Water quality and Herefordshire’s Nutrient Management Plan (NMP)

Often our rivers are where economic pressures and environmental constraints most obviously come face to face. Herefordshire is no exception.

Most of Herefordshire is in the catchment of the River Wye and its waters are a measure of the health of the county’s environment. A lot of our drinking water comes from the river and its tributaries.

But it is also where much of the pollution generated by human activity goes. One of the most important of these pollutants is phosphate. Too much phosphate encourages the growth of too much plankton, which can over-shade or suffocate fish and other plants.
In extreme cases it can lead to blooms of toxic algae harmful to humans and animals.

How phosphate accumulates in rivers is complicated and not fully understood by scientists. There seem to be two main sources for the Wye.

First “point sources”: These are mainly sewage works - bodily waste is rich in phosphate – and some industrial plants.

Secondly, “diffuse sources”, that is, run-off from land surrounding the river. This too can contain a lot of phosphate from animal waste as well as phosphate bound up in soil particles. The kind of farming carried out and how it is managed has a big effect here.

Special Area of Conservation
The River Wye itself has a high level of protection under European law as a Special Area of Conservation (SAC). This includes the River Lugg tributary as far as Hope-under-Dinmore. The Environment Agency (EA) regularly checks phosphate levels in the SAC, and the tributaries that feed into it, to ensure that they stay within agreed ceilings. In recent years the Wye has generally stayed within its ceiling – although often too close for comfort – but the Lugg is heavily and continuously over it.

This presents serious problems for housing growth in the county: with more houses come more people and with more people come more sewage and therefore more phosphate in the rivers. Unless something can be done, Herefordshire Council’s plans for new housing risks being unlawful.

Nutrient Management Plan (NMP)
When the Council was finalising its new Local Plan Core Strategy in 2015, it tackled this problem by creating a Nutrient Management Plan (NMP) to get all phosphate levels within the ceilings by 2027 at the latest, even allowing for the extra phosphate generated by the new housing included in the Core Strategy. And it set up a Board to ‘deliver’ the NMP. On this basis the Core Strategy was accepted as legal by a government inspector and came into force in October 2015.

Now, over two years on, what progress is the Board making towards the critical 2027 target?

The short answer is no one knows. So far the Board has not even monitored the EA phosphate data - and without such monitoring how can the Board know whether the actions it is promoting are working and whether the 2027 target is still viable? For nearly two years the EA has been promising the Board a “dashboard” that will turn the raw data into an easily understood graphic form, but so far nothing has emerged.

Phosphate mapping commissioned by Herefordshire CPRE
The good news is that Herefordshire CPRE has done the EA’s job for it and commissioned an expert to extract the raw data from the EA’s website for every current sampling point in the Upper Wye and Lugg catchment inside Herefordshire and turn the data into a set of easily read graphs and a map. You can look at it here (red points are over the ceiling, green are under. Click on each point to bring up the graph for that point): Map of phosphate data 

The map is based on Autumn 2017 data.
As of that date only five out of 49 sampling points were ‘green’ i.e. within the ceilings. The graphs show that when the Board started work in Autumn 2015 eleven points were green.

So, on the face of it, in the two years since the Board started work, the situation has got worse, not better.

Unless the Board can get a grip on the situation and create a significant and robust trend showing that the 2027 target can be achieved, then the NMP will be defunct and the whole Core Strategy which depends on it risks being unlawful and potentially facing challenge in the courts.