10 QUESTIONS & ANSWERS
10 May 2008
I have always been an ardent supporter and I hope friend of the Environment Agency and of the NRA before it. I was interviewed for, but declined a place on the Thames region’s Regional Statutory Advisory Committee in 2005 at Millbank Tower, the year after the water element on the Environment Agency logo was mysteriously removed. Without Environment Agency funding, and the fantastic efforts and enthusiasm of regional officers on the ground, the JetSet Trout in the Classroom work I now head-up in schools, latterly in partnership with the Agency would be in real and serious jeopardy. The children who have and hopefully will benefit country wide from this work are extremely grateful for your year on year support as of course am I. Proof if it were needed that the EA care about the future of our sport. Thank you. I think it is important and appropriate for a genuine friend to voice timely concern rather than to cynically and retrospectively cry ‘I told you so’. I am genuinely worried by the direction the agency is currently heading in or should I say being forced along. I have been a passionate angler for over 50 years and even without my NUBA hat on my views may be of some relevance and substance. I know they are echoed by many others. _____________________________________________________________ Without doubt the Environment Agency is presently under tremendous pressure from swingeing budget cuts and pervasive micro-management from upon high, quite understandably resulting in something of a crisis of shrinking resources, funding, manpower, eco-aspiration and morale. To further compound matters, climate change is causing summer deluge one moment then critical water shortage the next. Drainage and sewage systems all at once in virtual meltdown and an all consuming flood prevention, alleviation, defence and prioritisation the inevitable consequence of decades of successive government and industry neglect. Quite clearly some very difficult choices will have to be made. All this understood, it would still be a monumental blunder and a quite unforgivable misjudgement to embark upon a potentially and predictably disastrous experiment in water industry deregulation. If these companies are allowed, against all advice and common sense to police their own effluent discharge into our already struggling watercourses, the only real future I can envisage for our rivers is one of mere put and take fisheries and boom and bust ecologies constantly at risk and vulnerable to the malign whim of an industry who need absolutely no external encouragement to pollute. Most sensible thinkers would consider the present water industry uniquely unsuited for self-regulation and that this would presage disaster nationally for our riverine environment. Anglers, ecologists and the public in general require and quite rightly expect the Environment Agency to be rigorous guardians of the health, purity and sustainability of the water in our rivers, lakes, lochs, ponds, canals and becks etc. We see this as your core role and your fundamental reason to exist! Without constant and dependable clean water, all other habitat improvement and ecological enhancement work either you, we the public, or the many River Trusts struggle to carry out becomes mere window dressing and potentially futile squandered effort and commitment. In 1995 and following yet another disastrous Thames Water plc pollution of the river Wandle in South London, the JetSet charity and a highly motivated Wandle Valley community embarked upon ‘a decade’ of dedicated river restoration work which was to become nationally and internationally recognised. The result of many thousands of hours of often filthy, sometimes dangerous, but always inspiring and uplifting effort, the Wandle became a beacon of hope for blighted urban streams everywhere and a shining example of just what can be achieved when children, local business, the angling establishment and countless selfless valley residents pull together to rescue their local river. Ten years on, our work done and following great celebrations in proud collaboration with the Salmon and Trout Association at St Pauls Cathedral, (another £13,000 raised for the river soon to be shamelessly squandered) in October 2005 to commemorate the renaissance of Lord Nelson’s beloved stream and of course victory at Trafalgar, JetSet passed this now mended, virtually pristine historic London river to the newly formed Wandle Trust for it’s safe keeping early in 2006. Brown Trout were spawning once again in inner London, coarse fish of amazing size, diversity and quality proliferated famously and Kingfishers were thriving and plentiful once again against all the odds from Wandsworth to Carshalton and Croydon. A unique green lane of burgeoning riverine ecology amidst London’s urban sprawl. A mere 22 months later in September 2007 and to the absolute horror of all concerned Thames Water Plc our serially inadequate water utility in a seemingly constant cycle of recidivism contrived to all but destroy this rejuvenated jewel of a river yet again and this time they really did excel themselves. Fifteen years work and a decade of community pride and dedication sacrificed to Thames Water’s reckless incompetence. All our efforts rendered worthless and futile and totally heartbreaking for the Wandle community. Continuing infrastructural shortcomings, lack of adequate investment, basic human error, failure to install viable and long promised (since 1995) pollution monitoring equipment, cynical shareholder prioritisation, studied negligence and deceit from the very highest level of management. All the fatal avoidable and inevitable toxic recipe for eco disaster. See also recent cases i.e. Severn Trent, Southern Water etc. within the last six months. If my views on the water industry in general and of Thames Water Plc especially are deemed libellous, inaccurate, misconceived or even mischievously defamatory these massive cash rich companies are far better equipped to seek recourse to law to defend their reputation and performance than a mere individual. Fortunately, and Thames Water et al know it, no one in this country can be successfully sued for simply telling the truth however unpalatable it my be. I confidently await any challenge, let’s trade evidence. 10 QUESTIONS 1. How on earth can you possibly even contemplate allowing water companies the power to self police their own effluent discharge into our already vulnerable water courses when the historic and recent stock in trade of many of them is failure, deceit, cover-up, denial, infrasuctural neglect and inadequacy, inevitable shareholder prioritisation, falsification of data, performance faking, fraud and now even criminal deception? All of this and worse under existing Environment Agency scrutiny. Please explain your mysterious and potentially disastrous confidence in this serially failing industry and your decision to all but sacrifice our riverine ecology to their safekeeping. As one with bitter personal experience of the culture and shortcomings of this industry I humbly beg you to think again. The Environment Agency is making changes to the way it regulates discharges to water to bring about further improvements in water quality of our rivers and coastal waters, whilst making regulation less burdensome on business. Significant improvements in water quality have been achieved in the last two decades, in part due to the significant investment made by water companies in improving their sewage treatment and sewerage networks. The water industry has also sustained a good record of compliance with its discharge consents. The industry already self-monitors its own effluent quality at many of its larger sewage treatment works which are subject to the requirements of the Urban Waste Water Treatment Directive and where ultraviolet disinfection is required to protect bathing waters. In addition, the supply of drinking water is regulated using a self monitoring approach. Self monitoring is not therefore a new concept and it has proven to be an effective way to regulate. However, self-monitoring, is not the same as self-policing. The Environment Agency will remain responsible for judging compliance with discharge consents and for taking appropriate enforcement action where necessary. To assure the quality of self monitoring, water companies will need to demonstrate that their sampling and analysis procedures are robust and meet required standards. These will be subject to third party accreditation and we will inspect and audit their activities to ensure that these standards are met. _____________________________________________________________________________________________ If as many fear, you are determined to carry out your intention to delegate your river quality policing role to these companies, then not to criminally prosecute Thames Water would send an even more damaging and worrying message to all who cherish our rivers re the extent of your dislocation from their care. Future pollution incidents perpetrated by these companies must be very clearly perceived by them to result in such dire and unacceptable consequences for their reputation and their shareholders that they are forced to act competently and lawfully. To not sue would simply encourage malpractice. The £500,000 reparation fund coughed up by Thames Water following their latest murder of the Wandle (spread over three years) hurts them not a jot, sustains the river only until the next inevitable incident and is seen by them as a price worth paying. Question 2. Is the Environment Agency still intent upon criminally prosecuting Thames water Plc following the disastrous pollution of South London’s river Wandle in September 2007, or are your lawyers going to conclude that insufficient evidence exists to proceed? At this stage all I can say is we are proceeding with actions on this incident in accordance with our legal and functional obligations. I have performed an extremely minor role in encouraging the move to create a long overdue National Angling Museum in this country. To this end and 11 months ago I introduced Mr Neil Freeman, NUBA member and leading light behind the museum initiative to a senior Environment Agency colleague. Mr Freeman was there to offer the Agency (totally free of charge) a permanent rolling module within this potentially high profile, internationally recognised venue. This Agency officer, himself an extremely keen angler and of fairly senior position, stated quite candidly though reluctantly that the Environment Agency no longer had the motivation, the resources or the confidence to showcase it’s present eco-role or future eco-aspirations to the angling fraternity. Suffice to say Mr Freeman was quite incredulous and I was saddened and embarrassed. Question 3 Was this gentleman accurately ‘on message’ re the Environment Agency's present and future eco-aspirations? Without knowing what the officer said I do not know whether your interpretation is correct and therefore it is difficult to comment.
Relating to the previous question and if asked once again, would the Environment Agency now be willing to showcase it’s present Eco achievements and future eco-aspirations to anglers, ecologists, children and all others visiting the proposed National Angling Museum? Surely this would be a unique and valuable opportunity not to be missed and an effective foil to the prevailing and increasing disquiet. We have to prioritise the projects we support or contribute to. We seek to work with initiatives that contribute resources and help each parties funding go further. Without knowing more about the project you mention, it is difficult for us to make a commitment to the project you mention. Question 5 To be rather more positive, what would you consider to be the three most important things anglers could do to most constructively and effectively assist the Environment Agency in it’s work? Other than of course to buy an Environment Agency licence which anglers must all do to fish legally. Anglers spend a lot of time by the waterside and have a major role in being the ‘eyes and ears’ on the ground. Reporting incidents in a timely manner and giving as much information as possible helps our teams make the right decisions in how to respond. Enforcement is an important activity. Gathering intelligence and targeting our resources to deal with the serious illegal movements of fish or illegal fish removals is a priority for us. Anglers can therefore help us build this intelligence so can take action in the right places. Finally, getting involved in local initiatives with clubs or river trusts that improve the river environment and fish stocks would be useful contribution to our work. _____________________________________________________________________________________________ A growing number of anglers now believe that we urgently need a separate organisation who’s clear focus and priority is the environment and not one which is so unfairly stretched and blighted by budget cuts and micro-management. In the view of many today the Agency has sadly become mainly a flood defence crisis task force. Quite inevitably, when under such unremitting pressure and with well recognised climate change events to come, (summer deluge etc.) the existing Agency model simply cannot give our riverine habitat the resources, the consideration, the priority and confident future we as anglers who cherish our lakes, lochs, rivers, canals etc. expect of it. Question 6 We anglers now recognise this unavoidable conclusion. Is it not now time you did too and looked favourably upon the formation of a completely separate body similar to the American model with clear and focussed habitat and species prioritisation? This situation has become more pertinent this week given that a Government internal study and DEFRA findings warn that hundreds of key installations of national infrastructural importance (water and power utilities etc) are now at the ‘highest level of criticality’ re potential and imminent flood events with even crisis control centres at real risk of being overwhelmed. The Government now places flood risk on an equal level with terrorism! It is clear that the present Agency will be increasingly preoccupied to the inevitable detriment of eco-considerations for years to come. The Governments independent Fisheries Legislative Review examined the question of how fisheries should be administered in England and Wales and concluded that the Environment Agency was the most appropriate body to take this forward. We seek to work closely with other interested parties in improving fisheries which is why we signed a framework agreement in 2006 with the Association of Rivers Trusts, and why we work in partnership with many other bodies to deliver initiatives such as National Fishing Week. We welcome the current initiative by the main angling bodies to come together to form a unified body for anglers. There has been too much fragmentation in the efforts of angling bodies and we know that this single organisation will keep us on our toes but also be a stronger partner to work with._____________________________________________________________________________________________ Question 7 Could you please detail definitively exactly how and upon what rod licence revenue is spent? If the Agency does relinquish it’s water quality policing role, my sincere and genuine fear is that many anglers, unhappy already at what they consider scant protection and action against polluters will object to paying for a rod licence at all. If our rivers suffer as predicted following deregulation it would be very difficult to criticise them. The very last thing we need is for a further wedge of discontent to be driven unnecessarily between anglers and the Agency. Both now more than ever need the confidence, respect and support of the other to prevail. The services we delivered in 2007/8 included:
_____________________________________________________________________________________________ Risking once again inevitable accusations of xenophobia, the utterly unacceptable fish stealing crisis perpetuated by an element of a now estimated 1,500,000 recent immigrant influx is not going away. Question 8 When exactly will policy be sensibly rationalised nationally to address at last the ludicrous regional confusion relating to just how many fish can be taken from our waters? (Most decent coarse anglers would say none) This crazy situation continues to sustain and give succour to this unacceptable rape of our national fish stock. The admirable and impressive patience of the ordinary angler in the face of this assault on our long practiced sport angling culture is being tested to breaking point. Would you please act with utmost haste to avoid an inevitable and understandable backlash which would be disastrous for all? When we receive new legislative powers through the Marine Bill we will have clarity on legislation and we will be able to begin consultation on the limits for removal of coarse fish. The Governments current intention is to bring forward the Bill to parliament in 2009. _____________________________________________________________________________________________ Given that we continue to retain less than 10% of this country’s available annual rainfall, surely it is now time that a simple engineering solution was adopted to harness this precious freefalling resource for the ecological survival and sustainability of our rivers. Southern chalk streams especially were at a completely avoidable state of near total failure only 18 months ago, and were only fortuitously rescued by sheer providence and a period of unprecedented summer deluge last year. With just a little foresight our rivers should long ago have been engineered to flow high and healthily with our reservoirs constantly replenished even during drought conditions. Question 9 Will the Environment Agency now urgently look to investigating and then adopting long overdue simple solutions by which this rain rich country can capture and retain sufficient yearly rainfall to adequately and consistently sustain both our reservoirs and aquifers for public supply purposes and our rivers for our precious indigenous fish, birds, plants, bats, insects, fungi etc etc? The water environment is already under pressure from development, and climate change will make these pressures worse. It is likely to affect demands, environmental requirements and resource availability. We are identifying a series of actions that we believe are necessary now, over the coming decades and beyond, and are developing the next water resources strategy for England and Wales. We plan to publish it at the end of the year. The strategy will show that it is increasingly necessary to strengthen water supplies and significantly improve the efficiency of water resources. _____________________________________________________________________________________________ Question 10 What plans do you have to maintain and increase access and facilities for the disabled angler? And what plans do you have to encourage the young to take up angling as a healthy viable pastime for mind and body? In 2007-08, £393,000 of Environment Agency funding was provided to 37 projects involving improved access. Together with partner contributions of £665,000 this resulted in a total spend of £1.058 million. We collaborated with the British Disabled Angling Association to produce comprehensive "Access Guidelines for Fisheries" on how to improve access for disabled anglers. This provides a reference point for all fishery owners on the design and issues of improving access for all. In 2008-09, subject to achieving licence sales targets, an additional £300,000 has been allocated to improving access, giving a projected spend of £600,000. The new work includes a joint programme with representatives of Disabled Angling groups of over 100 projects to identify where access can be improved for disabled anglers in particular. There will be additional access improvements projects delivered on the ground with fishery owners. Since 2006, the Environment Agency has produced free Angling Guides in paper and internet format. This provides information on the location of publicly accessible fisheries and whether these cater for disabled anglers. We continue to be a key sponsor in National Fishing Week and work with partners to provide opportunities to over 30,000 youngsters to try angling. _____________________________________________________________________________________________ DAVID KING DIRECTOR OF WATER MANAGEMENT |