It’s easy to be critical, but the ambition is one that we can all get on board with and overall, it is good to get the chance to see the Government’s thinking on water pulled together in one document. There are some welcome elements within the plan, for example, a focus on the Catchment Based Approach (CaBA) and partnership plans, unlimited fines for polluters ringfenced for water restoration, a ban on plastic in wet wipes, funding to restore our unique chalk streams, peatland restoration and edging towards a ban on, at least some, persistent chemicals. The big outstanding question is – does it all add up to the step change required to restore our struggling water environment that we need, and have been calling for?

The Plan remains a high-level document setting out a vision and some ideas for delivery – the detail for how most of the ambition will be implemented is still open for development and within that process lies many pitfalls; it is critical, therefore, that Government works closely with NGOs to ensure smart delivery of the plan and to realise synergistic outcomes.

The Catchment Based Approach

The plan clearly recognises that integrated water management across whole catchments is the only practicable way to manage the health of our rivers and that this should be undertaken collaboratively by all stakeholders through Catchment Partnerships – so far so good. There is also a commitment to additional funding which is welcome. But Government is not providing that funding – money from water company fines will go into a Water Restoration Fund to support Catchment Partnership working and water restoration projects. This will not provide the certainty of funding that Partnerships so desperately need to do their complex job of planning and delivering improvements to the environment. A catchment management system reliant on catching and fining polluters for causing harm suggests that if the fines are proportionate, then we will only have enough resources to repair the harm they cause – this won’t be enough to reverse the centuries of abuse on our rivers.

The Government has also so far failed to address the need to fill the ‘missing middle’, by creating a regional tier of management to integrate and provide coherence to the many plans and programmes of work and direct much needed funding to deliver local plans. This was a key recommendation from our governance working group over the past year, involving organisations from all sectors. Dieter Helm, the respected environmental economist, has called repeatedly for a ‘catchment system operator’ to direct funding at this super-catchment scale, and this idea is gaining momentum in water and land management circles.

Nature Based Solutions

Nature Based Solutions crop up throughout the plan - supporting water companies to increase nature-based solutions to improve the water environment. Nature based solutions to treat wastewater use much less carbon-hungry concrete – and fewer chemicals – and they can deliver multiple benefits to us and nature by increasing biodiversity, sequestering carbon and reducing flood risk. Alongside the plan for water the government announced the acceleration of £1.6bn of investment in water schemes this week. The first round of schemes identified by OFWAT rely almost entirely on pouring concrete and chemical treatments to reduce nutrients discharged into the environment – the focus should be on looking for opportunities to put in place nature based solutions throughout the catchment with all the multiple benefits they can deliver as the first solution – not the last.

Targeting action on our land and linkages between Local Nature Recovery Strategies, Catchment Based Approach and Environmental Land Management schemes

The plan recognises that managing farming and our rural landscapes within catchments is fundamental to healthy water systems. We need a fully integrated approach on land and water and solutions to tackle water pollution from our land need to be highly targeted to achieve the gains we need. But how is this going to be achieved? – how will farmers know where to take action to protect the water environment, how will they be incentivised to make those changes and how will that be integrated with nature recovery opportunities to make sure we are delivering the most we can on our limited supply of land. This requires Local Nature Recovery Strategies, the Catchment Based Approach and Environmental Land Management schemes to interact together effectively. The detail on how this will happen is a big gap in what government have shared so far.

Legislation, regulation and enforcement

Poor performance on enforcement has been a key failure in relation to regulation of the water industry. The plan sets out funding to increase the Environment Agency enforcement capacity which is well overdue to reverse years of staff and funding cuts. There needs to be a fundamental rethink about monitoring responsibilities and activities. Self-monitoring by the water companies, often referred to as ‘marking their own homework’ has led to systemic abuse and the huge public mistrust which has fuelled much of the outrage expressed in the combined sewer overflow media storm.

The plan talks opaquely about streamlining water policy and legal frameworks and specifically reviewing the Water Framework Directive. The commitment in the plan suggest that Government will retain the goal to restore 75% of water bodies to Good Ecological Status – it does not mention retaining the deadline to achieve this nor the method for assessing Good Ecological Status. These omissions suggest the timescales and assessment methods may well change, this sounds suspiciously like watering down protection for our water environment post Brexit and more clarity is urgently needed.

In some areas of the plan there is ambition, but the detail is lacking. In others, particularly where there is less public focus, there is a worrying lack of ambition. For example: on pollution from transport, 30 water quality initiatives in 5 years under the Road Investment Strategy is pitiful, we need at least an order of magnitude increase if we are to tackle this key source of pollutants. And on private sewage systems, there are 700,000 private sewage systems operating under the radar - often outdated, poorly maintained and overloaded, with minimal awareness or monitoring of the long-term, low-level discharges that can have a big impact on small streams and lakes.

In the long run what will this plan add up to in practice? We’ve had worthy ambition and vision in the past, but with limited commitment to delivery our water environment has continued to decline. Will it be the same this time? Or can we apply the pressure, hold the government to its vision to make sure the plan delivers the integrated solutions for our land, water and air to help avert the climate and biodiversity crises?