On 17th September, the Environment Agency published their assessment of river and groundwater quality for the last few years – see here for details. I have rarely been so angry. This blog explains why I am so angry and wonders how we can do better in the future.

The background

The EA’s key role is to protect our environment. In order to do this they have to monitor the quality of our rivers and underground waters. Once every 6 years they ringmaster the production of a “River Basin Management Plan” which outlines the current state of our rivers and the work necessary to improve them in line with the EU Water Framework Directive (which has been copied into UK law post-Brexit). In doing that they work with a host of external players, not least Catchment Hosts who were set up by Defra with the specific intent of bringing together stakeholders in river catchments to contribute to this work – this after the EA were strongly criticised the first time around (we are now developing the 3rd Plan) for a grossly indequate effort to involve external partners.

Developing that assessment and plan necessarily involves taking samples of our rivers to assess the current condition – known as WFD status. Any statistician will tell you that the quality of a data-based decision is fundamentally dependent on the quality and quantity of that data. I will come back to this point later. Developing the plan also depends on the current WFD status of the river – if it’s currently OK then only protection is needed, whereas a Poor status demands remedial action. This is where the EA’s failings first come to light.

Their classification of current status operates a ‘one out, all out’ policy for river chemistry. Essentially, if they analyse for 10 different chemicals and one fails then the whole river fails regardless of how good the other aspects of river chemistry are. Think about this. The more chemicals you analyse for, the more chance of the river failing regardless of whether there has actually been a deterioration.

So what has happened?

The published data shows that every single river in the country fails the chemical standards set for them. And it’s not that which makes me so angry. What makes me angry is that the failures are down to the EA changing their methodology. Let me quote the email I received with the local results:

“Improvements in laboratory analytical techniques mean that this is the first classification where we have used the improved, more sensitive analytical methods for many chemicals. This is also the first classification which includes substances identified as ubiquitous, persistent, bioaccumulative and toxic (uPBT), which have an alternative method of assessment using a biota (fish)-based environmental quality standard, rather than a sample from the water column.

Due to the new chemical methods, all surface waterbodies in Yorkshire now fail Chemical Status standards (mainly for mercury and polybrominated diphenyl ethers (PBDE), both uPBTs. As a consequence of the “one out all out” rule, this has a knock-on effect on Overall Waterbody Status. While the new chemical methods give a more accurate picture of environmental quality, they do not reflect actual environmental deterioration since 2016.”

Our rivers may not have actually deteriorated, they just appear to have done so because of this quirk of the system! But we don’t actually know because we are being asked to compare apples with oranges.
The EA could have, but haven’t, published a parallel data set showing the state of our rivers had the new methods not been implemented. I wonder what this might have shown? Any competent data handler would have done this. I wonder why they didn’t? Are they playing political games perhaps?

The media response

Perhaps predictably, this has caused righteous uproar in the media.

Shocking state of English rivers revealed as all of them fail pollution tests – The Guardian
Every river in England is polluted, government figures reveal – The Independent

Vocal commentators such as Feargal Sharkey – yes, the former Undertones singer, and long-term angler and critic of the EA – have waded in.

This inept piece of data handling and presentation just stokes the fires of anti-EA feeling. I have resisted this so far, knowing of the committment and dedication of the vast majority of EA staff with whom I work every day and who do thier very best with inadequate resources.

But that’s not all…

The value of any data set depends on both the quality and quantity of the data. The comments above relate to quality. What about quantity? How often are our rivers sampled and analysed? I wish I knew, that data is not so easily visible. What I do know, from watching this over the years, is that the frequency of sampling has decreased. I also know that the EA has a long-running “Strategic Monitoring Review”, ostensibly to establish the most effective monitoring regime but in many of our eyes to establish how little they can get away with. Enquiries about this review, which was supposed to be carried out in full consultation with their key partners, reveal little more than prevarication and assurances (which nobody believes) that it’s not a cost-reduction exercise.
However, one of my colleagues in a different area has done some analysis of the frequency of sampling in their patch. The results are telling. From a peak of 166,475 analyses in 2012, the latest number available, for 2019, has fallen to 68,829. At least that is up from a miserable 63,398 the previous year. The frequency of analysis has reduced by 60%. So on a significantly smaller data set, the state of our rivers is being condemned.

Shame on you EA.

Why am I so angry?

I have spent 45 years of my life working to improve river quality in the River Aire. I know for a fact that the quality of this river is vastly improved over that time. My former employers, Yorkshire Water, have spent hundreds of £millions improving the discharges from their sewage works such that we now have salmon coming up our river and looking for somewhere to spawn. For the last few years I have been a trustee in a rivers trust dedicated to improving the river and, in that role, involved in many projects that have actually improved the river. As I write, we are delivering a partnership project with the EA designed to allow those salmon right up to their historic spawning ground in the headwaters. Now, through a quirk of the system and indaequate sampling, I am being told that my beloved rivers have actually deteriorated despite all this good work.
I feel as if I have been kicked in the stomach and then had my head trampled on to boot. Surely all of those years’ work has not been in vain?

I know it has not, but ‘the system’ is telling me otherwise. This data, that has caused all the furore, was due for release in Spring but was delayed by the EA – I was originally told “because we are having some difficulties with it”; then more recently Covid-19 was invoked as a reason for the delay. Now we see the truth. It is an inadequate data set that tells a false story. A data set that belies the great work by the EA’s own staff, by the water companies and other dischargers, by rivers trusts and wildlife trusts and by the hundreds of volunteers (like myself) who turn out for free to help further improve our rivers.
Shame on you Environment Agency.

Tragedy or farce?

I started this blog asking whether what has happened is a farce or a tragedy – in my opinion it is both. It could have been handled so much better. For example, a bit of honesty/openness/transparency back in spring when the data was unexpectedly held back might have allowed us to prepare and understand the issues.

I know from personal experience how hard the dedicated staff of the EA work. They do their very best with inadequate resources. We in Rivers Trusts work with them on a daily basis actually improving water quality and other aspects of their ecology and we value their advice and the funds that come our way to help them in their quest for improvements.

The change could have been ‘trailed’ well in advance, giving us all time to prepare and understand the issues involved and be prepared for the inevitable media storm in which the nuances of this being an artefact of a change in methodology get lost. The results could have been published in parallel with what the results would have been had the changes not been made.

The challenge now is to get over the current situation and figure out how we can best continue to work together to achieve more in the future.

‘Free swimming’, aka swimming in rivers, lakes and the sea, is gaining is popularity. With the recent publication of a consultation on designating the Wharfe as a bathing water, now seems to be a good time to offer an opinion piece on this thorny issue. This will be a data-free zone, yet one based on many years’ experience dealing with bathing water issues since the original Bathing Waters Directive came into force in 1975. This piece is the personal opinion of the author and is not intended to suggest that it is the policy or opinion of the Trust.

When the original Directive came into force, the predecessors of Defra went to great lengths to minimise the number of designations. Inland waters were excluded and the criteria applied to coastal waters were so strict that only a very few were granted bathing water status. Moreover, they decided that only the minimum stadrds in the Directive needed to be applied.
The EU’s Bathing Waters page offers a wealth of information on the current state of bathing waters around Europe (incuding the UK as the data were collected before Brexit). The UK currently has 644 designations, compare to the extremes of 3348 in France and 17 in Luxembourg. Unlike in the UK, many countries in the EU have designated many inland waters. Doing so in the UK would represent a major change in policy with long-lasting and complex implications, both practical and economic.
This piece explores some of those implications, albeit briefly.

Early experience of complications or it’s not just about sewage

The prevailing mindset when standards were first introduced was that they could be met by effective sewage treatment and/or piping effluents well out to sea beyond the possibility that they could influence bathing waters (which were generally just the few metres between high tides and into the sea at low tide). Before long, we were examining tidal flow patterns around bays and along the length opf the coast, then exploring the impact of combined sewer overflows, then misconnections into allegedly clean watercourses dischargeing onto the beach, then urban runoff, then dogs and birds defecating on the beach….
I mention these complications only to help the reader understand that meeting the standards was not as simple as it might have first appeared and that a whole lot of unexpected factors significantly delayed compliance. How might similar factors play out in the case of the Wharfe at Ilkley, or indeed any other inland water? Upstream of any sampling point on rivers are likely to be several other sewage works, a host of (generally poorly maintained) private treatment plants or septic tanks, runoff from both urban and rural roadways, field runoff containg cow/pig/sheep/chicken etc faeces, any of which could carry a substantial load of coliforms and/or enterococci.

Practicalities and economics

What might meeting the standards involve? For the sake of this blog, let’s just consider sewage discharges from water company assets – Combined Sewer Overflows (intermittent discharges, theoretically only after heavy rain) and Sewage Treatment works (continuous discharges). At the moment there are no bacteriological standards on these discharges and the introduction of them would inevitably lead to the need to disinfect such discharges. In order to be able to reliably disinfect, they would almost certainly need treating to a higher standard than at present (no bad thing, but in this case technically necessary to enable disinfection). I am, of course, assuming that disinfection would be by way of UV treatment, as any chemical option would be likley to lead to disinfection byproducts unlikely to be acceptable in the receiving watercourse.
For CSOs “treating to a higher standard” is likely to first mean drastically reducing the permissible discharge to river – which of course is one of the campaigners’ wishes (not that it would not be welcomed by most people interested in improving water quality). But what then? CSOs do not typically have any treatment other than screening out physical debris (this could certainly be improved but it wouldn’t render the deischarges disinfected). But we still have a discharge containing substantial bacteriological load, and not only from sewage but also from runoff, so what next? I don’t know – do you? Perhpas we could delay the discharge until such time as the river genuinely has risen (that was the original concept behid CSOs after all) to a level where people could not realistically swim in it anyway? All of this would require significantly more sewage to be passed forward to the treatment works – and hence upgrading sewers and then additional treatment capacity at the works.
So here we are at the, now significantly bigger, sewage works. A works whose operating range has increased from a volume ranging from 1 unit to 6 units and now has to treat a range from 1 to ??? units. Now there’s an interesting challenge. Any process engineer will tell you that designing a system gets harder, and more expensive, as the range of operation increases. And that bigger works will need to treat sewage to a much higher standard, typically referred to as tertiary treatment, in order that disinfection can work.

So what’s the challenge?

Now all of this is technically possible, so what’s the challenge? Easy – money. All this has to be paid for, and who do you think will pay for it? Yes, us customers. OK, the arguments will now come out about the ‘rip-off profits’ of the water companies and how the owners should pay – but anyone with even a simple understanding of financing understands that owners invest in the companies and deserve a return on their investment (if they don’t get one why should they invest?) and that whilst they could be financed by borrowing, that needs to have interest paid on it and be paid off as well. And please, no arguments about re-nationalisation – this is not the place for that.

Is it worth it?

So we (whoever ‘we’ is) spend all this money on sewers and sewage works, will it result in ‘Rivers fit to Swim in’? My prediction is ‘NO’. No for the reasons I have mentioned – private sewage treatment systems, urban and rural runoff etc.

Please do contribute to the discussion. Knowing how sensitive this issue is I reserve the right to moderate comments.

When I was working as an organisational development specialist, we often talked about the ‘shadow organisation’ the parts of an organisation that just found ways to get things done, almost regardless and in many cases in spite of the ‘formal’ channels. Formal channels are often slow, stuffed with bureaucracy and depend on the hierarchy and organisational flow chart; the shadow organisation can be quick(er), often ignore ‘the rules’ and depend on human networks. When you need a fix for your computer and you know that means raising a work request that needs your manager’s counter-signature before it is passed to IT where it gets prioritised by someone who doesn’t understand how important it is to you….is when you ring your friend Jenny in IT who you know can and will just fix it for you. That’s the shadow organisation in action.

Reading this article from The Conversation, I was reminded of how society has its shadow organisations as well.
During Covid19 lockdown, how many of us have found alternative ways to get our weekly food fix – including the growth of food banks – or moved to online shopping, or asked the neighbours to help, or even met the neighbours properly for the first time?
Surely volunteers making scrubs for NHS staff when ‘the system’ was failing them is a shadow organisation workaround?
or individuals and restaurateurs spontaneously making meals for and delivering them to NHS staff?
Or self-fabrication of face masks when the government’s advice is ambivalent?
Or the thousands of volunteers who participated in ‘adopt-a-granny’ movements?
Or…find your own example.

Shadow organisations emerge in order to solve a problem created by or inherent in organisations. They cannot be created and they do not react well to those who try to institutionalise them (“Oh, the shadow organisation works well, let’s give it formal recognition in our HR structure, pay scales etc’). As soon as the formal structures get involved they tend to bring with them targets and constraints and reporting, all of which are anathema to a smoothly, efficiently functioning shadow organisation.
What they need is to be left alone and for the key players (and there are often a few key links or focal points in these shadow organisations) to be protected from organisational interference.

As I think you all know, I have a very significant sideline in organisational change and  not least hold organisations to account for the outcomes they purport to be driving

I was re-reading some stuff on the Cynefin Framework recently (see here for a Noddy Guide https://www.mindtools.com/pages/article/cynefin-framework.htm  and here to go to the HBR article that started it all off https://hbr.org/2007/11/a-leaders-framework-for-decision-making ), which deals with how to approach ‘managing’ and leading situations of varying degrees of complexity.

Less academically, this blog article (https://sluggerotoole.com/2016/07/05/soapbox-the-sorry-tale-of-outcome-based-performance-management/ rang some loud bells in the current context where the best laid plans are having to be revised. For me, it’s not a manifesto for abandoning outcome based performance management, more a strong warning that  A does not necessarily lead to B then C – not least in the currently disruptive environment (VUCA is hardly enough for what is happening now).

We need to be agile, with fast-running Plan-Do-Review-Replan loops.

Accountable for building a fish pass but not for exactly when or to exactly what budget – what if we get a flood during construction, or the fish don’t come?
Accountable for marketing our river into the BAME community but not for ensuring that 3% of the BAME community living within 5 miles of the river visit it at least once each year.
Accountable for continuous learning about how to run projects and move towards our key outcomes and not for following some pre-existing recipe.