A first hearing for the rivers Wye, Lugg and Usk pollution claim will take place at the High Court in London on Monday, 27 April 2026.
The claim, which is the biggest ever to be brought in the UK over domestic environmental pollution, now has more than 4,500 people on board.
The hearing next week will determine key aspects of the way the case will be managed, including a timetable and a deadline for other residents and businesses to join the legal claim.
River Action is supporting the legal claim and is organising a show of support outside the Royal Courts of Justice on the morning of the hearing. The giant Goddess of the Wye, a large-scale puppet symbolising the river, will appear outside the court alongside clean water campaigners calling for action to protect these threatened waterways.
The legal claim is against industrial chicken producer Avara Foods Limited and its subsidiary Freemans of Newent Limited, as well as the region’s sewerage operator Welsh Water.
It is argued that Avara’s and Freemans of Newent’s industrial chicken operations plus Welsh Water’s management of the sewerage system have resulted in widespread pollution in the rivers Wye, Lugg and Usk. All three defendants have denied the allegations.
The High Court hearing on 27 April will see the parties appear in court for the first time to argue how the claims should be managed going forwards. The claimants will argue that the community should be given a longer opportunity to join this environmental legal action, and that the poultry defendants should be ordered to disclose details of the locations of their industrial poultry operations across the region.
The legal claim against Avara, Freemans of Newent and Welsh Water alleges that pollution has been caused by water run-off from farmland containing high levels of phosphorus, nitrogen and bacteria from poultry manure spread on the land as fertiliser. It also alleges bacteria and nutrient pollution in the rivers has been caused by the discharge of sewage directly into the rivers from Welsh Water sewerage systems.
The claim was filed at the High Court in autumn 2025.
Leigh Day partner Oliver Holland, who leads the claim, said:
“This first court appearance marks an important step in the Wye, Lugg and Usk pollution claim. There has been a great deal of effort put in by the community and environmental campaigners to help drive the proceedings to this point, showing the strength of feeling from those involved about the state of the rivers. They feel that the government and regulators have not done enough to prevent the deterioration of these rivers, leaving court action as their only option to pursue environmental justice.
“In this hearing, important aspects of case management such as deadlines for the next stages and disclosure of information by both sides will be determined. We are hoping for a positive outcome, and to be able to look ahead to presenting our clients’ arguments in full to the High Court in due course.”
River Action’s head of legal Emma Dearnaley said:
“This case comes at a critical time for some of our most cherished rivers and the communities connected to them. We believe industrial-scale chicken production supplying major supermarkets and fast-food chains has placed immense pressure on the Wye, Lugg and Usk, driving nutrient pollution levels that these sensitive ecosystems cannot absorb. Sewage pollution must also be reduced and stopped to reverse the decline of these rivers.
“River Action supports this claim because it gives a voice to thousands of people who refuse to accept the continued degradation of their rivers. Communities should not have to live with the consequences of sewage pollution or an intensive farming model that we believe pollutes their waterways. This action offers an important way to hold those allegedly responsible to account and secure the systemic change needed to protect and restore our rivers for generations to come.”
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.
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.”
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.
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 narrowview 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.
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:
Proper and consistent enforcement of anti-pollution regulations, ending reliance on under-resourced, reactive compliance.
A well-resourced and properly trained Environment Agency, with the capacity to monitor, inspect and enforce agricultural pollution rules.
Appropriate funding and updated planning guidance for slurry infrastructure, to prevent pollution from storage and land application.
Mandatory Sustainable Nutrient Management Plans, overseen by a Defra-led taskforce to ensure accountability and coordination.
Lower thresholds for Environmental Permitting Regulations, extending tighter controls to beef and dairy operations currently outside the regime.
A transition to catchment-based nutrient management, using regional water authorities to manage pollution at river-basin scale.
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)
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.
Cleaning up the UK’s river crisis was a key election commitment for this government, but current efforts risk falling short by focusing too narrowly on sewage.
Despite popular claims that sewage is the leading cause of the UK river’s poor health, agriculture is the biggest culprit, affecting 45% of water bodies. This is primarily driven by nutrient and chemical pollution running off agricultural land.
Nutrient pollution from fertiliser use – particularly nitrogen and phosphorus – drives eutrophication, harming ecosystems, contaminating drinking water and damaging coastal areas.
Synthetic fertiliser and livestock manure are the two primary drivers of nutrient pollution.
Synthetic fertilisers are used to boost crop yields beyond nature’s limits, but both the production and use come at an environmental cost. In the UK, the current nitrogen use efficiency of synthetic fertilisers is 55% for crop production, meaning about half of fertilisers are lost to the environment, and this drops to 6-37% for animal products, like dairy.
Livestock manure is a valuable nutrient resource that is recycled onto land to fertilise crops, providing an array of nutrients to soils. Its environmental impact is determined by its form, depending if animals are housed in slurry or straw based systems.
Nutrient pollution risk is directly related to the type of farming system. Industrial livestock farming systems are higher risk because animals are raised indoors – in confined spaces – and thus produce vast amounts of manure that has issues relating to storage and application. The rapid increase in industrial livestock units across England and Wales means slurry is produced in ever increasing quantities. These units rely on synthetic fertilisers to grow feed both in the UK and abroad, driving deforestation in biodiverse areas, with half of agricultural land used to grow feed for animals in these systems. High concentrations of phosphate and nitrogen in feed means the livestock manure is highly concentrated in these nutrients, and is thus a risk for environmental pollution.
There are a multitude of confounding reasons for such a large agricultural water pollution issue, including:
Poor enforcement of regulations at the mercy of reduced budgets
Piecemeal regulation with a multitude of inconsistent requirements of farmers
Ever intensifying agricultural livestock production, supported by synthetic fertilisers
Poor quality of slurry infrastructure due to financial constraints of small-scale and tenant farmers
Beyond nutrient pollution, sewage sludge is a fertiliser that is unprecedented in its impact, with alarm bells being raised by NGOs over the chemical contaminants present. Sewage sludge is an emerging source of pollutants, with evidence showing contamination with PFAS, microplastics and industrial chemicals. Water companies are paid by chemical producers to take their waste, which is mixed with wastewater before farmers are given the product to use as fertiliser. Typically, farmers are unaware of the contaminants and the potential fertility impacts of continuous use of sludge on soils, with over 3.5 million tonnes of sewage sludge is spread on agricultural land every year.
Our recent survey found that 92% of people in the UK believe water companies should ensure sewage sludge on UK farmland is not contaminated; 88% support making water companies publicly report contamination levels in treated sewage sludge; 87% support increasing regulation on monitoring of treated sewage sludge.
To conclude, we have put together an Agricultural Water Pollution Strategy with seven recommendations that would help the government to tackle water pollution with the same ambition that has been shown to tackling the water sector crisis:
Proper and clear enforcement of anti-pollution regulations
A well resourced and better trained Environment Agency
Appropriate funding and updated planning guidance for slurry infrastructure
Implement Sustainable Nutrient Management Plans overseen by a Defra Task Force
Lower thresholds for Environmental Permitting Regulations and extend to beef and dairy
Transition to a catchment-based approach to nutrient management, using regional water authorities
Prevent toxic sewage sludge contaminating agricultural land
The event brought together policymakers, regulators, farmers, scientists, and environmental campaigners to outline a credible, evidence-based roadmap for reducing agricultural pollution while supporting fair and sustainable farming. Speakers welcomed the strategy as a basis for concerned parties from the farming and environmental sectors to work with the government to identify a way forward. Helen called for better monitoring to assist regulators in identifying progress on farms, as well as more research into agricultural practices that work for both farmers and the environment.
A new YouGov/River Action poll reveals that three-fifths (61%) of UK respondents do not know that farmers commonly use sewage sludge from water companies, and 50% believe this practice carries risks for health and food quality.
The findings will be revealed as a petition calling for an end to the spreading of contaminated sewage sludge, signed by more than 62,800 people, is handed over outside DEFRA’s headquarters on Marsham Street, London, at 10:05am on 16 December.
The petition will be delivered to the Minister for Water and Flooding, Emma Hardy, by River Action and Greenpeace, urging immediate government action.
Water companies are selling this toxic sludge to farmers, putting rivers and human health at risk and leaving farmers concerned about the impact on their soil and water. The government must act immediately to stop contaminated sewage sludge being spread on farmland and support farmers in producing safe food while protecting our rivers.
Treated sewage sludge is sold as a cheap fertiliser, but water companies are not required to remove PFAS “forever chemicals,” microplastics, or other modern contaminants, because legislation governing sludge treatment was drafted in the 1980s — long before these pollutants existed. The sludge is now spread widely across farmland, draining into rivers already under severe pressure.
Key public findings from the YouGov survey
92% say water companies should either have a great deal of responsibility (79%) or a fair amount of responsibility (13%) when it comes to ensuring that sewage sludge that will be used on UK farmland is not contaminated.
89% say the government should have a great deal (59%) or a fair amount of responsibility (30%) when it comes to ensuring that sewage sludge that will be used on UK farmland is not contaminated
88% support requiring water companies to report publicly on levels of contamination in treated sewage sludge
87% support Increasing regulation on monitoring of treated sewage sludge for contaminants
87% support requiring water companies to conduct further treatment to remove contaminants including forever chemicals and microplastics from sewage sludge
85% support setting legal limits on levels of contaminants in treated sewage sludge spread on UK farmland
47% support banning the spread of treated sewage sludge on UK farmland
62% see a risk from using treated sewage sludge on farmland to water health, around 50% see risks to food quality and personal health
39% think water companies should find a different way of disposing of treated sewage sludge, even if this means water bills are more expensive
Findings from River Action’s farmers survey*
Alongside the national polling, River Action surveyed 105 farmers across the UK to understand how sewage sludge contamination is affecting those who buy and use it on their land. Although the sample is very modest relative to the size of the UK farming sector, the results show a striking level of awareness: 83% of respondents recognised the risk of contamination in biosolids..
Concern is widespread. Seventy-two per cent said they were worried about the impact of contaminated biosolids on water health, with almost 40% describing themselves as very or extremely worried.
A similar picture emerges for soil health, with 69% of farmers worried about the application of contaminated biosolids with 41% describing themselves as very or extremely worried.
The findings point to clear demand for stronger safeguards. Farmers expressed strong support for:
Better treatment to remove contaminants (76%)
Public reporting on contamination levels (58%)
Legal limits set on contaminants (56%)
Tighter regulation on monitoring contaminants (53%)
CEO of the Nature Friendly Farming Network Martin Lines said, “These findings show just how worried farmers are about the contamination of sewage sludge. And who can blame them? They’re already under huge pressure from supply chains chasing ever-higher profit margins, while water companies are offering cut-price or even free sludge that turns out to be contaminated.
“Farmers should not be the ones carrying the blame for a problem they didn’t create. This is a mess for the water companies and government to fix, not the people producing our food. Farmers want to do the right thing for their soil, their customers and their rivers, but they need a system that doesn’t set them up to fail.”
Farmer John Hall from County Durham said, “Water companies expect farmers to pay for the privilege of taking their waste, insisting that sewage sludge is a ‘valuable fertiliser’. In any other sector, waste producers cover the cost of safe disposal. But when the ban on dumping sludge at sea came in, water authorities and the Environment Agency simply assumed farmers would pick up the tab and take this supposedly valuable product off their hands.”
A southern Scotland farmer, who wishes to remain anonymous, told River Action, “Having used biosolids in the past, I became increasingly concerned that a natural by-product was becoming laced with household chemicals and industrial wastes, often described as forever chemicals because they break down so slowly in the soil.
“The ongoing accumulation of these substances will damage soil life, be absorbed by food crops, and eventually enter the wider water environment. These materials are more harmful than other inputs applied to the soil.”
River Action’s Head of Campaigns Amy Fairman said, “Farmers do not want to be dumping contaminated sludge on their land. Water companies are selling sludge laced with forever chemicals and microplastics, and the public is rightly concerned. Human health and our rivers are at risk, and the government must act immediately.”
Hugh Fearnley-Whittingstall added, “People are rightly worried about forever chemicals, microplastics, and other contaminants entering our rivers, soil, and food. Much of it is coming from “toxic sludge” which, astonishingly, is being given to farmers to spread on their land without telling them what’s in it. Urgent action is clearly needed from both water companies and the government to stop this pollution, support our farmers and food producers, and protect the environment.”
River Action’s Agricultural Water Pollution Strategy
River Action will launch its Agricultural Water Pollution Strategy on 17 December at the Palace of Westminster. The strategy was developed with farmers, food producers, supermarkets, and major fast-food chains to create practical solutions for sustainable farming while restoring river health.
Seven-point plan for clean rivers and fair farming:
Enforce the law properly – Create a single compliance framework requiring the Environment Agency to act when voluntary approaches fail.
Resource the regulators – Ringfence fines to fund training, farmer support, and monitoring tools like satellite imaging and citizen science data.
Fix failing slurry infrastructure – Redirect agricultural subsidy funds to urgently upgrade unsafe or outdated storage systems.
Establish regional water authorities – Create catchment-based bodies with powers to coordinate nutrient reduction and implement Water Protection Zones.
Smarter planning and data use – Integrate environmental, farm, and planning data to streamline compliance and remove barriers to essential farm upgrades.
Modernise sludge regulation – Bring sewage sludge under Environmental Permitting Regulations, with legal limits for forever chemicals, microplastics, and other contaminants.
Notes to Editors
All figures, unless otherwise stated, are from YouGov Plc. The total sample size was 2,150adults. Fieldwork was undertaken between 2-3 December 2025. The survey was carried out online. The figures have been weighted and are representative of all UK adults.
The complete YouGov poll dataset is included in full so you can see the numbers behind the headline findings.
River Action undertook its own survey of the farming community between 19th November – 10th December. The survey was carried out online and received 105 responses. The finding can be found here.
Media can download images of contaminated sewage sludge here. If used, please credit: Fighting Dirty
Members of the media are invited to attend the launch of River Action’s Agricultural Water Pollution Strategy, Hosted by Alistair Carmichael on 17 December at 1pm in Dining Room A, Palace of Westminster. Keynote address will be given by Minister Hardy. Register interest at: media@riveractionuk.com
Thames Water knew over 90 sewage sites were failing as 13 communities and Sir Steve Redgrave launch UK’s first coordinated sewage pollution statutory nuisance action
We can today reveal, using documents submitted by Thames Water to Ofwat, that 93 sewage treatment works and water pumping stations the company promised to upgrade remain unfinished, leaving rivers across the Thames catchment exposed to continued pollution and dangerously high levels of bacteria.
With Thames Water failing to act, 13 communities from Buckinghamshire and Elmbridge to Hackney, Hammersmith & Fulham, Oxford and Richmond to Wokingham are now fighting back, sending statutory nuisance complaints to their local authorities to demand accountability and urgent action.
This marks the launch of the first coordinated statutory nuisance action of its kind, with communities uniting to ask local authorities to hold Thames Water legally accountable for the impact of sewage pollution. Rowing legend Sir Steve Redgrave and Olympic champion Imogen Grant MBE have also submitted nuisance complaints, joining residents from across the Thames. It follows a nuisance complaint brought by Matt Staniek of Save Windermere after pollution by United Utilities harmed England’s most famous lake.
Communities fighting back
With Thames Water failing to act, residents across the Thames catchment are turning to the law to challenge sewage pollution in the River Thames. communities in Buckinghamshire, Elmbridge, Hackney, Hammersmith and Fulham, Hounslow, Oxford, Richmond upon Thames, South Oxfordshire, Southwark, Vale of White Horse, Wandsworth, West Berkshire and Wokingham have today sent statutory nuisance complaint letters to their local authorities based on the sewage pollution experienced in their area, asking them to make Thames Water take decisive action to stop its sewage pollution that is causing harm along the River Thames.
River Action and these communities believe that discharges of untreated or inadequately treated sewage from infrastructure operated by Thames Water constitute a statutory nuisance under section 79 of the Environmental Protection Act 1990.
This type of complaint should trigger an investigation by the local authority to determine whether a statutory nuisance has occurred or is occurring and take reasonable steps to investigate the issues raised. If sewage is found to cause a statutory nuisance, an abatement notice — a legal order that would require Thames Water to stop causing the nuisance or face criminal prosecution – is required to be served on Thames Water by the local authority.
A statutory nuisance is an activity that unreasonably interferes with peoples’ use or enjoyment of land and is likely to cause prejudice or injury to health – for example, through noise, smells or other forms of harm. A ‘nuisance’ is described in case law as being a state of affairs which is not something “objectively a normal person would find it reasonable to have to put up with”. In this case, residents argue that sewage pollution from Thames Water’s failing sites and infrastructure has made rivers unsafe, disrupting recreation, sport, local businesses and everyday enjoyment.
Real-world examples underline the risks:
A 16-year-old rower from the Henley Rowing Club became unwell after training on the river; tests confirmed he had contracted E. coli. His illness coincided with his GCSE exams, preventing him from revising and sitting some papers.
In West Berkshire, a kayaker capsized and became unwell over the following days.
At Taggs Island, five children fell ill after playing in the River Thames near Hurst Park.
These complaints seek to hold Thames Water legally accountable for the harm and interference caused by sewage to riverside communities, recreation, business and public health.
Community member from Oxford, delivering her statutory nuisance complaint letter.
Calls for intervention
We are calling on local authorities to investigate these complaints and for the Government to apply to the High Court to put Thames Water into special administration to prioritise investment in sewage infrastructure and protect bill payers and the river that sustains our economy.
Our Head of Campaigns, Amy Fairman said:
“This action is about fixing sewage pollution in the Thames for good, not compensating people for past failings.
Each local authority must investigate these complaints and, where statutory nuisance is found to exist, issue an abatement notice and take enforcement action. Councils now have a legal duty to act.
Despite extensive evidence of performance failures and being on the brink of insolvency, the Government has not taken steps to place Thames Water into a special administration regime, a process that would allow for urgent infrastructure upgrades, put public interest ownership and governance first, and protect communities and the environment.
River Action is calling on the Secretary of State for the Environment to act now: the Government must take temporary control of Thames Water to end the era of private profiteering and stop polluting the river.”
Dirty discharges and dangerous bacteria levels
At several sites, it’s not just sewage overflows that are causing pollution but also the quality of treated effluent which also presents a direct threat to public health.
At Henley-on-Thames Treatment Works, Thames Water’s own data – obtained by River Action from Thames Water via an Environmental Information Request – shows E. coli levels in treated effluent reaching 28,000 cfu/100 ml in September 2023 – more than 30 times the safe limit for designated bathing water. This toxic cocktail is a direct threat to swimmers, rowers, anglers, and wildlife.
Newbury STW discharges into the River Kennet, within a globally rare chalk-stream catchment. The river is designated as a Special Area of Conservation and Site of Special Scientific Interest.
Over five years, the site has released almost 4,000 hours of untreated or partially treated sewage.
An upgrade was scheduled under Price Review 24 (PR24), while the linked London Road Pumping Station, due to be completed under PR19, remains unfinished.
Citizen science monitoring (22 September – 24 November 2025)
Local citizen scientist Blake Ludwig monitored E. coli levels in treated effluent at the Newbury Sewage Treatment Works and upstream sites along the River Kennet and Kennet & Avon Canal between 22 September and 24 November 2025, conducting 9 tests in total. All testing was conducted using a WHO-approved Fluidion Alert One E.Coli tester, in coordination with Planet Ocean.
Three highest readings: 2,650, 2,271, and 1,945 cfu/100ml – far above the safe swimming limit
Average E. coli level across all tests: 1,076 cfu/100ml
For an inland bathing site, the Environment Agency considers E. coli levels above 900 cfuCFU/100 mL to be poor and unsafe for swimming.
Local citizen scientist, Blake Ludwig, delivering his letter.
Citizen science monitoring (11 June 2024 – 16 September 2025)
Complementing the findings at Newbury, Citizen Scientists Buckinghamshire monitored E.coli levels in the treated effluent discharged from Little Marlow Sewage Treatment Works (Bourne End) between June 2024 and September 2025. The water quality testing groups conducted 14 tests on the final outflow.
6 out of 14 results exceeded 10,000 cfu/100ml
2 out of 14 results measured 1,000 cfu/100ml
9 out of 14 results were above 7,000 cfu/1200ml
As with the Newbury dataset, these readings sit well beyond the Environment Agency’s inland bathing-water threshold of 900 cfu/100ml, again indicating conditions that are unsafe for recreational water use.
Peaceful protest at Thames Water HQ
Campaigners from across the catchment staged a peaceful demonstration outside Thames Water’s headquarters, Clear Water Court in Reading. Many of those taking part were the very people who have submitted statutory nuisance complaints, and they carried placards naming the boroughs and districts involved. Groups from across the Thames basin joined the action.
Campaigners outside Thames Water’s HQ in Reading
Community groups and rowing legends join the action
Laura Reineke, founder of Friends of the Thames and a resident of Henley-on-Thames, said: “People here are fed up with living beside a river that’s being treated like an open sewer. We’ve submitted a nuisance complaint to our local authority because what Thames Water is doing is unacceptable.
“To find that treated effluent leaving their plant here has contained E. coli at levels 30 times higher than what’s safe for bathing is shocking. Local residents are angry and determined to hold this company accountable for the damage it’s causing to our river and our community.”
International rowing legend Sir Steve Redgrave said:
“As someone who has spent my life on the water, I am appalled by the pollution that Thames Water continues to allow. That’s why I’m joining River Action and communities along the River Thames in taking action to hold this company to account. Our rivers should be safe for everyone. It is unacceptable that people are being forced to fight for clean, healthy waterways.”
Olympic rowing champion Imogen Grant MBE said:
“Rivers are our lifeblood, for sport, wildlife, and community, and it’s shocking to see them poisoned by untreated sewage time and time again. I have filed a nuisance claim with Wokingham because I’ve had enough of pollution putting me and other river users at risk. I stand with River Action to hold Thames Water accountable and protect the rivers we all rely on.”
Friends of the Thames, CEO, Laura Reineke outside Thames Water’s HQ in Reading
Notes to editor
This document, submitted by Thames Water to Ofwat, outlines the 93 improvement projects the company requested permission to carry over from PR19 to PR24. For ease of use, we have extracted the relevant data and displayed it in this document.
In response, Ofwat expressed concerns about non-delivery and whether customer protection is adequate. In this document it stated, “The company does not provide sufficient and convincing evidence that the proposed investment does not overlap with base activities or was not already sufficiently funded for delivery for the period 2020-2025 (PR19). It provides no evidence that non-delivery could have been mitigated.
“This enhancement request is for £172.99m within the water price control (out of a total £1,134m claim). There is a need for Thames Water to complete the outstanding PR19 WINEP schemes by 2030. The company has provided a short business case covering the total claim, but it provides no other supplementary evidence to explain the additional requested funding for ‘Water other’ WINEP drivers. “The proposed funding covers additional investment for schemes under regulatory drivers including the Water Framework Directive (WFD), biodiversity and raw water deterioration. It also includes some capital maintenance costs to support scheme delivery. For capital maintenance, this is base expenditure rather than enhancement. For raw water deterioration, this was not an WINEP driver at PR19 for 2020-25 and should not attract additional enhancement funding under this category. “Some of the reasons for non-delivery of the total WINEP enhancement claim are stated by the company as: cost increases over 2020 to 2025; the scale of the WINEP programme; under-funding in its PR19 final determination; new framework contractors and delays due to Covid. Many of these issues impact other companies equally and are within management control.”
In this correspondence from Ofwat to Thames Water, known as an enforcement order, the regulator explains that while the company can carry over the 93 projects for which funds were already allocated, it can only access an additional £250 million to upgrade these sites, projects that should have been completed during PR19. Ofwat also fined the water company £104.5 million for failure to upgrade these sites in PR19.
To date, 13 statutory nuisance letters have been submitted to local authorities across the River Thames catchment. They are: Buckinghamshire, Elmbridge, Hackney, Hammersmith and Fulham, Hounslow, Oxford, Richmond upon Thames, South Oxfordshire, Southwark, Vale of White Horse, Wandsworth, West Berkshire and Wokingham.
The Oxford Rivers Improvement Campaign used an Environmental Information Request (EIR) to obtain data on Newbury STW. The data show that sewage spill hours rose from 482 in 2019 to 1,630 in 2024, an increase of 240%. Over five years, the site discharged almost 4,000 hours of untreated or partially treated sewage. River Action used its analysis of this data to calculate these figures. You can view the calculations here.
Download stills and footage from the peaceful protest outside Thames Water HQ here.
