Consultation outcome

Draft river basin management plans consultation: summary of responses

Updated 22 December 2022

Executive summary

River basin management plans (RBMPs) are nationally important plans to protect and improve the water environment. They describe the challenges that threaten the water environment and how these challenges can be managed and funded. They set out how organisations, stakeholders and communities will work together to improve the water environment.

The aim of these plans is to enhance nature and the natural water assets that are the foundation of everyone’s health, wealth, and wellbeing. Along with the things people value, including culture and wildlife. Rivers, lakes, canals, estuaries, coasts and groundwater, and the essential services they provide, underpin economic growth and are worth billions of pounds to the economy. All parts of society benefit from clean and plentiful water.

The Environment Agency co-ordinates the 6-yearly review of RBMPs. The plans will next be reviewed and updated by December 2027. The draft plans describe the framework used to protect and improve water quality in each river basin district and were last updated in February 2016. The draft plans have been produced under the Water Environment (Water Framework Directive) (England and Wales) Regulations 2017 (WFD Regulations) and Ministerial Guidance on river basin planning 2021.

We co-ordinated the preparation of the draft RBMPs with flood risk management plans, aligning with the consultation on draft flood risk management plans open from 22 October to 21 January 2022. This was to enable integrated outcomes and multiple benefits for both managing flood risk and the water environment.

This report provides a summary of the main points raised from the 270 responses we received from this consultation on the draft RBMPs. The main themes you told us about are:

• biodiversity

• chemicals and plastics

• climate change

• flood and coastal erosion risk management

• funding

• implementation

• nature-based solutions

• partnership working

• planning and regulation

• rural issues and rural land management

• urban issues

• water industry

You largely supported the implementation principles. However, you asked for more detail on how the principles will be implemented. Most agreed with the environmental objectives in the RBMPs. You wanted the environmental objectives to be achieved as soon as possible to help the environment deal with climate change. At the same time, you acknowledged that the scale of the challenge to achieve the objectives will also increase because of the pace of climate change. Many of you are concerned about the lack of progress since the last river basin management plans towards meeting good ecological status. You said that the draft RBMPs lack ambition.

Many of you wanted more clarity and improvements to the information about measures and you found this information difficult to use. Some of you wanted and expected to see more information on local measures about local places presented in a more accessible way. Conversely, other people wanted to see greater clarity on the strategic approach to prioritising action across different catchments (that is between different local places).

Catchment partnership pages are included in the RBMPs for the first time and you welcomed them. Many of you said the partnership pages demonstrate the growing importance of the Catchment Based Approach (CaBA) and catchment partnerships in implementing RBMPs.

There was wide agreement on these issues:

• a system-wide approach, from source to sea, is the most appropriate way to manage the water environment

• wider engagement with water users to increase knowledge of the importance of clean and plentiful water, and compliance with water quality regulations and water efficiency measures

• a long-term planning approach to adapt to climate change

• the significant collective challenge now and ahead, particularly regarding chemicals

• changes to planning and regulation across government, and adequate funding to deal with the impact of activity in urban areas, housing, water supply and rural areas

• the need for more nature-based solutions, accepting and managing the risk inherent in these approaches

• long-term funding for organisations, particularly catchment partnerships, to improve the environment by working collaboratively using the catchment based approach

• monitoring and data collection using a wider range of sources, including citizen science

• better linking across other plans and strategies and with partners, for example on flood risk management and managing coastal waters

• more easily searchable data, particularly at more local levels

1. Introduction

The consultation on draft RBMPs was open from 22 October 2021 to 22 April 2022. These draft plans were for the following river basin districts:

• Anglian
• Humber
• Northumbria
• North West
• Severn
• South East
• South West
• Thames

Your feedback through this consultation helps us produce updates to the current RBMPs. We will use the information you provide to inform, improve, and shape how the water environment is managed.

We will also use your responses to help us consider how some of the current approaches to managing water in England will need to change. This includes changes in the medium and long-term in response to the changing climate and a growing population.

When the consultation responses have been considered, the Environment Agency will submit the proposed updated plans to the Secretary of State for Environment, Food and Rural Affairs for their approval. Once approved the updated plans will be published on GOV.UK.

This document provides you with a summary of responses to the consultation on the draft RBMPs. In the autumn, the Environment Agency will produce a further document that summarises how your feedback through this consultation has helped us update the RBMPs and how your views help shape the future approach to the management of the water environment.

The Severn draft RBMP included in this report is the only cross border RBMP. There are 2 other cross border RBMPs not referred to. These are for the Dee Basin (on the English and Welsh border) and the Solway Tweed Basin (on the English and Scottish border).

The draft Dee RBMP, led by Natural Resources Wales, was consulted on between December 2020 and June 2021 and published in July 2022 Dee RBMP 2021-2027 summary.

The draft Solway Tweed RBMP, led by the Scottish Environment Protection Agency, was consulted on between December 2020 and June 2021 and published in December 2021 Summary of the Solway Tweed River Basin Management Plan in England.

1.1 Previous consultations

The draft RBMP consultation builds on these previous consultations.

The Working Together consultation was open between 22 June and 22 December 2018. You can:

• read the River basin planning 2021 - working together consultation

• see the submitted responses (where consent was given to publish) on the Working Together consultation

The Challenges and Choices consultation was open between 24 October 2019 and 24 September 2020. You can:

• read the Challenges and Choices consultation summary report for details of the feedback received

• see the submitted responses (where consent was given to publish) on the Challenges and Choices consultation website

It is also informed by feedback the Environment Agency receive from partners through engagement as part of routine implementation of Programmes of Measures such as issuing permits, collaborating on catchment management initiatives and dealing with incidents.

2. The consultation processes

We asked 6 questions in this consultation. These asked for your views on the:

• implementation principles

• objectives

• measures – whether any were missing

• new measures proposed and any additional measures

• catchment partnership pages and priorities

• anything else you felt important

We ran the consultation on our Citizen Space website. Paper copies of the consultation were also available on request in Environment Agency offices in each river basin district.

We contacted over 3000 people and organisations to let them know about the consultation. These people and organisations had previously asked to be kept informed about river basin and flood risk management planning. They were also organisations with responsibilities associated with the water environment. We used the government’s ‘notify’ service to email the contacts. We also placed statutory notices in newspapers in each river basin district and a national paper. During the consultation we sent email reminders to encourage people to respond.

Environment Agency colleagues used regular meeting opportunities before and during the consultation period to let people know about the consultation, presenting or providing information. Agenda items and presentations took place with national and local key stakeholders including:

• the National Farmers Union (NFU)
• the Coastal Groups Network
• the Local Government Association
• Local Nature Partnerships
• the Angling Trust
• the London Drainage Engineers Group (LODEG)
• water companies
• wildlife trusts

Response-gathering sessions with catchment partnerships were held in each of the 8 river basin districts. These facilitated joint sessions gathered responses for the draft RBMPs and draft flood risk management plans and took place during 22 October 2021 to 21 January 2022 when both consultations for these draft plans were open. The stakeholder sectors included:

• flood management
• angling
• estuarine and coastal
• local authority
• recreation
• trade body
• consumer group
• catchment partnerships

Some facilitated sessions were held with other national key joint stakeholders with a focus on specific measures. These were with:

• Regional Flood and Coastal Committee conservation members
• Shoreline Management Plan leads
• the Consumer Council for Water
• the Angling Trust Freshwater Advisory Group
• the British Egg Industry Council
• the Association of Directors of Environment, Economy, Planning and Transport (ADEPT) Flood and Water Group
• Kent County Council
• the Sports Turf Research Institute
• the Yorkshire Integrated Catchment Solutions Programme (iCASP)

We worked with the Water Leaders Group, a sector reference group with representatives of major sectors and national organisations across the water system that helps shape water system-wide initiatives and wider strategic activities.

Some organisations included information about the consultation opportunity in their newsletters, for example ADEPT, CaBA and the Angling Times.

2.1 Consultation response

We received 270 responses; 187 were from organisations and 83 were from individuals or no information was given.

Organisation type	Count
National organisations	12
Individual	60
Defra group or governmental bodies	8
Wildlife Trusts, River Trusts or Angling Trust	17
Private sector	11
Utility organisation	11
Local environment management organisations	96
National environment management organisations	19
Local government	25
Unknown or other	11

We received 230 responses through the online consultation tool on Citizen Space. A few were submitted by email to [email protected] and some responses were gathered at meetings which were added on to the consultation tool. Some organisations provided both a national and local response.

People who responded gave the following information about how they found out about our consultation.

Please let us know where you found out about this consultation	Count
Email from the Environment Agency	88
Internet search	4
Social media	16
Meetings or calls with the Environment Agency	67
Government website	21
Other	37
Not answered	37

Of the 270 respondents, 226 (170 organisations and 56 individuals) gave their consent to publish their responses. You can find the published responses on the draft river basin management plans on Citizen Space. These are anonymous and moderated where necessary in line with publishing standards, which includes for data protection purposes.

3. Summary of consultation responses by question

This section provides a summary of relevant common topics, suggestions, and views that you provided together with some specific points raised. It does not summarise all the points given but is a representative summary.

3.1 Question 1. Implementing the plan – what are your views on these principles?

We asked for your views on the following principles for implementing the measures within the plans and how easy or difficult these might be.

1. Take a collaborative place-based approach. Align initiatives on water and pool resources to achieve more than partners can achieve alone.

2. Make evidence led decisions. Work with partners to build the evidence base. Use it to make evidence led decisions that are explicit about the intended benefits of actions and transparent about the assumptions used.

3. Take account of future and changing risks to delivery – in particular, the effects of climate change and population growth – to make sure actions perform as intended over their lifetime.

4. Consider a range of possible futures (for example 2°C and 4°C temperature rise by 2100). Use flexible approaches that enable solutions to be modified in the light of changing circumstances or new information.

5. Contribute to net zero. Minimise greenhouse gas emissions and maximise carbon capture aiming for net zero.

6. Restoration of the natural environment offers the potential to deliver carbon sequestration as well as other benefits. Many partners have already committed to ambitious net zero targets.

7. Build catchments resilient to warmer water temperatures, more frequent floods and drought, and rising sea levels. Choose measures that help natural assets cope with or recover from shock.

8. Work with natural processes. Where possible choose nature-based solutions to protect and improve natural water assets and deliver multiple benefits.

9. Promote restoration and recovery of freshwater, estuarine and coastal habitats, and species. This will provide resilience to climate impacts. It may also sequester carbon and provide many other benefits for people and wildlife.

You welcomed the new principles for implementing the plans and support them. You also said that further guidance is needed when the plans are implemented. You wanted to see better integration with other strategic plans, including how to fund the measures set out in the plans. You said policies, strategy and legislation need to be better integrated and aligned. This is needed to help pool resources and improve the likelihood of meeting ambitious targets to protect, manage and maintain water resources.

The increased public and political attention being given to river health, and to the wider issue of the nature and climate emergencies, emphasises the importance of effective measures to restore our precious waterbodies. This profile and timing provide a once-in-a-generation opportunity to attract critical support and finance for making real progress. It also shines a very bright light on the RBMPs – they are one of the central mechanisms for delivering better river health, so it is more important now than ever that they are up to the task.

Quote from the wildlife sector

Many of you said there are too many principles. You recommended that they are summarised and simplified to maintain the focus on restoring and recovering habitats and species and more integration with the government’s 25 Year Environment Plan. You found some of the language and the amount of detail on the implementation principles either vague or lacking in explanation. You questioned terms like ‘place-based’ and said this needs more detailed explanation to add clarity.

Some of you were concerned that all the principles are very broad. Others said they are clearly focused on water quality and landscape, but there is a lack of balance with other socio-economic factors, including food production.

In responding to this question, the topics you most often referred to included the lack of ambition in the RBMPs, the difficulty in finding the information you wanted in the plans, and the following subject areas:

• biodiversity
• chemicals and plastics
• climate change
• data
• flood and coastal erosion risk management
• funding
• implementation
• nature-based solutions
• partnership working
• planning and regulation
• rural issues and rural land management
• water industry

3.1.1 Take a collaborative place-based approach

There was strong support for this principle. Some of you suggested using the term ‘catchment based approach’ rather than place-based approach. Many of you said that the CaBA network of catchment partnerships in every river basin district is essential for delivering the RBMP principles, especially for this principle about collaboration. However, you said the principles need to be more joined up at a catchment scale to work. You said there is sustained commitment from catchment partnerships to deliver and there is a good structure already in place that underpins the catchment based approach. You said the catchment based approach will deliver more cost effective, efficient, and multi-benefit projects. You suggested the catchment level is the logical scale of water management, as it is recognised in the resilience principle.

You also said that place-based working must be from catchment to coast. More focus within catchment partnerships on the coast and the estuarine environment is needed to deliver this principle and achieve more effective results.

You noted that the CaBA data package encompasses over 200 geographic information system (GIS) data layers, associated guidance, and thematic data hubs, much of which is directly relevant and of potential benefit to the (place-based) Nature Recovery Networks and Coastal Partnerships.

You said relevant stakeholders want to understand how they can contribute to implementing the RBMPs and it is important for them to be included in planning and partnerships. You wanted better collaboration, engagement, and involvement across a whole range of people and partners. For example, a closer working relationship across the water sector including catchment partnerships and Highways England. Additional finance could be effectively channelled through Highways England to catchment partnerships to reduce pollution and run off from roads and cars.

Working together (wider stakeholder groups, river groups, local government, academics, water companies, wastewater companies and agriculture) is vital in understanding the environment and in achieving greater benefits for it.

Quote from the water industry

You said linking up at government level is important, so that industry is not trying to comply with competing measures in an already complex area. Collaboration and consistency of approach is important too. The collaboration should include:

• local authorities
• businesses
• the private sector
• agriculture and landowners
• catchment partnerships
• Environment Agency flood and coastal erosion risk management teams

Some of you said that farmers and landowners are under-represented in catchment partnerships and that more effort is required to increase this. You said farmers want to be part of the solution. They can make a major contribution to delivering the ambition of the both the RBMPs and the flood risk management plans. You also said it can be challenging to bring together differing and sometimes competing interests of stakeholders. Better governance, coordination, and guidelines are needed to help catchment partnerships work more effectively. And roles need to be clearly defined. You stressed the benefits of more public engagement and education.

A barrier to achieving a place-based approach is the high level of investment needed for project development, engagement, and collaboration. You suggested increasing public sector co-operation agreements between partners to use resources more effectively. Along with increasing budgets to improve the effectiveness of RBMP measures.

Although catchment partnerships are in a prime position to work to these delivery principles, they need more investment, multi-year funding and resources. You said the time and resource required to deliver through collaboration are underestimated. The true costs are not reflected in funding allocations to catchment partnerships. Lack of funding for technology and resources are barriers to collaborative working across more locations with partners. You said adequate long-term resourcing is important to success and you wanted government recognition of the value of catchment partnerships.

You suggested initiatives need to align with regulations, and regulations need to be fit for purpose. You would like to see a streamlined approach through the Environment Agency permitting process for catchment partners delivering river basin management plan targets. You also suggested a review of the permitting system and funding criteria to ensure alignment with these principles and the government’s 25 Year Environment Plan.

You cited a range of funding sources, for example Flood Defence Grant in Aid (FDGiA), Water Framework Directive Grant in Aid (WFD GiA) and Water Environment Improvement Fund (WEIF) and gave information about how they can support river basin planning. You raised the important role of environmental land management schemes (ELMs) in improving the environment and meeting RBMP objectives. Many of you raised concerns over funding when considering how to fulfil the aims of the RBMPs. You said government cuts in funding for the Environment Agency limits the ability to implement the plans, including monitoring, regulation, and enforcement to combat persistent polluters at catchment level.

You asked for a review of FDGiA funding policy to better recognise the value of plans such as RBMPs working alongside them. You said FDGiA funds bring a range of flood risk management and water environment benefits, particularly in rural catchments that are less likely to qualify for funding due to low population density. You suggested that allocating funding from the FDGiA Programme that recognises the catchment scale will help reduce flood risk.

Many said there is still lack of integration in the Environment Agency between river basin management planning and the flood and coastal erosion risk management. However, you recognised that progress has been made. You said that, as responsibilities for water and flooding are spread among a wide range of different bodies, collaborative working is essential. This is helped by close engagement on local planning. This can be done through building evidence to support the local delivery plan and through collaborative management decisions.

You also said that the Environment Agency can be disproportionally risk averse in responding to a small change in hydrology in floodplains. You suggested this makes it difficult, time consuming and more costly to implement measures within the RBMPs and to apply several of the listed principles.

Due to the cross-cutting nature of the estuarine and coastal environment, many of you asked for a national framework of estuarine and coastal partnerships to help improve and manage activity at the local and area level. Many of you also called for an overarching principle supporting a catchment to coast approach. This will make more explicit connections between the built and water environment to take place. It will also improve integration in transitional and coastal environments.

There was some discontent about the separation of RBMPs and flood risk management plans. You said it will be useful to show how the various plans for the water environment work together, where they overlap and any gaps which will lead to a more joined up way of working. An example is the Making Space for Water option SW12: Making space for water where wider riparian corridors remove some agricultural land from riparian zones. These riparian zones are becoming more marginal for agriculture.

You also suggested that local authorities and the Environment Agency work collaboratively and use a place-based approach to address issues, especially protected area compliance and nutrient neutrality. Current gaps include local plans, which are the main means of place-based working. You suggested that increased engagement regarding biodiversity net gain and nutrient neutrality work can identify wider sources of funding.

In relation to drinking water, you raised the importance of ample, clean water for the future. You said it is important to have a robust collaborative evidence base, multi-sector funding and to improve partnership working. You wanted to see a balance of water quality and quantity issues in the RBMPs. You expressed concern over the pressures on nature from landowning interests and activities which affect the availability and quality of drinking water. You saw a need for improved regulation and enforcement and a balance between voluntary and regulatory interventions.

Improved processes for cross-border river basin districts were called for. The Environment (Wales) Act means Natural Resources Wales has a duty to produce Area Statements to help implement the priorities established in Welsh Government’s Natural Resources Policy. You said that while Natural Resources Wales continues to advocate Area Statements within the river basin management process, not all stakeholders support their use as an evidence base or a prioritisation tool (or both). The boundaries of river basin districts and Area Statements do not align which adds a further layer of complexity. Added to this, the Severn and Dee River Basin Districts cross the Wales-England border.

3.1.2 Make evidence led decisions

You agreed that prioritising activity in the RBMPs must be evidence-led. You said evidence needs to be better explained for non-specialist audiences. Some agreed that the Catchment Data Explorer is an improvement, but others told us that they find the data confusing. You feel there are many omissions in the list of current challenges across many catchments. You requested an interactive map to show priority areas and projects and said an integrated view of the whole water cycle is necessary, with catchments treated holistically, such as water quantity and water quality dealt with in an integrated way.

There was concern about the Environment Agency’s reduced water quality monitoring. A significant number of you described levels of monitoring as inadequate, underfunded and out of date. You wanted to see more resources and funding, improved monitoring scope and frequency, and collaborative working on data and evidence.

You said it can be difficult to obtain or include funding to build an evidence base when you are developing project funding bids. You said more funding is needed to make regulation more effective, and for the whole lifespan of projects to help monitor and quantify their impact.

Many of you were concerned that a lack of monitoring and evidence will prevent actions from being taken forward. Others suggested that a lack of evidence should not, under the precautionary principle, prevent work on environmental protection from taking place. Some of you said there can be a greater reliance on self-monitoring. Others said there is too much reliance on operator self-monitoring and there is a lack of enforcement action.

You said the ability to provide evidence to identify the sectors responsible for non-compliance relating to water body status is lacking. And this is used to justify inaction. Many of you felt that too often the cost burden is left with stakeholders and landowners.

Many agreed that working with partners is a valuable principle where data sharing must be at the centre. You cited some best practice examples such as the work on the river Tamar and the Catchment Systems Thinking Co-operative (CaSTCo) initiative. This new initiative is building a national framework for a catchment monitoring cooperative, using citizen science and standardised approaches to data collection and management. It is critical, therefore, that this collaborative and innovative project is backed by government.

Many said catchment partnerships already share data using national data packages and by pooling resources. This enables them to provide environmental benefits that would not be possible by working alone. You supported combining resources to increase efficiencies and suggest this could be done through blended and varied funding streams. Others said a balance of free and paid-for data is required because access charges for local environmental information reflects the cost of keeping databases maintained.

You told us that there is a lot more data available beyond what the Environment Agency use, and you recommended creating a collaborative evidence base. You said that while catchment partnerships can access Environment Agency and some water companies’ data, not all this data is open, and it can be very hard to obtain. You told us that local record centres are full of important data, but these are not fully used. However, you advised against ‘analysis paralysis’ and said that in many cases there is enough evidence to proceed with actions.

Many of you wanted better recognition and use of citizen science to fill evidence gaps, working with communities and sharing data. You suggested the national Riverfly citizen science project should be included in RBMP measures.

You would like to see standards for monitoring methods so that the data collected by others is more likely to be used. You said it would be useful to know the level of contamination that producers contribute to the environment. For example, soil and atmospheric pollution. An accurate and true picture of the impact can help decisions on investigations. You said industry needs guidance on good and bad practice.

You said the Regional Water Resource Plans that are currently being developed will calculate long-term water supply budgets, consider drinking water, and supply needs, and could offer valuable insight into river basin planning.

You said a ‘one size fits all’ policy to tackling rural diffuse pollution issues will not work and that a targeted approach using local evidence is required. Further, you said that the monitoring regime in Welsh rivers has largely developed historically to understand the impact of sewage treatment works. You suggested that monitoring locations may no longer be optimal in Welsh rivers and elsewhere.

You questioned whether there is sufficient monitoring to identify the activities responsible for diffuse pollution in different catchments. Also, whether it will be possible to monitor the improvements because of rural diffuse pollution measures identified in the third cycle plans.

3.1.3 Take account of future and changing risks to delivery, contribute to net zero, build resilient catchments, work with natural processes, promote restoration and recovery

You wanted clearer, simpler language to explain complex terms and concepts. In addition, you said that innovation is lacking in the plan. You suggested that encouraging innovative solutions and risk-sharing should be a principle. This would drive more catchment and nature-based solutions in river basin management.

Many said we should work with natural processes to build catchments that can withstand warmer water temperatures, more frequent floods and drought, and rising sea levels. You said we should sustain water resources in all lakes, rivers, tarns, and groundwaters. For example, by managing extremes of high and low water levels and flows to achieve optimum ecological habitats and populations.

You said long-term planning of 10 to 20 years is becoming standard across all industries because this is the investment term. You said that industry needs to adapt to linking to the Intergovernmental Panel on Climate Change (IPCC) and the latest evidence base on climate change. You said there is not enough urgency in addressing the implications of climate change. Also, that there is a lack of a coherent and well-funded strategy for understanding the impacts of and adapting to climate change. You urged the Environment Agency to get better at long-term planning and integration. You said current Defra-funded work needs to align with local authorities’ climate emergencies work.

There is strong support for the restoration and recovery principle. You want it to have more prominence in the list of principles. That is, reference to nature recovery, protected sites, and education. Some respondents request more focus on biodiversity, and habitats and species recovery should act as a steering principle. However, many of you question how this can be achieved without substantially increased investment.

This river basin management plan round should be looking to the future and as well as addressing the issues of climate change, it needs to consider other issues impacting water quality and ways to reduce or remove the effects.

Quote from a catchment partnership

You said that a better understanding is needed on the benefits of building resilience into catchments for people and the environment. Also, it needs adequate funding. You recognised a growing need to understand the true value the environment provides. For example, a monetary value for the services the environment provides.

You suggested a review of the permitting regime to ensure it meets the challenges of climate change. You also suggested a new strategy to help the country adapt to climate change, co-delivered by local authorities, the Environment Agency, catchment partnerships and business.

You commented on long term plans for a range of climate scenarios. You suggested that while this is being considered across many strategic plans such as Water Resources Management Plans and Water Resources South East, it needs sharing more widely taking a catchment scale approach. You said it is vital to plan but acknowledged that, at a catchment scale, it is difficult to do. You suggested investigating catchment scale vulnerability and working towards adaptation and mapping future opportunities.

You wanted to make sure climate change effects are built into coastal and fluvial flood protection schemes. Thinking of the link between RBMPs and other plans, you noted that the shoreline management plans feature ‘managed realignment’. This may increase the saltmarsh area and hence the carbon capture, so you recommended that marine management and shoreline management plans are linked to the river basin management plan. Many of you mentioned that habitats such as seagrass and salt marsh will be an essential part of helping to manage climate change. For example, by providing carbon sequestration and carbon sinks.

The water industry would welcome flexibility to invest in the whole-catchment approach to achieve multiple benefits for the water environment. However, you wanted to see better monitoring of the environment to understand the impact of water companies’ activities and the effectiveness of their actions. They are working towards net zero and building a low-carbon approach into project design where possible. However, they are not fully in control of their carbon footprint such as the source of fuel from electricity suppliers.

There is strong support for giving nature-based solutions a much greater priority. These will help manage the water environment and help restore estuarine and coastal habitats and species. However, you stressed the importance of engineered options and maintenance. Many recommended a blended approach, using nature-based solutions alongside engineered options. You’d like to see evidence of the benefits of potential and actual nature-based solutions, for example by showing benefits using mapping techniques.

You asked for less rigid regulation on natural processes to encourage departure from the status quo and bring in dynamic change. You said regulation is unbalanced; those who want to undertake positive works must fulfil extensive requirements, while those who break the law are rarely prosecuted. You said it is wrong to assume that funding local actions is too costly or is unachievable. This should not restrict the ability to work with natural processes.

Many of you said that nature-based solutions should be prioritised. significant number of you highlighted the need for a clear strategy for nature-based solutions focusing on:

• how solutions can be implemented
• what the specific role of partnerships is

You advocated catchment partnerships to identify catchment priorities and where nature-based solutions fit within them. As part of this strategy, several of you highlighted the need for champions with strong ambitions for addressing climate change and the biodiversity crisis. Some wanted catchment groups better linked with industry to get a better understanding of goals and opportunities. Large-scale, fundamental commitment by government to catchment partnerships is also wanted.

Taking a catchment-based approach will offer the best opportunities for understanding the scope to deliver habitat restoration from source to sea, implement nature-based solutions which limit carbon emissions and deliver against wider objectives such as flood risk reduction, develop natural connected rivers that aid support healthy fisheries with fish free to migrate throughout the system, and build catchments which are naturally resilient to future pressures such as climate change.

Quote from the angling sector

Some respondents reflected on their positive experience when they delivered natural flood management measures. Numerous respondents raised the challenge of finding resources to manage and maintain natural flood management measures, such as leaky barriers, which can help increase resilience to climate change.

To enable more natural flood management measures and natural processes to be used, you suggested making current permitting processes simpler and reviewing permitting for chalk rivers. You said that, to re-naturalise heavily modified chalk rivers to provide flood relief benefits and natural capital, there needs to be more ambition in making catchment based assessments as identified in the principles. Too often any change in hydrology of the floodplain is not consented easily. And for third party delivery organisations it makes the whole process of making improvements time consuming, costly, and more difficult than it needs to be.

You said that, with dedicated funding, the coastal partnership network can support collaboration with regional coastal groups. Part of this is agreeing cost-effective and longer-term solutions to shoreline management. You gave examples of coastal habitat restoration as a nature-based solution and of linking natural flood management, green-blue infrastructure with heavily modified waterbody corridors and coastlines reflecting a catchment to coast approach.

You suggested more explicit references to transitional and coastal waters in various funded measures would ensure risk management authorities, water industry and non-government organisations partnerships can easily identify which measures include transitional and coastal water benefits. For example, Local Nature Recovery Strategies, water industry led improvements, farming initiatives, diffuse pollution, and green-blue infrastructure measures.

You were broadly supportive of the strategic approaches for managing physical modifications and ask for longer term, more sustainable funding. Some of you wanted to remove barriers and culverts and ask for more funding for urban catchments. The value of urban rivers is noted, and you point out opportunities to better manage physical modifications. You said a flexible and balanced approach to managing physical modifications is needed that pays attention to protecting current uses.

You said the growing supply and demand gap is leading to degraded freshwater environments in our chalk catchments, and we should address water efficiency at source. You suggested mandating water efficient development, retrofitting social housing, and providing subsidies for private housing upgrades. You stressed the importance of a National Planning Policy Framework that is fit for purpose in water stressed areas. You said to stop relying so heavily on customer behaviour change to meet shortfalls, which is unpredictable and variable and consistently puts chalk rivers under more pressure. You suggested implementing the precautionary principal approach for chalk rivers and asked for support for catchments where post-mining activity is a risk.

You also suggested smaller diffuse discharges need to be addressed. You said nutrient pollution from intensive agricultural practices hampers activity to build healthy, well-functioning catchments and the solution is nutrient management and removal. You wanted to educate plumbers and homeowners about pipe misconnections and the problems caused by putting wastewater into clean water systems. You are concerned that polluted water resources in increasingly urbanised catchments will mean we will likely never achieve the full ambitions of the river basin management plans. You said that opportunities to use natural processes to treat discharges and run off should be increased. More flexibility is welcomed to reduce contamination.

Funding is mentioned often. You wanted to see pooled and blended approaches and a much longer-term funding consideration, recognising the longer-term nature of nature-based solutions. You highlighted several funding routes and schemes including:

• Basic Payment Scheme
• Environmental land management schemes (ELMs)
• Flood Defence Grant in Aid (FDGiA)
• Countryside Stewardship
• Catchment Sensitive Farming initiative

Some said there is a lack of people and funding to carry out fisheries work to tackle ongoing issues affecting fish stocks and fisheries. Resource can be redirected or unlocked from other funding streams, for example from flood risk, especially in relation to improving fish passage and reducing habitat pressures.

You agreed that reducing invasive non-native species is a priority issue. Some asked that invasive non-native species and biosecurity are highlighted in the principles within section 2.1 of the plans. You said that funding for invasive non-native species is critical because controlling this is expensive and current funding is not working. More evidence needs gathering and action needs to take place at the catchment scale. There is a clear desire to see the control of invasive non-native species feature in all aspects of the plans. You wanted to see more and faster action to slow the introduction, spread and impacts.

Conversely, you also said limited funding can sometimes lead to decisions on which priority species to support, when not all species can be protected. You said little money or time is given to coastal waters and habitats. There was concern that previous RBMPs have not delivered for protected sites.

You noted that natural flood management and nature-based solutions are not commonly funded through Regional Flood and Coastal Committees or FDGiA and you thought this should change. You also suggested capital funding, including through the WEIF, is needed. You said the lack of recognition of nature-based solutions and natural flood management by funding allocators needs to change as it is hard to get funding. Nature-based solutions and natural flood management need higher prominence. In addition, estuarine and coastal waters are neglected by funding mechanisms. Long-term, sustained funding will help with these activities.

Some of you said the current arrangements for funding and payments make it difficult to fund some projects. For example, activity to help catchments become more able to withstand climate change. Others felt biodiversity net gain and nutrient neutrality payments can help encourage landowners to restore habitats. You said that many schemes and funding streams are about compensation and net gain. It can appear that the Environment Agency are compensating for what is already lost rather than focusing on catchment resilience. You said investment does not match diminishing returns and that there is a balance between money spent to get to the net zero target and the cost of adapting to climate change. Some of you said there are barriers for partners to get funding from the Environment Agency and you want partners to be more trusted if they are already engaged. Funding more than just the core work can help deliver projects more smoothly and give greater confidence to partnerships. You also said you are looking for opportunities to dovetail river basin management planning actions with wider works in the water environment, either through the forthcoming ELMs or biodiversity net gain funding. You asked for clarity over opportunities within the schemes at a farm scale for detailed nature recovery.

You raised the important role of the food market in helping agriculture to improve water quality and reduce pollution. You suggested that food retailers need to pay producers’ adequate amounts to enable them to protect the environment. You said farmers and landowners will look at the bigger picture, but the incentives must benefit them and meet their objectives. You wanted to see catchment level direct engagement with farmers to develop smart funding solutions that will meet mutual goals. You said that the agriculture sector has not had access to the same funding as many other sectors and the current move away from the Common Agricultural Policy sees the biggest change in policy in decades with the reduction and phasing out of Direct Support Payments eventually be phased out by 2028. This significant reduction in cashflow will make it increasingly difficult for farmers and land managers to invest and help improve water quality. With other global factors having an impact, you stressed the need for adequate funding support available to farmers.

You saw opportunities for payment for ecosystem services and wider sources of investment. You welcomed natural and social capital metrics and values to consistently measure our impact and help agree best value decisions. This will benefit people and the environment if the metrics help avoid any skewing of the measures. It will trigger alternative ‘greener’ solutions and drive innovation and partnership working. You said it is difficult to assess multiple benefits of nature-based solutions and accurately complete cost-benefit analysis on these types of measures. And this needs to be developed to ensure this principle is adopted by all sectors and organisations and incorporated in decision making. You said we should accurately model the multiple benefits of nature-based solutions and share this data with partners.

You suggested that a new organisation that approves projects and quantifies benefits, so businesses can buy into approved projects, could work for small scale voluntary schemes. You said being able to stack (build up investment risk, starting with low risk investments) and trade other natural capital goods along with carbon trading will help fund measures to deliver necessary carbon reductions. You suggested working with natural processes will become easier with developments in natural capital accounting.

You said achieving net zero carbon emissions will be difficult because:

• definitions of it vary
• there’s a lack of clear planning on how to achieve it
• it’s very difficult to measure ‘net’ and needs standardisation

Industry and many other sectors will be impacted. More funding to reduce carbon emissions may make principles easier to adopt, you said. Current funding arrangements make it hard for partners already committed to ambitious net zero targets to put measures in place. You said that identifying wider benefits helps recognise other beneficiaries of these services and can unlock partnership funding streams.

You said working with public money can result in a more risk averse approach. You wanted authorities to work better together, and for partners to have more resource to do so. You said that cyclical funding for the water industry helps but because the environment takes time to respond, results may not always readily inform the next cycle.

You said that extending Making Space for Water beyond protected rivers will act as a financial benefit for landowners. You also said that land purchase and working with re-wilding companies is a way to guarantee long-term land use planning and sustainability. You said financial incentives will help to release land and ensure schemes are maintained. You wanted to see more innovation and changes in the way success is measured to encourage investment.

You suggested that prioritising nature recovery can be incompatible with, for example, recreation. You’d like more evidence to demonstrate the effectiveness of nature-based solutions so they can be used more often. You wanted the true value of land to be recognised because people need to be paid to relinquish, protect, and restore land. You said that linking this to planning will help raise money from developers and making net gain mandatory can provide funding. You said that opportunities for restoration and adaptation need to be:

• clear
• based on good evidence
• prioritised through spatial plans and policy – for example linked to Local Nature Recovery Strategies to secure and focus investment

You suggested industry and land users would be willing and are trying to decrease pollution in pressured environments. They may not directly increase restoration and recovery, but they may be unaware of how, if at all, their impacts have a direct influence downstream.

You said government and water companies are putting too much emphasis on behavioural change rather than technologies to reduce consumption and wasted water. You said funding skills-based education programmes where participants are taught skills to manage water use can be useful but are difficult to fund. There should be more education on river habitats and wildlife, and more education on these topics for children.

3.2 Question 2. Do you agree with the environmental objectives in this draft plan?

We asked you to what extent you agreed with the objectives in the draft plans and which, if any, you would like to change and why.

Do you agree with the environmental objectives and targets in the draft plans? Tick the box that applies	Count
All	59
Most	81
Some	53
None	8
Not answered	70

You agreed that to meet the objectives outlined in the plans, a strong ambition is needed but you questioned whether the river basin management plans are ambitious enough to meet the objectives.

Many of you expressed concern about the lack of progress on meeting good ecological status (GES) since the last RBMPs. It was noted that some water bodies have deteriorated in status since 2015. Many of you wanted greater consideration given to protected species, habitats, and protected sites like Sites of Special Scientific Interest.

You wanted to see evidence on current classifications or reasons for not achieving good ecological status. You said there is inadequate technical evidence supporting measures in the RBMPs. Priority actions, measures and reasons for not achieving good status (RNAGS) are only partially listed, are not up-to-date and are different from local catchment knowledge.

You recognised the Water Framework Directive (WFD) methodology is well established but are concerned that progress towards good status is being masked by the ‘one out all out’ rule. This rule means that if one of the different chemicals, biological and physical elements is not achieving good or better, then the water body cannot be at good overall status. You asked for more detail on water quality status. For example, reporting where there is progress in the right direction, even where good status has not yet been achieved. This will motivate and mobilise industry to take more action to improve water quality.

Regarding ambition, you said that while objectives and targets are worthwhile, the legislation and policy need strengthening. Public bodies making sure that these principles and the environmental objectives of the plans are reflected in their processes (The Town and Country Planning Act and Local Plans) is a great idea in principle but could prove tricky to implement. In particular, if the objectives are not enforceable or backed by a statutory consultee status on future and current proposals.

Some of you felt progress has not been limited by the effectiveness of local catchment partnerships but has been affected by a decrease in Environment Agency and Natural England resource for regulation and enforcement. Also, some of you felt that government was failing to address some of the causes of deterioration and RNAGS in headwater areas of catchments. You welcomed government schemes to aid catchment recovery, such as Landscape Recovery and ELMs programmes. However, you questioned why other policy changes have not been made in parallel, for example to safeguard improvements that can be gained through such schemes as the National Planning Policy Framework.

You suggested it would be useful to understand what ‘disproportionately expensive’ and ‘disproportionate burdens’ mean. This would help to identify what could be done to reduce those costs and burdens.

You said the plans should detail what funding will be used to achieve the objectives, alternative objectives, and the associated measures and projects. Many of you noted that most of the objectives for 2027 are proposed with ‘low confidence’. Some of you thought it is unrealistic to expect much progress by 2027 without, for example, additional and different measures and funding. You also said that the plans miss the opportunity to show how sector-wide effort by risk management authorities in each RBMP region will work together to meet European conservation objectives.

You said that public bodies should make sure the RBMP environmental objectives are reflected in their processes and plans. For example, the town and country planning system and statutory local development plans. You felt this approach needs to apply across government, including that policy takes RBMP objectives into account so that targets are achievable.

You said that a canal system has an effect on water bodies that interact with it or are downstream, not just the canal system itself. Water bodies downstream of reservoirs should be appropriately classified as artificial or heavily modified.

Some of you supported the objectives to deal with metal pollution from abandoned metal mines and stressed that these should reflect the proposed long-term Environment Act target to reduce pollution of rivers and estuaries from this source. Some stressed the importance of the continued funding from the Department for Business, Energy, and Industrial Strategy (BEIS) sponsored coal mine water programme (preventative and remedial schemes) and the Defra-sponsored Water and Abandoned Metal Mine Programme (point and diffuse sources).

Chemicals and plastics

Many of you wanted to know how the objectives for chemicals has been set, particularly the date of 2063 for getting to good chemical status. Some of you wanted to see emerging chemicals and plastics considered.

We received several suggestions about how to reduce microplastics in the environment. For example, enforcing the law for removing microplastics from sewage. Or introducing laws on litter and rules for water butt and solar panel ownership. A change to the water body status objectives (section 4.5) was suggested to include the challenge of addressing microplastic contamination. This will make sure all parameters to meet good status are considered. You said that objectives should be changed to include microplastics in the chemical status of non-priority substance as they have big impacts on public health and aquatic environments. The approach for testing for persistent organic pollutants (POPs) could be applied to microplastics in water environments. The Environment Act and the RBMPs highlight this approach, offering innovation and the ability to present research findings. To illustrate this issue, a University of Manchester study is cited where the River Tame is the most contaminated water course in the world in terms of microplastics.

You said where abstraction reductions are implemented to meet the water resource objective, the water quality element may deteriorate if it’s not taken into consideration. Some of you said that nutrient neutrality should be a requirement for all water courses. Several respondents highlighted that Natural England has issued ‘nutrient neutrality’ advice to developers in specific catchments. These respondents want to better understand the implications for the RBMPs as well as the water body and protected area objectives. However, consideration will need to be given when protected area condition assessments become more limited in scope and less spatial in the future. You said that affected catchments need to include nutrient neutrality in their objectives, but this can be included within nutrient sensitive areas and elaborated upon in section 5.4.2 of the plans.

You noted the important role Diffuse Water Pollution Plans play because they are complementary to RBMPs and support key work areas such as nutrient neutrality, Local Nature Recovery Strategies and Protected Sites Strategies. You recognised that actions detailed in the Diffuse Water Pollution Plans will contribute to meeting the government’s 25 Year Environment Plan targets for biodiversity, WFD objectives for European Sites and Environment Act targets.

There was support for RBMPs to align with the government agenda in the Environment Act 2021, with ELMs, nature-based solutions and working with natural processes. You supported projects which can play a role in other initiatives including nutrient neutrality and making green spaces attractive for people and nature. This approach delivers multiple benefits, for example river restoration, salt marsh and intertidal habitat creation and restoration, and other ELMs work.

You said more funding for research into phosphorus compounds capture will help reduce concentrations in water bodies.

Data

You said that there is a lack of data for chemical status objectives, and no objectives for the chemical status of non-priority substances or for emerging pollutants, all of which contributes to lack of progress. You asked for inclusion of extra parameters in Environment Agency status assessments, including microplastics, bacteria levels, and radionuclides.

Funding

Many welcomed government backing for nature recovery. However, regarding funding, some said current nature recovery objectives have not been met because of funding cuts. You were unclear on what will be achievable under the forthcoming ELMs funding mechanism. You said a reduction in Water Environment Improvement Funding and insufficient government funding for catchment partnerships means it is unlikely that meaningful work on a catchment scale is carried out. This affects the ability to achieve the overall targets as significant investment is needed. You suggested nature recovery is not prioritised or incentivised in rural payment schemes. You said government was not doing enough funding of regulatory bodies to address the sources of water quality deterioration. You said multi-sector participation, funding and action is required outside of water companies’ remit to ensure no further water quality deterioration.

You wanted to see how a non-statutory approach can work in the absence of putting in statutory water protection zones. You asked whether more funding will be given to sites with low confidence in achieving good status nearer the target date. You also asked for greater transparency and want to know why government is not investing in improvements for water bodies that are unlikely to reach good status.

You suggested that technical infeasibility in reaching good ecological status (GES) can be both a blocker and a trigger for new investment in research and innovation. Similarly, where there is disproportionate expense in achieving GES, you said those decisions can be reviewed to identify the point where the value of water becomes high enough to make investment a viable solution. You suggested that a globally scarce resource such as chalk streams should be prioritised where practicable. You said trends in water bodies need to be accurately measured so that there is reliable evidence for spend and resources. You asked how success is measured and reported across plans and strategies and you stressed the need to avoid double counting that can threaten future funding.

You requested more funding for catchment partnerships, monitoring and data. You said poor baseline data compromises waterbody status which makes fundraising difficult.

You suggested that preventing status deterioration for both surface and groundwater bodies needs to be supported with a robust evidence base. You thought that non-government organisations or citizen science collaborations will help to build this evidence base.

You were not confident that the funded measures will deliver the targets and asked how measures might be prioritised if funding is insufficient. You asked for more focus within the RBMPs on the methods for financing nature and catchment recovery. You said that the programme of measures should include, for example, additional funding allocated by governments in both England and Wales for regulatory activities focusing on manure management plans and nutrient run off mitigation plans.

Planning and regulation

In the context of chalk streams, you said the environmental objectives should ideally be more explicit on the need to address the impacts of over-abstraction and physical modification. There were some suggestions to clarify objectives around physical modifications and to establish targets for morphology.

Solutions included designating chalk rivers to bring legislation and planning policies to bear on chalk rivers, proper enforcement and ensuring that the status of chalk rivers is a primary consideration when deciding on how to take enforcement forward. You said where no Special Area of Conservation-designated waterways are present, yet underlying chalk aquifers are recognised as being over-abstracted, the formal process to challenge local plans or new developments is unclear. You were concerned that insufficient resources will be devoted to enforcement to ensure success and said better education, regulation, enforcement, and investment are essential.

You would like to see the objectives in the RBMPs urge government to invest in:

• a coordinated and strategic response to tackle all sources of river pollution, including agricultural and highways; preventing and managing flooding; managing the effects of all developments such as housing, commercial, urban, transport
• greater community involvement and wider partnership working
• different plans for urban and rural areas to recognise different influences and scenarios upstream and downstream
• action on chemical and plastic pollution, and on protecting chalk streams
• tougher building regulations – council, building on floodplains, porous car parks, sustainable drainage systems (SuDS), new planning regulations for both industrial and domestic development must include natural flood defences in the buildings themselves and areas surrounding them (such as green roofs, green walls)
• preventing run off from carrying more pollution into rivers
• basic legislation that’s enforceable
• review of the farm advisory landscape to understand its effectiveness, value for money and the outcomes achieved
• reduce combined sewer overflows’ spillage by better use of the planning system to deal with problems associated with growth, developing storm overflow discharge reduction plans
• more investment in infrastructure by water companies
• reducing water abstraction from rivers
• remove the automatic right to connect surface run off from new developments to the sewage system
• water metering for all properties where physically possible
• remove the right of poor performing water companies to self-monitor

3.2.1 Which, if any, objectives will you like to see changed and why?

Some respondents suggested that biodiversity should be included in the RBMPs high-level objectives (section 4.2 of the draft RBMP summary). In contrast, other respondents noted that broadening the remit of the RBMPs from their current focus on water body improvement towards nature improvement can be a distraction from the core ambition. Others wanted to see sites referenced in the objectives, such as Sites of Special Scientific Interest. Some respondents wanted to see an objective related to water-dependent priority habitats and species.

You said there is no cohesive plan or identifiable actions for fish stocks, and a specific lack of actions within RBMPs for salmon. Many of you said monitoring and classifications do not match the state of your local waters or catchments. This is largely around fish classifications not matching your experience of local fish populations. You were not able to recognise clear actions for fish that you are expecting to be identified. Several reasons are cited for this, typically lack of monitoring or monitoring in the wrong location, and the inability to make use of third party data in classifications.

You saw the potential for adjusting the status of some heavily modified watercourses that meet certain criteria to attract more funding.

Many of you said there is a gap between RBMP content and the marine scape, and that the objectives do not reference estuarine and coastal habitats. Many of you wanted a better link to the UK Marine Strategy (UKMS) and to see how source to sea improvements can benefit the relevant UKMS descriptors.

You asked for financial support for changing land management practices where these conflict with environmental objectives. You wanted to see a focus on multi-functional land use, where practices can deliver multiple benefits. This should help align funding and increase economic viability of actions needed to achieve the objectives.

Protected areas, including those designated because of their high value to threatened species or habitats, need to be considered within Management Plans. Both over-abstraction and water pollution can prevent these sites from reaching favourable ecological status. Land managers have a role to play in mitigating or avoiding these impacts, but decisions need to balance environmental objectives with local social and economic impacts.

Quote from the agricultural sector

Some said that research and development in trials of innovative treatment technologies was missing from the RBMP programme of measures.

The Coal Authority identified new strategic challenges and potential conflicts caused in treating inland saline mine water, mine water with elevated manganese and mine water with elevated bromide impacting on drinking water protected areas. They asked for guidance and assistance from the Environment Agency and government partners about the way forward where there are conflicting environmental objectives and funding limitations.

3.3 Measures

Both questions 3 and 4 in the consultation ask about measures. You gave views, comments, and solutions about measures in general as well as potential new or missing measures. This section reflects your feedback in response to the two specific questions but also summarises your more general comments about measures.

3.3.1 Question 3. Are you aware of any funded measures that are missing from the programme of measures? Please let us know what measures are missing.

Are you aware of any funded measures that are missing from the programmes of measures? Tick the box that applies	Count
Yes	93
No	98
Not answered	80

Missing measures list

Through the consultation feedback you gave and continued engagement with you on measures, a large number of local measures that you felt were missing were suggested. We have included here some examples of these local ones, followed by some of your suggestions for national ones (that could apply to any river basin district).

Local measure suggestions

Anglian

Strategic Fens and Lowlands policy review. The Environment Agency and other Risk Management Authorities will work with other bodies to provide evidence and advice to government from the strategic work in the Fens and Lowlands to inform suggested areas for policy review in the Fens and Lowlands Strategic Area

Severn and Humber

Collaborative working with partners to further engage with businesses and local communities to improve awareness and promote action that delivers multiple benefits in the Environment Agency West Midlands and East Midlands Areas to reduce flood risk, improve the environment and contribute to climate resilience.

Humber

Aligning strategies and plans: Yorkshire and Humber Climate Commission, Humber 2100+.

Thames

Anchor Sluice Refurbishment and Medway navigation fish passage project. Re-vitalising chalk rivers.

South East

Sussex Kelp Restoration Project – multi partner (Sussex Wildlife Trust led).

South West

Catchment Monitoring Cooperative and citizen science.

National measure suggestions

You noted that no single water body in England is currently achieving good chemical status. You suggested a range of solutions including a chemicals strategy with a framework for tackling chemical pollution across all sectors, encompassing monitoring, policy and legislation, source control and measures to tackle chemicals released into the environment.

You noted research into microplastics in road run off could be included and welcome new measures to investigate nature-based solutions to reduce plastic pollution.

You supported continued use of the National Water Vole Database and Mapping Project led by The Wildlife Trusts and delivered by Hampshire and Isle of Wight Wildlife Trust, the project was established in 2008 by the UK Water Vole Steering Group to collate water vole survey records, map the distribution of this species and identify important areas for water vole conservation.

You pointed out that the Canal & River Trust are leading on several funded projects which will enhance nature and biodiversity. These funded projects include the Green Recovery Challenge Fund – Pollinators and Water Voles and the Canal and River Invasive Species Eradication Project (CRISEP) which is funded by Severn Trent Water.

Some respondents highlighted that flood and coastal erosion risk management maintenance work and local flood schemes were missing from the programmes of measures. You suggested that reviewing and, if necessary, improving dredging plans should be included as measures.

You said that reservoir management strategies were missing.

You said that high level engagement programmes by water companies with farmers around drinking water protected area work, with specific focus on pesticides and nitrates in high priority catchments, could be included.

You suggested a need for more measures around educating people on the value of nature and nature-solutions based on current lack of investment opportunity and education on the and in pursuit of the associated greater economic benefits.

There was support for including research and development in the Programme of Measures.

Funded measures missing from the programmes of measures include Defra investment in trials of new technologies that can be installed to address abandoned mine contamination as outlined in the Environment Act environment targets consultation.

You suggested High Speed 2 (HS2) mitigation measures were missing.

You noted that Coastal and Estuarine Partnerships have many best practice approaches relating to coastal litter initiatives and work closely with ports and the recreational sector. You suggested assessments and litter monitoring carried out in the Marine Programme of Measures National Strategy should be included.

You suggested a measure was needed about groundwater infiltration into sewers, and recommended linkage to the appropriate plans, for example Drainage and Wastewater Management Plans, Diffuse Water Pollution Plans and Safeguard Zone Action Plans.

You highlighted evidence requirements for the real-world risks and impacts of invasive non-native species as understanding how effective measures will allow certain measures to be prioritised given limited funding.

You proposed national strategy action plans for certain invasive non-native species such as mink and signal crayfish.

You suggested that climate related changes in invasive non-native species risk could be better captured and the need to ensure that the associated measures align with GB Invasive Non-native Species Strategy.

You suggested there are some uses of heavily modified water bodies missing, particularly socio-economic uses, for example there are no specific agriculture or offshore power generation uses.

3.3.2 Question 4. Do you have any comments on the potential new measures set out in the programme of measures? Please tell us about any other new measures that can be taken forward with support from partners to achieve the objectives in the plans.

You gave broad support for many of the measures included as potential new ones within the draft plans. You gave broad support for a number of topics, some of which you felt should be prioritised in measures. These included:

• climate change adaptation
• net zero
• water-dependent protected areas (all designated sites) and priority habitats and species within catchments
• restoring biodiversity and habitat
• Local Nature Recovery
• nature-based solutions
• Biodiversity Net Gain
• local environmental land management schemes’ (ELMs) measures
• transitional, coastal and marine waters
• integration with shoreline management plan measures
• ‘whole catchment’ interventions with a focus on the entire freshwater landscape
• Water Industry National Environment Plan (WINEP) measures
• restoring and protecting groundwater
• urban pollution
• reducing or mitigating the impact on catchments from private septic tanks
• reducing pesticide contamination
• nutrient neutrality issues affecting protected areas
• mitigation of artificial or heavily modified water bodies
• integration with flood risk management
• green-blue infrastructure
• shellfish waters
• bathing waters
• research and development

You gave more information in respect of some of these measures and priorities which is summarised here.

Water quantity

You said the Environment Agency should review the licencing system to ensure water supplies remain secure, including source grouping at the catchment level.

In relation to water availability and flows, you said several measures are missing from the draft RBMPs. These include:

• greater use of hands-off flow and hands-off level conditions to constrain abstraction during drought
• permitting higher levels of abstraction where water is available
• use of The Water Services Regulation Authority’s (Ofwat) Abstraction Incentive Mechanism

You said there is no reference to relocation of abstractions from upstream to downstream in catchments and that investigation of artesian boreholes’ contribution to base flow is missing. You said the measures regarding no compensation for abstraction licences after 2028 are welcome. You questioned why these measures are only listed as potential measures and said they should be included on the main measures list. You suggested that while new powers to change abstraction licences come into effect after 2028, preparatory work should commence long before.

Water quality

You said more stakeholder engagement and guidance is needed to tackle diffuse pollution from urban sources such as highway run off, contaminated land, and misconnections, suggesting chemical amnesties for farmers and small businesses. More fuel, chemical and sewage management is required, and for chemicals manufacturers to ensure that environmental harm is minimised. You advocated nutrient mitigation plans incorporating nature-based solutions. You said that diffuse water pollution plans are complementary to RBMPs and support other key work areas such as nutrient neutrality, Local Nature Recovery Strategies and Protected Sites Strategies.

You had concerns about the lack of evidence and understanding of rural diffuse pollution and said that, to address this, there should be more research on source apportionment. You said there needs to be more understanding of other influences such as sewage discharges and domestic septic tanks. You suggested that privately owned septic tanks which drain into the catchment area and not through the main sewage system need to be improved. This would include setting strict local standards of all discharges, which are measured and will increase local standards of phosphate. Focusing on phosphate levels means being specific about outcomes, rather than method. This will reduce pollution in each catchment, improving the national picture. You suggested a solution can be a register of owners of systems who are subject to an initial round of inspections to assess current discharge levels and then subject to ongoing monitoring. The data, the incentives, and the requirements of actions need to be shared with all stakeholders. You wanted more education and awareness about septic tanks and how to maintain them, and more enforcement of the General Binding Rules.

You called for proper application and enforcement of the Environmental Permitting Regulations, such that highway outfalls that cause pollution are served with notice to apply for a permit, and that the permit conditions define the necessary level of treatment at the outfall and includes a requirement for the proper maintenance and operation of outfall treatment devices.

You said measures to address pollution and run off should be applied to upstream brooks as well, not just in a concentrated area within urban areas or just at outfall sources.

The Control of Agricultural Pollution Regulations (2021), effectively a nitrate vulnerable zone across the whole of Wales, is anticipated to cost the farming industry £360m to achieve compliance. There is a call for its contribution to meeting WFD objectives to be robustly assessed.

You suggested making a range of options available regarding who should pay in delivering objectives. You said that government funding for sectors is influenced by the polluter pays principle, but that there is a divide between sectors that can recover costs from customers and those that cannot. You also suggested an independent regulatory body funded differently to the Environment Agency can issue financial penalties that outweigh any financial gains for those not complying. You also suggested an independent public body could ensure funds are used to address specific goals and targets relating to water quality and water use and could hold water companies to account for spending these funds.

There was support for a planned pipeline of nature-based solutions and sustainable urban drainage system measures that, if packaged together into an investable proposition, could increase investor confidence, and attract finance.

You said that education is key to tackling sewage and improving water quality because it is at the heart of encouraging more people to value and connect to their local river system. This is especially relevant in an area where chalk streams are a vital part of the system. You said helping people understand the link between demand, supply and water quality connects them to the river system. You said that clean water helps protect sensitive ecosystems and habitats, promotes recreational use, and makes our river systems places people want to visit and spend time. You said that involving everyone, from government through to the public in improving the water environment creates a sense of ownership, engagement, and awareness.

You also felt that education to change behaviour around single use plastics would be welcome, as well as focusing effort on manufacturers and supply chains. An example of this, in the agriculture sector, is to provide fertilizer in reusable containers. The ‘reduce, recycle, reuse’ concept can of course be applied to many other sectors in many ways.

You also suggested increased engagement and guidance for pesticide users. You said giving incentives to use Integrated Pest Management is a more sustainable solution than increasing pesticide use. This, coupled with increased regulation and behavioural change campaigns will reduce the impact of chemicals.

Water industry

You called for water companies to make a substantial increase in their investment in nature-based solutions. You welcomed a longer term, outcomes-based approach for water company planning with better alignment to the government’s 25 Year Environment Plan.

You saw a role for Ofwat in ensuring that funding mechanisms do not inadvertently discourage the uptake of nature-based solutions by not allowing future operational costs. You asked whether water companies have sufficient funds to upgrade their infrastructure.

You said understanding water company customers’ priorities and willingness to pay will help shape additional investment to enhance the water environment.

You said water metering for all properties should be a goal.

Sustainable drainage systems (SuDS) and nutrient neutrality

Many of you wanted more funding and resourcing, alongside clearer guidance for partners, such as local authorities, to create more SuDS at catchment scale. Some suggested SuDS could be mandatory for new developments, recognising that development can help meet RBMP objectives when designed appropriately. Other suggestions included removing the automatic right to connect surface run off from new developments to the sewage system, and developers making a fair contribution to sustainability. However, alongside sustainable building practices, some respondents called for the right combination of incentives and levies for developers. Suggestions included compelling developers to integrate sustainable water management into proposals. You said that mapping and evidence-based approaches can help to locate SuDS and nature-based solutions in the best locations. Some respondents raised the principle of stopping building in floodplains.

Sustainable Urban Drainage Systems, including nature-based solutions, improve urban water quality, diminish flood risk, and enhance engagement of local communities with nature. They also provide space for nature recovery together with amenity value. Resources and policy must drive greater implementation of sustainable urban drainage system nationwide, with greater resources for Local Authorities to support this.

Quote from a catchment partnership

You said that, in certain catchments, protecting habitats through achieving nutrient neutrality in new developments is proving challenging and currently is falling on developers to resolve. Some of you suggested nutrient neutrality has become a huge impediment to growth and the Environment Agency needs work collaboratively with local authorities and others as their highest priority. Research is needed to help develop nutrient neutrality schemes and to begin addressing planning applications. You suggested a strategic approach is needed rather than a reference to nutrient pollution in current plans. Technical solutions, such as green infrastructure and nutrient trading schemes, which have positive effect on water quality, are recognised. You suggested Landscape Scale Recovery of our river corridors and streams is needed and that whilst environmental plans and legislation mention this, actions are piecemeal and directed at small areas of land.

Chalk rivers

You highlighted working with the Environment Agency on revising the chalk rivers programme. This includes an ambitious set of river restoration projects and the river-restoring sustainable abstraction programme. You welcomed the inclusion of this measure in the programme of measures.

You would like more specific measures for chalk rivers in each plan suggesting that chalk rivers need more protection and prioritising above other habitats by authorities and government as they are a globally rare habitat.

You would like to see additional abstraction reductions by water companies to tackle the remaining unsustainable abstractions affecting chalk streams in catchments.

Some of you suggested a new designation type specifically for chalk rivers and use of the precautionary principle (how to avoid environmental harm while there is still a lack of evidence). You said changes to natural flows and water levels are a priority, particularly in chalk streams. Restoring flow in headwaters by reducing abstraction is a priority, you said, as it will have significant downstream benefits.

Groundwater

You noted that the measure relating to supporting groundwater recharge through land management policy, can further reduce flood risk in areas prone to surface water flooding.

You said regional groundwater models should be improved to take account of chalk hydrogeology. You said that further work is needed to understand the benefits of minimising the amount of groundwater draining to the sewer network. This is particularly in the context of planned groundwater abstraction reductions meeting environmental needs, especially under low flow conditions, to help ensure water is returned locally to the river system.

Nature Recovery

Some respondents pointed out that several measures identify Local Nature Recovery Strategies as strategic plans which can ensure the right habitats are restored or created in the best place.

Some of you were in support of species reintroduction, such as beavers that can “have hugely beneficial effects on flood retention and biodiversity”.

You would like to include a measure or a potential new measure within the RBMPs at a national level that relates to ensuring water bodies and water courses are seen as valuable assets within Local Nature Recovery Strategies. Along with appropriate funding opportunities and protections through the planning system to follow.

Invasive non-native species

You strongly supported the national measures for invasive non-native species and many of you provided suggestions of local measures for this. Some of you felt that more detail was needed and most said more action should be taken sooner, for example on the post 2027 measures now. A common request was for the Environment Agency to be transparent about the reasons for not being able to deliver those measures now. There was frustration at the lack of invasive non-native species measures identified at the catchment level and the under-reporting of invasive non-native species as a reason for not achieving good ecological status.

Many of you called for sharing invasive non-native species data on the Catchment Data Explorer. Evidence requirements are highlighted for the real-world risks and impacts of invasive non-native species. You said understanding how effective measures are will allow certain measures to be prioritised, given limited funding. Examples were shared of research projects that can feed into this national evidence gap.

You said invasive non-native species are best controlled at a catchment scale and in partnership as there is no single group responsible for addressing them. You raised some species-specific concerns and proposed national strategies for certain species such as mink and signal crayfish. Some of you highlighted the link between large infrastructure projects such as water transfers and invasive non-native species and how those are addressed by mechanisms such as the water companies’ Price Review process (PR24). You suggested how the coastal environment and mechanisms for delivering measures can be more effectively referenced. Some respondents thought we can better capture climate related changes in invasive non-native species risk and ensure that the associated measures align with GB Invasive Non-native Species Strategy.

Some wanted to make sure that control and biocontrol research are clear in the measures and that biosecurity is not the only focus. Others thought the focus ought to be more on biosecurity and prevention.

A significant number of you highlighted that long-term funding is a significant barrier to action and lack of funding opportunities will hinder delivery of measures at the local scale.

Nature-based solutions

You said there is a lack of investment opportunity and education on the wider benefits nature provides and we should prioritise nature due to those greater economic benefits. Many of you wanted more funding and resourcing, alongside clearer guidance for partners, such as local authorities, to create more nature-based solutions at catchment scale.

Several respondents wanted to see beavers re-introduced into our rivers and greater advocacy for re-wilding. Improving and restoring wetlands and reedbeds is also highlighted by several respondents, mentioning the potential for improved water quality through nature-based solutions.

Specific schemes and projects are highlighted, where nature-based solutions play a key role, with several suggestions for including these projects and broader programmes of work within the updated RBMPs. Many of you commented that natural rivers need reconnecting to floodplains along with buffers between the channel and agricultural activities.

Nature-based solutions cannot be considered in isolation. You said lowland carriers are designed to convey water from highland areas of the catchment, and out to sea. They are part of water management systems that allow not only food production but also flood defence for low lying rural and urban settlements, the protection of utilities, transport, services, and infrastructure. Nature-based solutions, engineering and maintenance are a trinity that need far greater emphasis in the RBMPs.

Modifications

You said there is often a lack of understanding of terms used in river basin planning, for example, what an artificial or heavily modified water body is and their purpose. Many said it is not helpful to differentiate between ‘artificial’ and ‘heavily modified’ water bodies when the mitigation measures to address issues are the same.

Removing structures is also highlighted, suggesting that we provide monies to do this. You note that some historic modifications remain beneficial. You suggested there are some uses of heavily modified water bodies missing, particularly socio-economic uses, for example there are no specific agriculture or offshore power generation uses. You suggested that a lack of notice around timing and short-term funding (typically one year) is not enough to rectify and implement measures for many artificial or heavily modified water body issues. You called for long-term multi-year commitments. You also talked about the need for funding to maintain mitigation measures, not just initial capital spends, and an overall lack of funding sources coupled with lack of clarity about which funding can be used for artificial or heavily modified water body mitigation measures. You said that the ‘significant adverse impact on use’ must continue as a provision for not implementing a measure to mitigate the impact of a heavily modified water body.

Flood and coastal erosion risk management and waters

You said that coastal, marine, and estuarine habitats have relatively fewer initiatives yet can deliver some of the biggest benefits in terms of climate mitigation and adaptation. Several respondents suggested that a positive environmental impact can be achieved through aligning the development and implementation timeframes for various strategic initiatives. For example, the RBMPs, flood risk management plans, and the water companies’ asset management plans. You said that more integrated flood risk management plans and RBMPs will better address water quality and better manage and respond to the effects of climate change.

You said that properly maintained rivers are important to ensure effective water conveyance through catchments.

You advocated the value of natural flood management and of routinely using those approaches. Several respondents recommended the further use of natural flood management but highlighted the lack of funding to maintain or replace natural flood management measures as a potential barrier to wider adoption. It can be unclear where the responsibility and cost for replacement lies. There was support for new planning regulations for both industrial and domestic development which include natural flood defences in the buildings themselves and areas surrounding them such as green roofs, green walls. Some said legislation should ensure that the increased building costs of these new regulations are not passed onto the public but are covered by developers.

Coast, estuaries and marine

Some respondents raised the need to ensure that nature-based solutions in transitional waters and coastal waters join up effectively with flood and coastal erosion risk management activities. There was support for the estuarine and coastal specific measures proposed but you identified the need for long-term sustained funding for coastal and estuary partnerships to implement these, linking across land and sea, catchment and marine. You also said that where there is funding, more explicit reference to transitional and coastal waters is needed across various funded measures to ensure that risk management authorities, water industry and non-government organisation partnerships can more easily identify which measures include transitional and coastal water benefits.

You were supportive of opportunities for seagrass, wetland and saltmarsh habitat creation like England’s Nature for Climate fund which supports the delivery of England Trees Action Plan and England Peat Action Plan.

You welcomed the measure on sustainable shellfish aquaculture in recognition of the role that sustainable shellfish aquaculture can play in providing a low carbon, low environmental impact protein, and its importance for the UK’s food security. You said diversification of the fishing industry is needed, and as such, this measure should incentivise fishers to diversify away from other, less sustainable practices. You felt however, aquaculture and mariculture policies are currently underdeveloped. Aquaculture development must be integrated with planning for the marine environment. Operations should be spatially planned and balanced with other uses of our coasts and seas (that is the potential for co-location with other developments is explored). You called for Ecosystem-level assessments to be mandatory before any development – not only assessing the possible impact on local species and habitats, but the whole production cycle and sustainability of biological pest control. While there is the potential to explore new and innovative means of aquaculture, strict biosecurity policies must be in place to minimise the introduction of invasive non-native species, in line with the precautionary approach.

You said educational and public awareness campaigns should relay the benefits of and pressures on our coastal habitats, along with actions the public can do to protect them.

Funding, investment and resource

Many of you made offers to work with the Environment Agency to achieve funding goals.

You asserted government’s central role in ensuring funding mechanisms are sufficiently complementary, substantial, and long-term. You called for flexibility in the application of funding to meet varying situations and conditions, as the current rigid mechanisms are a major constraint. You said that funding should be identified and guaranteed by government through legislation and through an ongoing investment plan spanning well into the future that focuses on sustainable water supply and quality.

You said non-profit environmental organisations should receive government funding preferentially over private consultancies and note there are opportunities for private finance to contribute through biodiversity credits as part of nature-based solutions.

You said the right combination of incentives and levies are needed to implement the measures. You described the need for blended finance and bespoke measures at catchment scale for urban areas with their specific challenges. Funding from various sources and pooling resources will result in multiple benefits in communities. You said that more funding for catchment partnerships is required, and you suggest this can be achieved through a mixture of:

• payments and loans
• increasing farmer participation
• attracting more private funding, with loans and repayments fed back into the fund to enable enhanced growth and returns for investors

You said that both revenue and capital funding are required to seed improvements, and you want to see more match funding over successive cycles of projects and plans. You were unclear what proportion of funding is spent on actual outcomes and what is spent on administration and would like clarity on this.

You noted a reliance on private transactions such as Payments for Ecosystems Services and ask for clarity over how these investment schemes work. You wanted clarity on the shortfall that private investment may need to address. You said external funds will be needed to support schemes that are otherwise not able to be funded but which deliver greater benefits for the natural environment. The need for investment leading to natural capital delivery can have a positive impact on public wellbeing through promoting engagement with our water environment. And you agreed with the benefits of increasing a sense of connection to nature and inspiring people to act.

Several respondents mentioned there should be opportunities for innovative approaches to financing such as habitat banking and blue carbon credit schemes. You saw this as particularly relevant to measures for habitats and species and through a natural capital approach and innovative financing for climate change adaptation measures that can be scaled up. An example given was the contribution energy production can make from adapting existing river structures.

You stressed the need for long-term catchment partnership funding and linking activities from inland catchment to coast. You gave examples of local activity, for example from fisheries, that can be considered as a means of funding to contribute to catchment level improvements. You also gave examples of projects with a focus on water credit, biodiversity, and carbon trading.

You gave examples of where you think funding is required, for example around technology available to farmers, controlling ammonia emissions, addressing pollution from abandoned mines and to understand how nutrient neutrality can be solved.

You commented on the reduction in Environment Agency staff support and less funding at a local scale. You were unclear whether European Union funding prior to European Union exit has been obtained, withdrawn, or replaced with equivalent funding.

Partnership working and aligning priorities

There was support for the Nature Bid designed and developed by the Environment Agency and the Sylva Foundation, with the broad goal of increasing climate resilience and nature recovery through an innovative form of engagement.

You said dialogue with stakeholders is essential when deciding mitigation measures.

Some of you felt support is needed for communities and partnerships to help them plan and implement nature-based solutions to address predicted flood issues and future limited water availability. Some proposed a coordinated and strategic response to prevent and manage flooding, led by one organisation that has responsibility, accountability, and oversight throughout the area. You wanted to see an integrated water management approach that:

• involves greater engagement with partners and communities
• considers different types of land use and timescales (short, medium, and long-term plans)
• includes natural flood management techniques upstream, downstream and on farmland
• manages the effects of all developments (housing, commercial and urban) to ensure sustainability

The planning system must better respect the needs of the environment and enable development which is sensitive to the needs of future generations.

Quote from the public

There were several offers of engagement support to help implement some measures in RBMPs. For example, for the Environment Agency to work with the Solent Plastics pollution hub on the Preventing Plastics Pollution (PPP) project in the Solent catchment and from Peel Ports at Liverpool, Heysham, Medway and Great Yarmouth. This work is to develop an education campaign which targets shipping, ports, harbours, and the fishing industry to relay concerns around shipping and the fishing industry about their fuel, chemical and sewage management, plastics, and disused ghost nets littering the sea.

Many of you felt there was a lack of join-up with other organisations and other initiatives, plans and schemes. Examples were alignment of the RBMP process with the water industry business planning cycle and WINEP where you were concerned this may result in missed investment opportunities. In respect of groundwater infiltration into sewers, you recommended linkage to the appropriate plans, for example Drainage and Wastewater Management Plans, Diffuse Water Pollution Plans and Safeguard Zone Action Plans. You also felt that artificial or heavily modified water bodies mitigation measures were not always considered or can be forgotten when people think about projects, plans and initiatives.

3.3.3 General feedback about measures

There was some concern about delaying some measures until after 2027, and you said that it is hard to see how the measures in the plan can achieve their objectives, given the climate and biodiversity crises.

You wanted to see more detail on how the measures will be prioritised, and which measures need to be applied where, to achieve good status. You would also like to see where measures have not been achieved and how collaborating on measures can achieve larger, more holistic outcomes.

You also said that information is lacking about the measures. For example, the origin of the ideas, likelihood, cost, or strategic planning.

You welcomed the Environmental Land Management Schemes (ELMs), the Environment Act and its Local Nature Recovery Strategies and Nature Recovery Network and would like to see them delivered ambitiously. However, the full roll out of these policies, and other mechanisms to fund them such as Biodiversity Net Gain, is not expected before 2024. You felt therefore, that not only do those policies and programmes need to deliver quickly and effectively for water quality and quantity, but more targeted water body restoration will be needed to achieve the RBMP objectives.

You were also concerned about whether organisations also responsible for implementing the measures have enough capacity. Many suggested it is unlikely that existing funded measures and new initiatives currently in development will be sufficient to achieve all the environmental objectives of the RBMPs. You said the Environment Agency’s ability to collaborate with partners to achieve new measures around, for example, chemicals are constrained by their stretched resources.

Information

Some of you had expected to see reference to individual measures you are familiar with, and that local measures information were missing however some of you recognised these have been included in the programme of measures on the catchment partnership website. You found it hard to work out what applies at the scale you are interested in.

Some of you were unclear about how the measures had been grouped and the difference between spreadsheets. Some of you said you there was too much information in the spreadsheets with some repetition and you asked for filters. There were several preferences expressed for how to group information that included measures grouped for by region, by category, by same pressure (for example all those relating to invasive non-native species appear consecutively) or by sector.

In relation to measures information within catchment partnership pages, some of you said this content is hard to find. You were also uncertain over how the measures information on these local pages link to the programme of measures. Some of you recommended that the catchment partnership pages should include measures from other strategic documents to capture the larger scale, more integrated measures with wider benefits.

There were some comments that farmers and landowners, who are not always fully represented in catchment partnerships, have not been able to fully contribute to developing the programme of measures.

Some of you asked for clearer policy statements around measures generally and also wanted to see greater clarity around targets and outcomes for catchment measures.

You would like better recording of nature-based measures within the RBMPs so as not to miss some important work being delivered.

3.4 Question 5 Catchment Partnerships - Do you have any comments on the challenges and measures suggested as priorities in your local catchment partnership page? Please give catchment specific examples and tell us where, by working together, more benefits can be achieved.

Catchment partnership priorities included the following.

1. Managing climate change.

2. More monitoring on site and in places which better describe the water body status.

3. Urban and transport issues as current and emerging challenges.

4. Recognise the future importance of sea level rise or the cumulative effects of pluvial, fluvial, and tidal flooding.

5. Unlocking flood risk funding to remove fish barriers.

6. Physical modifications are seen as a local challenge (place-based) and clarity is needed on what the issues are and who addresses them. You talked about removing unnecessary culverting and support naturalising riverbanks.

7. Focusing on freshwater role in estuarine and coastal habitats. These habitats are vital to mitigating climate change.

8. Transitional and coastal waters and heavily modified water bodies are not representative of whole water body. It is perceived to be only shore-line modifications and you ask about sub-littoral (tidal area) impacts of wind power generation, pipelines, and trawling activities.

9. Longer term funding to ensure the biodiversity metric is not undermined and freshwater habitats not put at risk.

10. Changes to natural flows and water levels are a priority, particularly in chalk streams.

11. Restoring flow in headwaters by reducing abstraction to provide significant downstream benefits.

12. More resourcing to fund and maintain local projects which improve the environment; building design must not risk the water environment ensure that Biodiversity Net Gain also delivers a gain for waterways.

13. Pollution from wastewater, from town, cities and road transport and associated run off and diffuse pollution from fertilisers and sediment run off primarily from arable fields are the main issues, in addition to pollution from current and legacy POPs such as perfluorooctanesulphonate.

14. Collaboration with stakeholders, better regulation, inspection, and enforcement.

15. A holistic review of chemicals and wastewater releases at the development planning stage in addition to increased resources and funding.

16. The impact of development, leading to an increase in urban pollution from land use change, wastewater, and transport.

17. Natural flood management to manage the impacts of climate change; training and capacity building to encourage take-up.

18. No monitoring of some key waterbodies, assessment points are too far downstream or have been merged and do not give an accurate picture of the waterbody.

19. Tighter enforcement and penalties for fly tipping and litter; tackle at source instead of relying on voluntary clean up.

20. Community ‘Source to Sea’ litter pick, wet-wipes campaigns and pet flea treatment awareness campaigns are positive for community engagement, health, and well-being as well as increasing people’s knowledge and actions around litter and microplastics. Future engagement can include domestic chemicals awareness or briefings on the habitat, plants, or aquatic life.

There were many supportive comments for the catchment partnership pages as a way for partners to use local evidence to identify priorities and demonstrate local delivery. Many said that they demonstrate the growing importance of the catchment based approach and partnership approach to implement river basin management plans. There was also recognition that the pages are a new development in the RBMPs for this cycle and that their intention aligns with those of the RBMPs.

Many asked for additional measures and successes to be added including Moors for the Future and projects within the Flood and Coastal Resilience Innovation Programme. The suggestion to include invasive species and woodland creation actions is mentioned multiple times. You asked for clarity over what and where mitigation measures should be placed in a water body, suggesting the plans are not specific enough or the description is too high level to be meaningful.

Many of you also requested a change to the catchment partnership pages to enable the partnerships to include challenges for the wider water environment. For example:

• climate change
• biodiversity
• water resource
• pollution from wastewater
• sea level rise
• tourism
• new chemical pollutants
• mental health and wellbeing

This reflects the holistic role that partnerships provide in bringing together multiple drivers to achieve much wider benefits. You also said you would like to include commentary on the future challenges for the catchments to explain how climate change, population growth and land use change may affect your catchments.

Some of you suggested making the catchment partnership pages easier to find in the RBMPs, and easier to navigate through. You also mentioned that the pages contained insufficient information, are too data-heavy, use overly technical language, and do not give enough explanation.

You wanted to see evidence on current classifications or reasons for not achieving good ecological status. You said there is inadequate technical evidence supporting measures in the RBMPs. Priority actions, measures and RNAGS are only partially listed, are not up-to-date and are different from local catchment knowledge. You felt there are many omissions in the list of current challenges across many catchments. You requested an interactive map to show priority areas and projects and said an integrated view of the whole water cycle is necessary, with catchments treated holistically, such as water quantity and water quality dealt with in an integrated way.

Coastal organisations and partnerships said there are not enough links in the catchment partnership pages to other strategic plans relating to the coastal environment.

Some asked that catchment partnership pages are kept up to date through the life of the RBMPs instead of, or as well as, being in the statutory document.

Some of you requested that the catchment partnership pages be used to encourage and engage partners not currently actively involved to become more involved. Some suggestions include local authorities, water companies, farmers and landowners, communities, coastal partnerships, highways, HS2, anglers and private businesses. Agricultural partners agreed with this, saying that if agriculture is a major source of failure in a catchment, then it is entirely logical for more farmers to be around the table to help resolve issues. The expansion of the Catchment Sensitive Farming scheme and its popularity with farmers could be an ideal engagement and delivery mechanism.

You gave examples of investment frameworks that catchment partnerships can be involved in to make environmental improvements. You also gave examples of catchment partnerships working with farmers on nature-based solutions. Along with identifying long-term funding strategies and support from water companies through funding, resourcing, and in-kind contributions.

Regarding large scale infrastructure, HS2 was seen as both a challenge and an opportunity to implement environmental improvements and you would like support and assistance from the Environment Agency and its Area teams to engage with HS2.

3.5 Question 6. Do you have any further comments on the draft river basin management plans, not covered by the previous questions?

Here are some examples of your comments.

You were concerned that the updating the National Water Environment Benefit survey (which underpins the cost benefit analysis within RBMPs) will not take place in time to inform the ambitions of this cycle of RBMPs. You saw this as a risk of having plans which do not fully reflect, and deliver against, the ambitions of society. Linked to this, you said that awareness of societal and economic changes and resulting changes to industry process are important because they, together with other pressures, will have a resulting impact on the environment and add complexity for producers.

You said that RBMPs can make a central contribution to source-to-sea thinking. Particularly in relation to marine litter, nutrient, and chemical pollution, which are primarily land-derived.

Biodiversity

You noted that many Special Area of Conservation, Special Protection Area and Ramsar sites are already in ‘unfavourable condition’ due to nutrient pollution so are subject to ‘nutrient neutrality’ advice. Nitrogen and phosphorus loads caused by developers assessing and offsetting the impact are expected to increase. This offers a way for interventions to be developed, trialled, and refined (for example, measure 62: investigate novel solutions to remove nutrients). Government has been clear that nutrient neutrality is only an interim measure, as we

must act to address the sources of pollution and tighten up the associated regulatory frameworks to prevent further harm to protected sites”.

Quote from a catchment partnership

This recognises that nutrient neutrality offsets damage with little improvements. But the techniques used to achieve neutrality will be the same techniques (limiting nutrient contributions from agricultural land) that need to be introduced to enhance protected sites and achieve water body objectives generally.

Chemicals and plastics

You wanted to see comprehensive monitoring and analysis for chemicals suggesting that without resources for sufficient monitoring and enforcement of baseline regulations - further improvements cannot be delivered. You noted the delayed Chemical Strategy and said that the cost benefit analysis, disproportionate cost, and technical infeasibility can be a reason for inaction. You questioned how often analyses are reviewed. You said the Chemicals Strategy must include a framework for tackling chemical pollution across all sectors. It should encompass:

• increased resources and funding
• increased scope and frequency of chemical monitoring
• stronger policy and legislation
• control at source
• measures to address chemicals once they released into the environment

You said too much plastic pollution is cited as a reason for water bodies across the country not achieving good ecological status. Measures to tackle plastic pollution should be prioritised, rather than relying on voluntary action or education. Measures on fishing gear should focus on proper disposal facilities and not just best practice theories. Some future measures should be brought forward such as education and behaviour change on single use plastics and items which should not be flushed away. This will highlight the impact on the marine environment, as they are the destination of this pollution. Improving plastic capture and collection with ports and others, using collection devices such as sea bins will ensure best practice is rolled out. There is an overarching need, however, for the government to ban single use plastic products, as collection and recycling only do so much.

You felt there is a missed opportunity to include micro and macro plastics in the RBMPs, despite it not being included in WFD regulations. If this is not dealt with urgently at a national scale the impact on the environment and human health will be huge and irreversible. Sewage Sludge Regulations, you said, are no longer fit for purpose due to the amount of microplastics present in everyday items, meaning the composition of sewage sludge has changed. The risks to human health and the soil environment are not yet known.

You wanted to see laws around removing microplastics from sewage better enforced and said plastic production at source should be reduced, rather than relying on clean up by volunteers and citizen science.

You suggested single-use plastic management requires a cohesive supply chain. To address plastic in agriculture, you recommend working with farmers, fertiliser manufacturers and fertiliser container manufacturers to support distribution of fertiliser in re-useable containers.

Data

Many of you raised concerns about the difficulty of finding your way around the information in the RBMPs. You wanted to see a stronger link between the principles and the actions. You noted that much of the data is old – it’s from the last plan published in 2016 and so trust in Catchment Data Explorer is low. You found the search function on Catchment Data Explorer hard to use, for example it does not retrieve all the expected results and there are requests for user guides. You suggested using infographics and water body specific plan summaries.

Flood and coastal erosion risk management

You noted that the Environment Agency’s flood and coastal erosion risk management strategy states that the number of natural flood management projects will be doubled. You said more investment can be targeted to gain maximum benefits and progress from this approach.

Many of you said floodplains would benefit from being classed as a distinct land type with respect to planning, land-management schemes, biodiversity conservation and the wider sustainability policies. A floodplain strategy will be beneficial in aligning different policies and financing. As floodplains cover 5% of land area with a high natural capital value, some of you suggested increasing uses of and funding for natural flood management. Some of you called for greater consideration of Environment Agency advice not to develop on floodplains. You advocated further flood mitigation measures including a funding scheme to help Flood Action Groups in small communities to either implement natural flood management or build DIY flood defences.

Partnerships

You stressed that education is essential to how we:

• learn
• influence each other
• shape our world
• protect our most valuable resources, such as our rivers and our planet

To be effective, you felt that education must be proactive, broad, and fluid, intergenerational, and available in a range of languages and mediums. You saw proactive education helpful in preventing pollution events and misuse of water courses in the first place. You said it contributes to better understanding, better engagement, better use and management of rivers and encourages citizens to better connect to rivers and advocate for and protect them.

You also thought this education should be government funded, clearly available and provided by partnerships in coordination with other groups. You felt water companies should fund local communities and groups to raise public awareness on the challenges for the water environment. You recommended more than a single education campaign. You wanted to see an ongoing and strategic process that targets the most pertinent issues, for example pollution and access. All generations need to be involved and it needs to be provided in many different formats, incorporated into the primary and secondary education curriculums, and all other community, public and informal education events, and all media formats. You gave examples of other campaigns which changed behaviour that are clear, understandable, and compelling so showing that change can be easy and rewarding.

Planning and regulation

Some of you said government should make legally binding water targets applicable to medium and large businesses in the same manner that carbon targets have been made law.

You would like planning to be more joined up to limit polluting activities such as intensive farming. Some of you called for a review of planning policy to introduce water efficiency measures and to reduce pollution.

You said that more should be done by developers for all new builds to introduce water efficiency measures that can enhance biodiversity and reduce flooding, for example green roofs. Many of you call for changes in regulation, planning policy and associated guidance to make sure RBMP objectives are embedded within planning processes.

Some respondents comment that nutrient neutrality has become a huge impediment to growth where affected local authorities cannot permit development unless there is certainty there will be no negative effect on the site’s condition. The Environment Agency needs to work collaboratively with local authorities and others.

You said large investment for the water environment should come from water companies, private companies, polluters, and water users. In addition, you said water should be safe for bathing and recreation including lakes. There was a concern that bathing waters are being de-designated based on low-use when the real reason is poor water quality. You also noted that bathing patterns now include swimming outside of the traditional bathing water season and request that inland bathing waters be designated and improved.

You commented that high levels of nutrients from sewage treatment works, and septic tanks are causing algae growth and de-oxygenation and some called for a review of the approach to sewage in the Environment Act. For example, bigger sewage works have controls in their permit conditions, but smaller sites do not which can result in relatively high levels of pollution at smaller sites.

Many would like the RBMPs to align with the Waste (England and Wales) Regulations 2011 waste hierarchy and that dredged material must not be accepted for disposal where reusing or recycling opportunities exist.

Rural and land use

You said the concept of clean water is central to natural capital and nature recovery. Many of you called for a focus on multi-functional land use, for example where land management practices can improve water quality in combination with biodiversity, carbon sequestration and other benefits such as improving flood resilience for urban areas. You acknowledged this requires considerable thought and consultation especially with the agricultural sector, as land use is a major factor in the catchment being heavily modified.

You were concerned that, with the National Economic Assessment, you were only able to comment on the ‘interim findings’. For agriculture you said that costs given for both the current uptake of regulatory measures and the cost of future voluntary land management measures appear to be significantly underestimated. You are interested in why and how such scenarios are being pursued and asked for more information about catchment economic appraisals.

Many of you said that the issue of reduced groundwater flow from aquifers needs highlighting and the impact this has on water quality.

Urban issues

You said legislation and mandatory standards should enforce the Water Lifecycle Management of Industrial Estates and Business. Increasing urbanisation, with large areas of impermeable surfaces, leads to faster run off and, along with poorly maintained drains and culverts, water backs up. New development on flood plains also increases the number of properties at risk of flooding nationwide.

You said there is a need to map high-risk outfalls conveying urban run-off into the river in the towns across the catchment and work with the local highway authorities to develop ‘off-the-peg’ solutions that can be incorporated when planned street-works or roadworks are being carried out as opportunistic improvements in water quality.

You are concerned about there being no estimate of increased water consumption and resulting abstraction pressures from new housing development plans. You thought there should be more consideration given to identifying key actions which address urban specific environmental problems.

You stressed that new developments must demonstrate that its infrastructure will either maintain or improve water quality, reducing the risk of flooding. These schemes must be in place before the site is occupied. When assessing planning applications, local authorities must invest in expertise to provide consideration of drainage issues, including the cumulative impact of new developments.

You said there is an inadequate reference to housing developments in the RBMPs with no evidence of the scale of potential problems caused by recent housing developments and large numbers of houses proposed in current plans over the RBMP3 period. You felt this is not clearly highlighted and substantiated as a reason for not achieving good status. You noted the RNAGS consistently identify some big, difficult-to-manage pressures, such as transport, wastewater, agriculture, urban development, which appear to be growing faster than they are being addressed.

You are concerned that the impact of increasing population leading to increasing development in many catchments is not covered in the RBMPs. Water saving, harvesting, capturing, monitoring and more permeable surfaces could offset this. You said that, despite water featuring heavily in the 25 Year Environment Plan, filling gaps is left to under-resourced local authorities, water companies and catchment partnerships.

You added that there should be more consideration around identifying and addressing urban specific aspects of rivers. For example:

• physical condition
• impact of litter
• waste and surface water and road run-off
• the problems of culverted rivers and constrained or absent floodplains
• the social aspects of lack of access to clean rivers

You said there are some areas where RBMPs could provide stronger support for demand management, for example with strong statements supporting local authorities requiring high standards of water efficiency in new homes.

You point out that changes to river basin and water management can have intended or unintended consequences for people and the historic environment for example, the construction and operation of new infrastructure and SuDS and changes in land management have the potential to impact on the significance of heritage assets and their settings. This includes impacts on water related or water-dependent heritage assets.

4. Summary of responses by river basin district

This table shows the number of responses received for all or river basin district.

Option	Total
England (all river basin districts)	62
Anglian	28
Humber	26
North West	30
Northumbria	8
Severn	30
South East	41
South West	21
Thames	73

Below is a summary of issues and comments relating to each individual river basin district. Issues and comments which were the same as those raised in national (all England) responses are included earlier in the document.

4.1 Anglian River Basin District

Twenty four respondents gave an answer about the Anglian draft RBMP.

You suggested that the Broadland Catchment Partnership’s work in restoring water levels will increase biodiversity and increase numbers of existing species.

You said that Internal Drainage Board engineers are an untapped resource in local knowledge for extensive lengths of water body but are not necessarily funded for environmental improvements which may meet RBMP objectives.

You noted that over 70% of the water bodies in East Anglia are designated as artificial or heavily modified. This includes vast areas of level based (pumped) systems and Fenland. You felt that partners, for example Internal Drainage Boards, have potential for environmental improvement but are frustrated by blockers such as restrictive designations and funding. You said there is huge scope for environmental improvement in heavily modified water bodies and Fenland areas, constrained by funding and prioritisation of more populated areas, when joining up with flood risk management projects.

You said Catchment Sensitive Farming involvement is missing and some priority actions and measures are not included.

Some current challenges you felt were missing were about diffuse pollution and abstraction reform for example the Cam, Ely, and Ouse catchments for diffuse pollution and from East Suffolk Catchment Partnership over-abstraction and the challenge of abstraction reform.

Some respondents noted that the Fens Strategy and its flood and coastal erosion risk management maintenance work is missing.

You noted there is no mention of Affinity Water’s (water company) current wider WINEP measures dealing with catchment management and no deterioration.

You pointed out that the River Waveney is omitted from Catchment Data Explorer.

4.2 Humber River Basin District

Eighteen respondents gave an answer about the Humber draft RBMP.

You asked for monitoring of the Wharfe at regular intervals and for the information to be published (physically and online).

You wanted to see more investment in monitoring because of a concern over some classifications being largely based on old data, particularly reasons for not achieving good, reasons for deterioration and confidence for the Swale, Ure, Nidd, Ouse and Wharfe catchments.

You said that the most valuable measures for farmers and land managers in the Humber are collaborative and advice-led (rather than regulatory such as Catchment Sensitive Farming and Tried and Tested) where the farmer has a meaningful relationship with one coordinator. You felt these initiatives should be made accessible to all farmers wishing to take part.

You said that ‘good ecological status’ or ‘good ecological potential’ is not good enough for some species such as the freshwater pearl mussel. You suggested the Esk needs ‘high’ ecological status to support its vulnerable freshwater pearl mussel population. You felt that setting the target at ‘good’ largely prevents the Environment Agency from adequately investing in this catchment and therefore from helping to prevent the regional extinction of this water dependent species.

You let us know that a further measure around Humber Cluster is being considered in consultation with partners in Yorkshire, East Midlands, Lincolnshire, and Northamptonshire Areas.

You asked for a range of new measures. Specific examples were for HS2, the Loughborough Flood Risk Project, to represent the Humber 2100+ project, the Peak District National Park Defra Abandoned Mines Project, and Moors for the Future. You also asked for new measures where appropriate around the Environment Land Management Schemes, natural flood management and Catchment Sensitive Farming.

4.3 Northumbria River Basin District

Seven respondents gave an answer about the Northumbria draft RBMP.

You said that the agriculture sector needs significant support to implement the measures, and this must also be delivered collaboratively. You felt the most valuable measures for farmers and land managers in Northumbria are collaborative and advice led, rather than regulatory. You said it is essential that farmers and land managers are involved in project development and engaged from an early stage.

You gave the example of the Team Valley Surface Water Management, Team Partnership work on integration of retrofitting Sustainable Urban Drainage Systems into the Team Valley Trading Estate and wider catchment. You said this is an opportunity, with their Preliminary Surface Water Management Plan, to develop a long-term delivery plan integrating Sustainable Urban Drainage Systems into open space and highways led by Gateshead Council (Lead Local Flood Authority) with assistance from the Team Catchment Partnership. This has potential to provide multiple benefits including:

• improving resilience to climate change
• reducing surface water flood risk and pressure on the public sewage network
• improving visual and public amenity
• enhancing biodiversity and improving water quality.

You noted that a lot of work has been done looking at climate change adaptation and mitigation in relation to farming and landscape, for example the Cheviot Futures project. You said therefore the expertise and knowledge are there but there is no funding to help to develop and deliver it.

You said that in particularly in high quality lowland areas, restoration must be balanced with food production.

4.4 North West River Basin District

Twenty one respondents gave an answer about the North West draft RBMP.

You were supportive of taking future and emerging risks into account when producing updated RBMPs. You recognised the expanding population of Greater Manchester and with that the need for space for housing and economic development. You gave the example of Places for Everyone, the Joint Development Plan of Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Tameside, Trafford, and Wigan Councils that notes an “integrated catchment-based approach will be taken to protect the quantity and quality of water bodies and managing flood risk”. This includes a commitment to return rivers to a more natural state “where practicable” in line with the North West RBMP. This strategic, city-region wide, commitment would benefit from being reinforced by similar commitments within local plans and through the decisions around individual planning applications. This is to ensure that every available opportunity is taken to return rivers to a more natural state during the development process.

Some of you noted a focus in the North West measures around peatland restoration, for example the Great North Bog, sustainable lowland drainage system, wetter farming, and coastal resilience. You were concerned that this could potentially lead to land being taken out of production to create habitat and restore peatland, recognising this as a big challenge particularly in areas that are productive agricultural lands.

You talked about the nature-based solutions approach on the Wyre catchment and that the budget for adaptive management includes leaky dams, wetlands, slow the flow, soil health (permeability) and hedgerows. You said there is support for this approach, but the work should be at a meaningful timescale, such as 20 plus years.

You suggested including United Utilities’ compensatory measures in the River Ehen and St. Johns Beck where they are removing redundant assets.

You said that measures in the draft RBMP do not appear to have any funded measures for the Alt and Crossens catchment which you pointed out is a priority catchment for water resources. You also noted a lack of measures for the Douglas catchment.

You suggested including the River Kent Special Area of Conservation (SAC) LIFE project with multiple benefits including for Freshwater Mussels.

You gave an example of the Tawd Valley Strategy in Skelmersdale where multiple stakeholders continue to be committed to providing time and finance to regenerate the town, putting green and blue spaces at the heart of the long-term plan.

You gave some examples of initiatives that you would like to see included such as Cumbria Coastal Communities Forest projects, Farming in Protected Landscapes projects in the Lake District National Park and possibly other protected landscapes in Cumbria. You suggested the Cumbria River Restoration Strategy has a significant programme of works to reduce physical modifications and barriers in the Derwent (NW), Eden and Kent and Leven.

You said more measures were needed for the Lower Mersey catchment.

You asked for more engagement to see whether HS2 can deliver measures to improve the water environment.

You said that the suggestion from the Flood and Coastal Resilience Programme to have natural solutions in coastal areas presents a challenge particularly where this could impact on land being used for agriculture.

There was a concern raised from local experience of sewage overspilling onto farmland. You expressed frustration over this, and you would like more transparency about how regulation for farmers and for water companies is carried out.

4.5 Severn River Basin District

As a cross border River Basin District, this RBMP has been developed in consultation with Natural Resources Wales. Operational activity and engagement continue to take place with input and activity from Natural Resources Wales and the Environment Agency.

Eighteen respondents gave an answer about the Severn draft RBMP.

You were concerned about nutrient pollution from intensive agricultural practices along the River Wye and tributaries and feel that this is not sufficiently addressed through diffuse pollution regulations and the Nutrient Management Plan for the Wye. You called for a plan to address and resolve these impacts to be implemented with immediate effect. You asked for further controls over intensive livestock production units’ activities through planning and permitting.

Some of you also felt that agriculture has suffered from negative attention and being singled out in recent years over water quality. You stressed the importance of engaging with the farming community and said that it was vital that respect is afforded to all sectors and that the challenges are described sensibly and inclusively.

You wanted to see additional government funding for the Environment Agency and Natural Resources Wales to carry out inspections of all intensive poultry units and anaerobic digestors to ensure Manure Management Plans and Nutrient Runoff Mitigation Plans are approved and implemented within the required timescales. You wanted to see that funding includes provision for annual audits and any associated enforcement. You said that enforcement is needed on a catchment-wide basis with the Environment Agency and Natural Resources Wales working in close collaboration.

You were concerned about the introduction of the Water Resources (Control of Agricultural Pollution) (Wales) Regulations 2021. You anticipated this will result in farmers’ focus and resources being channelled into securing compliance with this piece of regulation, irrespective of its contribution to WFD objectives, which has not been assessed.

You said it was important to ensure that internal drainage boards (IDBs) are part of the conversation and part of the partnerships. Involving internal drainage boards is a good way of engaging landowners and can accelerate local change.

You would like assurance that the Environment Agency will continue to work with partners including the River Severn Partnership to further engage with businesses and local communities to improve awareness and promote action that delivers multiple benefits in their West Midlands and Wessex Areas. This is to reduce flood risk, improve the environment and contribute to climate resilience in the Severn River Basin District.

You suggested including the measure of Severn Trent Water’s Severn Trent Environment Programme (STEPS) which addresses nutrient input and water management on farms in high priority catchments. These are measures for biodiversity improvements as well as water quality with advisors sometimes hosted and supported by local wildlife trusts.

You raised the issue with POPs and stressed the importance of research and innovative techniques in addressing the problem.

You wanted to see invasive non-native species removed, particularly Himalayan Balsam in Finham Brook in and around Kenilworth and the River Avon near Stoneleigh to avoid bank collapse and siltation. These are high up in the Avon system so will deliver downstream benefits.

You said that the Environment Agency needs to make it easier to develop water storage reservoirs. For example, the Vale of Evesham and Stratford upon Avon area currently have irrigation issues, and models have shown a future lack of available water. However, there are barriers to adding storage capacity such as securing funding and grants, and planning and permitting difficulties. Related to this, you suggest there is value in promoting rainwater harvesting and alternative solutions for abstractors across the river basin district but particularly in the Vale of Evesham and Stratford upon Avon area.

You said it was important to encourage co-operative working with HS2.

4.6 South East River Basin District

Thirty one respondents gave an answer about the South East draft RBMP.

You offered to work with the Environment Agency to implement a range of measures, for example the Solent Plastics pollution hub offered to collaborate on the PPP project in the Solent catchment and Peel Ports at Liverpool, Heysham, Medway and Great Yarmouth also offered support. This work is to develop an education campaign which targets shipping, ports, harbours, and the fishing industry to relay concerns around shipping and the fishing industry about their fuel, chemical and sewage management, plastics, and disused ghost nets littering the sea.

You said that the sustainable abstraction reductions and all the options being assessed in the South East Regional Planning process to increase supply infrastructure are temporary solutions at best if high water consumption is not addressed.

You would like to include major schemes from Water Resources South East as they are currently reviewing the potential impacts of major water resource infrastructure schemes in the Thames and South East River Basin Districts. These major schemes could have a significant impact in terms of water flows and water quality.

You asked for acknowledgement in the plans that industry input, for example regarding fisheries. Rod and line fisheries employ around 100 river keepers in the Test and Itchen River catchment and investment value are approximately £3 million a year. This should be recognised as a significant element of funded work in the catchment.

You raised concern about whether cost benefit analyses have been carried out on a few of the agricultural measures for example, changing land use for high-risk practices concerning oil seed rape and wheat.

You asked for more detail on some measures and for several new measures where there is confidence of funding, for example:

• Chichester Harbour Protection and Recovery of Nature (CHaPRoN) – a multi partner (lead Chichester Harbour Conservancy)
• flagship chalk streams project, for example for the River Ems where there is a 10-year restoration plan funded by Portsmouth Water (Arun and Rother Rivers Trust led)
• Sussex Kelp Restoration Project – multi-partner (Sussex Wildlife Trust-led).

You asked for the Revitalising Chalk Rivers programme to be included. This has an ambitious set of river restoration projects and the Restoring Sustainable Abstraction programme, alongside several WINEP schemes which are not listed.

Several of you were concerned about the River Ebbsfleet in Northfleet where many pollutants enter this rare chalk bed river whenever it rains from the A2. There is no protection from road run off.

You were concerned that some water bodies in North Kent no longer have what you consider essential monitoring data collected. You said its downgraded status is based on inaccurate data.

You gave examples of various developments which attempt to provide nutrient neutrality mitigation in East Kent, suggesting none are close to demonstrating effectiveness for the more than 80 years required. You suggested the solution to water issues in East Kent is Landscape Scale Recovery of our river corridors and streams.

You said that the significance of the Weald of Kent and Sussex’s extensive networks of small but significant tributaries is often under-appreciated and many of them are not sampled resulting in changes in their environmental quality risk going unrecognised. Its significant habitat, for example as sea trout spawning habitat is at risk from climate change. This is due to very low summer flows, reflecting their predominantly rain-fed catchments.

4.7 South West River Basin District

Fourteen respondents gave an answer about the South West draft RBMP.

You recommended that a truly collaborative evidence base is delivered, such as the work on the Tamar and the Catchment Systems Thinking Cooperative (CaSTCo) initiative.

You wanted measures around bathing water and shellfish water compliance to be included in the in the programme of measures.

You said that the measures specific to the West Dorset Rivers Operational Catchment as set out on the catchment partnership pages need to form part of the South West RBMP.

You pointed to funding for farming in protected landscapes as another source of funding that could help address issues. In addition, you said rural land management measures should also include actions to tackle invasive non-native species.

You were concerned that the sectoral measures outlined in the river basin plans do not directly address urban pollution such as road run off and misconnections and would like this to be addressed.

You also commented that the current groupings do not appear to include actions to tackle emerging threats, such as chemicals like polybrominated diphenyl ether.

You said there appears to be little join up between RBMPs and the UK Marine Strategy. You stressed that source-to-sea thinking is essential, particularly in relation to impacts such as marine litter, nutrient, and chemical pollution, which are primarily land-derived.

You also suggested that Defra’s Water and Abandoned Metal Mine programme needs to be refreshed to tackle the smaller diffuse sources in Cornwall which impact UNESCO World Heritage Sites in Cornwall (Cornish Mining).

4.8 Thames River Basin District

Forty two respondents gave an answer about the Thames draft RBMP.

You said the rate of development and growth across Hertfordshire is currently in discord with creating a sustainable catchment. It is a ‘severely water stressed area’ as classified by Environment Agency since 2007 and is in one of the fastest growing populated regions. The amount of water being abstracted to supply current and future demand exceeds the available source, resulting in below average flows much of the time. The amount of effluent requiring treatment exceeds (or will by 2040) capacity of sewage facilities, resulting in chronic pollution. You suggested The National Planning Policy Framework (NPPF) which could help improve this situation by mandating water efficient development across the South East, does nothing to ensure the principles listed in the RMBP can be met in a developing catchment.

You felt the Sustainable Abstraction Reductions and all the options being assessed in the South East Regional Planning process to increase supply infrastructure are temporary solutions at best if the roots of water consumption are not addressed. You felt that government and water companies are placing too much emphasis and reliance on behaviour change programmes to close the growing supply/demand gap that is leading to degraded freshwater environments in our chalk catchments, rather than attempting to address at water efficiency at source by mandating water efficient development and carrying out retrofitting of social housing (and providing subsidies for private housing upgrades).

You suggested that less water, that is more polluted, in an increasingly urbanised catchment due to (effectively unregulated) development, means we will likely never achieve the full ambitions of the RBMP and WFD. You urged the Environment Agency to press the importance to government of a National Planning Policy Framework that is fit for purpose in water stressed areas and stop relying so heavily on customer behaviour change to meet shortfalls, which is unpredictable and variable and consistently leading to chalk rivers under more pressure.

You said that water neutrality of future developments is a significant concern for the River Ock.

You said HS2 enhancements are largely not included in the programme of measures and projects need to be captured across its route.

You recommended increased legislation and enforcement of highways network pollution given the impact of road run off in urban areas through legislation and local plan policies. The east of Basingstoke is at the headwaters of the chalk stream and the impact of run off at the headwaters has a disproportionate effect downstream. Reading University’s Land wise project has been looking at more natural ways to control run-off. Road run off is significant near Black dam ponds and above the watercress beds – now disused because of chemical pollution from road run off. You called for a review of the springs near Junction 6 of the M3.

You are concerned that the River Thames Scheme and Thames Valley Flood Scheme are not represented.

You commented that strategic water transfers could result in invasive non-native species being brought into the Thames River Basin District.

You pointed out that government funding has helped remove or modify many structures which were compromising fish passage, hydromorphology and so on, but many previously unidentified structures are still coming to light. For example, in the South East Rivers Trust eel project walkover surveys identified structures in the Mole catchment and there is a significant legacy of structures to be addressed.

You have concerns that in the River Lea the RNAGS listed for each of the Upper Lea water bodies are not accurate and several are missing. Similarly, you said the actions and confidence levels are not up to date for the River Medway and the objectives for the River Wandle require updating to reflect the ambition and plans of partners working on the river.

You raised road run off ­in the River Ebbsfleet in Northfleet from the A2. You said there is a long section of culverted river which, as a chalk stream contains 6 barriers to migratory fish between the River Thames and what should be spawning grounds.

The Darent, Cray and Shuttle are particularly affected by changes of natural flow and water levels due to public water supply abstraction. You listed several new measures which you felt were missing.

You suggested 5 measures for the Darent. These included among others the Ecological Improvement and Adaptive Management Scheme in Honeypot Stream, Upper Darent working with several partners to improve the ecological health of the river and resilience to run off, low flows and drought. You also wanted to add several partnership engagement, education and project working initiatives including the Darent Valley Farm Cluster, the Darent Restoration and Resilience Project and the Darent Environmental Enhancement Programme.

You highlighted a number of River Cray new measures. These partnership initiatives include among others Uplifting the Upper Cray to address pollution, weir barriers and restore vegetation. The CrayWatch Project in Foots Cray Meadows is restoring the river using a range of interventions including the Riverfly citizen science initiative.

You gave examples of missing measures including the Ravensbourne catchment (a tributary of the Thames) Rivers Clean Up programme and the Thames and Tributaries Plastic blitz – a citizen science project which cleans up the tidal Thames. You wanted to add the work involving the Building Oxfordshire Freshwater Network which is the first project to put into practice Freshwater Habitats Trust’s new approach to the protection of freshwater biodiversity. The project is demonstrating this approach in Oxfordshire, one of the most important areas for freshwater wildlife in England.

You wanted to add Affinity’s Revitalising Chalk Rivers programme which includes an ambitious set of river restoration projects and the Restoring Sustainable Abstraction programme. You also highlighted Affinity Water’s current wider WINEP measures (for example, catchment management no deterioration or Drinking Water Protected Areas schemes) across multiple catchments in the Thames (and other river basin districts).

5. Using your feedback from this consultation

Your feedback through this consultation will help us produce updated RBMPs that will inform, improve, and shape how the water environment is managed. You will be able to see how it has been taken into account and improved the plans themselves in a summary document available in Autumn 2022.

The Environment Agency will also use your responses to help them consider how some of the current approaches to managing water in England will need to change with a changing climate and a growing population.  Your feedback will help to shape wider water policy and investment decisions beyond the horizon of the RBMPs.

6. Appendix

6.1 Organisations responding to the consultation

The following organisations responded to the consultation and gave consent for their response to be published:

• Action for the River Kennet (Environmental Group)

• Adur and Ouse Catchment Partnership

• Affinity Water Limited

• Alt Crossens Catchment Partnership

• Ancholme Catchment Partnership

• Anglian Water

• Angling Trust

• Ashford Borough Council

• Blue Marine Foundation

• Blueprint for Water, part of Wildlife and Countryside Link.

• BRCS

• Brent and Harrow Rivers Alliance (BHRA).

• Brent Catchment Partnership – CaBA Catchment Partnership

• Bristol Avon Catchment Partnership

• British Egg Industry Council (BEIC)

• Broadland Catchment Partnership

• Buckinghamshire Council, Local Authority

• Bungay Cherry Tree Angling Club

• Caerphilly County Borough Council

• Calder Catchment Partnership

• CamEO catchment partnership

• Canal & River Trust

• Catholic Action for Animals, animal rights. Also St. Barnabas Laudato Si Group, a local parish green group

• CCW – The Consumer Council for Water, which is the voice for water consumers in England and Wales

• Charity

• Coastal Partnership East

• Cornwall Catchment Partnership

• Council for the Protection of Rural England

• Country Land and Business Association (CLA)

• Coventry City Council

• Coventry University

• Cuckmere and Pevensey Catchment Partnership

• Dales to Vale Rivers Network, the CaBA catchment partnership for the SUNO and Whafe & Lower Ouse catchments

• Darent and Cray Catchment Partnership

• Devon County Council

• Dorset AONB team

• Dorset Catchment Partnerships

• Douglas Catchment Partnership

• East Hampshire catchment partnership members

• Elmbridge Borough Council

• Environmental campaign group

• Evenlode Catchment Partnership

• Fish Legal

• Fish Legal, legal representative for Pickering Fishery Association (local angling club with fishing rights at Costa Beck)

• Flood prevention society

• Freshwater Habitats Trust

• Freshwater Habitats Trust & River Thame Conservation Trust - Co-Catchment Hosts for Thame Catchment

• Friends of the Mimram 2020

• Friends of the Westbrook and Stonebridge Pond

• Fylde BC

• Gateshead Council

• Gloucestershire County Council

• Gloucestershire Wildlife Trust

• Greater London Authority

• Greater Manchester Combined Authority

• Greater Manchester Combined Authority

• Hampshire County Council

• Harrow Nature Conservation Forum

• Heathfield & Waldron Parish Council

• Heathrow Airport Limited

• Hertfordshire County Council

• Herts and Middlesex Wildlife Trust

• Humber (Nottinghamshire Wildlife Trust, Staffordshire Wildlife Trust, Derbyshire Wildlife Trust, Severn Trent Water, Trent Rivers Trust)

• RGCG and CPRE Norfolk

• Inland Waterways Association – South East Region (Registered Charity)

• Irwell Catchment Partnership

• Island Rivers catchment partnership members

• Kent County Council

• Kentish Stour Countryside Partnership

• Lake District National Park Authority

• Lincolnshire Chalk Streams Project

• Local Authority

• Loddon Catchment Partnership

• London Lea Catchment Partnership – CaBA catchment partnership

• Lower Mersey Catchment Partnership

• Maidenhead to Teddington Catchment Partnership

• Medway Valley Countryside Partnership - Not for profit conservation organisation

• Middle Tame and Anker sub catchment partnership, part of Tame Anker Mease Catchment Partnership

• National Farmers Union

• National Farmers Union – South East Region

• National Farmers’ Union – North East response

• National Farmers’ Union – West Midlands

• National Farmers Union – East Midlands Region

• National Farmers Union Watercress Association

• National Highways

• National Trust

• Natural England

• Natural England – Cumbria Area Team

• Network Rail

• New Forest Catchment Partnership

• North Lincolnshire Council

• North Walsham and Dinham Canal Trust

• North York Moors National Park Authority

• North Yorkshire Crayfish Forum

• Northfleet Harbour Restoration Trust

• Northumberland IFCA

• Northumberland Rivers Catchment Partnership

• Northumbrian Water

• NW Coastal Group

• Old Bedford including Middle Level Water CAae Partnership

• Ouseburn Lower Tyne Citizens’ Jury

• Partnership for South Hampshire (www.push.gov.uk)

• Peel Ports (the Statutory Harbour Authority, responsible for ensuring safety of navigation as the Mersey Docks and Harbour Company, Manchester Ship Canal Company, Heysham Port Limited, Great Yarmouth Harbour Authority and Port of Sheerness Limited)

• Pesticide Action Network UK

• Ravensbourne Catchment Improvement Group (the Catchment Partnership for the Ravensbourne - environmental group)

• RevIvel. (River Ivel North Herts/Beds- heavily over abstracted chalk stream)

• Ribble Life Catchment Partnership

• River Action

• River Gipping trust

• River Mole Catchment Partnership

• River Waveney Trust

• River Wharfe Citizens’ Jury

• Roding, Beam and Ingrebourne Catchment Partnership

• RSPB – Kent and Essex

• Salmon & Trout Conservation

• Severn Fisheries Group

• Severn Vale catchment partnership

• Solent Protection Society (Charity)

• SOLVE – Save Our Loddon Valley Environment

• South Chilterns Catchment Partnership – CaBA catchment partnership

• South Devon Catchment Partnership

• South East Rivers Trust

• South East Water

• South Essex Catchment Partnership

• South West Rivers Association representing riparian owners and anglers

• Southampton City Council

• Southern Water

• Suffolk Wildlife Trust

• Tamar Catchment Partnership

• Tamar Estuaries Consultative Forum

• Tamar Valley AONB

• Test & Itchen Catchment Partnership

• Thames Valley Citizens’ Jury

• Thames Water Utilities Ltd

• The Aire Catchment Network

• The Association of Drainage Authorities

• The Catchment Partnerships in London Group (CPiL)

• The Coal Authority, Non-Departmental Public Body

• The Forestry Commission

• The Marine Management Organisation

• The Rivers Trust

• The Royal Society for the Protection of Birds (RSPB)

• The Wildlife Trusts, conservation organisation

• Tidal River Thames Citizens’ Jury

• Tunbridge Wells Borough Council (TWBC)

• UK Centre for Ecology & Hydrology (UKCEH)

• United Utilities

• Upper Thames Catchment Partnership

• Ver Valley Society

• Wandle Catchment Partnership

• Warwickshire Avon Catchment Partnership

• Wealden District Council

• Weaver Gowy Catchment Partnership

• Wessex Water

• West Cumbria Catchment Partnership & West Cumbria Rivers Trust

• Westcountry Rivers Trust

• Wey Landscape Partnership

• Windermere Citizens’ Panel

• Worcestershire Wildlife Trust

• WWF

• WWF-UK

• Wyre Rivers Trust

• Yorkshire Integrated Catchment Solutions Programme (iCASP)

• Yorkshire Water

• Yorkshire Wildlife Trust

• Your Tees Catchment Partnership

• Zoological Society of London