Water Quality and the Nutrient Management Plan
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 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 has bee 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 three years on, what progress is the Board making towards the critical 2027 target?
The short answer until recently was that no one knew. The EA was not providing the Board with up-to-date data about phosphate levels in the SAC and the Board in any event had not created a trajectory against which it could match such data in order to judge progress.
Phosphate mapping commissioned by CPRE Herefordshire
In 2017, out of frustration, CPRE Herefordshire did 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
By clicking on any of the points you can bring up a time graph of sampling results for that point. Individual samples can vary from month to month, so to help establish whether there is any definable trend over time, the graph includes a 12-month moving average as a red line. So far there seems to be no clear trend of improvement across the catchment since 2015 - despite the invaluable work done by the Wye and Usk Foundation and other local environmental groups in helping farmers reduce phosphate run-off from their land.
There are 45 EA sampling points on the Upper Wye and Lugg catchments within Herefordshire. Of these 7 are situated on the Wye and Lugg rivers themselves, within the SAC, and therefore directly relevant to assessing whether the NMP is succeeding:
four on the Wye - at Bredwardine Bridge, Bridge Sollars Bridge, Victoria Bridge, and Carrots Pool,
and three on the Lugg - at Mordiford Bridge, Wergins Bridge, and Ford Bridge.
The other 38 are on tributaries of the Wye and Lugg and therefore indirectly important to assessing progress since, of course, the tributaries account for most of the water in those rivers.
However, it has recently emerged that around 2017 the EA, as a cost-saving measure, stopped sampling at 37 out of the 45 points. All but two of these cuts were on the tributaries and one was on the SAC itself (at Wergins Bridge). In effect, the EA has reduced sampling to the bare minimum to be seen to be meeting its legal duties in respect of the SAC. CPRE thinks this a desperate loss which can only make it more difficult for the NMP Board to target resources and meet its 2027 deadline.
The Environment Agency 'Dashboard'
The EA has at last produced a 'dashboard' of data for the NMP Board. This includes basic phosphate data as well as other management information. You can view it here.
Judge for yourself how useful it is.