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 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.