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Author: Molly Allen

Natural Resources Wales Must Prevent Pollution – Not Pass the Buck as the Wye and Severn Decline

Posted on by Molly Allen
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By Emma Dearnaley, River Action’s Head of Legal

Across Wales, rivers that should be a source of pride – places for connection, wildlife and local identity – are in visible decline. 

In recent years, much of the public debate has focused on sewage discharges, storm overflows and Victorian infrastructure doing 21st-century damage. That remains an important focus. But if we are serious about restoring our rivers, another very significant source of pollution must be understood and addressed with an equivalent amount of resolve: nutrient pollution linked to intensive livestock production and, in Wales especially, the waste generated by industrial-scale poultry units. 

This is not about farmers trying to do the right thing in challenging circumstances. It is about whether the regulatory system governing intensive agricultural operations is working as Parliament intended and whether regulators are using the powers they have to prevent harm before it occurs. 

Pollution from intensive poultry production does not usually appear as a dramatic brown slick after heavy rain. Instead, it spreads more quietly. Vast quantities of chicken manure, rich in phosphorus and nitrogen, are being spread on land or exported and spread on other land that in some catchments is already saturated with nutrients. From there, rainfall can wash those excess nutrients into nearby streams and rivers, fuelling algal blooms that choke oxygen from the water, damage wildlife and smother riverbeds. By the time the ecological harm becomes visible, the pollution has already taken hold. 

‘Diffuse’ agricultural pollution comes from widespread activities across a catchment, making it harder to pinpoint and regulate than obvious point-source pollution such as a sewage discharge or a chemical spill. But complexity is not an excuse for inaction: it requires coordinated, consistent, catchment-wide management, not regulatory blind spots. 

That is why River Action has launched a judicial review challenging Natural Resources Wales (NRW)’s decision to approve permit variations allowing three intensive poultry units in Powys to expand. The issue is not whether intensive poultry farming should exist. It is whether Wales’ environmental regulator is properly doing its job by using the legal powers it has to prevent pollution linked to those operations. 

In approving the permit variations, NRW proceeded on the basis that it had no legal power under the Environmental Permitting Regulations 2016 to regulate manure once it leaves the boundary of a permitted poultry unit. On that view, the environmental impacts of manure exported off-site fall outside the permitting regime and are instead matters for the planning system, but without NRW first being satisfied that effective and enforceable pollution controls would in fact be secured elsewhere.

In effect, NRW treated the boundary of the site as the boundary of its regulatory responsibility. Rivers, inconveniently, do not respect such lines.

Manure from intensive poultry farming is a major source of nutrient pollution affecting Welsh rivers, including the Wye and the Severn. This is not theoretical harm. Both rivers are already under severe ecological pressure from excess nutrients, causing declining water quality and damaged habitats.

Environmental permitting exists precisely to prevent unacceptable pollution before it happens. Parliament entrusted NRW, as Wales’ environmental regulator, with assessing whether permitted activities are likely to cause pollution and with imposing conditions to control and stop it. River Action’s case argues that NRW has taken an extraordinarily narrow view of its own powers and misdirected itself in law by excluding the potential off-site impacts of manure from its permitting decisions on the basis it has no legal power to address them. We say that approach is unlawful. The Environmental Permitting Regulations do not stop at the farm gate. If waste arises from a permitted activity and is likely to cause pollution wherever it ends up, NRW as the regulator must assess and, wherever necessary, control those impacts. That is both logical and, we say, what the law requires. Recent court judgments do not say otherwise, despite NRW’s insistence that its hands are tied.

What makes this more troubling is that NRW’s counterpart in England, the Environment Agency, accepts that it must consider and prevent water pollution through the permitting process including impacts that may occur beyond the site boundary. There is no rational basis for Wales’ regulator to do less, especially when making decisions in sensitive and protected catchments on the Welsh border. Environmental protection should not weaken when you cross Offa’s Dyke.

If NRW’s position is allowed to stand, the consequences extend far beyond these three poultry units in Powys. It risks creating a significant regulatory gap, allowing industrial-scale agricultural operations to expand in vulnerable catchments without effective oversight of one of their most environmentally damaging consequences.

This case is not about attributing blame after the damage is done. It is about prevention. Once excess nutrients enter a river system, they are extremely difficult and costly to remove. Rivers such as the Wye cannot be restored while pollution continues upstream without effective regulatory control. 

NRW exists to prevent environmental harm, not to assume that someone else will deal with it. Passing the buck to the planning system on a mistaken understanding of legal powers, without securing robust safeguards elsewhere, won’t wash.  

Wales rightly aspires to environmental leadership. It has strong and progressive environmental frameworks and internationally important rivers. But laws only matter if they are used and followed. 

River Action’s case asks the court to clarify a simple and fundamental point: to confirm that environmental regulation in Wales means what it says, NRW’s interpretation of its powers was wrong, and that pollution prevention does not end at a conveniently drawn boundary line. Our rivers cannot afford another lost decade of buck-passing. If we are serious about protecting and restoring them, we must ensure that those tasked with safeguarding them are equipped – and required – to use their powers in full.

River Action launches legal challenge, accusing NRW of “washing its hands” of intensive poultry pollution

Posted on by Molly Allen
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We have launched a judicial review challenging Natural Resources Wales (NRW)’ approval of three expanded poultry farms in Powys, accusing the regulator of “washing its hands” of manure pollution by taking an unlawfully narrow view of its powers.

The case focuses on whether NRW is properly using its role as environmental regulator to prevent pollution from intensive farming or whether responsibility is being passed to others while Welsh river catchments such as the Wye and the Severn continue to deteriorate. 

The legal challenge follows NRW’s decision in November 2025 to approve permit variations allowing three intensive poultry units to expand in Powys. In doing so, NRW proceeded on the basis that the environmental impacts of manure once it leaves the farm boundary fall outside permitting and should instead be addressed through the planning system, without first being satisfied that effective and enforceable pollution controls would actually be put in place elsewhere.  

We say NRW’s approach is a serious misunderstanding of the law, and that NRW misdirected itself by proceeding on the basis that it had no power under the Environmental Permitting Regulations 2016 to assess or regulate the off-site environmental impacts of manure, and so excluded those impacts from its permitting decisions altogether. We also say NRW has misinterpreted recent court judgments – including Squire v Shropshire Council, NFU v Herefordshire Council and Caffyn v Shropshire Council – to justify its position.  

We argue that, properly understood, the law requires NRW to assess and prevent potential pollution impacts that could arise if manure is exported off-site – rather than ruling them out or passing the buck. 

This case matters because environmental permitting is meant to prevent unacceptable pollution before it happens, and Parliament specifically entrusted NRW as Wales’ environmental regulator with making those decisions, rather than deferring responsibility on a mistaken understanding of its powers or assumptions about future planning controls. 

NRW’s sister regulator in England, the Environment Agency, accepts its responsibility for preventing and controlling potential water pollution through the permitting process. We believe there is “no rational basis” for NRW taking a narrower approach in Wales and not taking responsibility. 

If left unchallenged, NRW’s approach could create a significant regulatory gap. This could allow intensive poultry units, and potentially other industrial-scale agricultural operations, to expand without effective control of one of their most environmentally damaging consequences, even in protected and sensitive river catchments such as the Wye and Severn. 

“Pollution from intensive poultry farming doesn’t stop at the farm boundary, and regulation can’t lawfully stop there either,” said River Action’s Head of Legal, Emma Dearnaley. “NRW has treated the boundary of the installation as the boundary of its regulatory responsibility, even though the environmental harm caused by excess manure occurs well beyond that line.”

Manure from intensive poultry farming is a major source of nutrient pollution in Welsh rivers, contributing to algal blooms, declining water quality and ecological damage in catchments including the Wye and the Severn. River Action says that environmental permitting is a vital tool to prevent this harm, particularly where planning controls are absent, delayed or ineffective. 

“NRW exists to prevent pollution, not to pass responsibility elsewhere,” Emma Dearnaley added. “If the regulator assumes someone else will deal with manure pollution without securing meaningful safeguards, rivers like the Wye and the Severn will continue to decline.”

After months of objections, correspondence and pre-action engagement, We are asking the court to declare that NRW’s interpretation of its powers was wrong, make clear NRW must lawfully assess and regulate manure-related impacts through environmental permitting where they are a consequence of the permitted activity, and quash the three Powys permit decisions. 

The case is about ensuring environmental regulation works as Parliament intended, preventing pollution before harm occurs rather than wrongly passing responsibility to others or reacting after damage has already been done to our rivers.

Leigh Day solicitor Julia Eriksen said, “NRW’s decision to vary existing environmental permits on three intensive poultry farms will enable thousands more chickens to be housed and produce significantly more manure. River Action argues that it is NRW’s job to guard against any resulting pollution impacts.

“River Action has already secured a court ruling that rules around agricultural pollution should be properly enforced, and hopes this claim for judicial review will make it clearer still what responsibilities NRW has in this area.”

Our Pre-Action Protocol letter to NRW can be read here. NRW’s response is here. 

You can read our Statement of Facts and Grounds in full here.

Red Tractor Misleads On Environmental Claims

Posted on by Molly Allen
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By Amy Fairman, Head of Campaigns at River Action UK

Britain’s rivers are in terrible shape, and our biggest supermarkets are up to their necks in it. For years, retailers like Tesco and Asda alongside their agribusiness suppliers have relied on the cosy logo of Red Tractor, telling customers their food is “farmed with care… from field to store all our standards are met”. In late 2025, the Advertising Standards Authority (ASA) called time on this charade.

The regulator has ruled that Red Tractor, the UK’s largest farm assurance scheme, misled the public by suggesting its logo guarantees environmental protection. It doesn’t. The most recent Environment Agency data shows a staggering 19,000 breaches across 60% of inspected Red Tractor–certified farms between January 2020 and July 2025, exposing a systemic failure behind the label’s “environmentally friendly” claims.

This isn’t a marginal issue. It goes to the heart of how our food system operates, and how some of the biggest companies in Britain shield themselves from responsibility while rivers and lakes collapse under a deluge of pollution caused by intensive agricultural practices.

Take Tesco. Controlling nearly 30% of the supermarket sector, it is the single most powerful buyer of British farm produce. Its chicken and pork supply chains run through industrial-scale operators like Avara Foods and Moy Park. These are not quaint family farms but subsidiaries of US agribusiness giants Cargill and Pilgrim’s Pride. These companies have been linked to ecological crises such as the collapse of the River Wye and the ongoing algal disaster in Lough Neagh, the UK’s largest freshwater lake.

At a recent Sustainable Food Conference in London, River Action’s Head of Engagement asked Tesco CEO Ken Murphy why the company continued to stock Red Tractor products after the ASA upheld a greenwashing complaint against the scheme. His response was: “That’s an issue for Red Tractor.”

For years, supermarkets have pointed to the Red Tractor logo as their environmental shield. But that line has now been shredded. In a landmark ruling, the UK’s ASA concluded that Red Tractor’s environmental claims were misleading, finding that the advertising exaggerated the scheme’s standards and misled consumers. This is no longer just campaigners or scientists raising the alarm; it is an independent regulator confirming that the reassurance offered by the logo does not stack up. Any retailer still presenting Red Tractor as a marker of good environmental outcomes is not reassuring customers, but risking greenwash.

The data underpinning the ruling is stark. Between January 2020 and July 2025, 7,353 Environment Agency inspections of Red Tractor–certified farms found 4,353 breaches, meaning nearly 60% of farms failed to meet environmental rules. These were not trivial lapses.  Inspectors recorded 19,305 instances of non-compliance, including thousands of breaches intended to stop slurry and fertiliser entering rivers – pollution that fuels algal blooms, kills fish, damages ecosystems, and contaminates drinking water.

This is not just a story about dirty rivers. It is about a food system where the biggest players, multinational agribusinesses and the retailers who buy from them, use weak, industry-controlled assurance schemes to insulate themselves from scrutiny. Red Tractor is not a neutral standard-setter. It is designed by the very interests it is supposed to regulate. And guess who controls it? The majority of seats on Red Tractor’s governing council are held by the UK’s various National Farming Union bodies. Yes, the farming lobby actually controls its own product quality scheme.

Red Tractor’s defenders will say that criticising the scheme means attacking farmers. Let’s be clear, it does not. Many farmers care deeply about the land and waterways that sustain them and us all. They are being undercut by a system that rewards scale, intensification and cutting corners, while paying lip service to environmental protection.

As Martin Lines, CEO of the Nature Friendly Farming Network, has put it: “Consumers and farmers want real sustainability, not a sticker.”

Farmers who are genuinely improving soils, protecting rivers and reducing chemicals see little reward for their efforts. Supermarkets cannot claim ignorance. They have been told repeatedly about the links between their suppliers and river pollution. The Environment Agency rejected Red Tractor’s bid for “Earned Recognitions” precisely because it fails to meet good environmental standards. Yet retailers still rely on the logo as their shield.

This complicity matters because of their sheer market power. When supermarkets demand Red Tractor chicken, vast supply chains, from feed mills to slaughterhouses to contract farmers, are locked into a destructive model. This legitimises the industrial systems polluting our rivers. And when consumers challenge them, they point to the little tractor logo, as if that settles the matter.

The ASA ruling proves it doesn’t.

We now face a choice. Tesco, Asda, Aldi, Lidl, Morrisons and others can continue to sell food tainted with pollution, hiding behind a logo that regulators have called out as misleading on environmental performance. Or they can do the honest thing: demand genuinely high environmental standards from suppliers, pay farmers properly for producing food in ways that don’t wreck our rivers, and support the farming community’s transition to nature friendly farming.

This isn’t just about protecting wildlife or river users such as this nation’s army of wild swimmers. Though that should be enough. It is also about restoring trust in our food system. Consumers deserve to know that when they buy British, they are supporting farming that safeguards our countryside, not destroy it. Farmers deserve a level playing field that rewards those who do right by the land. And companies that profit from selling us food have a duty to ensure their supply chains comply with legal standards, both under the law and broader social responsibility.

For too long, Red Tractor has allowed agribusiness and retail giants to dodge that duty. Thanks to the ASA, the greenwash is now exposed. The question is whether the supermarket giants will finally face up to reality, or whether they will cling to a broken system until public trust collapses.

Britain’s rivers cannot wait. Neither can the farmers who are trying to do the right thing. The time for excuses is over. We hope that conversations like the one with Tesco’s CEO plant a seed and prompt supermarkets to take real responsibility for the food they choose to stock on their shelves.

Environmental and nature-friendly farming groups warn Government risk missing river clean-up targets without action on agricultural pollution

Posted on by Molly Allen
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Leading environmental and nature-friendly farming organisations, including River Action, Nature-Friendly Farming Network, The Rivers Trusts, Surfers Against Sewage, Wildlife and Countryside Link, WWF-UK, Wildfarmed, RSPB and the Soil Association, have written to the Secretary of State for Environment, Food and Rural Affairs calling for urgent government action to tackle agricultural water pollution.

The letter follows the launch by River Action in December 2025 of a dedicated Agricultural Water Pollution Strategy, warning that current efforts to clean up rivers risk falling short by focusing too narrowly on sewage while neglecting a major source of pollution. 

The Strategy identifies excess nutrients from large-scale livestock systems and contaminants from sewage sludge as two leading sources of agricultural water pollution. Both nutrients and sludge are used as fertilisers, yet are not often valued as they should. Sewage sludge in particular holds great risks because of toxic chemicals, plastics and pharmaceuticals, including ‘forever chemicals’, which risks further contaminating soils and rivers after being spread on farmland.

Agriculture is now recognised as a significant source of water pollution as sewage, yet it has not received the same political focus, regulatory attention or investment. Without decisive action, the Government will fail to meet its pledge to clean up rivers, particularly when the recently published Water White Paper dedicated only one page to agricultural water pollution, reinforcing its treatment as secondary to sewage.

The signatories welcome Defra’s revised Environmental Improvement Plan and its new targets to reduce agricultural pollution. However, they warn that these targets are unrealistic without significantly stronger action and are likely to be missed on current progress.

The Government’s own regulator supports these concerns. The Office for Environmental Protection has warned that slow progress on agricultural water pollution is undermining overall efforts to improve the water environment.

While recent attempts to reform agricultural pollution rules, including greater engagement between Defra, farmers and environmental groups, are encouraging, they do not yet go far enough to deliver change at the scale required. Farmers need stable, long-term support and clear direction, not short-term schemes or piecemeal reforms, to reduce pollution while continuing to produce food.

River Action’s policy and advocacy manager Ellie Roxburgh said, “The government cannot credibly claim it is cleaning up rivers while continuing to sidestep a major source of pollution flowing into them. Agricultural pollution does as much damage to our rivers as sewage, yet it remains under-regulated, under-resourced and politically neglected. 

“We welcome the Government’s consultation on sewage sludge. It must lead to strong updated regulation with meaningful action that goes beyond end-of-pipe solutions, stopping water companies from selling contaminated sludge to farmers and with all polluters across the supply chain held responsible.”

“We also welcome the Government’s new forever chemical plan, but it lacks the level of ambition needed, relying too heavily on monitoring and voluntary action rather than firm regulation and enforcement.”

In response, River Action’s Agricultural Water Pollution Strategy sets out measures it says are essential if government is serious about cleaning up rivers:

  1. Proper and consistent enforcement of anti-pollution regulations, ending reliance on under-resourced, reactive compliance.
  2. A well-resourced and properly trained Environment Agency, with the capacity to monitor, inspect and enforce agricultural pollution rules.
  3. Appropriate funding and updated planning guidance for slurry infrastructure, to prevent pollution from storage and land application.
  4. Mandatory Sustainable Nutrient Management Plans, overseen by a Defra-led taskforce to ensure accountability and coordination.
  5. Lower thresholds for Environmental Permitting Regulations, extending tighter controls to beef and dairy operations currently outside the regime.
  6. A transition to catchment-based nutrient management, using regional water authorities to manage pollution at river-basin scale.
  7. An end to toxic sewage sludge contaminating farmland, including stronger controls on contaminants such as PFAS and microplastics.

 

Richard Benwell, chief executive of Wildlife and Countryside Link, said the breadth of support behind the letter showed the urgency of the issue. “If ministers are serious about meeting their nature and water quality commitments, tackling agricultural pollution must now be a top priority, not an afterthought.”

This year presents a rare policy window. Major strategies and legislation covering land use, farming incentives, food policy, circular economy measures and water reform give the Government the opportunity to act decisively if they are aligned and used boldly.

The environmental sector is united in calling for urgent, coordinated action and stands ready to support solutions that enable food production without harming rivers.

The message to ministers is clear: delivery, not delay. The credibility of the Government’s commitment to clean up rivers is now at stake.

 

Notes to editors

The letter to the Secretary of State for Environment, Food and Rural Affairs was signed by a cross-party group of parliamentarians, environmental organisations, farming networks, legal experts and civil society groups, reflecting broad concern about the impact of agricultural pollution on rivers.

Signatories include senior figures from leading environmental organisations, including River Action, Wildlife and Countryside Link, WWF-UK, RSPB, Surfers Against Sewage, The Rivers Trust, the Soil Association and the Nature Friendly Farming Network, alongside representatives from farming, research, legal and community groups.

Political signatories span parties and chambers, including MPs from Labour, Liberal Democrat and Green parties, as well as members of the House of Lords.

The full list of signatories is as follows:

James Wallace (CEO, River Action UK)
Terry Jermy MP (South West Norfolk, Labour)
Roz Savage MP (South Cotswold, Liberal Democrat)
Ellie Chowns MP (North Herefordshire, Green)
Adrian Ramsay MP (Waveney Valley, Green)
Siân Berry MP (Brighton Pavilion, Green)
Carla Denyer MP (Bristol Central, Green)
Lord Randall of Uxbridge
Baroness Jones of Moulsecoomb
Helen Browning (CEO, Soil Association)
Richard Benwell (CEO, Wildlife and Countryside Link)
Catherine Gunby (Executive Director, Fidra)
Gavin Crowden (Director of Advocacy, WWF-UK)
The Duchy of Cornwall
David Wolfe KC (Matrix Chambers)
Alison Caffyn (Rural Researcher)
Alastair Chisholm (Director of Policy, CIWEM)
Martin Lines (CEO, Nature Friendly Farming Network)
Rebecca Wrigley (CEO, Rewilding Britain)
Ellen Fay (Founder, Sustainable Soil Alliance)
Kevin Austin (Director of Policy and Advocacy, RSPB)
Giles Bristow (CEO, Surfers Against Sewage)
Georgia Elliott-Smith (Founder, Fighting Dirty)
Mark Lloyd (CEO, The Rivers Trust)
Natasha Hurley (Deputy Director, Foodrise)
Dee Edwards (Chair, Communities Against River Pollution)
Rob Bray (Chief People and Sustainability Officer, Wildfarmed)

The letter was sent to Rt Hon Emma Reynolds MP, Secretary of State for Environment, Food and Rural Affairs. A copy of the letter is available here. 

The “Make a Nuisance” Campaign: Using the Law to Speak Up for Our Rivers

Posted on by Molly Allen
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By Chloe Peck, Senior Engagement Coordinator at River Action

 

When River speaks, what does River say?

When River is harmed, how does a body of water make its cries heard?

And when we step in to speak for River, through our human legal systems, whose voice do we really use?

At River Action, we recently helped amplify a cry for the river through the launch of the ‘Make A Nuisance’ campaign.  The campaign creates a way to speak through the law. Working alongside Friends of the Thames and 15 people from 13 different areas across the Thames catchment, we supported local residents to submit Statutory Nuisance complaints about Thames Water to their local authority. The aim of the campaign is to create a collective noise, which further holds Thames Water to account by enabling community members to take direct action using a powerful legal tool. 

Statutory nuisance law is a long standing area of UK law which requires local councils to investigate harms from pollution or noise. If the pollution is found to be causing a problem, the council enforces the polluter, Thames Water, to seize and desist the action, sewage pollution, through Abatement Notices.

In order to ensure the letters were rooted in real life experiences of pollution, the participants were responsible for gathering stories and data to evidence their complaints. This included photos of sewage smears on rowing boats, data from nutrient and pathogen tests, and testimonies from local people who had become sick from swimming. This was complimented by compelling evidence on failing sewage treatment works gathered by River Action’s Campaigns Analyst  Dr Samir Seddougui. Their letters were accompanied by an attachment outlining the relevant legal procedures, prepared by our Head of Legal, Emma Dearnaley, alongside lawyers from Leigh Day. 

Using statutory nuisance as a campaigning tool is powerful, as it uses the law to allow local people to have their voice heard. This is useful where previously the community’s lived experience of the sewage crisis has been dismissed and sidelined. The campaign challenges this by forcing responsibility back into a system where regulation repeatedly stalls and accountability slips. The process creates formal records, duties, and pressure. It is slow, procedural, and intentional — not a protest stunt – however, it has the potential to make substantial change.

Statutory nuisance as a form of protest offers a unique way to demand action, however, when used to speak for nature, we must consider its limits. Statutory nuisance is unapologetically human-centred. The law exists to protect residents from activities that interfere with their health, comfort, or enjoyment of their home or local environment, and it places a duty on local councils to investigate and act when such interference occurs. It fundamentally is concerned with human’s experience of the environment, not the environment’s own experience. The river has no legal standing without humans.

This is not to say this is the perception across the world. The Whanganui river is often cited in nature writing as an example of a river with legal personhood. The river was granted personhood in 2017 after 140 years of negotiations fought by the Māori group of Whanganui, who consider the river as their ancestor. With personhood status, if the Whanganui river is harmed, the law recognises this as a harm to the Maori group. The group and the river are one connected being. In the UK, we do not have the same recognitions in place; in legal standing what harms nature does not harm us. Lawfully, we are not one and the same with the world around us.

Despite these legal limitations, the people who wrote nuisance complaints are deeply connected to the Thames and its tributaries. They are rowers, swimmers, house boat dwellers, kayakers, and citizen scientists. They rely on the river for community, exercise, business, as well as spiritual and mental wellbeing. And despite its limitations, the campaign is genuinely exciting, as a community-led action, with people taking initiative to use law as something real; not a distant inaccessible tool, but something that propels momentum and possibility for change. 

This connection is reflected in the experience of campaigner Blake Ludwig, who took part in the Make A Nuisance campaign on the River Kennet:

“We have to see that water isn’t simply a dead material for us to use at our leisure, or as a waste receptacle… Through collecting evidence and building a nuisance complaint, I’ve come to understand how invisible pollution can be — and how only long-term relationship, observation and care allow us to really see what’s happening to our rivers.”

What the system of nuisance complaints tells us is that we live in a climate which recognises people and nature as separate. We have not retained the historic kinship between human and nature which the Maori people have. In our social system a person is legible through documents, numbers, and certificates. Personhood is administrative. Within this system, the river’s voice is only heard when it passes through us. So we therefore have a duty to nature to ensure that nature’s voice is heard.

And how do we do that authentically? By knowing a river as we might know a family member, and caring for it as we would a friend. And all the while recognising that a river is not human at all. A river is a living system with its own rhythms, flow, and resilience, deserving of respect not because it resembles us, but because it exists in its own right.

When I talk about sewage pollution, I am often asked by wild swimmers if they should stop their beloved sport. The answer is no. Not because the dangers aren’t present, they are, but because connection matters. By spending time and interacting with the river, we are able to create a deep and intimate relationship with the river. 

The power of the Make a Nuisance campaign has come from people who live entwined, not separate, from the river. So the work, for now, is slow, careful and continuous. Keep swimming, keep connecting, keep being with the river. Speak to the river, and the river may well speak through you.

The Government’s Water White Paper: The Good, the Bad and the Ugly

Posted on by Molly Allen
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Written by Ellie Roxburgh, Policy and Advocacy Manager at River Action

This Government’s focus on reforming the water sector is welcome and timely. Recent failings by South East Water and Thames Water have demonstrated that water companies are defective on multiple fronts. The public is mobilised for change and the Government must go further than minor tweaks to the status quo. The current model of profit-driven privatisation has failed, evidenced by the polluted state of our rivers, exploitative ownership models and inadequate regulatory oversight in the water sector. The water pollution caused by agricultural practices, industrial waste and road run-off must also be urgently recognised and addressed. 

The time for change is now. We need a government that is bold in ambition and willing to implement reforms fast enough to deliver the measurable improvements needed to fulfil its election promise to clean up our rivers, lakes and seas.

So, what is a White Paper?

A White Paper is a government document that precedes legislation. It sets out what to expect in the upcoming King’s Speech when the parliamentary agenda is laid down by the King. This White Paper focuses largely on the recommendations made by Sir Jon Cunliffe’s Review of the water sector in 2025. Below, we’ve set out the good, the bad and the ugly of the government’s plans for water reform.

The Good

Tough, independent regulators: For too long, water companies have gotten away unscathed with polluting our rivers. Today’s announcements put some strength into the regulator, including no-notice powers for the regulator to check security and emergency preparedness, Performance Improvement Regimes for failing water companies, and a Chief Engineer to monitor infrastructure.

The government announced a consolidation of water industry regulators into one entity, with oversight of all sectors impacting the water environment. This new regulator will have public health and environmental protection as a key objective, alongside affordable bills, financial resilience of the water sector, and robust oversight of water companies’ infrastructure. This regulator must have enough teeth to hold water companies to account with penalties that stop them polluting. We need a regulatory system that enforces the law and, to do that it must be well-financed.

Democratic decision-making: The government has committed to introducing a regional water planning function by bringing together councils, water companies, farmers and developers, with double the funding for catchment partnerships. The cross-sectoral and target-driven characteristics of the new regional water planning function are welcome. However, while it is important that these actors have a seat at the table, there needs to be an independent authority that makes decisions based on the environmental health of the catchment and the public health of customers.

These authorities need to sit above water companies and other self-interested actors. They need powers to influence local planning authorities decisions over industrial planning applications and permit decisions, based on the ecological health of the river and surrounding habitats. Regional oversight should support a tiered approach to action on water pollution, whereby the most affected areas are prioritised as the focus of rapid action and enforcement (including Scientific Sites of Scientific Interest and chalk streams). This would enable the Secretary of State to enact Water Protection Zones and a potential moratorium on industrial livestock units in areas, such as the River Wye, that are experiencing significant nutrient loading from industrial agriculture.

A long-term water strategy: We are pleased to see the Government taking a long-term view of improving the water sector. However, decisions at local and regional levels must align with and enable the delivery of a national strategy for planning, financing, governing and regulating sewage treatment, water quality and supply to ensure a joined-up approach to securing water and clean rivers, lakes and seas. Measures and targets should be put in place to deliver on commitments within the Environmental Improvement Plan and Water Framework Directive across sectors and regions, to require all actors to contribute towards achieving national targets.

Abolition of self-monitoring: The government has committed to abolishing the self-monitoring of water companies. The White Paper has set out plans for the new regulator to have a Chief Engineer to monitor infrastructure, and for water companies to proactively report on infrastructure conditions. The test will be how regularly the regulators independently test the infrastructural quality and environmental impacts of water company operations.

The Bad

Limited scope on sewage sludge: While we welcome the Government’s commitment to consult on reforms on how sewage sludge use in agriculture is regulated and whether sludge should be included in the Environmental Permitting Regulations, meaningful action is needed that goes beyond end-of-pipe solutions. The Government should investigate whether legislation is needed to stop water companies from selling contaminated sludge to farmers, and as recommended by the Independent Water Commission, the Government must consider Extended Producer Responsibility for all of the contaminant producers across the supply chain.

Nothing new on agricultural water pollution: Agricultural water pollution is on a similar scale to water company pollution and the White Paper recognises this, estimating around 40% of river and groundwater pollution is due to agricultural practices. Yet agriculture has not had equivalent dedicated resources to identify and implement solutions to reduce environmental harm as the water sector. Consolidating agricultural water regulations is welcome, but we also need to see more funding for regulators, greater support for farmers to implement much-needed infrastructure, and a planning system that is empowered to decide when catchments have enough industrial farms. It is critical that environmental permitting is extended to industrial cattle and moves to do this must be swift.

The Ugly

Essential requirements instead of incentives: Today’s announcements start to embed public health and environmental protection in the water system with targets and objectives. Reform of the incentive framework to reward companies for delivering outcomes like public health, the environment and long-term resilience means these outcomes will continue to be seen as optional when they should be essential requirements of operating. 

Continued prioritisation of private interests: Regulation alone cannot fix a deeply privatised system that is designed to put profit first. The White Paper recognises some owners have prioritised “short-term profits over long-term resilience and the environment”. That is exactly why the ownership model must change. However, the White Paper still treats the profit-driven model as the default and focuses on constraining its worst excesses. The approach to ownership change is optional and company-led, which means it is very unlikely to happen. Most critically, the White Paper makes no commitment to a thorough, evidence-led review of alternative ownership models. We want to see a clear move toward public benefit models for water companies, not a slightly better managed private monopoly. A public benefit model would mean that water companies have legal duties to put public health and the environment first, profits and shareholder dividends are secondary, and short-term extraction is ruled out.

And what if water companies continue to fail financial and legal obligations?

New legal powers may be valuable, but the Government and regulator must use the extensive and powerful ones they already have. Performance Improvement Regimes are a step in the right direction, but the Special Administrative Regime has existed under the Water Industry Act 1991 for decades and must now be used by the Government and regulator. When a water company fails to meet its financial or legal obligations, as is unfortunately the case with more than one water company and with Thames Water being the clearest case for such an intervention. The commitment in the White Paper for water companies to establish plans for special administration is welcome, but transparency on when the regime will be triggered by the regulator and the Environment Secretary remains lacking.

Reforming the water environment requires bold and urgent action. We need to see the Government follow through on its reforms with greater ambition.

Government White Paper on Water Reform Falls Short of Real Reform

Posted on by Molly Allen
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Today, the government has released its long-awaited Water White Paper. This White Paper sets out the Government’s response to the recommendations made by Sir Jon Cunliffe’s Review of the water sector in 2025. Although there are some welcome steps, it falls short of the ambition and enforcement needed to Rescue Britain’s Rivers.

CEO of River Action, James Wallace said:

“The publication of the Water White Paper signals the Government recognises the scale of the freshwater emergency, but lacks the urgency and bold reform to tackle it. 

“Proposals for a new water regulator, including the appointment of a Chief Engineer, alongside infrastructure ‘MOTs’ and no-notice inspections of water companies, are welcome steps, provided the regulator is truly independent, equipped with real powers and funded by The Treasury to hold polluters to account.

“However, major gaps remain. These reforms will fail unless the privatised model is confronted head-on. The crisis is the result of a system that prioritises short-term profits and shareholder payouts over people, rivers, and public health. 

“Special Administration must be the clear route to a public benefit model for water. It is the mechanism by which failing water companies can be taken out of extractive ownership and restructured so that investment serves customers and the environment, not short-term results. This requires clear, published triggers for Special Administration and a firm commitment to reform ownership and finance so that profits are secondary, long-term, and conditional on strong environmental performance and public benefit.

“We are also concerned about the emphasis on smart meters, which risks placing responsibility on households when water companies have failed for decades to invest in ageing, leaking infrastructure. Millions of litres of water are lost every day, and consumers should not be asked to pay for corporate underinvestment.

“Finally, while agricultural pollution is acknowledged, the proposals do not yet go far enough in ambition or enforcement needed to tackle this problem at source. The abomination of sewage sludge epitomises the challenge: farmers pay water companies for sludge to spread industrial ‘forever’ chemicals on the land that grows our food. The real test of these reforms will be whether they deliver a system that puts public and environmental protection ahead of corporate profiteering.”

As the government prepares its upcoming Water Reform Bill, we will continue to push for real, meaningful reform and press for tougher enforcement, stronger accountability, and a water system that works for people and nature — not lining the pockets of polluters.

Meet Christian Fuller, River Action’s new Legal Coordinator

Posted on by Molly Allen
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Q1. Tell us about yourself

Hi, I’m Christian, and I’ve recently joined River Action as Legal Coordinator.

I grew up in Conwy, where the Eryri National Park was a constant part of my life. Those early experiences shaped my relationship with nature: not something to dominate, but something we live alongside and have responsibilities towards.

Before joining River Action, I worked across environmental law, political monitoring, and campaigning, most recently at Greenpeace International in Amsterdam. Alongside this, I’ve been involved in political and environmental campaigning through SERA, Labour’s environment campaign. I’ve just moved back to the UK, and I’m really excited to be putting my skills to use protecting rivers and supporting the communities that depend on them.

Q2. What first sparked your interest in protecting rivers and freshwater ecosystems?

I am lucky to have spent a lot of time kayaking and swimming in rivers and lakes. As I got older, seeing those same rivers increasingly affected by pollution, sewage discharges, the climate crisis and ecological decline made the crisis feel both urgent and personal. Historically, geographically, and politically, rivers are meeting points in the British Isles. Rivers are the places where the climate and biodiversity crisis, corporate exploitation and weak enforcement meet, but they are also the space where we can come together to write something new.

Q3. You have just spent 6 months at Greenpeace International. Can you describe the work you did there, the campaigns you were involved with, and what you learned from that experience?

After completing a Masters in International Environmental Law at Utrecht University, I joined the Greenpeace International Legal Unit in Amsterdam for a six-month internship. What stayed with me most was seeing how powerful the law can be when it’s used alongside campaigning and political pressure. I supported strategic litigation across several campaigns: challenging unlawful deep-sea mining in areas beyond national jurisdiction; pursuing accountability for forced labour at sea in corporate supply chains; and using European law to resist a multi-million-dollar SLAPP suit brought by a US oil company against Greenpeace. I was also lucky enough to attend the International Court of Justice’s historic Advisory Opinion on Climate Change and to scope future climate litigation to build on 2025’s historic legal victories.

Q4. You serve as an executive committee member at the Socialist Environment and Resources Association (SERA). Could you tell us more about that role, what the organisation does, and how that experience shaped your approach to environmental advocacy?

SERA is Labour’s environment and climate organisation, working to strengthen ambition across the movement by connecting grassroots members, trade unions, NGOs and parliamentarians, and putting climate, nature and environmental justice at the centre of political power. As an executive committee member, I contribute to strategy, governance, fundraising and campaign development. I also founded and led Our Earth in 2050, a youth-led initiative amplifying young people’s voices within Labour’s environmental agenda – defining its purpose, securing resources, coordinating volunteers and building partnerships. This experience has shaped my approach to environmental advocacy by highlighting the importance of coalition-building, clear strategy, and political judgement – an approach I now bring to my work at River Action, where legal accountability, community mobilisation, and political engagement are combined to protect rivers and the communities that depend on them.

Q5. Looking ahead to your new role as River Action’s Legal Coordinator, what will you be focusing on, and what can people expect to see from you in 2026?

My role focuses on using the law as a lever for change. That includes supporting River Action’s strategic litigation, producing legal research and briefings, monitoring legal and policy developments, and working closely with colleagues and communities to ensure legal action feeds into wider campaigns.

A key part of the role is helping connect legal expertise with grassroots action – ensuring communities have the tools, information, and confidence to challenge pollution and hold decision-makers to account.

I’m particularly excited to contribute to legal strategies that are scalable and catalytic, such as catchment-based approaches that stops pollution at source, strengthens enforcement, and supports community-led action. There’s huge potential to use the law creatively and collaboratively, and I’m looking forward to helping develop that work.

Q6. Finally, in your opinion, what needs to change to rescue Britain’s rivers?

We need to move from a system that tolerates pollution and decline to one that actively prevents it. That means deliberate decision-making, stronger enforcement, real consequences for polluters, and communities having access to information, tools, and legal leverage. It also means recognising rivers as living systems that deserve protection in the public interest.

We have to shift legal and governance systems, move the markets, and empower communities. I’m excited to join River Action, whose approach, combining law, campaigning, and community action, gives me a lot of hope.

Construction Site Pollution: The Silent Threat Smothering Our Rivers

Posted on by Molly Allen
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By Simon Hunter, CEO – Bristol Avon Rivers Trust

A Hidden Crisis With Very Visible Harm

If you’ve ever stood beside a river and watched it flow clear and vibrant, you’ll know the feeling of peace and connection that our waterways bring. Now imagine that same river turned murky and lifeless, its gravel beds choked with silt, its life below the surface silenced. This is not a distant problem – it’s happening right here in the Bristol Avon catchment, and it’s largely preventable.

Pollution from construction sites might not make the headlines like oil spills or chemical disasters, but make no mistake: it’s a silent killer of river health. Every time heavy rainfall washes sediment, concrete washout, fuels, lubricants, and other contaminants off poorly managed sites and into watercourses, our rivers suffer.

This isn’t just about aesthetics. Fine sediment literally smothers river beds, filling the gaps between gravels that invertebrates and fish eggs need to survive. It alters channel shape, reduces habitat diversity, and disrupts the very processes that keep rivers healthy. What’s more, with climate change driving more intense storms, the volume of runoff and potential for damage is increasing.

One of several outfalls within 100m, discharging from construction sites in North West Bristol in November 2025.

Communities Give Everything – Only to See It Washed Away

Across the Bristol Avon catchment, community groups pour heart and soul into river restoration. They clear invasive plants, remove rubbish, monitor water quality, and plant trees to stabilise banks. But when sediment-laden runoff from nearby development buries the habitats, they’re working to improve, it’s not just disheartening – it’s counterproductive.

We’ve seen this again and again: volunteers offer thousands of hours of effort, only to have their work undermined by pollution that should have been prevented at source.

River restoration volunteers in the Bristol catchment

Houses, Infrastructure – Yes. But Not at Nature’s Expense

We agree that new homes, schools, roads, and other infrastructure are necessary. Growth and development are part of a thriving society. But it’s not a choice between development and healthy rivers – we can deliver both. With proper planning, investment in pollution control measures, and rigorous enforcement, it’s entirely possible to build responsibly while maintaining thriving freshwater ecosystems.

The point at which the Hazel Brook joins with the River Trym at Combe Dingle. Notice the colouration of the Hazel Brook – summer 2025. Credit: Trout in the Trym.

The Problem Isn’t Ignorance – It’s a Failure to Act

The tools and guidance to prevent pollution on construction sites already exist. Best practice measures like sediment traps, wheel wash stations, appropriate stockpile management, and controlled drainage are well understood. What’s missing is consistent implementation and enforcement. When developers cut corners, or when regulators fail to act decisively, it’s our rivers that pay the price – and that cost isn’t abstract. It shows up in lost biodiversity, diminished recreation opportunities, and weakened climate resilience.

Another outfall discharging from a construction site. Credit: Peter Coleman-Smith (Trout in the Trym), November 2025

We Can and Must Do Better

At Bristol Avon Rivers Trust, we believe that healthy rivers are non-negotiable. They’re essential to climate adaptation, community wellbeing, and the natural capital that supports life in our region. Our rivers should not be collateral damage to development.

Here’s what needs to happen:

  • Developers must embed pollution prevention into day-to-day site practice, not as an afterthought but as standard operating procedure.
  • Regulators must act swiftly and transparently when prevention fails, applying the polluter pays principle without delay.
  • Communities and charities should be supported, not left to pick up the pieces after harm has occurred.

A Call to Action

Our rivers deserve more than well-meaning words. They deserve meaningful protection and robust action. The solutions are not beyond us – what’s needed is the collective will to implement them. Development and nature don’t have to be at odds. With commitment, collaboration, and accountability, we can secure thriving rivers alongside vibrant communities.

If you care about clean water, thriving wildlife, safe spaces for recreation, and resilient landscapes in a changing climate, then this issue matters. Let’s stop pollution at the source. Let’s defend our rivers before it’s too late.

Meet Ellie Roxburgh, River Action’s new Policy and Advocacy Manager

Posted on by Molly Allen
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Q1. Tell us about yourself

My name is Ellie, and I am the new Policy and Advocacy Manager at River Action! I am really excited to join such a dynamic and impactful organisation at such a critical time for water policy.

I have worked on environmental issues ranging from marine conservation, sustainable rice, nitrogen policy, and now rivers! This broad range of topics has equipped me with an understanding of how different sectors and practices impact water quality and the wider environment.

Q2.  What first sparked your interest in protecting rivers and freshwater ecosystems?

I grew up in Kent, which is a very green environment yet we had little access to rivers for swimming. Now that I live in Bristol, I am spoiled for choice and cherish swimming in my local river throughout the summer.

Having worked previously for the Soil Association on nitrogen, I became increasingly aware of the impact of agriculture on rivers, lakes and seas. I learned about the appalling water crisis unfolding in this country, and the dirty money trail leading straight to the companies in charge of keeping our rivers running and our tap water clean.

Q3:  You spent nearly three years at the Soil Association. What did your role there involve, and what did it teach you about the connection between soil health and the state of our rivers?  

During my time at the Soil Association, I convened a coalition of eNGOs to advocate for greater ambition and more integrated government action on nitrogen. The group of farming, climate, health and nature organisations came together after learning about the pollution swapping risks from taking a siloed approach to nitrogen policy. We hosted the coalition at the Soil Association to ensure that farmers were always considered in any solutions that we put forward.

Nitrogen is used as a fertiliser for crops, either in synthetic form manufactured using fossil fuels, as livestock manure, or supplied through nitrogen-fixing crops like legumes. In the UK, fertiliser application rates are high, with only about half of fertilisers being taken up by the plant.

The rest is lost to the environment, either as air pollution, a greenhouse gas or leached through surface and groundwater to the rivers. Too much nitrogen in rivers leads to eutrophication, whereby the nitrogen (and phosphorus) spur growth of algae to the point that it blocks light out of the river, killing wildlife and plants under water.

Ways to reduce nitrogen leaching into rivers starts with the soil. Building soil health will mean more nitrogen is held in the soil and it won’t wash away in heavy rainfall. Applying the right fertilisers at the right time, in the right amount and in the right place will reduce losses and – importantly – massively increase farm profitability.

Q4:  Tell us more about your position as secretary for the Society of Conservation Biology’s Impact Evaluation Working Group.

I am responsible for managing Volunteers and convening the Working Group. I joined the group after writing a paper on the impact of conservation organisations’ support for community governance of marine resources with the Journal (Society of Conservation Biology), and becoming interested in the use of impact evaluation in increasing effectiveness of conservation initiatives. With few resources to go round, and the biodiversity crisis deepening, it’s important that conservation projects and the communities they work with get the most bang for their buck.

Q5.  Looking ahead to your new role as River Action’s Policy and Advocacy Manager, what will you be focusing on, and what can people expect to see from you in 2026?

Given my experience in agricultural water pollution, I will be steering the policy work in this direction. The government’s shown appetite to clean up England’s rivers, but so far, is falling short of any immediate impact on agricultural pollution. I see better agricultural management of nutrients as integral not only to cleaning up rivers, but also to restoring biodiversity, air quality and reducing contributions to climate change. I will be kicking off 2026 by sharing our agricultural water pollution strategy with key decision makers in government.

The other area that I see as needing more attention from the government is the issue of water scarcity. Demand for water is only going up, with much drier and heatwave-ridden summers and the sudden appearance of data centres, the government needs a plan to ensure there is enough water to go around. That must include managing water for public interest to ensure corporations cannot guzzle it all on infrastructure.

Q6. Finally, in your opinion, what is further needed/what needs to change to rescue Britain’s rivers?

Holding polluters to account, re-structuring water companies to be for public interest. There’s a really interesting example of the Eau in France, where the water company is a charity and they invested in supporting farmers in the catchment to convert to Organic farming in a bid to clean up the river before the Olympics. These farmers produce healthy and nutritious food without the use of synthetic fertilisers or pesticides, which is then supplied to schools in the local area.

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