If you can’t measure it, how can you manage it?

Fundamental change is needed to the way in which the Environment Agency (EA) monitors and investigates the environment. Far too much data is recorded for no clear reason, with much of this never actually analysed or of insufficient quality to inform managers of the causes of problems. Furthermore, copious amounts of high quality data collected by other organisations are not currently used by the EA.

But, without effective measuring, you can’t manage our environment correctly. There are of course exceptions to this rule (as with most rules), but to manage water effectively it is generally essential to have high quality information on which to base your decisions. Is a river getting cleaner or more polluted? Where and when is pollution getting into the river or its tributaries? What is the principal source of the pollution? Unfortunately, for many rivers in England and Wales, we don’t have this basic information, or what we have is misleading.

The Angling Trust & Fish Legal have, for the last six years or so, been challenging the Environment Agency to address shortcomings in the way that it monitors and investigates river water quality, which is vitally important to our member angling clubs, fisheries and individual anglers, as well as being essential for protecting wildlife associated with watercourses. We believe that the current methodology is failing to identify problems with pollution on rivers due to its reliance on spot samples taken every few months, predominantly in dry weather and during the day. These samples will often fail to pick up spikes in pollution due to wet weather, or dips in dissolved oxygen at night, as the graph below shows. This is likely to have led to rivers being incorrectly classified, and failures to investigate and stop sources of pollution.

Figure 1. Diurnal Variation of Ammonia Concentration in Sewage Effluent.

It’s important to monitor night time quality, because it will be the first indication of impending problems, as an early warning system for identifying Sewage Treatment Works (STWs) where performance is beginning to decline.

Figure 2 below shows the ammonia concentration for two sets of samples at the River Eden at Sheepmount, taken in 2014. Even though spot samples were taken at a higher frequency than normal (weekly rather than monthly), it can be seen that they still completely failed to detect the higher ammonia values that occurred during wet weather. It is unlikely that the high levels of ammonia would ever have been detected by routine spot samples.

Figure 2. Ammonia concentration for two sample sets at River Eden in 2014.

The failure of the current system is really important because action to address the problems can only be justified if there is clear evidence. With more of our rivers failing to meet “good ecological status” than 10 years ago, we need to break this cycle of producing expensive action plans that don’t lead to any action being taken because there isn’t enough information to justify regulating industry and agriculture or investing money.

The Agency responded to our challenge three years ago by launching a Strategic Monitoring Review. Its brief was to look afresh at the EA’s £70 – £80 million water monitoring programme, to see if it was fit for purpose and better integrate it with organisations like the river trusts, who hold vast quantities of data about water. We were delighted with this response and excited by the possibilities it offered. We were shown a presentation which included a collaborative process with external organisations, and a 12 – 18 month timetable for completion of the review.

Since then, we have frequently asked for updates on progress with the review, but without much luck. The manager leading the initiative moved off into another job and the promised meetings with other organisations in the sector were never held. This week, The Angling Trust met the relevant team and the signs were encouraging that the review is back on track, albeit about 2 years late.

This must be a collaborative process with the voluntary sector if the review objectives are to have any chance of being achieved. There is a danger that this could otherwise become simply a cost-cutting exercise.

Monitoring and investigations should be designed to make it possible for the Agency to take action to improve the environment. The EA could also save money by commissioning others to carry out monitoring at a fraction of the cost and with match funding support. Such fundamental change will need strong leadership from the top, otherwise the Agency will waste yet more precious public money and continue failing to stop the widespread ecological declines on our rivers and lakes.

Mark Lloyd
Chief Executive, Angling Trust & Fish Legal