Take action
Take action

Campaigns

Latest

View All

Justice for Lough Neagh

View campaign

Toxic Sludge

View campaign

Author: Molly Allen

Can Farming Save the Cleddau? Lessons from the Pembrokeshire Pasture

Posted on by Molly Allen
By Chloe Peck, Senior Engagement Coordinator and Ellie Roxburgh, Policy and Advocacy Manager (River Action)

As we drove down to Pembrokeshire in early February, there was a feeling of hopefulness in the air, with the first bright yellow daffodils popping up along the verges and the sun reflecting off a wild, rough sea. A walk on a pebbly Welsh beach was certainly inviting, but we weren’t just there for the scenery. We were there to see if the ambitious goals of nutrient rebalancing and regenerative farming actually hold water when they meet the daily reality of a working dairy farm.

Cleddau Bridge, Pembrokeshire

A River Under Pressure

The Cleddau is at the heart of Pembrokeshire’s landscape, with the Eastern and Western Cleddau rivers flowing together into a deep-water estuary. It is a vital part of the area, but is currently facing significant pressure. Agricultural pollution remains one of the most significant pressures on rivers across the UK, and the Cleddau is no exception. Nutrient runoff from fertilisers and manure can enter these waterways, contributing to ecological damage and declining water quality.

We went specifically to speak about nutrient pollution in the catchment and how farmers are already making practical changes in farm management, alongside support from supply chains, to make a difference, as well as what more needs to be done. On the ground, this looks like a shift in how the land and herds are managed. Perhaps most importantly, we saw how “river-friendly” farming focuses on grazing management. By moving away from traditional intensive methods toward systems like conservation grazing, farmers can better protect the soil and the water that runs through it. 

Our trip was organised by Ric Cooper, the local linchpin and lead of The Cleddau Project. Ric is the kind of campaigner who is able to navigate complex nutrient data one minute, coordinate citizen science volunteers the next, and then talk practicalities with farmers. Because he is such a trusted local voice, he was able to introduce us to a wide variety of perspectives across the catchment.

From Indoor Housing to Open Pasture

Through Ric’s introductions, we met with local farmers Mike Smith and Andrew Rees to learn firsthand how they are implementing practical measures to reduce their environmental impact. Both are part of the First Milk cooperative, a British farmer-owned dairy co-op focused on regenerative, grazing-based systems. First Milk requires its members to provide at least 120 days of pasture access per year, advocating for grazing as a vital alternative to intensive indoor housing.

The benefits of this approach are rooted in the local nutrient cycle. In indoor systems, cows are often fed imported feed, rich in phosphates and nitrates that were grown elsewhere, sometimes even in another country. This introduces “new” nutrients into the local environment. In contrast, when cows graze on pasture, they are consuming nutrients already present in the local soil. This means that when the cows produce slurry, the nutrients within it are local to that specific area. By spreading this slurry back onto the same farmland, the nutrients remain balanced with the land rather than overwhelming it. This closed-loop system is essential for protecting our rivers from the nutrient runoff that leads to eutrophication – where excess nutrients cause algal blooms that choke the river of oxygen – damaging the ecology of the river.

This transition toward “river-friendly” farming isn’t limited to grazing alone. We discussed a variety of other approaches, such as improved nutrient management and more precise manure and fertiliser control, which can significantly reduce the risk of runoff into the Cleddau. At Moor Farm, Andrew has turned the traditional high-input model on its head by significantly reducing fertilisers and chemicals. He believes that these changes aren’t just an environmental “nice-to-have” lower inputs can actually maintain or even improve profit margins while restoring the health of the land.

Collaboration Across the Supply Chain

Ric also introduced us to Christopher and Emma at Puffin Produce, the largest supplier of Welsh fresh produce and partial owners of the Pembrokeshire Creamery. This dual role puts them in a unique position to influence both the fields and the dairies. They are leveraging the Landscape Enterprise Networks (LENs) to bridge the gap between commercial supply and environmental health.

Through this network, they co-fund nature-based solutions that are designed by the farmers themselves. It’s a bespoke approach: rather than a top-down mandate, it empowers each farm business to propose the specific regenerative practices that will best protect that local area’s unique geography.

The Big Picture: A Future for the Cleddau

As we left Pembrokeshire, it was clear that protecting rivers requires coordinated action across the entire food and farming system, from the farmers in the pasture to the cooperatives, retailers, regulators, and policymakers. Encouragingly, our conversations with leaders like Andrew Rees, Mike Smith, and the team at First Milk showed that many farmers are already working to be part of the solution.

However, scaling these efforts will require more than just environmental ambition. We learned that the transition to regenerative farming is often seen as a risk that takes several years to realise. To succeed, we must shift the frame, to show that “river-friendly” farming can be economically viable.

The commitment we saw from Puffin Produce, First Milk, and Ric Cooper’s citizen science network proves that when local trust and supply chain support align, real change is possible. Supporting and scaling these collective efforts will be essential to restoring and safeguarding the health of our rivers for future generations.

Farmers across England begin ‘Return to Sender’ programme for chemical-laced sewage sludge – April Fools

Posted on by Molly Allen

Concerned farmers across England have today announced a coordinated initiative to return sewage sludge contaminated with so-called “forever chemicals” back to the water companies that supplied it, citing growing fears for soil health, river health, food safety, and their own reputations.

The move follows mounting evidence that sludge spread on farmland contains PFAS chemicals, microplastics, and industrial residues that persist indefinitely in the environment. 

Much of this cocktail originates from chemical and manufacturing industries, which helpfully design substances robust enough to survive heat, pressure, sunlight, and, it turns out, most attempts at water treatment. Farmers say they are no longer willing to act as what one described as “the final chapter in a very long and poorly edited industrial experiment.”

Under the scheme, informally dubbed “Sludge Back Guarantee™”, farmers plan to deliver unwanted biosolids directly to water company offices, treatment works, and executive car parks, accompanied by polite notes reading: “Thanks, but no thanks. Please enjoy your product.”

“We were told this stuff was a ‘nutrient-rich soil improver’,” said one arable farmer from the Midlands. “Turns out it’s more of a forever-chemical retirement plan. We grow wheat, not legacy pollution.”

Farmers stress that they are not anti-recycling, anti-fertiliser, or anti-water company in principle. They are, however, reluctant to spread materials that behave less like compost and more like a time capsule for industrial chemistry.

Clean river campaigner and responsible farming advocate Hugh Fearnley-Whittingstall said:

“British farmers have spent decades improving soil health and food standards, so it’s reassuring to know they’re now trusted to warehouse a selection of synthetic chemicals that don’t degrade, can’t be removed, and weren’t invited. It’s a bold new diversification strategy.”

The action follows growing concern within the farming community that they are being used as a convenient outlet for sludge generated not just from households, but from industrial effluent containing persistent synthetic chemicals. Critics say the system works with admirable efficiency: chemical companies produce substances that resist breakdown, water companies circulate them through treatment systems not designed to remove them, and farmers are then offered the end product as a sustainable soil enhancer.

River Action’s Head of Campaigns Amy Fairman said:

“This arrangement has the elegance of all good cost-saving exercises: the pollution stays, the risk travels along our rivers, and responsibility quietly disappears. Farmers aren’t rejecting recycling – they’re declining to be mistaken for hazardous-waste facilities.”

Farmers say they are now calling on:

  • Chemical manufacturers to stop testing the limits of eternity in products that end up in wastewater
  • Water companies to stop accepting industrial chemical waste into systems that produce agricultural sludge (or at least stop calling the result ‘beneficial’)
  • Government to update decades-old rules and recognise that ‘persistent’ is not a synonym for ‘harmless’
  • Regulators to require full disclosure of what is actually in sludge, ideally before it is spread rather than several decades afterwards

“Food security doesn’t mean ‘spread now, regret indefinitely’,” said a mixed farmer from Yorkshire. “Our soils are our pension, our business, and our responsibility. We’d quite like them not to double as a long-term chemical archive.”

Water companies contacted for comment said they were “reviewing the situation” and confirmed that while sludge was safe “within current guidelines,” they would “prefer not to receive it back.”

The Department for Environment, Food and Rural Affairs reminded farmers that April 1 is “not an appropriate day to trial reverse logistics for biosolids,” before adding that it would “continue to engage constructively with all stakeholders and, where possible, reality.”

Farmers insist the message is serious, even if the timing is not.

“We don’t want sludge wars,” said one. “We just want clean water, clean soil, and slightly fewer forever chemicals. Ideally none, but we’re trying to be realistic.”

Notes to editor

This press release is issued as part of April Fools’ Day and the “Return to Sender” programme described above is satirical.

However, the practice of spreading sewage sludge on agricultural land in England is very real. Sewage sludge can contain PFAS “forever chemicals”, microplastics, and other industrial contaminants that are not routinely removed during treatment and can persist in soils and waterways.

Farmers’ concerns about being asked to spread contaminated sludge, the lack of transparency over its contents, and the long-term risks to soil health, water quality, food safety, and public trust are genuine and widely shared.

Public concern is also significant. A recent YouGov poll conducted for River Action found that 92% of people in the UK believe water companies must ensure sewage sludge used on farmland is not contaminated. The same polling shows that 61% of respondents were unaware that sewage sludge from water companies is commonly spread on farmland, while half (50%) believe the practice poses risks to health and food quality.

Justice for Lough Neagh: The First Hearing

Posted on by Molly Allen

Written by Christian Fuller, River Action’s Legal Coordinator  

This week, River Action took part in the first hearing of a legal case which, for the first time, asks the court to decide whether the Northern Ireland government is doing enough to tackle the water pollution crisis in Lough Neagh. 

Outside of the Royal Court of Justice in Belfast, clean water campaigners and members of the fishing community gathered to make their point plainly: the Lough is being destroyed by algae. Draped in green and holding placards reading ‘Justice for Lough Neagh’, the peaceful demonstration captured the now-familiar sight of blue-green algal blooms spreading across the water in recent summers.

Inside, representatives for the applicant, the Department of Agriculture, Environment and Rural Affairs (DAERA), Ulster Farmers’ Union, River Action and Friends of the Earth NI were present, with a packed courtroom due to public interest and concern.

The case is being brought by eel fisherman Declan Conlon, whose family has fished Lough Neagh for generations. He is challenging the failure of DAERA to comply with its obligations to safeguard and protect Lough Neagh from agricultural and wastewater pollution on eight legal grounds. The claim challenges the lawfulness of DAERA’s response, including its failure to adopt an adequate or lawful River Basin Management Plan. 

River Action has applied to intervene in Mr Conlon’s case to help the court assess whether DAERA is complying with its legal duties by raising important legal and practical matters. Our focus is on what the law requires and particularly the need for a lawful River Basin Management Plan to include clear actions and measures capable of restoring water quality, following the landmark case of Pickering. Drawing on major legal precedents on agricultural waste and nutrient pollution in which River Action has been involved in England, we hope to establish that DAEERA should put in place stronger measures as part of a lawful plan, including the proper enforcement of regulation to control the spreading of manure and sewage sludge, the implications of the classification of manure as waste following National Farmers’ Union v Herefordshire Council, and the need for planning and permitting to take account of cumulative pollution impacts. We will also seek to provide evidence to help the court understand the scale of the problem and what measures and practices could lead to the necessary reduction in pollution. 

At the hearing, the judge recognised the importance of this case. There were, he observed, no obvious “knockout blows” against the applicant. On the contrary, the judge said that this is “an important matter which will require a considerable amount of time to be devoted to it” and referenced “a significant element of public concern” in the situation with Lough Neagh. 

The judge repeatedly signalled there were a large number of issues and that detailed evidence would be required to “get to the bottom” of what is happening in the Lough. The judge emphasised that it was “important to leave no stone unturned” and that meant ensuring all “relevant players” were before the court.

The case will return to court on 1 May for a further review hearing, where the legal issues will be refined and the roles of additional parties considered. A permission decision will follow (to decide whether the claim is arguable and can proceed), with a substantive hearing anticipated later this year. 

This is the first real opportunity for the court to consider the Government’s response to the severe pollution of Lough Neagh and the applicable legal framework, with the potential to become the most significant water quality case in Northern Ireland for a generation. 

It is a critical opportunity to clarify what the law requires and to ensure that meaningful, urgent action is taken to restore Lough Neagh.

Fisherman launches High Court challenge against DAERA over Lough Neagh pollution crisis

Posted on by Molly Allen

Eel fisherman Mr Declan Conlon, whose family has fished Lough Neagh for generations, has brought a judicial review against the Department of Agriculture, Environment and Rural Affairs (DAERA).

The case argues that DAERA continues to rely on inadequate plans and unenforced pollution regimes despite clear evidence of ecological collapse over several years. It raises serious questions about how agricultural pollution is addressed by DAERA in Northern Ireland. 

Lough Neagh, the largest lake in the United Kingdom and Ireland, providing approximately 40% of Northern Ireland’s drinking water, has suffered years of severe blue-green algal blooms and ecological decline – which can be seen from space.

In a sworn affidavit to the High Court of Justice in Northern Ireland, Mr Conlon described the deep generational connection his family has to the lough.

“Our father James Gerard Conlon was an eel fisherman and his father Hughie Conlon before him was an eel fisherman. Going further back than that, beyond memory, my family would all have been fishermen.”

“My way of life has been destroyed by the blue-green algae and I want DAERA to do whatever is necessary to stop the algae and safeguard and protect Lough Neagh, the fish, the flies and the wildlife for the benefit of future generations.”

Speaking about the legal challenge, Declan Conlon said, “I’ve fished Lough Neagh all my life, just like my father and his father before him. Now I’m watching it die in front of my eyes. This isn’t just about my livelihood – it’s about justice for the lough before there’s nothing left for the next generation.”

Enda McGarrity, Director at P.A. Duffy & Co. and solicitor for Mr Conlon, said the case reflects the lived experience of those whose livelihoods depend on the health of the lough and is about securing justice for Lough Neagh and the communities who rely on it.

“Declan Conlon has fished Lough Neagh his entire life, and what he is witnessing in recent years is a collapse unlike anything seen before.

“Where there was once abundance, there are now no flies for the eels to feed on, barely any birds, and stretches of water that smell so foul you cannot stand near them.

“He has seen the impact with his own eyes, from wildlife disappearing to reports of animals becoming sick after contact with the water. The blue-green algae is not just unsightly; it poses a real risk to health.

“Declan did not take this case lightly. He has brought this challenge because he believes the lough, his livelihood, his way of life, and the community that depends on it deserve proper protection under the law.”

River Action UK and Friends of the Earth Northern Ireland will apply to intervene in Mr Conlon’s legal challenge concerning the ongoing pollution crisis affecting the lough.

We are seeking to intervene in the judicial review to help the Court assess whether DAERA is complying with its legal duties to protect Lough Neagh. By drawing on recent legal cases addressing agricultural waste, nutrient pollution and river basin planning in England, River Action hopes to establish that DAERA must put in place clear, enforceable measures to reduce pollution and restore the health of the lough and its internationally important habitats.

River Action’s Head of Legal Emma Dearnaley said, “Declan Conlon’s case raises urgent questions about whether enough is being done to tackle the pollution driving the decline of Lough Neagh. When pollution persists year after year and ecological harm becomes impossible to ignore, it is right to ask whether the legal frameworks designed to protect Northern Ireland’s waters are being properly applied. River Action seeks to assist the Court in answering that question. 

“For too long, decision-makers have relied on plans and promises while pollution has continued and Lough Neagh has visibly deteriorated. We hope this case will help bring about the clear, enforceable action needed to reduce pollution and restore this vital ecosystem.”

Leigh Day partner Ricardo Gama, who represents River Action, said, “As a national organisation, River Action hopes to make sure that all jurisdictions in the UK are taking a correct and consistent approach to dealing with the acute pollution crisis in our rivers and lakes. 

“They have already established important legal principles in cases brought in England, and they hope that they can bring these principles to bear in Mr Conlon’s case. This would not only be for the benefit of Lough Neagh, but also every other water body at risk of ecological collapse in Northern Ireland.”

Friends of the Earth NI has been campaigning to protect Lough Neagh for decades. Standing in solidarity with communities and grassroots groups such as Save Lough Neagh, Friends of the Earth NI is committed to seeking justice for Lough Neagh, whether that be inside our Courts or outside. 

Over 50,000 people have supported Friends of the Earth NI’s five point plan for a just settlement for the Lough. 

James Orr, Director, Northern Ireland, Friends of the Earth said, “Lough Neagh is dying and it is dying in plain sight.

“It is a sad indictment of the state of our environmental protection regime that it has taken a local fisherman to challenge government inaction through the Courts to protect the Lough.

“For generations the lough and its communities have been betrayed by those in power. Yet again, taking this case shows the leadership to protect our life support systems is coming from our local communities.” 

Campaign update: High Court rules on lawfulness of Ofwat’s approach to customers not paying twice

Posted on by Molly Allen

Today the High Court has handed down its decision on the lawfulness of Ofwat’s approach to its policy that water company customers should ‘not pay twice’ for sewer overflow upgrades to achieve environmental compliance and reduce pollution of our waterways. Although River Action’s claim was dismissed, the case has resulted in important clarity and should result in a better regulatory approach.

Ofwat is responsible for regulating water companies and controls what they can charge customers through its five-year price reviews, with Ofwat’s Price Review 24 (PR24) exercise setting charges for the sixteen largest water companies from 2025-2030. Following investigations into water company compliance after widespread sewage discharges were revealed in 2021, Ofwat promised that customers would not pay twice for environmental improvement works that had previously been funded and should already have been delivered. 

Last year, River Action took forward this case because investigatory work by Save Windermere and Windrush Against Sewage Pollution identified potential systemic failures in how Ofwat oversees compliance across the entire water industry and how it routinely signs off funding that could allow water companies to use customers’ money to rectify their own past non-compliance. As well as ensuring customers do not pay twice, the key issue from River Action’s perspective is the significant long-term failures of water and sewerage companies to upgrade storm overflows, sewage treatment works and pumping stations to comply with environmental law because the sewage pollution that results from those infrastructure failures is causing harm to our rivers and lakes.

Internal documents that only emerged as a result of this litigation revealed significant confusion at Ofwat, indicating Ofwat may have failed to follow its ‘not paying twice’ policy because, as it admitted privately but not publicly, “some historical investment programmes now appear to fall short of what should have been required to comply”. Those documents showed that Ofwat did not know whether there was full compliance and whether customers would ultimately pay twice in some instances because Ofwat had failed to look at Urban Waste Water Treatment Regulations (UWWTR) compliance as well as environmental permit compliance. This is a major mistake that, unless monitored closely in the future, could result in billions of pounds of investment being spent on environmental improvements that should already have been delivered. 

At the hearing, River Action argued that Ofwat’s approach was flawed and unlawful because:

Ground 1: Ofwat’s approach to implementing its ‘not paying twice’ policy was unreasonable because to actually show that customers would not pay twice (1) water companies needed to demonstrate current compliance (namely the reality on the ground, not simply assuming or modelling compliance) and (2) water companies needed to demonstrate customers would not pay twice for improvements that should have already happened. Essentially, our complaint was that Ofwat had publicly said that companies would have to demonstrate compliance but then dropped that requirement without explaining why.

Ground 2: Ofwat’s ‘clawback’ mechanism is flawed and incomplete because it is limited to double funding of permit compliance and does not deal with double funding of UWWTR compliance, despite Ofwat’s internal documents revealing both are required. This means it falls short of operating to ensure that customers will not pay twice.

The High Court has today ruled that Ofwat’s approach was lawful because Ofwat’s evidence provided a ‘sufficient logical basis’ for its approach. In reaching its decision, the Court said that Ofwat has ‘significant latitude’ when looking at the legality of its decisions relating to price controls and compliance because of its role and responsibilities as a regulator.

But the Court did not fully grapple with River Action’s case, focusing on whether Ofwat’s use of modelling data was in line with its ‘not paying twice’ policy but not addressing our key argument that Ofwat’s policy also requires companies to actually show permit compliance. The Court has also not addressed the regulatory gap that exists between Ofwat and the Environment Agency when looking at permit compliance.

There was a positive outcome on the issue of the ‘clawback’ mechanism (intended to prevent double funding when water companies cannot provide evidence of promised improvements towards the end of a price review period). At the hearing, it became clear that Ofwat has yet to settle the rules that will decide whether any clawback should occur, meaning this argument was found by the Court to be ‘premature’. This was a welcome clarification and leaves the issue open so that the clawback mechanism can be fixed and used by Ofwat to make sure customers do not pay twice.

Essentially, in dismissing River Action’s claim, the Court has said that it thinks Ofwat’s approach is good enough because in theory Ofwat might be able to ‘clawback’ money that is spent in breach of Ofwat’s ‘not paying twice’ policy.

That does not mean the water regulator should not do better. It can and it must.

Our legal challenge has shone a light on problems with Ofwat’s regulatory approach and highlighted the urgent need for reform. Going forward, the regulator must not allow customers to pay twice by ensuring that water companies comply with both permit compliance and compliance under the UWWTR. Ofwat must also settle the clawback mechanism so that it works in relation to both permit schemes and UWWTR schemes.

While we waited for judgment, in December 2025, the Office for Environmental Protection (OEP) published notices and reports finding that Ofwat, the Environment Agency and Defra failed to properly enforce the law relating to sewage discharges from combined sewer overflows. The OEP’s findings show that Ofwat did not understand for decades that it had a duty to enforce environmental compliance under the Water Industry Act and the UWWTR, only recognising in June 2022 it had this important enforcement function in addition to ensuring assets comply with their permits. This supports our case that Ofwat has not required full compliance in past price reviews and was trying to play catch-up in PR24, while claiming publicly that it only needed to look at permit compliance despite knowing that was only part of the picture.

This judgment and the OEP’s findings are timely as, following the recommendations of the Independent Water Commission, this Government now looks to overhaul the water sector including by creating a new integrated regulator to replace Ofwat and bring together economic, environmental and water quality regulation. The Independent Water Commission also made recommendations relevant to regulatory gaps in holding water companies to account for the delivery of infrastructure projects and customers not paying twice.

Whatever form the future regulator takes, its approach on this fundamental issue should be clear, transparent and fully compliant. Customers must not compensate water companies for poor performance by paying twice for improvements that have not been delivered. And the regulator must hold water companies fully accountable by enforcing all relevant laws.

We will not be appealing the decision. Our focus now is on continuing to push for the major regulatory reform needed to ensure real oversight and enforcement, so water companies are properly held to account and sewage pollution is stopped for good.

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

Posted on by Molly Allen

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

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

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

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
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.

Powered by  GDPR Cookie Compliance
Privacy Overview

This website uses cookies so that we can provide you with the best user experience possible. Cookie information is stored in your browser and performs functions such as recognising you when you return to our website and helping our team to understand which sections of the website you find most interesting and useful.