increased bank erosion, channel widening and the resultant loss of in-stream habitat diversity. In addition, resultant widening of the channel reduces the WBâ&#x20AC;&#x2122;s natural ability to ameliorate the effects of increased sediment loadings.

Figure 41 &42: Showing dark tunnelled section of the River Lodon. 5.6.5 Barriers to fish migration: The walk-over survey also highlighted the presence of significant barriers to fish migration, located within the lower and middle section of the catchment. These barriers were deemed to be an additional factor contributing to the WB, fish failure, preventing access for salmon and the in-stream

Component A - Appendix 1

movement of existing trout populations. In 14 locations, large woody debris has also collected in the channel and is also likely to be restricting fish movements in the channel.

Figure 43&44: Barriers to fish migration identified during the walk-over survey 5.7 Conclusions: Sources of agricultural P were identified during the walk-over survey and are likely to be contributing to the WFD target failure. The monitoring network needs to be extended to allow P apportionment to fully assess the loadings from Pencombe STW, domestic septic tanks and the Wye Valley Brewery. The walk-over survey has highlighted bankside erosion, as a result of uncontrolled livestock access as a significant source of fine sediment in the upper catchment. The impact of stock erosion is further intensified by increased shading from uncoppiced alders which are halting bank repair and the WBâ&#x20AC;&#x2122;s natural ability to ameliorate the effects of increased sediment loading. Measures to control suspended solids and P loadings from diffuse agricultural sources should be targeted to those areas where combinations of landscape attributes and land management generate the highest pollution risk. Combining the SCIMAP data with the knowledge gained from the river walk-over survey allows us to recommend and target specific mitigation activity to the problems identified. SCIMAP is a useful for tool for highlighting diffuse sources of fine sediment delivery in the catchment; however when working on a sub-catchment basis, local knowledge must be used to ground truth and highlight possible inaccuracies, ensuring land management advice is targeted effectively. SCIMAP reveals the extent to which arable cropping on significant slope angles with connectivity risks sediment and phosphorous transfer, particularly in the upper reaches of the Lodon. This was reinforced by the walk-over survey. Barriers to migration are also impacting on fish populations within the catchment.

Component A - Appendix 1

Subsequent to the WUF walk-over survey, EA chose to conduct their own geomorphological assessment of the catchment. It is really important that all interested parties working in this area co-operate with and inform each other of existing areas of knowledge so that maximum gain can be made and all best synergies achieved.

5.8 Achieving GES in the River Lodon: WUFs WB investigations have identified the following key actions as essential in order to achieve GES in the River Lodon: 1. Reduce overland flow of sediment and phosphate. Nutrient and sediment levels in the River Lodon are also a consequence of soil and fertiliser management under intensive cropping in the vicinity of the watercourse. A secondary issue in this area is the presence of intensive livestock systems and organic nutrient loss from hard surfaces and waterlogged fields. Additional action is also needed to address these diffuse sources of agricultural pollution, particularly in the upper catchment, where the shift from pastoral to intensive arable cropping on high risk sites provides greater risk. It is WUFs opinion that this is most effectively addressed through the use of advise, incentivisation and enforcement tools discussed in Section 2. 2. Maintain open access for fish passage. In-stream barriers are placing additional pressure on trout populations, preventing access to more suitable habitats. WUF recommends action to open up the catchment, through removal of the barriers or the construction of suitable easements. 3. Reduce bank erosion to improve the ability of the channel to ameliorate pollutants. The catchment investigations highlighted the need for targeted habitat restoration in the riparian corridor, through a concerted programme of stock exclusion and coppicing.

5.8.1 Action undertaken by WUF following the WB investigations: Under the Foundationâ&#x20AC;&#x2122;s LARA project, land management advice has been targeted in the catchment. Under this programme farmers have been offered free and confidential advice on aspects of their management that impacts on water quality, highlighting opportunities for environmental and financial gain. The advisory service has also been supported by a capital grant programme, assisting with funding works that bring measurable benefits to water quality. WUFâ&#x20AC;&#x2122;s incisive approach to awarding grant aid has tackled identified sources of sediment and P in the Lodon catchment. There has also been effective partnership working with the catchments CSF officer, information has been shared to ensure grant aid is targeted in the right places. Case studies below highlight work completed by the Foundation in the Lodon catchment over the past 6 months:

Component A - Appendix 1

5.8.2 Case studies illustrating WUFâ&#x20AC;&#x2122;s holistic approach to tackling agricultural phosphate and sediment sources in the River Lodon: Case study 1: Sediment and nutrient treatment ponds in the upper Lodon Following an advisory visit to a large arable and indoor pig rearing unit in the Upper Lodon catchment, the Foundation identified a significant source of nutrient and sediment run-off from the farm buildings and hard surfaces. With a total hard surface area of over 7,000sq. M., run-off was draining below the farmyard, causing water logging and poaching of the adjacent arable field. With connectivity over the surface, via tramlines, this resulted in considerable nutrient loading to the Lodon. Advice from WUFâ&#x20AC;&#x2122;s Catchment Officer, together with grant assistance allowed for the construction of a series of treatment ponds and a vegetative infiltration berm to slow the flow, providing a sink for sediment and nutrients, drastically reducing levels entering the river system. Total cost of the work was ÂŁ11,000, grant aid was provided at 50% intervention rate.

Surface run-off via in-field tramlines was acting as a direct pathway for sediment and phosphate transfer into the Upper Lodon. Yard run-off is now treated through a series of treatment ponds and a vegetated in-filtration berm.

Case study 2- Watercourse fencing in the River Lodon A major source of sediment is derived from bank erosion as a result of uncontrolled livestock access. To date, WUF grant funding has supported over 1.2km of watercourse fencing in severely impacted sections identified during the Foundations walk-over survey. Further stock exclusion works are planned in the near future.

Component A - Appendix 1

Case Study 3: Run-off from an organic dairy farm The Foundation had major concern over with the impact of an Organic Dairy Farm located next to a small tributary of the River Lodon in its middle reaches. The watercourse, which spans the length of the holding was found to be inundated with fine sediment and showed major signs of nutrient enrichment. The farmer was contacted in April 2011 but was initially reluctant to engage with the Catchment Officer, fearing that undue attention would result in statutory intervention. However, confidence was gradually gained along with the realisation that existing practise was untenable. Once this hurdle was overcome strong and enthusiastic engagement was achieved and the measures, as described below instigated. The ability of the WUF, catchment officer to be ‘the honest broker’ in this case was a major factor in advice being accepted and the following measures implemented.

Poor yard buffering was leading to run-off into the watercourse which runs along the length of the yard

Arrow indicates where yard run-off was discharging directly into the watercourse

The source of the problem was soon identified- the holding yard was poorly buffered and slurry and manure leachate was draining across the hard surfaces and entering the watercourse at numerous locations. The officer explained the deleterious impact this was having on the waterbody, and highlighted the possible financial implications to his business if this was identified by the Environment Agency. The farmer admitted he had been living in fear of an EA visit, but financial constraints had prevented him from addressing the problem. The officer advised urgent action be taken to increase yard buffering and divert the flow of yard runoff into a new cross drain and collection tank. The farmer agreed to take up the WUF grant assistance to cover 60% of the capital works and within a month the work had been completed. Total cost of this project was £4,690, 40% of the capital works costs were covered by the farmer and the remainder funded by the SITA Trust under the Foundation’s LARA project. In addition to this very focused intervention, the WUF catchment officer identified further improvements that could be made to the unsatisfactory yard surface. The farmer was introduced to the Natural England CSFO and assisted with a CSF grant application. As a result he now has funding secured to completely resurface the yard area, to the considerable betterment of water quality downstream from the holding. Cont....

Component A - Appendix 1

Subsequent to the infrastructure works being completed an EA environmental officer visited the farm. Following the visit the EA officer contacted WUF to discuss the works and expressed his satisfaction with the action that had been taken to protect water quality in the River Lodon.

New cross drain and dirty water tank intercepting yard run-off- previously discharging into the watercourse

Drain has been blocked and yard buffering increased

Component A - Appendix 1

References Council of the European Communities, 2000. Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for community action in the field of water policy. Official Journal of the European Communities L327: 1-72. Ellis, J. & V. Adriaenssens, 2006. Uncertainty estimation for monitoring results by the WFD biological classification tools. WFD Report GEHO1006BLOR_E_P. Environment Agency, Bristol. http://publications.environment-agency.gov.uk/PDF/GEHO1006BLOR-E-E.pdf Kelly, M. G., S. Juggins, H. Bennion, A. Burgess, M. Yallop, H. Hirst, L. King, B. J. Jamieson, R. Guthrie & B. Rippey, 2007. Use of diatoms for evaluating ecological status in UK freshwaters. Science Report: SC030103. Environment Agency, Bristol. http://www.wfduk.org/LibraryPublicDocs/diatoms_sc030103 Kelly, M., S. Juggins, R. Guthrie, S. Pritchard, J. Jamieson, B. Rippey, H. Hirst & M. Yallop, 2008. Assessment of ecological status in U.K. rivers using diatoms. Freshwater Biology 53: 403-422. Krammer, K., 1997a. Die cymbelloiden Diatomeen. Eine Monographie der weltweit bekannten Taxa. Teil 1. Allgemeines und Encyonema Part. Bibliotheca Diatomologica 36: 1-382. Krammer, K., 1997b. Die cymbelloiden Diatomeen. Eine Monographie der weltweit bekannten Taxa. Teil 2. Encyonema part., Encyonopsis and Cymbellopsis. Bibliotheca Diatomologica 37: 1-469. Krammer, K., 2002. Cymbella. In Lange-Bertalot, H. (ed.), Diatoms of Europe. Diatoms of the European Inland Waters and Comparable Habitats. Volume 3. A.R.G. Gantner Verlag K.G., Ruggell. Krammer, K. & H. Lange-Bertalot, 1986-1991. Bacillariophyceae 1. Teil: Naviculaceae, 876 pp.; 2. Teil: Bacillariaceae, Epithemiaceae, Surirellaceae, 596 pp.; 3. Teil: Centrales, Fragilariaceae, Eunotiaceae, 576 pp.; 4. Teil: Achnanthaceae. Kritische Ergänzungen zu Navicula (Lineolatae) und Gomphonema, 437 pp. In Ettl, H., J. Gerloff, H. Heynig & D. Mollenhauer (eds), Sußwasserflora von Mitteleuropa Band 2/1-4. G. Fischer Verlag, Stuttgart. Lange-Bertalot, H., 2001. Navicula sensu stricto. 10 Genera Separated from Navicula sensu lato. Frustulia. In Lange-Bertalot, H. (ed.), Diatoms of Europe. Diatoms of the European Inland Waters and Comparable Habitats. Volume 2. A.R.G. Gantner Verlag K.G., Ruggell. Reichardt, E. 1999. Zur Revision der Gattung Gomphonema. Die Arten um G. affine/insigne, G. angustatum/micropus, G. acuminatum sowie gomphonemoide Diatomeen aus dem Oberoligozän in Böhmen. Iconographia Diatomologica 8: 1-203.

Stretford Bksource to conf Tippets Bk Stretford Bk- Conf Tippets Bk to conf R Arrow Pinsley Bk- source to conf R Lugg

R.Lodon- source to conf R Frome

Tippets Bksource to conf Stretford Bk

GB109055036 580

GB109055036 660

GB109055036 630

GB109055041 940

GB109055036 640

WB name

WB ID

Good

Poor

Mod

Status

Nil

Fish Invertebrates

Fish Inverts

Inverts

Biological data

n/a

Fish (Poor) Phosphate (Mod)

Fish (Mod) Inverts (Mod)

Phosphate (Poor)

Failing elements

n/a

GS by 2027

GS 2027

Status objective (overall) GS 2027

Disproportionately expensive, Technically infeasible n/a

Technically infeasible

Disproportionately expensive

Justification for non-attainment

Table 1: Showing classification and justification of waterbodies selected for desk based study

Appendix:

Low confidence in current classification in absence of biological monitoring data. Opportunity to conduct biological monitoring to support or show inaccuracies in the current classification.

Fish are predicted to reach GES by 2015, but inverts fail. Scope to investigate reason for invert failure and recommend mitigation measures Candidate for additional investigations to identify cause of failure and appropriate mitigation measures

Failing WB with cause unknown. WUF investigation to attribute source of P.

Reason for selection

Component A - Appendix 1

Table 2: Full macro-invertebrate sampling results for all sites in the Tippets Brook Macro-invertebrate Taxa Ephemera danica Ephemera Serratella ignita Ecdyonurus torrentis Ecdyonurus Rhithrogenia semicolorata Leptophlebiidae Habrophlebia fusca Athripsodes Mystacides Odontocerum ablicorne Sericostoma personatum Tinodes waeneri Caenis luctuosa Rhyacophila dorsalis Agapetus fuscipes Agapetus (early instars) Limnephilidae (early instars) Chaetopteryx villosa Halesus radiatus Halesus digatatus Halesus Limnephilus lunatus Micropterna sequax Nemoura avicularis Ancylus fluviatilis Gammarus pulex Hydroptila Corixidae Hydrometra stagnorum Dytiscidae larvae Oreodytes sanmarkii Platambus maculatus Elmis aenea Limnius volckmari Oulimnius tuberculatus Oulimnius Hydraena Elodes Hydropsyche instabilis Hydropsyche pellucidula Hydropsyche siltalai Hydropsyche Dicranota Pilaria Hexatoma Tipula Simuliidae

Tippett's Brook

at Dovecote

d/s bridge in Luntley 2 1 18 5

2 6 3 1

1 2 4

3 22 7 1

30 1

9 3 1 2 2 2

2 2 6 1 1 9 4

26 10 11

2 7 3 14 100

2 85 55 45 1 2 9

25 10

160 40

10 8

2 1 7

1 4 1150

6 220

1 1 3 48

3 1320 8

1 1 1

19 16

1 32 27 2

12 4

70 25 1 3

1 28 3 5 14 1

2 32

4 4

3 2 6 1

9 5 1 1 1 1

9 4

1 1 35

Cont...

Component A - Appendix 1

CBaetis rhodani Sialis lutaria Potamopyrgus antipodarum Lymnaea peregra Anisus vortex Gyraulus albus Glossiphonia complanata Helobdella stagnalis Erpobdella octoculata Erpobdella Asellus aquaticus Chironomidae OLIGOCHAETA Ceratopogonidae Diptera Dolichopodidae Empididae Hydracarina Hemerodroma Tabanus Muscidae Psychodidae Sisyridae Stratiomyiidae Succinea BMWP Score TAXA ASPT

800

105

1360 1

2 3

1 3

2 8

3 8

1 135 5 18

1 35 6

6 7

2 235 6

3 2

111 21 5.29

2 2 157 26 6.04

10 4 3 3 1 140 1 22 1 1 3 75 3

5 2 2 140 25 5.6

240 1

1 1 13 7 9 55 2 35 2 17

1 110 2 1 2 4 3 160 28 5.71

Component A - Appendix 1

Macro-invertebrate Taxa Ephemera danica Ephemera Mystacides Sericostoma personatum Sericostoma (pupae) Agapetus (pupae) Agapetus (early instars) Limnephilidae (pupae) Limnephilidae (early instars) Chaetopteryx villosa Polycentropus flavomaculatus Nemoura avicularis Gammarus pulex Dytiscidae larvae Platambus maculatus Elmis aenea Limnius volckmari Oulimnius tuberculatus Oulimnius Orectochilus villosus Haliplus (larvae) Elodes Dicranota Tipula Simuliidae Baetis rhodani Baetis Centroptilum luteolum Sialis lutaria Potamopyrgus antipodarum Lymnaea peregra Cincinna piscinalis Glossiphonia complanata Erpobdella octoculata Erpobdella Sphaeridae Asellus aquaticus Chironomidae OLIGOCHAETA Ceratopogonidae Diptera Dolichopodidae Hydracarina Muscidae Psychodidae Succinea BMWP Score TAXA ASPT

Tippett's Brook nr Bidney Farm d/s Tyrrell's Court 4 2 2 1 11 6 2 9 24 4 3 2 19 1 2 1 10 590 5 40 1 4 48 10 39 5 9 5 25 1 2 3 4 1 2 6 1 1 3 2 3 5 570 1 2 3 5 16 21 3 2 7 11 1 1 3 185 125 2 11 9 4 1 6 6 3 4 3 1 106 111 21 22 5.05 5.05

Component A - Appendix 1

Table 3: Full diatom sampling results for the Tippets Brook site 4 (Upstream A4112 Bridge) SampleID SiteID SampleDate Alkalinity (as mg/L CaCO3) Taxon code ZZZ835

Species name (Authority) Achnanthidium minutissimum (Kützing) Czarnecki

AM012A

Amphora pediculus (Kützing) Grunow

CO001A

Cocconeis placentula Ehrenberg

CO005A

Cocconeis pediculus Ehrenberg

DT003A

Diatoma vulgaris Bory

EY9999

Encyonema sp.

GO050A

Gomphonema minutum (Agardh) Agardh

GO013A ZZZ834

Gomphonema parvulum Kützing Gomphonema pumilum (Grunow) E.Reichardt & Lange-Bertalot

ME015A

Melosira varians Agardh

NA751A

Navicula cryptotenella Lange-Bertalot

NA023A

Navicula gregaria Donkin

NA095A

Navicula tripunctata (O.F.Müller) Bory

NI042A

Nitzschia acicularis (Kützing) W. Smith 1853

NI065A

Nitzschia archibaldii Lange-Bertalot

NI015A

Nitzschia dissipata (Kützing) Grunow Nitzschia dissipata var. media (Hantzsch) Grunow 1881

ZZZ930 NI009A

TU003A

Nitzschia palea (Kützing) W.Smith Planothidium lanceolatum (Bréb. ex Kützing) Round & Bukhtiyarova Rhoicosphenia abbreviata (Agardh) LangeBertalot Surirella brebissonii Krammer & Lange-Bertalot 1987 Tabularia fasciculata (Agardh) Williams & Round

TF001A

Tryblionella constricta (Kützing) Poulin 1990

SY001A

Ulnaria ulna (Nitzsch) Compère

ZZZ897 RC002A SU073A

TippetBrook TippetBrA4112br 16/09/2011 263 % relative abundance

Count 11 14 1 12 11 5 23 1 1 412 3 4 18 1 3 3 16 3 1 12 14 10 3 9

1.9 2.4 0.2 2.0 1.9 0.8 3.9 0.2 0.2 69.7 0.5 0.7 3.0 0.2 0.5 0.5 2.7 0.5 0.2 2.0 2.4 1.7 0.5 1.5

Component A - Appendix 1

Table 4: FCS2 Diagnostics River Lodon â&#x20AC;&#x201C; source to conf R Frome (GB10905503660) Site W064D, Classification: Poor EQR (Environmental Quality Ratio): 0.04839 Expected number of species: 3 Observed number of species: 1

Salmon Trout Eel Bullhead Stoneloach Minnow Lamprey Spined Loach Stickleback Roach Carp Pike Perch Tench Rudd Grayling Chub Barbel Bream Gudgeon Bleak Ruffe Dace

Probability (Exp-Obs) 0.771 0.051 0.8197 1 0.6966 0.706 0.8357 0.9999 0.9129 0.978 0.9997 0.9997 0.973 1 0.9993 0.9503 0.99 0.998 0.9997 0.995 0.9987 0.999 0.9997

Expected Prevalence

Observed Count

0.229 0.949 0.1803 0.9166 0.3034 0.294 0.1643 0.0001447 0.8714 0.022 0.00003333 0.0003333 0.027 0 0.0006667 0.04967 0.01 0.002 0.0003333 0.00325 0.001333 0.001 0.0003333

0 0 0 200 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Site: WO64L, Classification: Poor EQR (Environmental Quality Ratio): 0.188 Expected number of species: 4 Observed number of species: 2

Salmon Trout Eel Bullhead Stoneloach Minnow Lamprey Spined Loach Stickleback

Probability (Exp-Obs) 0.7243 0.179 0.777 1 0.6511 0.6687 0.8053 0.9999 0.8914

Expected Prevalence

Observed Count

0.2757 0.964 0.223 0.9383 0.3489 0.3313 0.1947 0.0001309 0.1086

0 4 0 350 0 0 0 0 0

Component A - Appendix 1

Roach Carp Pike Perch Tench Rudd Grayling Chub Barbel Bream Gudgeon Bleak Ruffe Dace

0.975 0.9997 0.999 0.975 0.999 0.999 0.9543 0.9913 0.999 0.999 0.9968 0.9997 0.9993 0.9983

0.025 0.0003333 0.001 0.025 0.001 0.001 0.04567 0.008667 0.001 0.001 0.002125 0.0003333 0.0006667 0.001667

0 0 0 0 0 0 0 0 0 0 0 0 0 0

Site: W171K, Classification: Good Environmental Quality Ratio (EQR): 0.5857 Expected number species: 6 Observed number of species: 5

Salmon Trout Eel Bullhead Stoneloach Minnow Lamprey Spined Loach Stickleback Roach Carp Pike Perch Tench Rudd Grayling Chub Barbel Bream Gudgeon Bleak Ruffe Dace

Probability (Exp-Obs) 0.414 0.496 0.5463 1 1 1 0.729 0.9908 1 0.925 0.9987 0.965 0.8387 0.9987 0.9963 0.8057 0.867 0.9877 0.9887 0.8558 0.9987 0.9983 0.8973

Expected Prevalence 0.586 0.932 0.4537 0.9753 0.7935 0.7825 0.274 0.0092 0.1462 0.075 0.001333 0.035 0.1613 0.001333 0.003667 0.1943 0.133 0.01233 0.01133 0.1314 0.001333 0.001667 0.1027

Observed Count 0 8 0 316 3 31 0 0 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Component A - Appendix 1

Site WO64M, Classification: Poor EQR: 0.08732 Expected number of species: 5 Observed number of species: 2

Salmon Trout Eel Bullhead Stoneloach Minnow Lamprey Spined Loach Stickleback Roach Carp Pike Perch Tench Rudd Grayling Chub Barbel Bream Gudgeon Bleak Ruffe Dace

Probability (Exp-Obs) 0.368 0.23 0.6657 1 0.4291 0.389 0.7437 0.9998 0.9117 0.917 0.9983 0.9843 0.903 0.996 0.9967 0.877 0.9613 0.992 0.995 0.9376 0.997 0.9977 0.9843

Expected Prevalence

Observed Count

0.632 0.942 0.3343 0.9646 0.5709 0.611 0.2563 0.0002201 0.08825 0.083 0.001667 0.0567 0.097 0.004 0.003333 0.123 0.03867 0.008 0.005 0.05212 0.003 0.002333 0.01567

0 4 0 80 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0

Component A - Appendix 1

Table 5: WUF Walk-over survey results:

Component A - Appendix 1

Defra Strategic Evidence and Partnership Project Component A Appendix 2 Developing a catchment management framework for the delivery of â&#x20AC;&#x2DC;Goodâ&#x20AC;&#x2122; Water Framework Directive status at a sub-catchment scale

Component A - Appendix 2

Westcountry Rivers Trust

Strategic Evidence & Partnership Developing a catchment management framework for the delivery of ‘Good’ Water Framework Directive status at a sub-catchment scale

In partnership with…

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Contents Contents ............................................................................................................................ 2 Summary ........................................................................................................................... 3 Overview ........................................................................................................................... 6 Investigation.................................................................................................................................. 6 Justification ................................................................................................................................... 6 Delivery of measures ...................................................................................................................... 7 Assessment of outcomes ................................................................................................................ 7 Introduction ....................................................................................................................... 8 Justification ....................................................................................................................... 9 Investigations................................................................................................................... 11 Condition assessment................................................................................................................... 11 WFD classification .................................................................................................................... 11 Overall WFD status ................................................................................................................... 12 Biological indicators.................................................................................................................. 15 Fish population monitoring ....................................................................................................... 15 Invertebrate monitoring ........................................................................................................... 16 Phytobenthos (diatoms) ........................................................................................................... 18 Physicochemical indicators ....................................................................................................... 19 Dissolved oxygen, biochemical oxygen demand (BOD) & ammonia ........................................ 20 Phosphate ............................................................................................................................... 22 Sediment & dangerous substances .......................................................................................... 24 Causation diagnosis ......................................................................................................................25 River Basin Management Plan (RBMP) .....................................................................................25 Sediment ................................................................................................................................. 26 Organic pollution & nutrients................................................................................................... 29 Delivery of measures ......................................................................................................... 30 River Basin Management Plan ...................................................................................................... 30 WRT on-farm measures ................................................................................................................ 31 Assessment of outcomes ................................................................................................... 33 Environmental improvements ...................................................................................................... 33 Ancillary benefits .......................................................................................................................... 34 Cost-benefit analysis .................................................................................................................... 35 Conclusion ....................................................................................................................... 35 Further information & contacts .......................................................................................... 36 References ....................................................................................................................... 37 2

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Summary In this study the Westcountry Rivers Trust sets out how, through the development of a targeted & cost-effective programme of monitoring, diagnosis and catchment management intervention, we can facilitate the delivery of river waterbodies into good condition at a local, catchment or subcatchment scale. The Westcountry Rivers Trust believes that the best way to improve the condition of river waterbodies is by working to improve ecosystem function across whole catchments. We also believe that the delivery of integrated catchment management is best done through the formation of catchment partnerships, comprising as many local interest groups as possible. To achieve these goals our work is split into four key areas; (1) investigation, (2) justification, (3) delivery of measures, and (4) assessment of outcomes. To demonstrate the feasibility of implementing our catchment management framework for the delivery of â&#x20AC;&#x2DC;goodâ&#x20AC;&#x2122; Water Framework Directive status at a sub-catchment scale we are currently in the process of applying it to a number of river catchments and sub-catchments across the Westcountry region. In this report we describe the implementation of our approach in the River Ottery, a subcatchment of the River Tamar. Justification There are a number of reasons why we have focussed one of our principle catchment management programmes on the tributaries of the River Tamar (of which the River Ottery is just one example). Firstly, we have received numerous anecdotal reports in recent months that some sections of the River Tamar and its tributaries appear to be in poor condition. Secondly, the River Ottery contributes approximately 1o% of the water in the River Tamar at South West Waterâ&#x20AC;&#x2122;s Gunnislake abstraction and its catchment therefore makes a significant contribution to the water abstracted from the River Tamar for human consumption. Thirdly, in addition to the provision of drinking water, the River Ottery also has the potential to provide a number of other important ecosystem services, which may need catchment management to be undertaken if they are to be protected or enhanced. Investigation Before we can begin to develop a catchment management plan for the Ottery, it is vital that we first undertook an accurate assessment of the true condition of the river waterbodies in the catchment. This would help us to understand the character and scale of the problems we face and begin the process of diagnosing the causes of any degradation in river ecology. The first set of evidence that we can use to assess the condition of the waterbodies in the Ottery is their WFD classification. Examination of the WFD classification for these seven waterbodies reveals that, while five of them are classified as being in good ecological status, two are failing because they have only achieved moderate status in their fish classification. Only three of the waterbodies have classifications for more than one biological indicator and these are all high invertebrate classifications. No information on the impact of invasive species has been reported for these waterbodies. None of the waterbodies have been ascribed a chemical status, but all of the physicochemical indicators have been recorded for all seven. In every case these parameters have been given good or high status classifications.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust We have identified a number of issues raised by the WFD classifications for the Ottery catchment waterbodies:1. The overall condition assessment for the catchment appears to be rather at odds with the assessment of the river made by local experts and other reports we have received on the condition of the catchment. 2. There is an almost complete reliance on fish assessments within the biological classification, which means that some indicators potentially more sensitive to diffuse pollution derived from agriculture have not been assessed. 3. The universally good or high status recorded for the physicochemical parameters is also surprising when we consider that the Ottery catchment has some of the most intensive livestockbased agriculture found anywhere in the westcountry. 4. The lack of any chemical status classifications for these waterbodies is interesting as we know that the Ottery catchment contributes significantly to the water abstracted at Gunnislake for human consumption. In light of these issues, and some additional concerns about the sensitivity of the monitoring and assessment methods used to generate WFD classifications (discussed below), we felt that further data and evidence would be required if we were to gain the information we needed to assess the condition of these waterbodies. Supplementary data and evidence can be obtained in two ways. It can be generated through the re-evaluation of existing data using more sensitive indicators of ecological health or by applying different evaluation criteria. It can also be obtained through the collection of further evidence in the field through a variety of survey and monitoring methods. The evidence we have presented appears to suggest that the ecological condition of the River Ottery and its tributaries is being impacted in some locations to a greater degree than the WFD classifications suggest. In particular, we have preliminary evidence which suggests that the fish, invertebrate and diatom assemblages in the catchment may be degraded and that these impacts may be due to the occurrence of pollution in the form of sedimentation, organic pollution and nutrient enrichment. In light of these findings, and in order to facilitate the development of tailored and targeted catchment management interventions, we have also used a variety of the data and tools available to identify what is causing these problems. The South West RBMP lists the most frequent causes for waterbody failure identified by Environment Agency staff using monitoring data and their knowledge and experience of individual waterbodies. The SW RBMP and the WFD classifications data tables do not give any specific reasons for the failure of the two waterbodies in the Ottery catchment. Through the integration of existing data and modelling outputs with targeted field surveys of different types, we have gone a long way towards diagnosing the agricultural and other causes of waterbody degradation in the Ottery catchment. Delivery of measures Having developed a targeted and tailored plan of what needs to done and where we then deliver a suite of targeted catchment management interventions to achieve the best possible environmental and economic benefits for all of the interested parties. The tools available to us and other organisations are diverse and varied and all have their merits, but it is their tailored and targeted 4

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust application in response to challenges encountered in the catchment, and not a one-size-fits-all approach, that will yield the best results for the condition of the river. Over the last 10 years the Westcountry Rivers Trust has developed farm management advice, which can help minimize loss of pollutants from farms whilst maximizing their on farm usage to increase yields and save costs. Assessment of outcomes The principal, over-arching aim of our work is to improve raw water quality in Westcountry rivers and to significantly contribute to their attainment of good ecological status in accordance with the EU Water framework Directive. In light of these over-arching aims, we have developed a range of approaches that will allow us to assess various outcomes delivered by our catchment management work. This approach is designed to achieve the following objectives; • Quantification of our interventions. We must gather precise and detailed evidence of what we have delivered, where we have delivered it, what it has cost and, perhaps most importantly, what the intended outcome is for each. • Establish strong baseline evidence. If we are to demonstrate the effectiveness of our interventions, it is vital that we collect baseline data (of the type presented in this report). • Monitor and evaluate benefits. We will attempt to collect a comprehensive and robust set of data and evidence which demonstrates qualitatively and quantitatively that we have achieved genuine improvement in raw water quality and created ancillary benefits. • Develop and disseminate best practice. We want to establish a core methodology that can be adopted, with modification, by any catchment management partners. This will ensure that monitoring outcomes is consistent and that data and evidence can be integrated into that of other organisations (such as the Environment Agency). Conclusion The current Water Framework Directive monitoring and catchment management intervention strategy, as encapsulated in the South West River Basin Management Plan, gives a spatially and temporally averaged estimate of waterbody status that is largely designed to report upward and centrally. While we acknowledge the importance of the RBMP as a strategic vision for the management of river catchments generally, we are concerned that there is a general lack of fine-scale resolution and local sensitivity in the high-level and nationally applicable approach to river assessment it adopts. As a result of these deficiencies we feel that there may be a number of waterbodies for which the true condition of the river, and the problems it faces, are not reflected in their WFD classification. This uncertainty means that the current waterbody assessment methods and criteria are not particularly useful for informing the integrated and targeted restoration of river catchments at a local, subcatchment scale. Having gained further insight into the condition of the study waterbodies through supplementary monitoring and more detailed data analysis, and having characterised the causes of the degradation encountered, we are now far better placed to recommend a targeted, cost-effective and evidencebased programme of remediation for the catchment in which we work.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Overview In this study the Westcountry Rivers Trust sets out how, through the development of a targeted & cost-effective programme of monitoring, diagnosis and catchment management intervention, we can facilitate the delivery of river waterbodies into good condition at a local, catchment or subcatchment scale. The Westcountry Rivers Trust believes that the best way to improve the condition of river waterbodies is by working to improve ecosystem function across whole catchments. We also believe that the delivery of integrated catchment management is best done through the formation of catchment partnerships, comprising as many local interest groups as possible. A partnership approach to integrated catchment management will avoid duplication of effort, enhance a wider array of ecosystem services and facilitate the development of funding streams for catchment management which can be spent locally to deliver a shared catchment vision. To achieve these goals our work is split into four key areas.

Investigation To demonstrate that catchment management intervention is timely, targeted and necessary we use the latest modelling, surveying and mapping techniques to investigate river condition, identify threats to ecosystem health and create integrated catchment management plans. The first stage in this process is to collate and evaluate existing data and evidence already collected by other organisations, such as the Environment Agency, water companies and other conservation bodies. Routine and statutory monitoring work, such as that undertaken by the Environment Agency for Water Framework Directive assessments, generates huge quantities of high quality data, which in many cases will reveal the true condition of a catchment and the causes of any problems. In some circumstances, however, where we believe the pre-existing data is of insufficient coverage or quality to accurately inform catchment management, we will undertake further monitoring or survey work to supplement and complement this evidence. In addition to data and evidence collected in the field, we also use data, mapping and modelling techniques to identify and characterise potential sources of pollution and to target both our additional monitoring programmes and to tailor our intervention strategy.

Justification Once we have built a comprehensive and robust evidence-base, we then use the data and evidence we collect to strategically target catchment management initiatives, target the delivery of interventions within catchments and tailor the measures proposed to each individual situation and objective. In addition to facilitating strategic planning and practical delivery of interventions, the data and evidence collected is also used to engage with farmers, land-owners and the potential funders of catchment management. The effective engagement of these stakeholder groups is vital if the catchment management approach is to be a viable option and the measures we propose are to be taken-up. To achieve this, we must therefore use the evidence to establish a clear link between the processes that are occurring in the catchment and the observed degradation of the river ecosystem. 6

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust We must also convince these key stakeholders of their potentially critical role in ecosystem management and of the potential secondary benefits to them of being involved. Westcountry Rivers Trust are currently demonstrating that this approach to the engagement of funders and key stakeholders can work effectively through their Upstream Thinking catchment management initiative being undertaken in association with South West Water.

Delivery of measures Having developed a targeted and tailored plan of what needs to done and where, we then deliver a suite of targeted catchment management interventions to achieve the best possible environmental and economic benefits for all of the interested parties. For over 10 years the Westcountry Rivers Trust has been working to develop a suite of on-farm measures that reduce the availability of pollutants in the landscape, reduce their mobilisation and disconnect the pathways via which pollutants are transferred to the rivers. These measures, termed Best Farming Practices (BFPs) have been assessed by a group of academics, funded by DEFRA, to produce a peer-reviewed and published manuscript, which describes the effectiveness of the BFP measures for the reduction of diffuse agricultural pollution (Cuttle et al 2007). The measures are also fully costed and the potential financial benefits they bring to the farmer have been carefully evaluated.

Assessment of outcomes Perhaps the most important stage in our catchment management approach is the demonstration that our interventions have not only been effective in delivering demonstrable and quantifiable environmental outcomes, but also that we have delivered a wide array of ancillary financial, social and ecological benefits. We also want to ensure that the outcomes delivered have not been achieved to the detriment of other ecosystem services or to local stakeholders: we want to deliver improvements for the river, but not at the expense of food production or farmersâ&#x20AC;&#x2122; businesses. To achieve this â&#x20AC;&#x2DC;proof of conceptâ&#x20AC;&#x2122; we will continue to monitor and model the river ecosystems to evaluate, where possible, the improvements we have achieved and to estimate gains in the provision of other ecosystem services. Finally, we can demonstrate the cost-benefit ratio of our intervention work to the funders, local stakeholders and the other beneficiaries of the ecosystem services we have enhanced.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Introduction To demonstrate the feasibility of implementing our catchment management framework for the delivery of â&#x20AC;&#x2DC;goodâ&#x20AC;&#x2122; Water Framework Directive status at a sub-catchment scale we are currently in the process of applying it to a number of river catchments and sub-catchments across the Westcountry region. Figure 1 shows one sub-catchment on which we are currently working, the River Ottery, which is a sub-catchment of the River Tamar and comprises seven WFD river waterbodies. In this report we will present a case study of the findings and experience obtained during the application of our catchment management framework to this sub-catchment.

Figure 1. The River Ottery showing its 7 WFD river waterbody boundaries and its location in the wider Tamar catchment.

With a length of 33km, the River Ottery drains an area of 124.5km2 and forms one of the main subcatchments of the Tamar system. Due to heavy impermeable clay soils and low permeability and porosity within the underlying geology (mostly shale), groundwater storage within the catchment is limited and flood risk is high, particularly around the village of Canworthy Water. Historically, mining in the Ottery and Canworthy headwaters has led to an increase in mineral levels in the river, accentuated by rapid run-off from the land. Excess mineral loadings have led to fish kills in the past, the most recent event taking place in the autumn of 1995. Most of the area consists of large specialist dairy farms (of which there are around 80), although cattle and sheep can be found at the downstream end. The main arable crop is maize in addition to a little cereal growing. There are five SSSI's in the Ottery catchment including the Ottery Valley SSSI in the headwaters which consists of 33ha of rapidly diminishing culm habitat.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Justification The condition of UK river waterbodies must improve to meet the quality standards set out in the European Water Framework Directive (WFD), which was transposed into UK law in 2003. The main objectives of the WFD are to protect and improve the ecological condition of aquatic ecosystems and to ensure that they are managed in a coherent and sustainable manner. In addition to, the Water Framework Directive has several further overarching aims that include; • • • • •

Promoting sustainable use of water as a natural resource; Conserving habitats and species that depend directly on water; Reducing or phasing out the release of pollutants that threaten the aquatic environment; Contributing to mitigating the effects of floods and droughts. Aiming to achieve at least good status for all water bodies by 2015;

There are a number of reasons why we have focussed one of our principle catchment management programmes on the tributaries of the River Tamar (of which the River Ottery is just one example). Firstly, we have received numerous anecdotal reports in recent months that some sections of the River Tamar and its tributaries appear to be in poor condition (see Figure 2). This has raised concern that some rivers in the Tamar catchment will need to be improved if they are to meet the primary objective of the Water Framework Directive, which requires all waterbodies to be brought into good ecological status by 2015. Secondly, the River Ottery contributes approximately 1o% of the water in the River Tamar at South West Water’s Gunnislake abstraction and its catchment therefore makes a significant contribution to the water abstracted from the River Tamar for human consumption. In any location where water is abstracted from a river for human consumption the waterbody surrounding the abstraction point is designated as a Drinking Water Protected Area (DrWPA). This means that its condition is subjected to extra scrutiny to ensure the quality of the raw water abstracted. Furthermore, the catchment upstream of the DrWPA, which contributes water to the abstraction, is identified as a Drinking Water Safeguard Zone, a status that should also make it a higher priority for river condition monitoring and improvement work. Thirdly, in addition to the provision of drinking water, the River Ottery also has the potential to provide a number of other important ecosystem services, which may need catchment management to be undertaken if they are to be protected or enhanced. To assess the capacity of a catchment to provide different ecosystem services we have developed a series of ecosystem service provision models (shown in Figure 3). These models clearly indicate that while the River Ottery catchment could, theoretically, make a significant contribution to the provision of ecosystem services, such as clean water for ecological health and drinking and greenhouse gas sequestration, it is currently one of the most intensively farmed sub-catchments in the wider Tamar catchment. When overlaid, these models suggest that the intense agricultural production being undertaken in the Ottery catchment is, in many areas, being undertaken on land that is, or could, play a key role in the provision of other ecosystem services. This conflicting use is therefore likely to be having a direct effect on the ecological condition of the river and the ability of the catchment to provide those other services. 9

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust Figure 2. Images showing the visual condition of two tributaries of the River Ottery in the summer of 2011. (A) Caudworthy Water and (B) Bolesbridge Water.

Figure 3. Models of ecosystem service provision for the Tamar catchment showing the potential conflict between the production of food and other ecosystem services provided in the Ottery catchment.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Investigations Condition assessment Before we can begin to develop a catchment management plan for the Ottery, it is vital that we first undertake an accurate assessment of the true condition of the river waterbodies in the catchment. This will help us to understand the character and scale of the problems we face and begin the process of diagnosing the causes of any degradation in river ecology. All of our investigative work in river catchments is undertaken in accordance with the ‘sourcereceptor-pathway’ principle of pollution. First, we must examine the receptors (the rivers) themselves and assess whether they are being damaged. If there are pollutants present and they are shown to be damaging the ecology of the river, then we can begin to identify their sources in the catchment and characterise the mechanisms that are allowing them to be mobilised and transported into the river.

Having identified where the rivers are damaged or degraded due to pollution, we can then take action to reduce the availability of pollutants in a catchment, block their mobilisation and/or disconnect the pathways via which they are reaching the river.

WFD classification The first set of evidence that we can use to assess the condition of the waterbodies in the Ottery is their WFD classification. The Water Framework Directive condition assessments are currently undertaken by the Environment Agency using methodologies agreed with the UK Technical Advisory Group (UK TAG) and recommendations for remedial catchment management interventions are made through River Basin Management Plans (RBMPs). For surface waters, such as rivers and lakes, the ‘overall status’ of a waterbody is comprised of an ecological and a chemical component. Ecological status is recorded on the scale high, good, moderate, poor and bad (with moderate or worse being regarded as failure), while chemical status is measured simply as good or fail. Figure 4 shows how overall WFD status is determined. Each component of the classification has several different elements that are each measured against specific standards and targets developed by UKTAG and the European Union. The lowest classification recorded for any of the parameters will form the final WFD classification for that waterbody. In circumstances where limited resources are available for monitoring and this prohibits the assessment of all parameters, only the indicators considered to be the most sensitive are assessed and these form the final classification.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust In broad terms, a classification of good ecological status is applied to natural water bodies that show only slight variation from their undisturbed natural condition. Figure 4. Schematic summarising the component indicators used to derive waterbody classifications for WFD.

Overall WFD status The overall WFD status for each waterbody in the Ottery catchment is shown in Figure 5 and the individual classifications for each WFD parameter are shown in Table 1. Examination of the WFD classification for these seven waterbodies reveals that, while five of them are classified as being in good ecological status, two are failing because they have only achieved moderate status in their fish classification. Only three of the waterbodies have classifications for more than one biological indicator and these are all high invertebrate classifications. No classifications are reported for microalgae, macrophytes, phytobenthos (diatoms) or phytoplankton. No information on the impact of invasive species has been reported for these waterbodies. None of the waterbodies have been ascribed a chemical status, but all of the physicochemical indicators have been recorded for all seven. In every case these parameters have been given good or high status classifications.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust Figure 5. Overall WFD status of the 7 waterbodies comprising the River Ottery catchment.

Table 1. Individual component classifications for the waterbodies in the Ottery sub-catchment.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust There are a number of issues raised by the WFD classifications for the Ottery catchment waterbodies shown in Figure 5 and summarised in Table 1. 5. The overall condition assessment for the catchment appears to be rather at odds with the assessment of the river made by local experts and other reports we have received on the condition of the catchment. 6. There is an almost complete reliance on fish assessments within the biological classification, which means that some indicators potentially more sensitive to diffuse pollution derived from agriculture have not been assessed. 7. The universally good or high status recorded for the physicochemical parameters is also surprising when we consider that the Ottery catchment has some of the most intensive livestockbased agriculture found anywhere in the westcountry. 8. The lack of any chemical status classifications for these waterbodies is interesting as we know that the Ottery catchment contributes significantly to the water abstracted at Gunnislake for human consumption. This lack of classification is made all the more interesting when we consider that the waterbody that forms the Drinking Water Protected Area around the Gunnislake abstraction is actually the only waterbody with a chemical status in the entire Tamar catchment and it fails to meet the required standard for the priority and dangerous substances assessed to determine the chemical status.

In light of these issues, and some additional concerns about the sensitivity of the monitoring and assessment methods used to generate WFD classifications (discussed below), we felt that further data and evidence would be required if we were to gain the information we needed to assess the condition of these waterbodies. Supplementary data and evidence can be obtained in two ways. It can be generated through the reevaluation of existing data using more sensitive indicators of ecological health or by applying different evaluation criteria. It can also be obtained through the collection of further evidence in the field through a variety of survey and monitoring methods.

In the following sections we describe the variety of data analysis, modelling, monitoring and survey methods we have used to further evaluate the condition of the seven Ottery waterbodies and to diagnose the causes of the problems found. We have focused our investigations on a number of key WFD measures that are the most indicative and those which can be studied in a relatively simple and cost-effective way.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Biological indicators Fish population monitoring Fish populations, especially of salmonid species, are widely accepted to be good biotic indicators of river ecosystem health. Their complete dependence on the supply of clean and well oxygenated water, the availability of accessible reproductive habitat, and a good supply of food makes them highly sensitive to perturbation of their ecological niche in river ecosystems. Barriers that block fish migration up and down rivers, the accumulation of silt in their spawning gravels, and pollution that has toxic effects on them directly or reduces the abundance of their invertebrate food can all cause declines in fish populations. However, while fish are sensitive to these specific and often quite severe perturbations, there are other biotic indicators, such as invertebrate or microbial assemblages in rivers, which are actually far more sensitive to low level, chronic pollution resulting from diffuse pollution. The WFD assessment method for fish uses a non-parametric geo-statistical model called the Fisheries Classification Scheme 2 (FCS2) to predict the abundance of different fish species that should be found in a particular river based on a number of recorded environmental variables and the geographic location of the site. Comparing the number of fish found during an electrofishing sample with the number predicted to be present by the model allows the condition of the fish population to be assessed. Figure 6 shows the current fish status for each waterbody in the Ottery catchment, as classified during the first round of WFD classification. The map also shows the results of electrofishing surveys carried out in 2010 by the Environment Agency, which have been run through the FCS2 model to determine the WFD status that would have been given if this data had been used for classification. Figure 6. WFD status for fish in the River Ottery catchment waterbodies. Unofficial WFD classifications derived from 2010 electrofishing data collected by the Environment Agency are also shown.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust The data shown in Figure 6 clearly shows that, while the data used for the first round of WFD classification resulted in just two of the waterbodies failing the WFD assessment, the 2010 data would have given six failures (2 at moderate, 3 at poor and 1 at bad status). The only waterbody not failing, Canworthy Water, was not assessed in 2010 and so it remains challenging to draw conclusion as to what its current status is for fish. It is important to note that the FCS2 model predictions for all waterbodies is soon to be made available to WFD co-delivery organisations and this will allow Rivers Trusts to undertake electrofishing surveys and interpret them according to WFD criteria. In 2012 the Westcountry Rivers Trust, in partnership with the DEFRA Demonstration Test Catchment consortium will be undertaking detailed electrofishing surveys on the Ottery catchment and the data collected will be integrated with the continued routine monitoring data collected by the Environment Agency to create a comprehensive fish population dataset.

Invertebrate monitoring The evaluation of invertebrate assemblages in a river is perhaps the best method for assessing the impacts of environmental stress. Invertebrate samples collected using standardised methods are identified to the level of taxonomic family or species and their approximate abundance in the sample recorded. This data is then used to calculate biotic indices which are used to draw conclusions about the condition of the river and to make comparisons between sites on the same or different rivers. For WFD assessment the Environment Agency use a software package called the River InVertbrate Prediction and Classification System (RIVPACS) developed by the Institute of Freshwater Ecology (IFE). RIVPACS takes physical and geographical information about the sample site and makes a prediction of the invertebrate assemblage that is ‘expected’ to occur in a river of that type. The WFD invertebrate classification is then derived through comparison of this expected community with that which was actually observed in the sample taken. Figure 7 shows the WFD invertebrate statuses of the waterbodies in the Ottery and shows the sampling locations used to generate the classification. Only three of the waterbodies have invertebrate classifications and they are all high status. Invertebrate samples have been collected in three of the four unclassified waterbodies but not for at least 10 years. The sensitivity of invertebrate monitoring, and therefore its ability to detect chronic pollution due to diffuse pollution, is entirely dependent on the taxonomic resolution of the sample identification undertaken and the biotic index used to make the assessment. The current biotic index used for WFD classification is termed the ‘average score per taxon’ (ASPT) index. In this long established method taxa are allocated scores according to their sensitivity to pollution. When a river becomes polluted the most sensitive and highest scoring taxa are the first to be lost and the average score falls. Where the average score of the taxa found is high it indicates that the most sensitive taxa are present in the river and that, by inference, pollution levels are low. It is widely accepted that the ASPT index is very good at detecting high levels of organic pollution (for which it was developed), but it has been criticised because it does not take the relative abundance of the invertebrates found into account and it therefore performs poorly when attempting to detect diffuse pollution impacts. To address this deficiency, in recent years a number

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust Figure 7. Invertebrate WFD status of the 7 waterbodies comprising the River Ottery catchment. Supplementary WRT sampling sites are shown. Numbers correspond to EA sampling sites for which data has been re-analyses with additional indices.

of more sophisticated invertebrate indices have been developed which do incorporate an assessment of abundance and which are, in some cases, finely tuned to detect the more subtle and chronic impacts of diffuse pollutants such as sediment and pesticides. We felt that the lack of invertebrate monitoring in four of the waterbodies in the Ottery catchment, which has resulted in them receiving no invertebrate status under WFD, combined with the potential limitations of the ASPT index used, mean that there is little robust invertebrate evidence on which to base an assessment of river condition. In light of this, we have obtained the invertebrate sampling data from the Environment Agency in order to re-analyse it with the more sensitive indices available. Preliminary outputs from the reanalysis of existing invertebrate data to calculate indices that include abundance scores seem to show that the invertebrate assemblages are still scoring quite highly. In the next few months it is anticipated that the RIVPACS River Invertebrates Analysis Tool (RICT) will incorporate the ability to generate expected scores for several other more sensitive and pollution-specific indices. This will allow us to compare the observed and expected scores for these sites and draw more accurate conclusions about the ecological condition of the river. To further supplement this invertebrate data, we have also taken some additional invertebrate samples to fill in some of the gaps in the existing data. These samples have been identified to species-level and the abundances of each taxa have been recorded to allow the most informative and sensitive indices to be calculated. The collection of invertebrate samples to the RIVPACS standard is something that can easily be done by rivers trust staff following a short training course and to have samples sorted and identified by experts at an accredited laboratory is relatively inexpensive (prices start at ~ÂŁ120 per sample). 17

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust This makes invertebrate sampling a cost-effective way of obtaining a considerable amount of data about the condition of a river. Figure 8 shows the preliminary results in which the existing invertebrate data has been used to calculate an alternative pollutant-specific index; the Proportion of Sediment-sensitive Invertebrates (PSI) index. This measure can be used to assess the degree to which riverine sites are impacted by sediment. While it will be important to compare these scores with those predicted by RICT to get a true assessment of the degree of sedimentation in these rivers, the data in Figure 8 does give an initial indication that four of the waterbodies surveyed are showing intermediate signs of impact from sedimentation. In contrast, the other waterbodies appear to be minimally impacted by sediment. It is interesting to note that none of the waterbodies with invertebrate assemblages showing signs of sedimentation impacts have been sampled for invertebrates for over 10 years. Figure 8. Preliminary data derived from the re-analysis of existing EA samples collected at the sites shown in Figure 7 with the Proportion of Sediment-sensitive Invertebrates (PSI) index. Colours show approximate bands of sedimentation impact.

Phytobenthos (diatoms) Diatom indices are a well-established method for assessing water quality. It is widely accepted that a detailed evaluation of the structure and function of phytobenthic (diatom) communities in a river can provide robust evidence for assessing its ecological condition. Diatom community composition is particularly affected by changes in the pH and nutrient levels in the water and can be used to identify rivers impacted by these types of pollution. The criteria for the assessment of diatom communities for WFD classification were developed through the Diatoms for Assessing River Ecological Status (DARES) Project. This project assessed diatom assemblages at a series of reference sites and developed a model that allows the composition of the benthic diatom assemblage in a river to be predicted. Comparison of the predicted assemblage with that found through sampling allows the ecological condition of the river to be assessed. 18

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust None of the waterbodies in the Ottery sub-catchment have been given a diatom classification under WFD, but two diatom samples were taken on the Mid River Ottery in 2006 and so we can examine the data collected to get an impression of what was found. It is important to note that the calculation of a predicted diatom score is based on the average alkalinity of the river in the year in which the sample was taken, but because no alkalinity data was collected in 2006 we have based our calculation on the average for the four year period 2000 to 2003. The results of our analysis of these samples are shown in Table 2. This shows that these samples both give an unofficial classification of poor according to the WFD criteria for the Mid River Ottery waterbody. This gives an indication that the Ottery may well be impacted by elevated levels of nutrients in the water. Table 2. Re-calculation of diatom status for samples collected on the Mid River Otter waterbody. WFD diatom status class boundaries for UK rivers are also shown (UK TAG).

Mid River Ottery

June 2006

Sept 2006

Diatom score from sample (May 2006)

64.55

54.99

Annual mean CaCO3 (2000-2003)

32.53

Calculated expected score

21.37

24.58

Diatom EQR for WFD

0.45

0.47

Unofficial WFD classification

Poor

Boundary EQR High/good

0.93

Good/moderate

0.78

Moderate/poor

0.52

Poor/bad

0.26

Physicochemical indicators Having examined the biological indicators of river health it is clear that there may be some water quality issues that are affecting the ecological health of the River Ottery waterbodies. From the WFD classification we have established that all seven water bodies were classified as either high or good status for all of the physicochemical indicators. To reconcile the apparent discrepancy between these classifications and the biological phenomena observed and to verify whether lowlevel diffuse pollution problems underpin them, we have undertaken an array of extra analysis and monitoring. The assessments of physicochemistry made for WFD are based on water quality samples taken once a month for a year at each location. Depending on the measure, the summary statistic for the location is then calculated as the 90th percentile value (the value below which 90% of the samples lie) or the annual mean. 19

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust To derive the thresholds for classification the physicochemical conditions measured in thousands of sites classified as good for biological indicators are analysed. The value achieved by the best 90% of these good sites is picked as the standard for good ecological status against which the calculated summary statistic for a site is compared. We believe that there are several potential risks associated with this approach:1. The choice of the 90th percentile is intended to remove the risk that waterbodies that are not actually good status are erroneously included in the analysis, but this cut-off is quite arbitrary. It is quite possible that more than 10% of the waterbodies have been misclassified as a result of the issues already discussed with the biological classification methods adopted. 2. Monthly sampling over a one year period is sometimes criticised because extreme, infrequently occurring events often escape detection and the true level of a pollutant will be underestimated. In contrast, UK TAG believe that the Environmental Quality Standards they have set and the way they are expressed does allow for the accurate assessment of levels and trends in the pollutants analysed. In response to concerns that these missed extreme events may be what is damaging a river, UK TAG states that, â&#x20AC;&#x2DC;actions targeted at risk, or actions that reduce the amount of pollution, that are actually directed at achieving compliance with standards expressed as the annual mean or an annual percentile, also act on the underlying causes of more extreme events. Improvements in the mean and percentiles of river water quality are associated with parallel reductions in the frequency and scale of more extreme events.â&#x20AC;&#x2122; The problem with this is that in many cases their approach does not detect that the river is damaged and so no management is undertaken. To gain a better understanding of the physicochemical condition of the Ottery waterbodies we have examined Environment Agency water quality monitoring data collected over a 10 year period and, where they exist, integrated the results with the outputs from predictive models of pollution. In addition we are undertaking a further programme of water quality sampling in the coming months. Dissolved oxygen, biochemical oxygen demand (BOD) & ammonia UKTAG have derived WFD assessment standards only for chemicals where there is general confidence that they cause biological impacts. Three of these proposed standards are for dissolved oxygen (DO), Biochemical Oxygen Demand (BOD) and ammonia. Oxygen in rivers is affected by complex interactions between ecological processes and by anthropogenic pressures. Additions of organic matter such as discharges from sewage treatment works and storm overflows, and agricultural sources such as slurry and silage liquor, reduce dissolved oxygen due to the enhanced microbial respiration (quantified by Biochemical Oxygen Demand: BOD). In addition, these pollutants can all increase the level of ammonia dissolved in the water. The WFD standards for dissolved oxygen, BOD and ammonia are that 90% of samples must be above 75% dissolved oxygen saturation, below 4 mg/l BOD and below 0.3 mg/l ammonium respectively to achieve good status. The data for each of these parameters in the Ottery waterbodies for the period 2000-2010 is shown in Figure 9. This shows that, while the WFD standards are not being failed there have been several occasions in some waterbodies where damaging and even severe levels have been detected. 20

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust Figure 9. Preliminary data derived from the re-analysis of existing EA water samples collected from (1) Bolesbridge Water, (2) Canworthy Water, (3) Caudworthy Water, (4) Upper River Ottery, (5) Lower River Ottery, (6) Mid River Ottery,(7) River Ottery (upstream of Canworthy Water). Colours show WFD classification thresholds for each parameter. Numbers show number of occasions on which the failure value has been exceeded.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust Phosphate While it is recognised that nitrogen compounds, such as nitrates and nitrites, play a key role in the enrichment of many waterbodies, it is generally accepted that biologically available phosphorus compounds play a more critical role in nutrient enrichment impacts on rivers. The UKTAG commissioned the DARES (Diatoms for Assessing River Ecological Status) project team to develop regulatory standards for Soluble Reactive Phosphorus (SRP). Diatoms are regarded as the most sensitive biological element to increases in the levels of nutrients and the standards are set according to the SRP levels found in waterbodies with healthy, good status, diatom assemblages typical for a river of that type. The PSYCHIC (Phosphorus and Sediment Yield Characterisation in Catchments) Project, led by ADAS, has developed a process-based decision support model of phosphorus (P) mobilisation in land runoff and subsequent delivery to watercourses. Modelled transfer pathways include release of soil P, detachment of suspended sediment and associated particulate P, incidental losses from manure and fertiliser applications, losses from hard standings, the transport of all the above to watercourses in under-drainage (where present) and via surface pathways, and losses of dissolved P from point sources. At a catchment-scale the PSYCHIC model can be used as a screening tool to identify areas within the catchment which may be at elevated risk of phosphorus loss. It also facilitates targeted water quality sampling, farm visits and stakeholder discussion, which would then be followed up with detailed field-scale modelling. The PSYCHIC model framework therefore provides a methodology for identifying critical source areas of sediment and P transfer in catchments and assessing what management changes are required to achieve environmental goals. The phosphorus risk map derived from PSYCHIC is shown in Figure 10. This shows that there is an elevated risk of phosphorus being lost to the rivers and stream in the north of the Ottery catchment and in a number of areas on the main stem of the Ottery itself. The WFD threshold for good WFD phosphorus status on a river of this type is an annual mean of 40Âľg/l. As Figure 10 shows, several of the waterbodies in the Ottery catchment have 10 year means very close to this level and one, Caudworthy Water, has a 10 year mean in excess of this level 44Âľg/l. In addition, all seven waterbodies have had samples well in excess of this level. Further evidence of the levels of phosphorus being lost to the Caudworthy Water has been obtained using the Export Coefficient Model Plus (ECM+) which uses phosphorus export coefficients and agricultural census data verified by farmer interviews and field surveys to predict the annual losses of phosphorus compounds from the catchment. The result of this analysis, which is presented in the form of a probability distribution, is shown in Figure 10 (lower panel). The model predicts that around 2.5 tonnes of phosphorus might be being lost from the Caudworthy Water, an amount that would equate to a failure of the quality standard for WFD.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust Figure 10. Preliminary data derived from the PSYCHIC Phosphate Model, the re-analysis of existing EA water samples collected from (1) Bolesbridge Water, (2) Canworthy Water, (3) Caudworthy Water, (4) Upper River Ottery, (5) Lower River Ottery, (6) Mid River Ottery,(7) River Ottery (upstream of Canworthy Water), and the ECM+ Phosphate Model. Colours show WFD classification thresholds. For full explanation see text.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust Sediment & dangerous substances Fine sediment loads in rivers draining agricultural areas are a major problem in many parts of the UK. Sediment impacts river ecology both directly by smothering the substrate in which invertebrates live and fish species such as salmon and trout lay their eggs, and indirectly because it carries other pollutants such as microbes, nutrients and pesticides in to the water. There is no condition assessment for impacts resulting from sedimentation within the WFD classification system. Suspended sediment loads are measured at the outflow of main tributaries, but these are too infrequent to assess the levels of sediment in the river which are typically flow related and occur over short periods of high flow. There are a number of methods for assessing the levels of sedimentation and their impacts on the ecology of the river. Westcountry Rivers Trust are undertaking sedimentation assessments of the substrate in various sections of the Tamar catchment using the established fluvial audit methodology and this is being done in parallel with sedimentation research project being undertaken by the University of Plymouth. In addition, we will be using real-time and automated high-flow sampling to study the sediment load in the river (using equipment like that shown in Figure 11). The situation for the detection of pesticides is similar to that for sediment. Despite the Ottery catchment forming a considerable proportion of the catchment for the Gunnislake drinking water abstraction, no chemical status is recorded for any of the Ottery waterbodies. The waterbody at Gunnislake, which forms the Drinking Water Protected Area for the abstraction, fails the WFD chemical status standard and we have considerable evidence that there are regularly pesticide levels at Gunnislake in excess of the 100 ng/l regulatory standard for drinking water. If a 100 ng/l spike of a pesticide detected at Gunnislake has originated in the Ottery catchment then its concentration in the Ottery is likely to be 1000 ng/l â&#x20AC;&#x201C; 10 fold higher than the regulatory standard. To assess the pesticide load in the Ottery catchment we are going to be using three different approaches: (1) regular spot sampling during high flows, (2) invertebrate monitoring for calculation of the SPEAR (Species At Risk) pesticide load index, and (3) a novel method of passive sampling to assess pesticide load that is being developed with the University of Portsmouth. Figure 11. Water quality monitoring equipment used to take real-time and/or regular out-of-hours spot samples.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Causation diagnosis The evidence we have collected appears to suggest that the ecological condition of the River Ottery and its tributaries is being impacted in some locations. In particular, we have preliminary evidence which suggests that the fish, invertebrate and diatom assemblages in the catchment may be degraded and that these impacts may be due to the occurrence of pollution in the form of sedimentation, organic pollution and nutrient enrichment. In light of these findings, and in order to develop tailored and targeted catchment management interventions, we must use all of the data and tools available to identify what is causing these problems.

River Basin Management Plan (RBMP) The South West RBMP lists the most frequent causes for waterbody failure identified by Environment Agency staff using monitoring data and their knowledge and experience of individual waterbodies. These causes and their suspected impacts are summarised Table 1 (adapted from the SW RBMP). The SW RBMP and the WFD classifications data tables do not give any specific reasons for the failure of the two waterbodies in the Ottery catchment. Table 3. Main reasons (known or suspected) for the South West’s rivers not achieving good ecological status.

Reason for Failure

Key elements impacted

Diffuse source agricultural

ammonia, diatoms, dissolved oxygen, fish, invertebrates, macroalgae, macrophytes, pesticides, phosphate

Disused mines - point and diffuse source

cadmium and its compounds, copper, fish, invertebrates, nickel and its compounds, pH, zinc

Point source water industry sewage works

ammonia (phys-chem), diatoms, dissolved oxygen, fish, invertebrates, macrophytes, phosphate

Physical modification - urbanisation and flood protection

fish, invertebrates, mitigation measures

Physical modification - water storage and supply (including for power generation)

fish, mitigation measures

Physical modification - land drainage

fish, mitigation measures

Physical modification - barriers to fish

migration fish

Physical modification - wider environment

mitigation measures

Point source trade industry - non water industry

diatoms, fish, invertebrates, macrophytes

Abstraction

hydrology

The SW RBMP goes on to state that, ‘because classification involves a wider range of elements than previous monitoring schemes, and many of the key pressures are complex and occur in combination, we often do not know the reason for a failure. For many waterbodies either the reasons for failure are unknown or it is uncertain whether there is a failure or whether pressures really are causing an impact.’

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust The conclusion of the SW RBMP is that further investigations will be required and to this end the Environment Agency are undertaking field surveys and desk studies to create Waterbody Information Packs, which summarise the problems in certain waterbodies and their causes. The aim of this work is to target regulatory and catchment management interventions in waterbodies by Environment Agency staff and other organisations in a catchment management partnership. One limitation of this extremely important work is that, until recently, it has largely been undertaken in isolation from local stakeholders and groups with an interest in catchment management. Another is that the survey work has been contracted out at considerable cost and, perhaps most importantly, studies have only been undertaken on waterbodies at less than good ecological status. Westcountry Rivers Trust believe that we can make a significant contribution to the waterbody investigation process and welcome recent increases in the integration of our investigative work with that of the Environment Agency. This enhanced collaboration and improved data sharing arrangements will greatly facilitate the delivery of catchment management across the Westcountry. o The following sections serve to illustrate how, through the integration of existing data and modelling outputs with targeted field surveys of different types, we can diagnose the causes of waterbody degradation in a catchment such as the Ottery.

Sediment Preliminary data analysis by a number of groups has shown that there may be sedimentation problems occurring in the Ottery catchment and so further investigation is required to determine its origin. The methods currently being adopted to identify the sources and dynamics of sediment transport in these rivers include:1. SCIMAP fine sediment risk modelling. Uses topographic, rainfall and land-use data to identify areas where a high propensity for the lateral flow of water over the land is likely to mobilise fine sediment and transport it to the river. 2. Sediment river walkover surveys. Rapid river surveys typically undertaken in wet weather to identify sources of sediment and organic material entering the river. 3. Source apportionment using magnetic particles. Developed by ADAS Water Quality to identify areas of river bank or land contributing to the in-channel sediment load. 4. Source apportionment using chemical/genetic crop signatures. Developed by ADAS Water Quality and University of Plymouth to identify areas of river bank or land contributing to the inchannel sediment load. The fine sediment risk map shown in Figure 12 was generated using the SCIMAP model. It gives an indication of where the highest risk of sediment erosion risk occurs in the catchment and also an indication of where the greatest risk of high sediment concentrations in the river might occur.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust The model indicates that, where the condition of the land is poor and sediment is available for mobilisation, there are several areas where it could generate high levels of suspended sediment in the tributaries of the Ottery. Interestingly the main River Ottery does not score highly for sediment risk due to dilution with cleaner water from higher in the catchment.

Figure 12. Maps showing the erosion risk areas (top) and in-stream sediment concentration risk (bottom), identified by the SCIMAP fine sediment risk model.

In 2010 the Environment Agency commissioned APEM to conduct walkover surveys of the entire River Ottery and its tributaries. During this survey they recorded all incidences of sediment, silt and

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust organic material such as slurry/manure entering the river. Each incident was classified on a scale of 1-3 according to its severity. The APEM findings, which included 653 recorded pollution incidents, are shown in Figure 13 along with a severity weighted â&#x20AC;&#x2DC;hotspotâ&#x20AC;&#x2122; analysis to show concentrations of incidents. Interestingly, there are considerable levels of overlap between what they found in the catchment and what the SCIMAP model predicted.

Figure 13. Maps showing the location of sediment and organic pollution incidents found during the 2010 APEM river walkover surveys (top) and a weighted hotspot analysis showing the greatest concentrations of incidents found (bottom).

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Organic pollution & nutrients The APEM walkover survey revealed that considerable quantities of organic pollutants, such as slurry/manure and polluted water from farmland, were entering the river, especially during wet periods. It is highly likely that these point and diffuse sources of pollution from agriculture could be one of the most significant underlying causes of the degraded ecological condition of the river in many sections of the Ottery catchment. Over the last 15 years, the Westcountry Rivers Trust have visited over 70 of the 80-90 farms in the Ottery catchment and are currently undertaking further detailed farm assessments across the catchment as part of our Upstream Thinking initiative with South West Water. During our farm assessments we identify where poor farm infrastructure or farming practices pose a threat to the water quality in the river and document the information to facilitate the targeting of on-farm interventions. Figure 14 shows some example of point and diffuse pollution sources that we have encountered on farms during our recent survey work. Figure 14. Example images showing on-farm point and diffuse sources of pollution encountered during farm surveys.

It is important to note that there are also other potential sources of nutrients and organic pollutants that should be considered in addition to the agricultural sources. For example, of the approximately 1,200 residential properties in the catchment some 500 are connected to sewage treatment works that discharge to the river, while the remainder (~700) presumably have alternative sewerage disposal infrastructure such as sceptic tanks or cesspits. It is likely that both types of sewage treatment infrastructure will be contributing to the nutrient load in the river, especially sceptic tanks that are not well managed or that are sited in close proximity to a watercourse. At present the impact of sewage effluent on the rivers is not known, but further study is being undertaken to identify bacteriological and chemical markers that will indicate where it is a threat to the condition of the river. 29

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Strategic Evidence & Partnership Westcountry Rivers Trust

Delivery of measures Having developed a targeted and tailored plan of what needs to done and where we then deliver a suite of targeted catchment management interventions to achieve the best possible environmental and economic benefits for all of the interested parties. The tools available to us and other organisations are diverse and varied and all have their merits, but it is their tailored and targeted application in response to challenges encountered in the catchment, and not a one-size-fits-all approach, that will yield the best results for the condition of the river.

River Basin Management Plan The SW RBMP 2009 outlines measures that will need to be implemented by various groups to make improvements to river waterbody condition and predicts that 42% of surface waters will be at good or better ecological status by 2015 and 65% of assessed surface waters will be at least good biological status. The key groups they identify as being important for these predicted improvements are: the agriculture and rural land management sector; angling, fisheries and conservation organisations; central government, the Environment Agency; industry manufacturing and other business, local and regional government; the mining and quarrying industries; navigation; the urban development and transport sector; the water industry, and individuals and communities. The South West RBMP outlines how a combination of incentive, advisory and regulatory measures are already in place for a number of years to help farmers and other land managers protect the environment and cites the Code of Good Agricultural Practice and agri-environment schemes, such as Entry Level Stewardship and Higher Level Stewardship, as good examples. Figure 15 shows the current uptake of agri-environment schemes across the Ottery catchment.

Figure 15. Current distribution of farms in Countryside (CSA), Entry Level (ELS) or Higher Level (HLS) Stewardship Agreements.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust Having listed the pre-existing tools that should be used to return catchments to good ecological status the RBMP does then acknowledge that, â&#x20AC;&#x2DC;the way in which land is being managed is still having a negative impact on natural resources and further action will be needed to address diffuse pollution and other key pressures in rural areasâ&#x20AC;&#x2122;. To achieve the improvements required the RBMP states that there should be adequate regulation, promotion of Catchment Sensitive Farming, promotion of agri-environment schemes and increased partnership working. While, the relative merits of the current tools for the delivery of catchment management and river restoration are discussed in another report from this project, overall the Westcountry Rivers Trust agree entirely with this ambition. However, we also believe that our suite of fully funded and highly effective catchment management interventions, which combine practical advice on good farming practice with grants for on-farm measures tailored to address the problems on the ground, represents another hugely beneficial and complimentary approach.

WRT on-farm measures Over the last 10 years the Westcountry Rivers Trust has developed farm management advice, which can help minimize loss of pollutants from farms whilst maximizing their on farm usage to increase yields and save costs. Some of the most common on-farm Best Farming Practices (BFPs) we recommend to farmers are illustrated in Figure 16. These BFPs have been assessed by a group of academics, funded by DEFRA, to produce a peerreviewed and published manuscript, which describes the effectiveness of the BFP measures for the reduction of diffuse agricultural pollution (Cuttle et al 2007). During the development of the measures there were a number of key design considerations which allow our farm advisors to correctly tailor and target their application:Mechanism of action. It is important to understand the mechanism via which the intervention will reduce pollution. Often this will require the presentation of evidence that it is the farming practice which is actually is causing pollution before intervention. Applicability. Each measure must have the farming systems, regions, soils and crops to which it can be applied clearly defined. Farm advisors must recommend interventions that are suitable for the situation found on a farm. Feasibility. The ease with which the measure can be implemented and any potential physical or social barriers to its uptake or effectiveness must be identified. Careful consideration must be given to measures that have impacts on other farming practices. Costs and benefits. The cost of implementing, operating and maintaining the measure must be clearly understood. The potential practical and financial benefits to the farmer of implementing the measure must also be estimated as it is vital for encouraging uptake of the measures. In some circumstances, for example where the cost is high or the measure will result in a loss of income to the farmer; there will be a need for the farmer or farm advisor to find additional funding from incentive or capital grant schemes.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Figure 16. Best Farming Practices (BFPs) which can minimize loss of pollutants from farms.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Assessment of outcomes The principal, over-arching aim of our work is to improve raw water quality in Westcountry rivers and to significantly contribute to their attainment of good ecological status in accordance with the EU Water framework Directive. It is therefore vital for us to collect sufficient evidence to provide an objective and scientifically robust assessment of the effectiveness of our interventions. Ultimately, we must be able to justify that the money we have spent and the interventions we have made across the landscape have either delivered significant improvements in raw water quality (and have therefore made significant contributions to the delivery of good ecological status of river catchments) and have generated significant secondary financial, ecological and social benefits. In light of these over-arching aims, we have developed a range of approaches that will allow us to assess various outcomes delivered by our catchment management work. This approach is designed to achieve the following objectives; • Quantification of our interventions. We must gather precise and detailed evidence of what we have delivered, where we have delivered it, what it has cost and, perhaps most importantly, what the intended outcome is for each. • Establish strong baseline evidence. If we are to demonstrate the effectiveness of our interventions, it is vital that we collect baseline data (of the type presented in this report). In addition to temporal (before intervention) controls we should also examine the potential for some catchments/sub-catchments to form spatial controls for our studies. • Monitor and evaluate benefits. We will attempt to collect a comprehensive and robust set of data and evidence which demonstrates qualitatively and quantitatively that we have achieved genuine improvement in raw water quality and created ancillary benefits. • Develop and disseminate best practice. We want to establish a core methodology that can be adopted, with modification, by any catchment management partners. This will ensure that monitoring outcomes is consistent and that data and evidence can be integrated into that of other organisations (such as the Environment Agency). We also want this methodology to provide a framework for the evaluation of future initiatives of this type in the Westcountry and in other regions of the UK.

Environmental improvements DEFRA are currently funding a £5 million Demonstration Test Catchment Project, which is evaluating the effectiveness of on-farm measures to improve water quality when their delivery is scaled-up to a real-life whole sub-catchment situation. The Westcountry Rivers Trust’s work to deliver on-farm measures in partnership with South West Water on the Tamar represents one of the DEFRA Test Catchments. While we wait for the findings of this research there are a number of mathematical models that we can use to predict the cumulative effects of implementing on-farm BFP measures at a catchment scale.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust Perhaps the most highly regarded model of this type is the social participatory Export Coefficient Model ECM+ developed by the University of East Anglia under the current Rural Economy and Land Use (RELU) Programme in which the Westcountry Rivers Trust is a partner. This model has been reviewed by scientific peers, the DEFRA Water Policy Group and local stakeholders and is currently being used as a method for rural land management planning through stakeholder participation. We have determined through our investigations in the Ottery catchment that phosphate is an important pollutant occurring in the waterbodies. We have also undertaken surveys, which have identified that this phosphate is primarily derived from organic agricultural by-products such as slurry from dairy herds spread onto land, slurry leaking directly into the watercourse or through sediment with phosphate attached moving into water with erosive flows of water over bare soils. In addition, fertilisers spread on land to increase yields, which contain inorganic phosphate are being washed off the land into watercourses. As we have already seen the ECM+ model can predict the quantity of phosphorus compounds being lost to the river in a waterbody such as the Caudworthy Water, but it can also estimate the reduction in this amount of phosphorus that could be achieved if the most popular on-farm BFP measures were taken up on all of the 15 farms in that waterbody. The results of these analyses, shown in Figure 17, indicate that the annual loss of phosphorus from the Caudworthy Water could be reduced from 2.5 tonnes to 0.5 tonnes, and shift in the phosphorus WFD classification from poor to good. Figure 17. Shows the marked reduction in phosphorus export from the Caudworthy sub-catchment in response to 100% implementation of the 35 most popular BMPâ&#x20AC;&#x2122;s.

Ancillary benefits In addition to delivering tangible improvements in water quality and the ecological condition of the rivers, our catchment management interventions should enhance the delivery of several other ecosystem services, including water resources regulation, greenhouse gas sequestration and biodiversity. We will be undertaking extensive further monitoring and modelling to quantify the magnitude of these ancillary benefits.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Cost-benefit analysis The Westcountry Rivers Trust are committed to undertaking a full cost-benefit analysis for the catchment management approach outlined in this report. We have already developed a clear and detailed understanding of the costs associated with our monitoring and intervention methods and this has been summarised in the Component B report of the Strategic Evidence & Partnership Project. In addition we are working on a number of projects that will allow the financial benefits of our work to farmers, land managers, the funders of ecosystem services provision and society as a whole to be fully quantified. The findings of this on-going work will be reported in 2012.

Conclusion The current Water Framework Directive monitoring and catchment management intervention strategy, as encapsulated in the South West River Basin Management Plan, gives a spatially and temporally averaged estimate of waterbody status that is largely designed to report upward and centrally. While we acknowledge the importance of the RBMP as a strategic vision for the management of river catchments generally, we are concerned that there is a general lack of fine-scale resolution and local sensitivity in the high-level and nationally applicable approach to river assessment it adopts. As a result of these deficiencies we feel that there may be a number of waterbodies for which the true condition of the river, and the problems it faces, are not reflected in their WFD classification. This uncertainty means that the current waterbody assessment methods and criteria are not particularly useful for informing the integrated and targeted restoration of river catchments at a local, subcatchment scale. Having gained further insight into the condition of the study waterbodies through supplementary monitoring and more detailed data analysis, and having characterised the causes of the degradation encountered, we are now far better placed to recommend a targeted, cost-effective and evidencebased programme of remediation for the catchment in which we work. The tools used by WRT are accredited, available, scalable and transferable as are the recommendations arising. This means that this process of detailed diagnosis and evidence based treatment could be readily delivered on any catchment. Moreover, the detailed characterisation of the catchments that we have undertaken allows us to access funds from local groups who would benefit from the rivers improved status and to direct those funds to the organisations and individuals who are best placed to manage the river. This makes the whole process action-oriented, decentralised and cost-effective with full community engagement.

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

Further information & contacts Dr Dylan Bright, Trust Director Director of the Trust with a sound scientific background, experienced in virtually all aspects of freshwater sampling Dylan has led numerous research projects and is a published scientific author. Email: dylan@wrt.org.uk Dr Laurence Couldrick, Head of Catchment Management Dr Laurence Couldrick is the Head of Catchment Management at the Westcountry Rivers Trust and Project manager for the Interreg funded WATER Project on the Payments for Ecosystem Services approach to river restoration. Email: laurence@wrt.org.uk Dr Nick Paling, GIS Officer Nick is an ecologist with an interest in GIS and will be digitising data collected from catchments to record, assess and map catchments to allow monitoring, modelling and visualisation of outcome. Email: nick@wrt.org.uk Hazel Kendall, Upstream Thinking Project Officer, BSc (Hons) AIEEM Working with Upstream Thinking partners to collate information and data collection for reporting, Hazel will combine this role with bio-monitoring undertaken as part of the proof of concept study supporting the physical works of the initiative, using a range of sampling techniques and Biotic Indices. Email: hazel@wrt.org.uk

Component A - Appendix 2

Strategic Evidence & Partnership Westcountry Rivers Trust

References Carvalho L, Bennion H, Darwell A, Gunn I, Lyle A, Monteith D and Wade M (2003). Physico-chemical conditions for supporting different levels of biological quality for the Water Framework Directive for freshwaters. Report by the Environment Agency. Kelly, M.G., Juggins, S., Bennion, H., Burgess, A., Yallop, M., Hirst, H., King, L., Jamieson, B.J., Guthrie, R., Rippey, B. (2008) Use of diatoms for evaluating ecological status in UK freshwaters. Report by the Environment Agency. Cuttle, S.P. et al., 2007. An Inventory of Methods to Control Diffuse Water Pollution from Agriculture (DWPA): A User Manual. DEFRA Report. Haygarth, P.M. et al., 2006. Processes affecting transfer of sediment and colloids, with associated phosphorus , from intensively farmed grasslands : an overview of key issues. Hydrological Processes, 4413(October), pp.4407-4413. Natural England, 2010. An evidence base for setting organic pollution targets to protect river habitat. Natural England Technical Information Note, TIN076. Willie Duncan, Robin Guthrie & Roger Owen (2006) The Development of Soluble Reactive Phosphorus Regulatory Values in UK Rivers. SEPA Report for UK TAG. UK Technical Advisory Group on the Water Framework Directive (2007) Recommendations on Surface Water Classification Schemes for the purposes of the Water Framework Directive. Ellis J.E. (2007) Combining Multiple Quality Elements and Defining Spatial Rules for WFD Classification. Report by the Environment Agency.

Defra Strategic Evidence and Partnership Project Component A Appendix 3 Strategic Evidence and Partnership Report Waterbody Assessments

Component A - Appendix 3

DEFRA Strategic Evidence & Partnership Fund

Strategic Evidence and Partnership Report

Severn Rivers Trust

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Component A - Appendix 3

Contents Contents..................................................................................................................... 2 1

Waterbody Assessment....................................................................................... 3

1.1

Current Waterbody Classifications.................................................... 3

1.2

SRT Waterbody Assessment ............................................................ 4 1.2.1

Failing Waterbodies ........................................................................................................4

1.2.2

Good Waterbodies........................................................................................................11

1.3 2

Chosen Waterbodies ...................................................................... 13 Methodology ...................................................................................................... 14

2.1

River Walkovers.............................................................................. 15

2.2

Scimap ............................................................................................ 15

Results............................................................................................................... 15

3.1

Septic Tanks ................................................................................... 15

3.2

Land use mapping .......................................................................... 16

3.3

Scimap Results ............................................................................... 17

3.4

Walkover Results ............................................................................ 21

Conclusions ....................................................................................................... 26

4.1

Waterbody Assessment .................................................................. 27

4.2

Tools ............................................................................................... 27

5 5.1 6

4.2.1

Scimap ...........................................................................................................................27

4.2.2

Walkovers .....................................................................................................................28

Recommendations............................................................................................. 29 Mitigation Measures........................................................................ 30 Appendices ........................................................................................................ 33

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1 Waterbody Assessment The Severn Rivers Trust completed a systematic review of the Water Framework Directive (WFD) ecological assessments, including analysis of the Waterbody Data within the Rea catchment. This initial assessment identified key waterbodies where there is low confidence in current classification and where there is a need to identify the cause of WFD failure.

1.1 Current Waterbody Classifications The River Rea is a small river that flows through south east Shropshire and passes just to the east of the small market town of Cleobury Mortimer, before entering the River Teme at Newnham Bridge in Worcestershire. Its waters eventually reach the Bristol Channel via the Severn. The upper stretch of the river is known as the Rea Brook. For a short stretch between Cleobury Mortimer and Neen Sollars the river forms part of the Shropshire‐Worcestershire border. The name of the river derives from a root found in many Indo‐European languages and means "to run" or "to flow". The historic or alternative name for the river is the "River Neen" and there are various settlements along its course of that name or variations of it, such as Neen Sollars, Neenton and Neen Savage. The character of the Rea catchment varies considerable between the upper and lower reaches. The upper Rea runs off Brown Clee Hill near to Ditton Priors cutting through sloping valleys. The river is reasonably fast flowing with series of pools and riffles and should provide an ideal habitat for brown trout and salmon. Uncoppiced alders line much of the banks, causing dark tunnelling of long sections of the river channel. As the gradient declines below Neen Savage, the Rea’s lower reaches slows and widens with a more uniform depth and flow rate. Throughout the catchment, riverside banks are steep and increasingly vulnerable to erosion with particular areas such as Hopton Wafer, exhibiting heavily forested steep bank sides. Land use is increasingly a mix of temporary grassland with intensive arable cropping. A mix of cereals and mixed livestock farming are predominant throughout with a large proportion of dairy farms still in existence, though this has been steadily declining due to the collapse of small scale dairy farmers. Figure 1.1.1 WFD Classifications of the Rea Catchment The Rea is a sub catchment of the Severn River Basin District and comprises of 8 individual waterbodies. Current classification has identified 3 of the 8 waterbodies are overall and ecologically poor, failing within the WFD. Of those 3 waterbodies, 2 are failing due to fisheries classifications resulting in poor status, whilst the third due to fish and phytobenthos data (See table 1.1 and 1.2). The waterbodies have been assigned unknown reasons and pressures for failure (Decision code: B2a) or suspected failure for sediment from diffuse source agricultural, with the source (sector or general activity) of the sediment impacting on the biology, though not yet confirmed (Decision code: S2a), with an unknown or technically infeasible solution. The remaining 5 waterbodies have been classified as Good.

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1.2 SRT Waterbody Assessment

1.2.1 Failing Waterbodies 3 out of the 8 waterbodies are failing due to fish and diatom data with an unidentified cause. Mill Brook – source to conf. River Rea GB109054044250  This waterbody has been classed as failing due to low fish numbers, however, the fish data used for classification is inappropriate. The location of the fish site is within a differing waterbody and is outside of the Rea catchment, in a neighbouring watercourse. Understandably, this draws very low confidence in the waterbody’s classification as this is based on incongruous data.  There is no physical‐chemical (phys‐chem) data monitored for this waterbody and classification was attained using extrapolated data from another waterbody. This also surmounts to a low confidence in its use in classification. Data has been collated since December 2009, but this was not used nor was it available to overview.  Concern over this waterbody has been highlighted as the brook flows into the lower River Rea waterbody (GB109054044260), which has also been classified as poor. Significant problems with siltation are known within the River Rea catchment and it is highly probable that the Mill Brook is also suffering the negative impacts associated with siltation.  Historical data of both the BMWPP and ASPT (not used in this waterbodies classification) appear to show a downward trend suggesting that water quality was declining during that period (Figure 1.2.1 1993‐1997). There has been neither explanation to its absence within the classification nor why the monitoring stopped, even though deterioration was observed.  The absence of any real data means there can only be a low level of certainty in its classification and demonstrates the need for further investigation to be able to draw any sound conclusions to the status of this brook. .2.1,

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shows the BMWP and ASPT scores recorded on Mill Brook before the cessation of monitoring. BMWP and ASPT scores observed at Neen Sollars on the Mill Brook 200

180

6.8

160

6.6 6.4

120

6.2

100

BMWP ASPT

5.8 5.6

Linear (BMWP) Linear (ASPT)

40 20

ASPT

BMWP

140

5.4

5.2 29-Sep-97

24-Apr-97

17-Apr-97

7-Oct-96

28-Feb-96

15-Aug-95

8-Feb-95

4-Oct-94

8-Mar-94

7-Sep-93

3-Jun-93

15-Feb-93

Sample date

R.Rea Conf. Farlow Brook to Conf River Teme‐ GB109054044260  This waterbody is classified as poor due to results from the fish data. Fish classification was derived from two fish sites surveyed in 2003: Neen Sollars (SO6630072300), and Newnham (SO6440069200). One site was exceptionally poor with a single eel caught, whilst the other site had a better diversity of fish but of low densities. Both sites appear to show there is an overall decline in the density of fish. Further investigation into the fish classification was not available as the data was not presented in time when requested.  Neen Sollars was classified as bad as only I eel was recorded (Figure 1.2.2 Density of Fish Caught at Neen Solars on the River Rea). FCS2 predicted that there was a high probability of catching Atlantic salmon, trout, bullhead, stone loach and minnow. In a previous survey at this site in 1999 a mixed population of coarse fish including chub dace and gudgeon was caught but in very low numbers a single brown trout was recorded. 2003 was an exceptionally poor year and the classification reflects this.

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Density of fish caught at Neen Solars on the River Rea 0.4 Density garms per Are

0.35 0.3 0.25 0.2 0.15 0.1 0.05 0 1993

1999

2003

Year Eel

Roach

Gudgeon

Brown trout

Chub

Dace

Figure 1.2.2 Density of fish caught at Neen Sollars on the River Rea



Newnham Bridge was classified as good, having a good mixed population of coarse and salmonid fish (Figure 1.2.3) with minor species. A classification of high would have been achieved if more trout and salmon had been caught. It is clear that 1993 was a good year at this site. Subsequent years have seen reduced catches.

Density of fish caught at Newnham on the River Rea

Density garms per Are

3 2.5 2 1.5 1 0.5 0 1993

1999

2003

Year

Eel Dace Minnow

Roach Atlantic Salmon Stone loach

Gudgeon Pike Bullhead

Brown trout Grayling

Chub Lamprey

Figure 1.2.3 Density of fish caught at Newnham on the River Rea



Insufficient data has been collected at both sites to make any comment on trends occurring overtime. An investigation was planned in 2010, which would have included both of these

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

Diatom data collected from this waterbody was not used to ascertain its classification. However the results were used, inappropriately, to derive classification for the waterbody located above (4280). This has a classification of poor, with high confidence. Again this has raised doubts to its use and unclear explanations as to why it was not used for this waterbodies classification. There are 3 monitoring points within this waterbody for phys‐chem data. The results indicate High classification, with the exception of phosphates, as Good. However, there is a degree of risk that the classification for phosphate will slip to Moderate, as annual averages recorded are bordering to the lower class boundary and trends indicated a probable downward shift in the future. (see below)

Table 1.2.1 Physchem classification was high for all determinands except phosphates, which were good. This is based on data from 3 sites:

Site

NGR

SLIMWIMS

Prescott

SO66134 81120

15785620

A417 Bridge, Cleobury Mortimer

SO67976 76332

15782410

Newnham

SO64391 69172

15779320



All of these sites are monitored under a ‘mandatory statutory EU Directive’ code. Data from all three sites was very similar. All determinands showed reasonable stability and were unlikely to change status. The only exception is phosphates at Newnham Bridge (Figure ) which was close to the margin between good and moderate status and has exceeded the class boundary (o.12mg/l annual average) in recent years.

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Figure 1.2.4 Orthophosphate measured at Newnham Bridge on the River Rea



Unusually, suspended solids have been measured at each site (Figure 1.2.5Error! No bookmark name given.). Similar trends can be seen at all sites and are subject to large fluctuations, with some exceptionally high concentrations.

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Figure 1.2.5 Suspended solid results from 3 sites in the Lower River Rea (values exceeding 100mg/l removed)



Similar trends for suspended solids can be seen at all sites, suggesting that the majority of suspended solids are derived higher up in the catchment. In some years (2008) the annual

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

The samples are taken on a monthly basis and, therefore, the true magnitude and frequency of events is uncertain. No seasonal model could be fitted to the data from any of the three sites. The problems with suspended solids, which are so apparent in the field, are not reflected in all of the elements within WFD classifications and providing tangible evidence of siltation problems and the impact, if any, this has on the ecological community is of the greatest importance in the River Rea catchment. Invertebrate data was not used in the classification, though the ASPT scores are exceptionally stable indicating that water quality is very good. This would suggest that any suspended solids are not adversely impacting the macro‐invertebrate community. The BMWP score is less stable, but this is likely to reflect changes in the physical habitat rather than water quality. However, there is a long established monitoring point at Newnham Bridge, with sufficient data to provide a robust classification. BMWP and ASPT scores recorded at Newnham Bridge on the River Rea 7

250

6 200

150

100

ASPT

BMWP

2 50 1 0

0 Mar-10 Oct-09

Aug-09 Apr-09

Nov-08 Jul-08

May-08 Oct-07

Apr-07 Nov-06 Jul-06 May-06

Oct-03 Apr-03

Nov-01 May-00

Sep-98 Mar-98

Sep-97 Apr-97

Oct-96 Feb-96

Sep-95 Mar-95 Sep-94 Apr-90

Nov-89

Sample date BMWP

ASPT

Linear (ASPT)

Linear (BMWP)

Figure 1.2.6 BMWP and ASPT scores recorded at Newnham Bridge on the River Rea



The classification elements used in this waterbody give a mixed picture to its condition and again a low confidence in its classification due to lack of accurate data. The general indication is that water quality is good as both the phys‐chem results (which were used in classification) and the invertebrates (not used in classification) classify as good. But diatoms, which could have been used in its classification, were poor, with high confidence. The fish data used was collected in 2003 and therefore does not accurately reflect the current situation, though at both sites there appears to be an overall decline in the density of fish.

River Rea conf Moor Bk to conf Farlow Brook – GB109054044280

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 

  



The classification of poor was based on both fish and diatom data. The diatom data was collected from a site outside of this waterbody and should not have been used in its classification. An investigation into a perceived decline in the brown trout population reported by anglers was undertaken in 2008, the data from which was used for classification. The conclusion of this investigation, which mainly focused on the upper reaches of the River Rea, was that fish recruitment was poor, with only a few brown trout recorded with no additional minor species recorded, most likely, as a result of suspended solids. There is a sense that this may be an error and clarification could not be attained as the data was unavailable. Based on extrapolated data, the phys‐chem was classified as high for all determinants except phosphates, which were good. Invertebrates were not used in the initial classification but have been since been collected from 500m upstream Farlow Brook at the lowest part of this waterbody. There is insufficient data to calculate a classification at present. Macrophytes were not used in the initial 2009 classification. They were, however, used in the 2010 classification (a single survey carried out in 2007 at the 500m upstream Farlow Brook site) where they resulted in a moderate classification with 53% probability that the survey falls within the moderate band. However, there was a 44% probability that the classification was poor. Recent macrophyte data, collected in 2010 from three sites resulted in a Good classification. During these plant surveys excessive silt was noted at all three sites. Sometimes the silt was sufficiently thick so obscure the macrophytes, namely mosses, which when disturbed produced huge plumes of silt into the watercourse. The apparent problems with suspended solids in this waterbody, not necessarily being reflected by all elements, are likely to give a complicated picture of the status of this waterbody. A move towards growing maize in the catchment was highlighted as a potential cause of increasing siltation. The classification of this site is highly unreliable due to a number of errors. Taking into account all the data, many of the elements are likely to be good but diatoms are at risk of being poor, though the data was collected from a site outside of this waterbody. Likely, there are errors in the fish data, resulting in a poor classification, though this could not be confirmed.

1.2.2 Good Waterbodies All of the 5 remaining waterbodies have been classified as Good, solely using extrapolated phys‐ chem data from the most southerly positioned waterbody. As mentioned before, there is an indication that the phosphate levels may drop to a classification of moderate. All of the 5 good waterbodies are located upstream of this monitored waterbody and therefore it would be appropriate to assume that levels are of the same or are below this classification. Similar trends were observed at the three monitoring sites, suggesting that the majority of suspended solids are derived higher up in the catchment. Overall, the wider River Rea catchment has long been known to have issues with suspended solids and there is the likelihood that this is reflected in these waterbodies. As limited or no monitoring has taken place on any of these brooks with dependency on classification from extrapolated data; this in itself draws low confidence in their classifications. Farlow Brook source to conf River Rea – GB109054044270

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

Based on current phys‐chem data this waterbody is in good status (derived from a single site in the waterbody). It has been documented there are sedimentation issues within this waterbody with Sonde data indicating elevated levels of suspended solids, measured since 2010.

River Rea source to conf Cleobury Brook GB109054044340  The current classification of good is based entirely on extrapolated phys‐chem data. There is very little data to validate classification and therefore draws low confidence in its status.  The Environment Agency (EA) have stated within their review that there is a significant risk that this waterbody has been incorrectly classified and is of lower status than initial classification suggests, worse than good, as there are known problems within the catchment with suspended solids. There is very little data to validate classification and the true condition of this waterbody is not being captured as there is no monitoring being undertaken. Moor Brook source to conf River Rea GB109054044300, River Rea conf Cleobury Brook to conf Moor Brook GB109054044290 and Cleobury Brook source to conf River Rea GB109054044320.  The remaining waterbodies have all been classified using solely phys‐chem data, extrapolated from another waterbody within the catchment. Absence of any real data has raised real concerns that no conclusions about the status and condition of any of these waterbodies can be confidently drawn.  No monitoring takes place on any of these waterbodies, however with the wider River Rea catchment, has known existing suspended solids issues and there is a high likelihood that these waterbodies may all suffer similar issues. In 2008, a survey was carried out as part of a local investigation request over concerns of the River Rea failing as a recreational trout fishery. Four sites within the stretch between Ford Farm and Hardwickforge Bridge were surveyed to assess the current fish population. The conclusion of this investigation was that juvenile salmonids, namely brown trout were insufficient in number to maintain a healthy population and that fish recruitment was poor, most likely, as a result of suspended solids. Below is an extract from the report. “This survey was carried as part of an investigation to assess the current brown trout population status of the defined stretch of the River Rea. The overall catch were disappointing compared to our experience of rivers similar to the River Rea in the River Teme catchment were we would have expected to catch many more fish. The further downstream surveyed the less fish present. As Hinton has been surveyed on a number of occasions we are able to compare the temporal trend figure 3, this has highlighted a decline over time. In the summary reports from past surveys it has been noted that the population is predominately made up larger older brown trout. These reports also highlight how unstable the population has been, in 1983 55 trout caught, 1984 15 trout and a single run produced only 2 trout in 1993. Apart from the survey of 1983, these results have been reported as being poorer than expected. During the age structure analysis some interesting facts were brought to light. Overall growth rates are good (above the national standard) and some individual fish had exceptional growth. This exceptional growth pattern is exhibited on scales from fish that have been introduced through stocking. Exceptional growth is achieved when the fish have been intensively reared on a fish farm. Anecdotal evidence and a check of the Live Fish Movements Database suggest that no supplementary stocking has occurred within this stretch. Therefore it can be assumed that the fish farm located four kilometers upstream of the Ford Farm is supplementing the fish stocks through escapees. The fact that a Rainbow trout was caught is also further evidence to support this. The presence of these escapee trout masks the true severity of the decline of this watercourse.

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Hinton Survey Catch Density Comparison

No of fish/100m2

5 4 3

Brown Trout Eels

2 1 0 1993

1999

2008

Survey Year

Figure 3Catch Density at Hinton The length frequency also highlights further worrying trends. Takeable trout, (those greater than 230mm (9 inch)) favoured by anglers whether taken or returned account for 33% of the total catch. Whereas juvenile fish those equal to or less than 0+ age class, only account for 38%. If we consider that usually 10% of 0+ fish will make it to maturity, then there are not enough juvenile fish to support a sustainable wild trout fishery. The growth data and the invertebrate data suggest that the river is productive, therefore if we consider that recruitment is the problem. What are the causes? Unseasonal flooding: for two consecutive years the brook has been hit hard by exceptionally high flows during the summer. This could be responsible for a reduction in fish numbers due to wash out or mortality of juvenile fish. Unfortunately there is very little we can do to protect against this, it is a fact of nature. Excessive siltation: the River Rea has always been a silty river in our experience. But the levels of the overlying silt covering the bed of the river appears to be excessive (> 95% bed covered on 3 out of 4 sites) and therefore destructive. Siltation to this degree will smother the invertebrate life and suffocate the deposited egg or alevin stage of trout fry while still in the gravels. On the pre survey visit and during the survey some of the causes of this siltation from diffuse sources were observed. These possible causes were identified as unsympathetic maize planting, livestock intrusion, excessive bankside erosion and field and road runoff. Conclusively, poor brown trout recruitment appears to be the primary cause of the fisheries failure, the likely cause, and siltation. Remedial work above and along this stretch to reduce erosion and therefore prevent siltation should be seriously considered. This can be achieved by riparian fencing to provide a buffer zone preventing livestock intrusion and stabilise heavily eroded banks, these are the primary causes of siltation in the catchment. Any approach to restoration or remedial work should start above Ford farm to first protect the areas identified most suitable for adult spawning and juvenile trout development.”

1.3 Chosen Waterbodies

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There is a significant risk that many of the waterbodies within the River Rea Catchment have been classified incorrectly and that the true conditions are not being captured. The River Rea has long been known as a catchment in serious decline most probable as a result of siltation but despite this no monitoring has been undertaken. All of the failures have been based on the few biological parameters monitored; fish and diatoms. The significance of biological monitoring parameters in determining waterbody ecological health calls into question those waterbodies that are passing simply because there has been no monitoring. In order that we solve the problems in the River Rea catchment, it is imperative that not only the failing, but that the good waterbodies are included in a ‘whole catchment’ appraisal The big failure on a national basis is phosphate and within this catchment there is a risk of levels deteriorating from good to moderate. Agricultural diffuse P in rivers originates from residual P in soil or from manure or fertilisers applied to agricultural land. Phosphorus becomes mobilised, either in particulate form or soil solution by surface runoff, splash detachment, dissolution and desorption processes. Once mobilised, it is transported via several hydrological pathways where it will interact with the environment before being delivered to rivers. Ecologically significant loads of phosphate and suspended sediment are likely to be originating from surrounding agricultural land, with a combination of landscape morphology and land management practice, generating the highest pollution risk. Sediment has already been identified as the suspected cause of fish failure and is known to be impacting on the ecological health of the waterbodies. Suspended solids, in this catchment, are indeed subject to large fluctuations and on occasion exceptionally high concentrations have been recorded, which could provide a link to elevated phosphorous levels. It is widely accepted that suspended solids in watercourses can adversely affect fish populations as a result of a number of factors. Siltation can hinder recruitment by consolidating gravels suitable for spawning, smothering eggs and making the habitat unsuitable for juveniles, though proving that these suspended solids are impacting the ecology can often prove difficult. The tools available for monitoring suspended solids are few and waterbodies with excessive suspended solids can still achieve better ‘than good status’ providing that the classifying elements do not reflect this problem. The whole catchment appraisal would aim to set about a wider investigation into the perceived loading of siltation in the River Rea. These selected waterbodies now formed the focus of more detailed investigation involving simple methodologies in relation to the apparent concern over the siltation levels and its possible affects on the ecological parameters of the waterbodies. This will prove helpful in attaining a better understanding of the levels and perceived sources of sediment whether natural, point or diffuse source pollution from agriculture, which should help to focus efforts.

2 Methodology

The unknown failures, in the poor waterbodies are likely to be primarily related to ‘diffuse’ pollution issues, which the River Basin Plans have struggled to identify, or at least failed to identify

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appropriate mitigation. We need to be able to pinpoint likely sources in order to target an achievable mitigation project, rather than rely on broad landscape scale approaches such as Catchment Sensitive Farming. As discussed previously, there are waterbodies that have inexplicably passed the waterbody assessment despite local concerns on river health, these waterbodies have no monitoring and lack basic biological parameters that indicate the function of the ecosystem. In choosing to use the below methods it is hoped to ground truth existing classifications and based on the knowledge of an existing siltation problem in the Rea catchment, identify the reasons or geographic locations of sources of loading to bridge the data gaps responsible for waterbodies ecological status.

2.1 River Walkovers

Working with the local Environment Agency, it was acknowledged that on the ground investigation was required; recommending walkovers of the catchment to assess the likely contribution each waterbody has towards sedimentation in the River Rea Catchment. The Environment Agency had already conducted general river walkovers in 2 of the 3 failing waterbodies. After discussion it was decided this would not be at a level substantial enough to fulfil the Severn Rivers Trust objective of sourcing possible pollution sources. As the whole waterbody assessment was extremely detached from local assessment, it was recommended to walk both failing and adjacent waterbodies to help focus such efforts on where in the Rea catchment, if any loading of suspended solids is highest and more accurately pinpoint issues. This detailed investigation would enable to fill some of the knowledge gaps in the catchment and lead to effective, targeted mitigation, and improvement in WFD ambition

2.2 Scimap Scimap, a modelling tool for fine sediment sourcing combines land use, slope and rainfall data to produce a risk map displaying areas of the catchment that are hydrologically connected to the watercourse and the level of risk of contributing diffuse pollution. SCIMAP works by: (1) Assessing the risk of pollution generation at a location through the use of land cover data and the apportioned ‘risk’ of soil erosion. (2) Identification of sources most likely to deliver pollution to the channel based on connectivity to the channel network by surface flow pathways during storm events (the hydrological connectivity risk or surface flow index). 3) Calculating in‐stream risk by integrating risk from all sources contributing to that point.

3 Results

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Sewage is a rich source of phosphorus (P) and water treatment works diligently remove this from household waste water. This has led to the assumption that agriculture is now the main source of P entering waterbodies in rural catchments. However, there is mounting evidence that this is not the case. Septic tanks are widely used across the UK for the disposal of household waste in rural areas removing much of this P from waste water before it reaches groundwater or surface waters. However, if a septic tank is not functioning properly it can cause pollution and act as small point sources of P. Figure 3.1 displays the total number of properties outside Severn Trent Water sewer treatment areas. A total number of 1,574 properties have been identified, though this may not be an exhaustive list. Many properties in the area aren't linked to mains sewage system and run off from poorly maintained septic tanks means phosphates find their way into watercourses. There is a clear concentration of properties not on mains sewerage in the middle of the catchment. It would be advised further investigation was carried out within this waterbody for monitoring of phosphates and a campaign of advice on checking the integrity of household systems.

3.2 Land use mapping Land use maps were created in ARCMAP using interpolated agricultural statistics from Defra 2010 ag‐census. Data have been interpolated using Inverse Distance Weighted algorithm and a cell size of 1000m. Livestock numbers are shown in figure 3.1.1. Notably, livestock farming is predominantly in the higher catchment with notable ‘hot spots’ in the lower waterbodies. Cattle farming is distributed in the higher half of the catchment, with indoor pig and poultry units focused in specific areas of the catchment. These farms would

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potentially be priorities for the delivery of nutrient management advice and assessments of slurry storage capacities. Figure 3.1.1 Livestock numbers in the Rea Catchment Dairy Cattle

Total Cattle (Beef and Dairy) Poultry

Pigs

KEY: Highest intensity Lowest intensity

Figure 3.1.2 Arable cropping in the Rea Catchment Cereals

Maize

Horticulture

Oilseed

Figure 3.1.2 shows that arable cropping is spread widely throughout the catchment; with a significant amount of winter cereals grown in the upper regions where cultivation land gradient increases the risk of diffuse run‐off. Soil conservation advice would be best targeted in these upper regions.

3.3 Scimap Results Scimap, a modelling tool for fine sediment sourcing combines land use, slope and rainfall data to produce a risk map displaying areas of the catchment that are hydrologically connected to the watercourse and the level of risk of contributing diffuse pollution. This has provided a clearer picture of the catchment and the ability to zone in on individual waterbodies and more specifically, land parcels deemed at high risk of sourcing sediment to the watercourse system.

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Figure 3.2.3 Scimap Results The colours that follow the stream network are indicating the risk categories for fine sediment concentration/delivery from that stream. There is the clear distribution between low risk (green) areas and high risk (red) areas; most striking is the higher percentage of high risk streams in the upper catchment. Mostly higher ground was identified as high risk (red), as would be expected on steeply sloping land in the upper catchment due to the valleys. The likelihood is that this sediment contribution from the upper waterbodies is highly likely to be affecting the lower waterbodies within the catchment, acting as a source. Another feature of most interest, waterbody (bottom right) 4260 which is failing, clearly indicates there is a high risk of sediment sourcing in the upper half of this waterbody, a clear focus for attention. Waterbodies in the lower catchment appear to have very low risk streams. This would equate to these stretches of river having little or no sediment within the gravels as there is no perceived risk of sediment contribution, though ground truthing would be recommended. The output of Scimap was combined with the results of the walkover surveys (See Appendices 2, figures 1.1‐1.8.), specifically arable buffer strips to attain if any correlation existed between high risk areas and riverbanks identified on the walkovers with lack of buffer strips on arable land. A number of areas were clearly visible with no or minimal buffer strips on high to moderate risk areas. The example below demonstrates this. Figure 3.2.4 Scimap and Walkover Result

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Within this waterbody two areas of interest have been identified as highly probable in sediment contribution to the river. The stretch of bankside identified with no buffer strips (purple) and of mid‐ high risk (orange) are corresponding factors in the ground truthing of sediment contribution to the river course. These areas would need action immediately. This has been verified by the walkover study, as areas of gravels were observed smothered in silt of loose compaction (fig 3.2.5). This confirms the localised effect of bad farming practises to siltation levels in the river and would be a major contributing factor for the decline in water quality. Figure 3.2.5 Gravels covered in loose sediment.

Figure 3.2.6 Walkover Results and Scimap for Waterbody 4290.

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Other waterbodies, for example Moor Brook (4290) exhibit large areas of arable fields with no or minimal buffer strips from the walkover survey results. Scimap had identified these areas as low risk and this brings into question the limitations to the modelling process and its danger of overlooking areas at substantial risk of sediment contribution.

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3.4 Walkover Results

Sediment walkover surveys were competed for the whole of the Rea catchment; the main focus was to assess the siltation loading across the catchment. Parameters deemed as high risk in their sediment contribution to the river system, such as no or minimal buffering on arable land and areas of poaching along the bankside were identified. Arable buffers were mapped into three groups accordingly, no or minimal buffer strips, 3m or 6m buffers. Poaching was assigned within a field and the overall number of points and their severity deemed a field to be either low, moderate or a high level of poaching. Other points of interest, such as weirs, tree blockages and natural erosion were also mapped. Overall, the process of walking the whole WFD river system of 76km, took 14 days to complete by one person. Figure 3.2.1 Rea Catchment Walkover Results for Poaching Severity The adjacent figure shows the distribution of levels of poaching recorded throughout the catchment. There is a variance of levels, though predominantly more poaching was mapped higher up in the catchment, with levels of Moderate to High. Within the failing waterbodies, minimal poaching was noted, an indication that sediment is most likely being sourced from higher in the catchment. Many of the poached banksides, included both banks of the river and are centrally focused on parcels of land. With further investigation it is likely this could be attributed to specific holdings in the catchment and result in a focused mitigation plan.

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Figure 3.2.2 Examples of Severe Poaching in the Catchment

Further results from the walkover surveys were able to map obstructions to fish passage, such as weirs and tree blockages in the river. The below figure demonstrates the high number of and distribution of tree blockages (blue). There is a high concentration of dead wood in the river in the upper catchment. This was not just woody debris, which can aid habitat for fish with cover, but more substantial blockages obstructing flow and fish passage (fig 3.2.4). Figure 3.2.3 Rea Catchment Walkover Results for Tree Blockages and Weir Obstructions It has been documented in adjacent sub catchments, riparian alders suffer with a degenerative disease, called phytophthora. The disease kills new growth and greenery, with tar like spots at the base of the tree, spreading and finally leading to failure of the tree. Historically, the lack of any riparian management has left these alders susceptible to falling into the river exposing tree scars (fig 3.2.5) prone to sediment erosion. Alders in the upper catchment have been confirmed to show this disease and this is likely to spread if not dealt with early. A program of coppicing and riparian management is highly recommended for these areas to reduce the risk of tree blockages and subsequent tree scar erosion, potentially acting as a sediment source and bank erosion point. Figure 3.3.4 Tree Blockages

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Figure 3.3.5 Tree Scar

The walk‐over survey also highlighted the presence of significant barriers (pink) to fish migration, predominantly located within the lower section of the catchment. These barriers are deemed to be an additional factor contributing to the fish failures, preventing access for salmon and the in‐stream

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movement of existing trout populations. To note, 5 of the mapped weirs with no fish passes had not been identified by the Environment Agency. In‐stream barriers are placing additional pressure on trout populations, preventing access to more suitable habitats and should be a focus for remedial work. Ongoing funded projects are attempting to address opening up fish passage in the lower part of the catchment and it is clear that here is a concentration, specifically, within the failing waterbody in the bottom right. In the last year the Severn Rivers Trust have been involved in a number of projects to address these issues with passes completed at Testill weir (Pass completed September 2010 (£85k) ‐ 13 metre Alaskan "A" pass & floating tilting hood screen.) and Prescot Weir (Pass completed October 2011 (£50k) ‐ Bypass channel with local stone). Feasibility studies have been carried out for a further two weirs at Lower Forge (Feasibility Study completed October 2011 (£30k) ‐ Bypass channel recommended, estimated cost £250k to build.) and Detton Mill Weir (Feasibility Study completed June 2011 (£5k) ‐ 7 metre Alaskan "A" plus bristle Eel pass, estimated cost £105k to build.). For each barrier a feasibility study costs around £5k. Removal of any fish barrier would be the preferred option, but where this is not possible, fish passes can cost anything between £45k for simple rock ramps to £250k for elaborate bypass channels and Alaskan "A" passes. In terms of WFD, fish access on the Rea is very important and these barriers are inhibiting the movement of fish and are a contributing factor to the possible low numbers of fish observed from survey, though not a unique answer. The below graphs demonstrate the percentage of riverbank with poaching and lack of buffer strips, considering both sides of the river per waterbody. Figure 3.3.6 Percentage of total river bank per waterbody exhibiting varying severity of poaching

A large percentage of the waterbodies demonstrate areas of high poaching. The impact of sediment contribution will be high risk and these areas should be deemed a priority. A total of 31,996m’s of riverbank exhibit areas of varying degrees of poaching, of which 9348m were classed of a high severity, predominantly caused by cattle.

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Figure 3.3.7 Percentage of riverbank with minmal or 3m buffer strip in place on arable fields

A total of 7,889m of the riverbank has been identified as at risk from soil runoff due to no or minimal buffer edges on arable land. The above figure should draw attention to waterbody 4290, with 30% of the riparian edge having no buffer in place or minimal buffering on arable land. Scimap results had identified this area as low risk to sediment sourcing, but as the photos below demonstrate this is not the case and is a cause for concern. Figure 3.2.8

This highlights the need to proceed with caution when resources for research only use modelling. This waterbody lies immediately upstream of a failing waterbody and the opinion formed from the walkover would conclude there is sediment ingression from this stretch of the river to below. Figure 3.2.9 Combining areas of poaching and arable with no or minimal buffer strips for each of the waterbody.

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Within two of the waterbodies over 50% of the riverbank attribute a possible source of sediment input into the river system. One third of the whole of the river system has been identified through walkovers with farming practice that will be high risk of affecting siltation levels within the river. Much of the upper catchment is grazed by cattle and sheep, with approximately 50% of the river bank currently unfenced. Unrestricted livestock access and resultant over grazing and trampling of bankside vegetation has lead to extensive poaching and is contributing large quantities of silt into the river channel.

4 Conclusions

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4.1 Waterbody Assessment

The WFD requires the assessment of individual waterbodies on the basis of ecological health. The parameters used for classification show a number of limitations to this approach including misclassification of waterbodies, but of more relevance, a failing to identify the cause of failure, based on the ecology of the river system.  It is evident not enough evidence exists or that monitoring is suitably located in the catchment to form confident conclusions to the classifications. Where monitoring is available, it has either not been used effectively or was assigned to a neighbouring waterbody, clouding judgement on status of failing or good.  Many of the tributaries of the River Rea (two‐thirds of waterbodies) have no monitoring data associated with them and have been classified entirely on extrapolated phys‐chem data. This lack of data calls into question those waterbodies that are passing simply because there has been no monitoring, when walkover evidence has shown there are major problems with silt ingress affecting the river system.  It is well documented that the whole of the Rea catchment suffers from excessive siltation, possibly affecting this ecosystem, however, this is not taken into context within the classifications of WFD.  The monitoring tools available for monitoring suspended solids are few and it would seem that these waterbodies with excessive suspended solids can still achieve better ‘than good status’. There is a real risk that many of the waterbodies should be of a lower status than specified.  During this process, the lack of available data and its untimely delivery became an apparent problem, which confined the assessment and results. Fisheries classification data is still waiting to be received and the reticent supply of recent electro fishing results from the local Environment Agency has restricted assessment.

4.2 Tools 4.2.1 Scimap The modelling tool, Scimap is a useful piece of evidence in pinpointing areas deemed high risk for sediment sourcing. These focal areas need confirming on the ground to their likely cause and to enable appropriate mitigation measures to be put in place. Scimap Advantages  A very quick and useful exercise for gaining an overview of the catchment, assessing individual waterbodies to their likelihood of sediment contribution and to further aid decisive targeting of investigations.  Ability to decipher which parcels of land are most likely the sources of sediment and use this as a focus for more detailed monitoring.  Mitigation measures can be instantly directed to these areas, for example buffer strips, contour/gill planting, wetlands or any other management measure that breaks the connectivity and thus severs the pathway.  SCIMAP reveals the extent to which arable cropping on significant slope angles with connectivity risks sediment and phosphorous transfer, particularly in the upper reaches of the Rea. This was reinforced by the walk‐over survey.

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

Analysing Scimap with the results of the walkover surveys gives a more focus targeted approach and allows us to recommend and target specific mitigation activity to the problems identified. For example, high risk areas of arable land with no or minimal buffer strips identified from walkover surveys can be prioritised against areas deemed at high risk from Scimap for targeted buffer strip implementation.

Scimap Disadvantages  SCIMAP is a RISK model, therefore it only highlights areas where there is a risk of fine sediment mobilisation. Risk may not be realised if land management practices are good, or something acts as an interceptor, but also human factors may produce a sediment source in a low risk area as in 4290.  Modelling techniques can be and are only useful so far in an investigation. They may help to zone in on areas of concern and enable a grounding of the bigger picture, but it does not take into context what is actually happening on the ground, which may differ from the model.  It is hugely reliant on accurate and up to date data that is fed into the model itself, otherwise false readings maybe produced and this leaves the danger of steering away from where the real problem may lie.  A concern remains regarding the high risk areas located on higher ground and on the smaller tributaries. Results of the walkovers would suggest that some of these areas would not have enough flow or force to be contributing sediment loading further downstream to the main river or brooks unless at times of considerable rainfall. The total of all the areas considered high or moderate risk would not equate to the amount of loading seen on the gravels throughout the river system from the walkover surveys (Confirmation could be attained through wet weather walkovers.). Scimap does not provide definitive answers but assists with targeting across broad spatial scales by assigning a risk probability framework to a landscape.

4.2.2 Walkovers As the whole waterbody assessment was extremely detached from local assessment, it was appropriate to walk both failing and adjacent waterbodies to help focus such efforts to problem areas and provide clarification, where, if any loading of suspended solids is highest and accurately pinpoint the issues. It became apparent, that the River Rea catchment contains extremely high quantities of sediment, predominantly sand sized particles. The natural process of erosion is expected to contribute to this, however results have shown this is exacerbated by certain farming practises taking place in the catchment. In particular, livestock farming with cattle and sheep, with unrestricted access to the watercourse are contributing to excessive quantities of sediment entering the watercourse. This sediment input is affecting the rivers ecosystem and will limit the spawning opportunity and success of trout, salmon and other gravel spawning species. Walkover Advantages  It was very apparent in the field that there is a problem with suspended solids, across the whole catchment, the fact that this has not been reflected in the process of the WFD assessment, highlights the importance in providing tangible evidence of siltation problems and their possible impacts.

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

The walk‐over survey has highlighted bankside erosion, as a result of uncontrolled livestock access and over shading from mature alders as two significant sources of fine sediment in the upper catchment.  Barriers to migration are also impacting on fish health within the lower catchment. The walkover survey identified a concentration in this area and is more than likely contributing to the factor of low fish numbers in these waterbodies.  Using the WFD assessment alone, there is the risk of focusing efforts on waterbodies that are failing, when reality and evidence has proven it is more than likely a problem occurring outside of this waterbody, further upstream or from an adjoining tributary. Walkovers have provided a basis of evidence and without a doubt we can call in to question those passing waterbodies in the catchment, upstream of a failing waterbody.  Many unknown failures are likely to be primarily related to ‘diffuse’ pollution issues, which the River Basin Plans have struggled to identify, or at least failed to identify appropriate mitigation. With local knowledge, being the key force here, in indentifying on the ground sources of sediment, actions can be mitigated straight to where it is needed.  Walkovers are more than just a mapping exercise. An overall picture can be obtained of the catchment and the ability to assimilate how waterbodies interact with each other. This is not a detached assessment and by collating on the ground hard evidence, it was clear to see the magnitude of the problem, siltation in every waterbody. Walkover Disadvantages  In comparison to other tools available, walkovers could be deemed labour and time intensive. It is highly reliant on trained personnel and if completed by a number of people, there is a risk of bias on the results.  Cattle’s poaching primarily occurs in dry weather, whilst land run‐off occurs in wet weather and clarifying which of these is contributing the highest loads should guide future actions by relevant parties. This would require both wet and dry weather walkovers to fully record accurate results, a huge drain of resource and time.  Results of walkover surveys have the ability to assess the ecology of a waterbody, but using this in WFD assessment would prove difficult as there is no monitoring associated. Currently, all classified ‘Good’ waterbodies are in worse condition in terms of sediment loading, turbidity and ecology than the three failing waterbodies. This is not to say the failing waterbodies should be upgraded as ‘Good’. Typically the waters were more turbid with a considerable amount of siltation smoothing the gravels. Problems from lack of buffer strips, areas of large poaching and easily erodible tree scars are all increasing the risk of sediment input into the system above the natural erosion processes. The whole assessment does not set out to disparage the WFD classifications, but enable to fill some of the knowledge gaps in the catchment and lead to effective, targeted mitigation, and improvement in WFD ambition.

5 Recommendations

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Overall, the lack of data and resulting low confidence in classification of waterbodies has left the feeling that there is a generalisation within the WFD assessment process. There is the risk of focusing efforts on waterbodies that are failing when reality and evidence from this project has proven it is more than likely a problem occurring outside of this, upstream or from a differing brook. Analysing the catchment as a whole will provide a much clearer picture to its status and particularly in this example has proven that good waterbodies above the poor waterbodies undoubtedly are contributing to the failing classifications. Within this catchment diatoms and fish are both in ‘poor’ status for the failing waterbodies with an unidentified cause. Walkover results have shown there is a major problem with siltation in the catchment, specifically upstream of the failing waterbodies, but linking these failures to suspended solids can be difficult. It would be helpful to attain a better understanding of the frequency and loading of suspended solids and how this relates to rainfall. The best way to achieve this would be to deploy a sonde, which will continuously record turbidity (a substitute for suspended solids) carefully placed in waterbodies exhibiting the most sediment pressures in the upper catchment. Sediment source testing would also be advised, to confirm whether this is predominantly bankside or land derived. Many of the tributaries of the River Rea have no monitoring data associated with them and have been classified as good, based entirely on extrapolated phys‐chem data. In order that the problems are solved in the River Rea catchment, the three phys‐chem monitoring points located within the waterbody need to be rationalised as they may be better placed in another waterbody higher in the catchment. This would provide better coverage of the catchment and enable a more robust classification of the upstream waterbodies. Whether sediment loading occurs in dry weather or wet water can give a better indication as to it sources. It is highly recommended to carry out wet weather surveys in this catchment, as fencing will prove of little benefit if the sediment loading occurs in high rainfall events. Dry weather surveys have identified there is a considerable amount of sediment ingress from livestock poaching in the upper catchment, though wet weather walking to identify sources of silt predominantly from arable land would prove most beneficial.

5.1 Mitigation Measures In order to achieve GES in the River Rea the following recommendations have been made and are deemed essential as key actions to improve the Rea catchment. The catchment investigations highlighted the need for targeted habitat restoration in the riparian corridor, through a concerted programme of stock exclusion and coppicing. Both cattle and sheep have unrestricted access to the river in this catchment and, consequently, poaching is widespread on grazed land and there is little riparian habitat to bind the bank side soil together. As a result, there are significant quantities of sediment both on top of and within the gravels. Measures should be taken to limit stock access, where overgrazing and poaching by livestock is leading to bank erosion. If stocking rates cannot be drastically reduced the riparian area should be fenced off with provision made for livestock drinks/water troughs and gates to allow the farmer access for maintenance, with periodic grazing to control vegetation and to retrieve stock. The table below documents the results of the walkovers and provides the length of river stretch recommended for fencing per waterbody. Table 5.1.1: Results of Walkover surveys. total m’s with poaching and the cost to fence. WB Name Total % of High Total to amount riverbank Poaching Fence all

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Component A - Appendix 3

with poaching in each WB

Mill Bk ‐ source to conf R Rea (4250) R Rea ‐ conf Farlow Bk to conf R Teme (4260) Farlow Bk ‐ source to conf R Rea (4270) R Rea ‐ conf Moor Bk to conf Farlow Bk (4280) R Rea ‐ conf Cleobury Bk to conf Moor Bk (4290) Moor Bk ‐ source to conf R Rea (4300) Cleobury Bk ‐ source to conf R Rea (4320) R Rea ‐ source to conf Cleobury Bk (4340)

of riverbank (m’s) with poaching 5056.9 6008.0 1777.5 3113.9 5454.6 1815.7 8769.5

Whole Catchment Total

31,996m

22%



 

only and the cost to Fence (£5)

27.0 2741.8 11.2 8633.6 10.9 37.9 7256.6 39.3 7973.7 22.0 6604.4 30.0 13531.8

levels of poached banks observed (£5) 25284.6 30040.1 8887.7 15569.6 27272.9 9078.3 43847.4

£46,742 £159,980

Columns dictate as follows the total amount in metres of riverbanks (both sides accounted for) that were observed with poaching in the waterbodies, so inclusive of low, medium and high poaching; the total percentage of riverbank observed with any level of poaching for each individual waterbody for example 4250 exhibits 27% of the total riverbank with poaching and therefore a possible sediment source; the costing of just addressing the high poaching areas to mitigate with fencing and lastly the total amount in pounds it would cost to fence all levels of poached bankside observed in each waterbody. Mitigating only the severe poaching in the whole of catchment would cost a total of £46,700 at £5/m for fencing. The cost to fence all poached areas within the catchment equates to roughly £160,000. *This is not fencing the whole of the catchment, but only were poaching was observed to supply a degree of risk of sediment input.

Figure 5.1.2 SRT funded riparian works

Fencing has been completed on some stretches of the River Rea, funded by the Severn Rivers Trust. Coppicing works, livestock drinking bays and sheep netting with gated access points have all created a substantial riparian buffer strip. This should set a good example to others within the catchment.



Other factors such as lack of field buffers on arable fields and susceptible scar bank erosion from fallen trees were identified

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Component A - Appendix 3



 



ment. Where arable fields have been identified with no or minimal buffer strips, landowners should be approached to encourage best farming practises or made aware of the cross compliant GAEC minimal buffer strip. It would be beneficial to promote and encourage entry into the agri‐environmental schemes to achieve up to or over 6m buffers. Areas of openly high risk soil erosion, such as recent tree fells or unstable open bank faces, should consider willow revetment works to provide protection for the banksides and decrease any further erosion. Historically, there has been a decline in riparian management, bank sides are now overcrowded and diseased alders are falling into the river causing blockages, leaving large exposed scar bank areas. Coppicing these failing alders encourage re‐ growth, resilient to the disease and limit the spreading. Ideally, trees should be cut for coppicing 20–30 cm above ground level, leaving a tall stump to develop new shoots under favourable space and light conditions. Tree works are highly recommended for the upper catchment to allow penetrable light to the brook, allowing base vegetation to grow and stabilise the bank and to help deter the spreading and affects of phytophthora on the alders. Action point reports for each waterbody have been completed and passed on to the appropriate Environment Agency Officer. Items such as, point source pollution sources will be investigated, for example sources of road drainage and sewage outlets observed on the walkovers.

Figure 5.2.3

Road drain with the resulting sediment contribution on the gravels below 

In addition, there are a number of in‐stream barriers placing additional pressure on trout populations and migration, identified within the catchment, as well as numerous blockages of fallen dead wood. These will limit the potential for fish to move up the system and may be causing flow restrictions. These pinch points should be further investigated to the possibility of either clearing the dead wood or opening up passage on weirs. There is a clear focus of concentration of weir barriers with no fish passes in the lower catchment and this should form a focus for feasibility studies, costing approx £5k and remedial work, costing anything between £45k for simple rock ramps to £250k for elaborate bypass channels and Alaskan "A" passes.

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Overall Poor Poor Poor Good Good Good Good Good

Fish Poor Poor Poor * ‐ Good Good ‐ *Mod results not used

Overall Poor Poor Poor Good Good Good Good Good

Phosphate Good Good Good Good Good Good Good Good

Ecological Poor Poor Poor Good* Good* Good Good Good* *No biology data

Phytobenthos Poor * *poor results not used

pH High High High High High High High High

Predicated Status 2015 Moderate Moderate Moderate

DEFRA Strategic Evidence & Partnership Fund

Chemical Not required Not required* Not required Not required Not required Not required Not required Not required *3 monitoring points High (Good P)

WB ID 44280 44260 44250 44340 44320 44290 44300 44270

Name Moor Brook to conf Farlow Brook Farlow Brook to Teme Mill Brook Rea source to Cleobury Brook Cleobury Brook Cleobury Brook to Moor Brook Moor Brook Farlow Brook

Table 1.1 and 1.2 WFD Water body Assessment

6 Appendices

DO High High High High High High High High

Temperature High High High High High High High High

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Ammonia (PC) High High High High High High High High

Justification Technically infeasible (S2b) Technically infeasible (S2b) Technically infeasible (B2a)

Ammonia (8) High High High High High High High High

Flow Good Good Good Good Good Good Good Good

Morphology Good Good Good Good Good Good Good Good

Component A - Appendix 3

Scimap and Walkover Survey Results Figure

1.1

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Figure 1.2

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Figure 1.4

Figure 1.3

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Figure 1.5

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Figure 1.6

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Figure 1.7

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Component A - Appendix 3

Figure 1.8

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Scimap Key Guide

The colours that follow the stream network are indicating the risk categories for fine sediment concentration/delivery from that stream. It’s calculated as standard deviation around the mean going from green (low risk) to red (high risk) with light orange being the mean for the catchment modelled. If you take a red stream (one that is delivering a disproportionate amount of fine sediment compared to its upstream area, i.e. is accumulating risk quicker then it accumulates dilution) and then look at the underlying model output surrounding the stream output (light blues to brown) you can decipher which parcels of land are most likely the source of sediment. This model output is calculated by multiplying the erosion risk of a parcel of land with a surface flow index. The brown zones are the ones most likely to be delivering effectively telling us where sediment sources are hydrologically connected to a water course (so there is a source, a pathway and a recipient stream). These are the places you would look to put in buffer strips, or carry out contour/gill planting or any other management measure that breaks the connectivity and thus severs the pathway. Note: SCIMAP does not provide definitive answers but assists with targeting across broad spatial scales by assigning a risk probability framework to a landscape

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Component A - Appendix 3

Walkover Results Figure 2.1

Figure 2.2

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Figure 2.4

Figure 2.3

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Figure 2.5

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Figure 2.6

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Figure 2.7

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Figure 2.8

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Figure 2.10

Figure 2.9

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Component A - Appendix 3

178.3

Totals 31996.1

65.1

16.3 Cows 6.0 Sheep 8.5 Cows

20.3 Sheep

4.3 Sheep 9.0 Sheep

27272.9 9078.3 43847.4

25284.6 30040.1 8887.7 15569.6

Total Fence (£5)

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11803.4

3.6 Cows 1.8 Cows

52.6

17.7 Cows

3.2 Cows

9348.3

60.6

1594.7 11.5 Cows 1320.9 16.0 Cows 2706.4 9.3 Cows

1451.3

Cause

2.9 Sheep

High%

1726.7

548.4

Cause High

23.4 Cows

Mod %

1602.7 11.5 Cows 3579.1 12.3 Sheep

1947.7 300.0

4373.9

Cause Mod

0.7 Sheep

Low %

46741.7 159980.6

High Poaching Fenicng (£5) 2741.8 8633.6 7256.6 7973.7 6604.4 13531.8

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39.3 22.0 30.0

27.0 11.2 10.9 37.9

Total % fence

5454.6 1815.7 8769.5

5056.9 6008.0 1777.5 3113.9

Total ms to fence

10844.3

2257.1 494.8 2484.1

2333.6 1477.5

1059.0 1893.0 762.7 6631.4

151867.9 7888.9 12414.2

3520 13885.5 8271.8 29200.8

1133.8

8207.7

2830.7 840.9

134.6

1662.6

2529.4 1273.7

53698.9 16373.7

Low

Poaching

1348.6

18709.4

Arable Total Riverbank 0m 3m

WB Name

Totals

WB Name

Table 5.1 and 5.2

Component A - Appendix 3

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Defra Strategic Evidence and Partnership Project Component A Appendix 4 Waterbody classifications and measures matrix

DEFRA Strategic Evidence & Partnership Component A: Waterbody Classification & Measures Matrix River

Waterbody ID

River Basin Plan Classification

Failing parameter(s)

River Basin Plan proposed remedial measure(s)

River Basin Plan proposed remedy delivery organisation(s)

Estimate of Rivers Trust opinion on classification & exisiting evidence cost (£)

Mid River Ottery

GB108047007780

Moderate

Fish

None given ‐ technically infeasible

None ‐ technically infeasible

None given We see no reason to dipute the fact that this waterbody is in degraded ecological condition.

CANWORTHY WATER

GB108047007790

Good

None

N/A

Might be true as the river comes straight off Bodmin Moor in its upper reaches. Invert status high, but no samples taken for 11 years. No other biological elements have a classification.

BOLESBRIDGE WATER

GB108047007800

Moderate

Fish

None given ‐ technically infeasible

None ‐ technically infeasible

None given

General feeling is that this waterbody is in poor ecological condition. Invert status high, but no samples taken for 11 years.

River Ottery (upstream Canworthy Water)

GB108047007810

Good

None

N/A

Might be true as the river comes straight off Bodmin Moor in its upper reaches ‐ invert data is extensive, but needs to be re‐analysed. In FCS2 2010 assessment this WB is classified BAD for fish.

Upper River Ottery

GB108047007820

Good

None

N/A

General feeling is that this waterbody may be in degraded ecological condition. There is no invert, diatom or invasives data. In FCS2 2010 assessment this WB is classified MODERATE for fish.

CAUDWORTHY WATER

GB108047007830

Good

None

N/A

General feeling is that this waterbody is in poor ecological condition. There is no invert, diatom or invasives data and Tobi Kruegar's model predicts it should be failing for phosphate at the very least. On inspection the waterbody is in a very similar condition to Bolesbridge Water, which fails for fish. Indeed, in FCS2 2010 assessment this WB is classified POOR for fish.

Lower River Ottery

GB108047007980

Good

None

N/A

The true condition of this water body is unknown. The fact that none of the Ottery waterbodies have a chemical status, that so many are potentially degraded for fish in 2010 monitoring and that only 3 sites have been monitored for inverts in the last 10 years all add to the concern that this lower section of the river may be lower than good status. Indeed, in FCS2 2010 assessment this WB is classified MODERATE for fish.

Phosphate: Moderate (Quite Certain) GES by 2027 (Disproportionatel y expensive, Phosphate or Total Phosphorus Unknown) R Lodon ‐ source to conf R Frome

GB109055036660

Tippets brook‐ Source to conf Stretford Bk GB109055036630

Stretford Brook‐ source to conf Tippets Bk GB109055036640

Poor

Fish: Poor (Very Certain) GES by 2027 (Technically infeasible, Biological element Suspected – sediment from diffuse source)

Establish and maintain a nationally funded advice‐led partnership under the Catchment Sensitive Farming Initiative to reduce diffuse water pollution from agriculture in at risk catchments. Progress delivery of Cross Compliance inspection and enforcement. Entry Level Stewardship &Higher Level Stewardship Schemes Reduce physical modification by encouraging better application of guidelines for managing drainage channels with biodiversity in mind, and educating as to best practice Fish passage and habitat restoration projects including Lugg and River Arrow project (LARA) to reduce physical modification and diffuse pollution through practical actions such as fencing and buffer strips and removal of obstruction to fish passage Improve understanding of the origins of and solution to diffuse pollution by carrying out local investigations

Good

None. No biological monitoring.

Moderate

Phosphate: Poor (Very Certain) (Disproportionatel y expensive: No planned remedial measures as there is not sufficient weight of Phosphate or evidence to confirm the need to control eutrophication risk. Total Phosphorus Unknown ‐ uncertain there is a failure / impact)

N/A

Establish and maintain a nationally funded advice‐led partnership under the Catchment Sensitive Farming Initiative to reduce diffuse water pollution from agriculture in at risk catchments.

Pinsley Bk ‐ source to conf R Lugg

GB109055041940

Moderate

Progress delivery of Cross Compliance inspection and enforcement. Fish: Moderate (Quite Certain) Entry Level Stewardship &Higher Level Stewardship Schemes Invertebrates: Moderate (Quite Fish passage and habitat restoration projects including Lugg and River Certain) Arrow project (LARA) to reduce physical modification and diffuse pollution through practical actions such as fencing and buffer strips and removal of obstruction to fish passage Improve understanding of the origins of and solution to diffuse pollution by carrying out local investigations

Natural England

Defra; Environment Agency; Rural Payments Agency Natural England Environment Agency; Internal Drainage Boards

High confidence in current classification. WB not assessed for diatoms.

Wye & Usk Foundation, Environment Agency

Environment Agency

N/A

No biological data. Very low confidence in current classification.

N/A

High confidence based on phosphate monitoring results. WB not assessed for diatoms or fish.

Natural England Defra; Environment Agency; Rural Payments Agency Natural England Low. The invertebrate and fish results of surveys conducted within the LARA project in 2010 and 2011 suggest the waterbody should now be classified as 'Good' for both fish and invertebrates.

Environment Agency; Internal Drainage Boards Wye & Usk Foundation, Environment Agency Environment Agency

Mill Brook

GB109054044250

Poor

Fish (Technically infeasible (B2a))

Cross compliance inspection and enforcement, GAEC, Address land management & diffuse pollution issues by farm visits & awareness campaigns, Water Protection Zones, Investigation into the cause ofsediment impact (All EA), Agri‐env (ELS and HLS targeted

Defra, EA, RPA, NE, CSF

Not available

Poor

Farlow Brook to Teme

GB109054044260

Poor

Fish (Technically infeasible (S2b))

Defra, EA, RPA, NE, CSF

Not available

Poor

Farlow Brook

GB109054044270

Good

No Fish Data. Classification based solely on ext physchem data

Moor Brook to confluence Farlow Brook

GB109054044280

Poor

Cross compliance inspection and enforcement, GAEC, Address land Fish/Phytobethos management & diffuse pollution issues by farm visits & awareness (Technically campaigns, Water Protection Zones, Investigation into the cause infeasible (S2b)) ofsediment impact (All EA), Agri‐env (ELS and HLS targeted

Cleobury Brook to Moor Brook

GB109054044290

Good

Classification based solely on ext physchem data

Poor

Moor Brook

GB109054044300

Good

Classification based solely on ext physchem data

Poor

Cleobury Brook

GB109054044320

Good

No Fish Data. Classification based solely on ext physchem data

Poor

Rea source to Cleobury Brook

GB109054044340

Good

Mod Fish Data ‐ not used

Poor

Defra, EA, RPA, NE, CSF

Not available

Poor

Estimate of cost Recovery monitoring recommended (£)

Rivers Trust Investigation(s) & new evidence

Rivers Trust opinion on cause of failure

Rivers Trust proposed remedy

WRT are examining all existing data and re‐analysing it according to more ecologically relevant criteria. We have undertaken invertebrate monitoring and will be undertaking farm and river walkover surveys higher in the catchment to identify potential sources of pollution.

Intensive agriculture leading to loss of nutrients, soil/sediment, pesticides (?) and organic material to the watercourse.

Delivery of on farm measures and land‐use/land management change £150‐300K to reduce pollutant mobilisation and disconnect pollution pathways.

Continued invertebrate and water chemistry monitoring in addition to continued walkover and farm surveys.

Some re‐analysis of invert data required. No other biological elements have a classification. Fisheries Walkover Survey to assess potential of river to be a salmonid spawning river.

Intensive agriculture leading to loss of nutrients, soil/sediment, pesticides (?) and organic material to the watercourse.

Tailored to issues found on the ground. If the water quality is found to be good then fisheries walkover surveys will allow us to target ? fisheries management interventions such as habitat restoration.

Further fisheries walkover surveys and electrofishing to assess impact of remedial work.