April 2022
Next week marks the end of a 6-month consultation on River Basin Management Plans, yet many will never have heard of them. So why should we all have an interest?
River Basin Management Plans (RBMPs) may seem like a dry topic, to pardon the pun. And they are. To many, the reams of information will be off-putting, the proposals theoretical. But to anyone who found joy in wandering down a riverbank during the pandemic, who swims, paddles or fishes in our waterways, or who simply values the wildlife habitats that sustain kingfishers, water voles and trout, these plans may be more significant than you might think.
In technical terms, they are plans for bringing our waters to ‘Good Status’. This generally means being free of pollutants (Good Chemical Status) and being in a good enough condition to provide for the fish, insects, plants and other wildlife that should naturally be found there (Good Ecological Status).
Operating on a 6-year cycle, it’s now time for these plans to be updated, and that’s what the current consultation is seeking views on. The proposed objectives aim to bring nearly 78% of our waters to at least Good Ecological Status. Whilst this leaves some waters ‘out in the cold’, perhaps the more important question is around how we are going to achieve even this. We have had similar targets in the previous 2 rounds of plans, but currently all of England’s waters fail chemical standards, and only 16% achieve ecological standards. Without significant new approaches, it’s hard to understand how this 3rd round of plans will be any more successful than the last.
Some of the proposed principles and measures show promise, but need to go further. For example:
- Government, take note: The plans note that their objectives need to be reflected in the processes and plans of public bodies, ‘for example statutory local development plans’. But the same must apply across central Government too, with BEIS, DLUHC and others all needing to ensure that their own policies and decisions don’t work against RBMP objectives. The plans are also a key means of delivering against other Governmental and societal priorities, and must be treated as such – the Environmental Audit Committee’s recent Water Quality Report highlighted that improving the quality of rivers will be crucial to complying with “the legally binding duty, established in the Environment Act 2021, to halt the decline in domestic species by 2030”. Failing our rivers means failing to bend the curve on biodiversity loss.
- Do sweat the little things: on land the plans encourage us to focus on the health of larger rivers and lakes, whilst inadvertently overlooking the flushes, runnels, streams, ditches, ponds and other wet features that underpin these larger waters and house a large portion of freshwater biodiversity. It’s little wonder that our waters remain denuded when we have failed to think about their constituent parts. Of course this level of detail may not sit well in these regional, strategic plans – so the solution is that delivery of Local Nature Recovery Strategies, which can provide that more detailed picture and set out where the greatest wins for nature can be delivered, should be supported by the measures set out in the RBMPs. These can similarly identify where species can be restored – like the water vole, lost from 97% of the sites at which it was once found – and where habitats that sequester and store carbon – crucial nature-based solutions in our fight against climate change – can be enhanced and protected.
- Support stewardship of the land: Agriculture has overtaken the water industry as the sector responsible for the most ‘reasons for failure’ against water targets. Farmers need a clear regulatory baseline as well as an indication of direction of travel in order to plan investment, and to be supported by farm advisors with environmental expertise. Clarity on options available in the forthcoming Environmental Land Management Scheme is necessary, and Government must consider what mechanisms are needed in ELMS and elsewhere to enable action on nutrient pollution, a key pressure on our rivers, lakes and coasts.
- Prevention is better than cure: Already a problem, and set to worsen with a changing climate, invasive non-native species (INNS) are amongst the top 5 threats to biodiversity world-wide. The plans include welcome measures to control those already present, but far more effective is to prevent their establishment in the first place. A report from Wildlife and Countryside Link’s INNS Group describes how investment in biosecurity and an INNS Inspectorate could prevent the establishment of multiple new invasive species and would deliver a return on investment of £23 for every £1 spent.
- Prevention is better than cure #2: The adage equally applies across any number of threats, but that of chemicals is a particularly pertinent issue. 100% of our waters today fail chemical standards due to pollutants known as uPBTs – ubiquitous, Persistent, Bio-accumulative and Toxic. These harmful chemicals are ‘widespread globally as a result of historical use’, and to tackle them once released into the environment is technically and financially challenging. To risk stating the obvious, it would be preferable that such chemicals were not released to the environment in the first place… Previously we were party to an EU-wide system for controlling chemicals called REACH; post-Brexit, Government must place clear expectations upon chemical manufacturers for significantly-increased testing of environmental impact, as part of a new UK REACH system. Without this, the burden unfairly falls to consumers to make informed choices, or to our environment to deal with the consequences.
These points and many more are being made in Blueprint for Water’s collective response to the consultation. Anyone concerned about the state of our waters can also respond, echoing these views if you wish, or sharing your thoughts on what else needs to happen to turn things around. Our waters, their wildlife, and society, will thank you.
Ali Morse is Water Policy Manager at The Wildlife Trusts and Chair of Blueprint for Water.
Follow: @WildlifeTrusts and @this_damselfly
The opinions expressed in this blog are the author's and not necessarily those of the wider Link membership.