River Action Launches Legal Challenge Against Ofwat Over Water Bill Hikes

River Action has filed a landmark legal challenge against Ofwat, accusing the regulator of unlawfully allowing water companies to pass the cost of their own failures onto customers. The case comes as water bills rise by an average of £123 a year, forcing households to pay for decades of underinvestment by the water industry.

The challenge, filed with the support of Leigh Day law firm, targets Ofwat’s Price Review 2024 (PR24), which granted enhanced funding to water companies like United Utilities without sufficient safeguards to ensure the money is spent on new water and sewage projects. Instead, River Action warns that customers will be left footing the bill for past infrastructure neglect, paying twice for the same failing systems.

Lake Windmere, Algea blooms | Matt Staniek ©

Paying Twice for Polluted Water?

The legal action stems from investigations by environmental campaigners Matt Staniek and Windrush Against Sewage Pollution (WASP), which exposed severe regulatory failings.

In August 2024, United Utilities requested extra funding to upgrade treatment works and pumping stations in the Windermere area, following 6,000 hours of raw sewage discharges into the lake that year alone. Ofwat approved the request under PR24, but River Action argues that the regulator:

  • Relied on hydraulic simulation modelling rather than real-world pollution data, which failed to reflect the true environmental damage.
  • Ignored key evidence of widespread sewage discharges when assessing funding needs.
  • Lacked a clear mechanism to regain funds if companies misused the additional investment.

As a result, customers could be forced to pay twice: first through water bills that should have covered infrastructure maintenance, and again through new hikes aimed at fixing the same problems.

Lake Windermere in cleaner times | Image by Pete from Pixabay

A Call for Reform

River Action is demanding urgent regulatory reform to stop water companies from passing the cost of their mismanagement onto the public. The financial burden of repairing the UK’s crumbling water infrastructure must fall on the companies and their investors, not customers.

Emma Dearnalely, Head of Legal at River Action, said:


Holding Ofwat Accountable

River Action’s legal challenge also raises broader concerns about Ofwat’s oversight and accountability, questioning whether the regulator has the necessary powers or will to prevent water companies from profiting at the public’s expense.

Ricardo Gama, solicitor at Leigh Day, commented:


Fighting for Clean Water

River Action’s legal challenge is part of its broader mission to hold water companies and regulators accountable. The group continues to campaign for stronger enforcement, greater transparency, and a financial and governance model that prioritises people and the environment over profits.

Thames Water’s £3bn bailout signals urgent need for Government action on failing water companies

STATEMENT:

Responding to the Court of Appeal’s decision to uphold Thames Water’s £3bn rescue plan River Action’s CEO said:

This decision is a disaster for Thames Water bill payers and the environment. Customers will now have to pay the price for the failing water company with about a third of their increased water bills paying for massive interest payments while our rivers remain choked with sewage.”

“Instead of allowing this interim plan to cause further financial and environmental damage, the Government must urgently seize the opportunity to place Thames Water into Special Administration before even more investor-centric restructuring plans are rolled out later this year. The current privatised system is a failed experiment, putting financial interests ahead of the needs of consumers and the health of our environment. Maintaining the status quo will only perpetuate this corporate takeover of the lifeblood of our economy and land. The government can and should step in now. 

“The onus is now on the independent Water Commission to propose a viable alternative financial and governance model for the water industry that puts people and the planet first. This is not just about managing a crisis; it’s about fixing a broken system that has allowed private companies to profit at the expense of public well-being.”

ENDS

For media enquiries, contact Amy Fairman at media@riveractionuk.com

High Court ruling adds weight to challenge to intensive poultry unit in Shropshire 

A judicial review case supported and funded by campaign group River Action as part of its drive to limit the uncontrolled growth of large-scale intensive poultry production farms has been strengthened by an important High Court ruling this week.

A judge has allowed further grounds to be added to the claim brought by River Action advisory board member Dr Alison Caffyn. It is challenging Shropshire County Council’s planning permission for the construction of a large-scale intensive poultry unit.

Granting permission, the judge said that there is ‘wider interest’ in the court hearing the extra two grounds at the substantive hearing due in the coming months, and emphasised that it would be helpful to have the court’s authority on the issues raised.

The case is now set to be heard on four grounds when it is presented to the High Court at a hearing in March or April 2025.

The legal action aims to stop the spread of intensive poultry production in Shropshire and the River Severn catchment area, and is part of a nationwide campaign by River Action to prevent river pollution caused by intensive agricultural practices.

An application for the poultry production unit by developer LJ Cooke & Son was approved by Shropshire Council in May 2024 after it had initially been rejected, with the site located north-west of Shrewsbury at Felton Butler.

In July 2024, a legal challenge opposing the poultry unit was launched by Dr Caffyn, who lives in Shropshire and is a member of River Action’s advisory board.

The case argues that the decision to grant permission failed to account for the cumulative impact of the rapid and uncontrolled increase of intensive poultry units being constructed within specific river catchments. It is argued that the effect of spreading manure and the emissions from burning biomass is causing severe concentrations of river and air pollution.

Following the recent severe pollution of the neighbouring catchment of the River Wye, which is believed to be because of the expansion of intensive poultry production, the case argues that the catchment of the River Severn is now being subject to similar environmental threats.

Follow the High Court ruling, the expanded grounds being argued in the March judicial review hearing are:

 

  • A failure to assess the effects of spreading manure and the emissions from burning biomass, which as indirect effects of the development, needed to be assessed.
  • A failure to impose a lawful planning condition on manure processing that would mean that the development would not cause groundwater pollution.
  • A failure to carry out a lawful appropriate assessment as required by the Habitats Regulations to ensure that the development would not adversely affect the integrity of a designated protected habitat – an area with special status due to its natural importance.
  • A breach of regulation 9(3) of the Habitats Regulations, which requires the council to take steps to avoid the deterioration of protected habitats.

 

The first two grounds were given permission in October 2024, with permission for the third and fourth grounds being given permission at a hearing in February 2025.

The proposed poultry unit would house 200,000 birds and include four poultry rearing buildings each over 100 metres long, as well as a biomass store with boilers. It would be located 400 metres from an existing poultry site, which is thought to hold nearly 500,000 birds.

Permission for the unit was initially refused after Natural England advised that three nearby protected sites, Shrawardine Pool, Lin Can Moss and Fenmere, could be impacted by aerial pollutants.

Council officers also raised concerns over the lack of detail on how the development would handle chicken manure without an anaerobic digester – a large sealed vessel used to break down organic materials.

However, the plans for the development were approved after LJ Cooke & Son proposed exporting manure to a third party anaerobic digestion unit.

Chairman and founder of River Action, Charles Watson, said:

“Like an appalling car crash in slow motion, exactly the same set of tragic events is now unfolding in catchment of the River Severn as has happened recently in the neighbouring catchment of the River Wye. We believe the waving through of permission for ever more giant intensive poultry units by Shropshire County Council is environmentally reckless. We are determined to do whatever it takes to support this critically important legal claim to end the ecocide which we say is being perpetrated upon our most iconic rivers by uncontrolled intensive agricultural practices.”

Dr Alison Caffyn said: 

“It’s really encouraging that the two extra grounds have been approved. We’re looking forward to demonstrating next month how inadequate Shropshire Council’s processes have been in granting planning permission for this industrial chicken operation. Shropshire has some really special countryside and habitats and local people need to be sure that the Council is protecting these and the River Severn catchment”

Leigh Day environment solicitor Ricardo Gama said: 

“Our client is delighted that the court has allowed two further grounds to proceed to a full hearing. This means that the hearing will now encompass the detrimental impact our client says the poultry unit will have on nearby protected habitats, as well as from the negative effects of pollution from manure and burning biomass. We look forward to arguing the case in the High Court, as part of River Action’s wider campaign to protect rivers from pollution caused by intensive agricultural activity.”

ENDS

River Action to sue Ofwat over water bill rises

 

WHAT IS OUR LEGAL CHALLENGE AGAINST OFWAT?

Our legal challenge focuses on funding allocated for wastewater treatment works and pumping stations by United Utilities in and around Lake Windermere.

The case is being taken after detailed investigations were carried out by Save Windermere and Windrush Against Sewage Pollution, which revealed significant and systemic flaws in Ofwat’s approach.

We’re taking legal action to compel Ofwat to reassess its PR24 determination for United Utilities in relation to Windermere and to encourage Ofwat to reassess other water company schemes wherever there are concerns that customers are unfairly covering the cost of past failures.

 

WINDERMERE: A DAMNING EXAMPLE OF REGULATORY FAILURE

United Utilities, currently under fire after evidence obtained by Save Windermere, revealed 6,000 hours of raw sewage was discharged into Windermere last year, and is a case in point. We have commenced legal action claiming Ofwat has allowed the company to divert funds meant for future projects to deal with past failures—rather than investing in vital improvements to wastewater treatment and pumping stations around the lake.

 

A SYSTEM RIGGED AGAINST THE PUBLIC

We believe Ofwat has acted unlawfully by approving these funds without ensuring they are spent on genuine improvements to essential infrastructure. Instead, this so-called ‘enhanced funding’ is being allowed to be used to cover up years of failure.

Effectively, Ofwat has signed off on a broken system where customers are being charged again for services they have already funded—while water companies continue to mark their own homework and pollute for profit. This scandal must be addressed. The cost of fixing the UK’s crumbling water infrastructure should fall on the companies and their investors—not on the British public.

We are calling for immediate regulatory action to ensure water companies stop passing the cost of failure onto customers—and start taking responsibility for the environmental damage they have caused.

High Court ruling declares farming manure as ‘waste’ in major victory for River Action in its fight against industrial-scale poultry production in Wye Valley

Landmark court ruling declares farming manure as ‘waste’ in major victory for River Action in its fight against industrial-scale poultry production in Wye Valley and exposes the failure of a regulatory regime that has failed to protect the environment

 

In a huge boost for River Action’s campaign against industrial scale poultry production, the High Court has today ruled that chicken manure can be classified as ‘waste’ and a council was entitled to require it to be disposed of under council waste rules. The Judgment has huge implications for handling manure on farms everywhere.

Pollution from agriculture, much of it from manure from animals on farms, is the biggest source of water pollution in the UK.

Following the adoption of Herefordshire County Council’s (HCC) Minerals and Waste Local Plan (MWLP) in March 2024, the National Farmers Union (NFU) mounted a judicial review challenge arguing that manure produced by agricultural developments like intensive Poultry Units (IPUs) is an agricultural “by-product” and should not be classified as ‘waste’ under the Waste Framework Directive (WFD). Before the court, the NFU did not dispute that chicken manure is the main source of nutrient pollution causing an ecological crisis in the River Wye. But it still argued that none of the controls on waste handling should apply and that HCC could not deal with it through a policy (policy W3) its MWLP.

In its intervention, River Action said environmentally damaging algal blooms in the River Wye have arisen as a result of livestock manure causing excessive phosphates to build up in the soil, which then runs off and leaches into waterways.  River Action argued that manure should be classified as ‘waste’ at least until its point of use under the WFD, and that controls need to be in place to ensure that waste producers take responsibility for disposing of waste in a lawful way.

The Hon Mrs Justice Lieven agreed that it cannot be assumed that manure will be used in an environmentally safe way. She then agreed with River Action that, given the environmental problems caused by chicken manure in the Wye catchment area with narrow and specific exceptions, manure is ‘waste’ in law up to the point it is sold or transferred to a third party. This means that chicken producers in Herefordshire will have to provide a detailed plan at the planning application stage to ensure chicken manure can be disposed of safely, including full transparency on the manure’s destination and application. They cannot rely on wastewater rules monitoring.

The judge also comprehensively rejected the NFU’s argument that HCC had to assume that the Farming Rules for Water (FRfW) – which regulate the spreading of manure on fields – were operating effectively to combat water pollution, so that no harm would be caused to the Wye by additional chicken manure – when all parties accepted that that was not the case. She observed that the FRfW are “a regulatory regime which beyond any doubt had failed to protect the environment from harm” and that HCC was justified in adopting a policy that recognised the FRfW were failing to operate effectively.

That is a clear win for common sense and realism given that historically developers often argue in planning cases that environmental consequences will be dealt with by other regulatory regimes, and so should not be the subject of planning controls.  The judge was clear that planning authorities did not have to make any such assumption, where there was clear evidence that other regimes were failing, as is all too often the case.

River Action chair Charles Watson said:

”This historic court ruling marks a major victory both for the River Wye and rivers generally across the nation and it exposes yet another attempt by the NFU to push back on important initiatives intended to end the blight of agricultural pollution in our rivers. 

We believe the ruling clarifies once and for all that the intensive factory production of livestock is clearly an industrial manufacturing process, whereby the often-toxic waste that it produces must be treated as such. 

This landmark ruling should set a vital precedent not just for other planning authorities to embed similar enhanced protections into all planning applications for livestock production developments. It also demonstrates that our environmental regulators need to now take urgent action to enhance pollution regulations to reflect the serious threat that intensive livestock production clearly poses to the health of our rivers.”

River Action was represented by Carol Day, Ricardo Gama and Julia Eriksen of Leigh Day and David Wolfe KC (Matrix Chambers) and Peter Lockley (11 King’s Bench Walk).

Leigh Day environment team solicitor Carol Day said: 

“The NFU sought to challenge common-sense policies in the Minerals and Waste Local Plan requiring new poultry units to have a detailed plan for disposing of chicken manure on the basis that the manure is not waste in law and therefore not covered by the MWLP.

“The judge resoundingly agreed with River Action that chicken manure is classified as ‘waste’ in law. This judgment vindicates HCC’s approach and is a victory for the River Wye and the wider environment.”

This means that people proposing new Intensive Poultry Units in Herefordshire will need to put in place proper arrangements for dealing with the huge volumes of manure that is produced. The judgment should also now mean that proper environmental controls are put in place across the country to oversee the production and handling of manure from animals on farms.”

—ENDS–

You can read the full judgment from the High Court, here.

Ofwat ‘acted unlawfully’—forcing customers to pay twice for failures, say campaigners

Environmental group River Action has accused Ofwat of acting unlawfully by using recent, significant bill hikes to cover past infrastructure failures—forcing customers, rather than investors, to foot the bill for decades of neglect. This is despite Ofwat having committed to put in steps to prevent customers paying twice.

Instead of funding essential new water and sewage projects, these price rises—approved in last year’s Ofwat price review—could be being misused to fix long-standing issues that should have been addressed years ago. This means there is nothing to stop customers from being charged twice to clean up an environmental disaster in the nation’s rivers, seas and lakes caused by chronic underinvestment in Britain’s water infrastructure.

River Action’s legal challenge against Ofwat

River Action has taken the first step in a legal challenge against Ofwat, on the basis it acted unlawfully in its Price Review 2024 (PR24) determination for United Utilities. The challenge focuses on funding allocated for wastewater treatment works and pumping stations in and around Lake Windermere.

River Action argues that Ofwat unlawfully approved ‘enhanced funding’ from customers without a mechanism to ensure the money will be used solely to improve sewerage services; rather than bring services into compliance when that should have already happened under past schemes. This means there is nothing to stop customers paying twice for services that have not yet been delivered.

This follows detailed investigations by campaign groups Save Windermere and Windrush Against Sewage Pollution, which exposed significant and systemic flaws in Ofwat’s approach.

River Action is taking legal action to compel Ofwat to reassess its PR24 determination for United Utilities in relation to Windermere and to encourage Ofwat to reassess other water company schemes wherever there are concerns that customers are unfairly covering the cost of past failures. However, River Action is not calling for PR24 to be overturned or for investment levels to be reduced, recognising the urgency and importance of increased investment in Windermere and elsewhere.

Windermere: A damning example of regulatory failure

United Utilities, currently under fire after evidence obtained by the campaign group Save Windermere, revealed 6,000 hours of raw sewage was discharged into Windermere last year, and is a case in point. River Action has commenced legal action claiming Ofwat has allowed the company to divert funds meant for future projects to deal with past failures—rather than investing in vital improvements to wastewater treatment and pumping stations around the lake.

Campaigners warn that millions of pounds intended for infrastructure upgrades may be used to patch up outdated and crumbling water and waste systems—exacerbating the pollution crisis in England’s largest and best-known lake.

A system rigged against the public

River Action believes this problem extends far beyond a single water company. Under PR24 (Price Review 2024), Ofwat has likely permitted other firms to operate in a similar way—leaving billpayers to pick up the tab for failings that should have been fixed with previous funding.

Emma Dearnaley, Head of Legal at River Action, said:

“We believe Ofwat has acted unlawfully by approving these funds without ensuring they are spent on genuine improvements to essential infrastructure. Instead, this so-called ‘enhanced funding’ is being allowed to be used to cover up years of failure.

“Effectively, Ofwat has signed off on a broken system where customers are being charged again for services they have already funded—while water companies continue to mark their own homework and pollute for profit.

“This scandal must be addressed. The cost of fixing the UK’s crumbling water infrastructure should fall on the companies and their investors—not on the British public.”

Leigh Day solicitor Ricardo Gama said:

“Ofwat has said again and again in public that it won’t let price rises be spent on fixing historic issues which are leading water companies to breach their permits. They’ve said in black and white terms that customers won’t be expected to pay twice. But in documents seen by River Action it looks like Ofwat hasn’t done its homework in checking whether the money it’s letting United Utilities take from customers will actually be used for that purpose. River Action believes that this is reflective of a broader lack of due diligence by Ofwat over the decades, which has led to money not being spent on infrastructure improvements and instead being diverted to investors’ pockets.”

River Action is calling for immediate regulatory action to ensure water companies stop passing the cost of failure onto customers—and start taking responsibility for the environmental damage they have caused.

ENDS

Dr Alison Caffyn: “Chicken farm… or factory?”

I have had to address this question twice in the last week. Both times I was chatting with people from conservation charities in Shropshire about the environmental impacts of intensive poultry operations locally. Both times the individual expressed sympathy with chicken farmers – along these lines: “It’s been so difficult for family farms in the last few years; what with low farm gate prices, huge shifts in support mechanisms and challenging climate changes. One has to symphathise if they feel their only option is to put up a chicken shed or two.” Each time I have tried to rebalance their perceptions of a typical ‘chicken farm’ in this area.

Firstly, it is true, there are some operations which fit the above description, particularly on and over the Welsh border. Small, one shed, free range egg units with, commonly, 16,000 birds operating in upland landscapes, diversifying from unprofitable sheep or cattle businesses. There are even some older chicken operations producing a few thousand organic and free range birds for the local market – but these are few and far between. The vast majority of intensive poultry units have capacity for 30-90,000 hens or many hundreds of thousands of broiler (meat) chickens.

When I interviewed farmers and land agents in Shropshire and Herefordshire for my research we discussed farmers’ motivations for going into poultry. I even developed a typology. The five ‘types’ included the ‘desperation factor’ described above. But there were also: older, large, well-established broiler operations – some dating back to the start of the industry in the 1960s and some still owned by the chicken processing company (Cargill). There were many large farms which diversified into poultry in order to support other farm enterprises. There were several large estates developing poultry as a new venture (for tenants) and finally, a few cases where investors had made speculative land purchases in order to set up a new poultry operation.

Some older sites have been expanded in stages over the decades with some IPUs now having 10-16 ‘sheds’ and up to a million birds. I was told the average return on investment (of about £500,000 per shed at the time) was ten years. Sooner, if the site installed biomass boilers and the like to receive generous Renewable Heat Incentive payments. Some IPUs were making substantial annual profits.

I’ve done a bit of number crunching to check my facts. The average size of all 150 odd IPUs in Shropshire is 131,000 birds. Broiler units are larger on average, housing around 200,000 birds per four sheds. Egg units are generally smaller averaging 83,000 hens – but that includes both several units with only around 4,000 birds and one large egg operation with nearly 2 million.

I have walked close to or through many IPUs in Shropshire and Herefordshire and spent more hours than I care to admit poring over satellite imagery of all the others. Most don’t look or sound or feel or smell like a farm. The brooding 100m long sheds, the acres of concrete, sickly reek and eerie stillness are not what you would expect on most farms. The operation is overseen on the site manager’s laptop or phone. There is a periodic rattle of feed being pumped along automatic feeding tubes. There will be someone who walks through each shed once a day to pick up the dead birds. Until, after six weeks, the lorries arrive to take the birds away to the processing factory.

You get the picture. And that picture is more factory than farm. An agricultural factory, in a rural location. But not a farm. And, indeed, many farmers say exactly this themselves.

We need to take this growing diversity of agricultural operations into account when addressing the impacts of the industry. No one want to accuse all farmers of environmental harm. Many are doing amazing, progressive things to transition towards more sustainable farming systems. Only a small percentage of farms locally have intensive livestock operations, but their environmental impacts far outweigh those that do not. But out of date perceptions and misplaced sympathy are not helpful – although they are often promoted by farming lobbyists.

Dr Alison Caffyn – River Action Advisory Board member

Emma Dearnaley joins River Action

We’re delighted to introduce Emma Dearnaley, our new Head of Legal at River Action. In our latest blog, we get to know more about Emma and the role that she will play to help rescue Britain’s rivers.

  Q1. Tell us about yourself

  Hello – I’m Emma.

I knew from pretty early on that I wanted to be a lawyer and, although I’ve now had a range of jobs, using the law has been the thread that has run through them all. I’ve charted my own course through roles in commercial and civil litigation at a global law firm, law enforcement, government policy and non-profits – before settling in environmental campaigning.

I decided to leave conventional City law in 2018 having become increasingly curious about the law’s societal role (and my own, as a lawyer) and frustrated by its lack of accessibility to those without power or deep pockets. A period of exploring roles acting in the public interest then followed. It was during my time at Good Law Project that I received a loud wake up call that made me realise I wanted to use my skills, experience and energy to find solutions to the interconnected climate, environmental and nature crises.

Alongside my day job, I am a trustee of two social justice charities – Cranstoun and Music of Life – who I support in their missions to, broadly put, empower people to make positive changes in their lives.

I am a pragmatic optimist driven by the need and opportunity to take action to protect and restore our rivers and environment, for us and for future generations. I believe nothing is more essential than this.

Q2. You were previously the Legal Director at Good Law Project (GLP).  Tell us more about the role and your biggest highlights leading its legal work.

  GLP is a campaign organisation that uses the law to hold power to account, protect the environment and uphold the rights of people and communities. As its Legal Director, I was responsible for developing and leading its strategic litigation and other legal work and I was part of its senior management team.

It was a fantastic role that provided a full immersion in legal campaigning – by which I mean the use of legal tools and processes to achieve change as part of a campaign strategy – and gave me the chance to work on many different issues of importance. GLP is probably best known for its work exposing the government’s ‘VIP lane’ for Covid-19 personal protective equipment contracts and Partygate, but it was the climate and environmental work that I was most drawn to and I proactively grew this strand of work.

The first case I developed was what became a judicial review against Defra’s Storm Overflows Discharge Reduction Plan and GLP’s ‘Clean Waters’ campaign. As well as pushing for Defra’s plan to be improved (which it was as a result of one of our arguments), we looked to use the litigation to revive an English legal principle called the public trust doctrine that says the state has a duty to safeguard vital natural resources including rivers and hold them in trust for the public. That argument didn’t succeed in this case – we always knew it was very ambitious – but it may yet be used to protect water, as well as resources such as air, in cases that are to come – with its recognition in some US states giving cause for optimism. Beyond the legal outcomes, this campaign raised public awareness and – together with the work of other groups like River Action – helped to push the sewage pollution scandal up the political agenda.

I am also really proud to have worked with Friends of the Earth and ClientEarth to bring legal challenges that resulted in a High Court ruling that the government’s Carbon Budget Delivery Plan was inadequate. This significant win secured greater transparency, accountability and ambition, with the government required to revise its plans to include more robust measures to meet emission targets.

A major highlight came at the end of my time at GLP when the Supreme Court gave its landmark ruling in the Manchester Ship Canal v United Utilities case – in which GLP supported the Environmental Law Foundation to intervene and evidence the systemic nature of United Utilities’ failures – that ended the impunity of water companies for the damage they cause through sewage discharges. This judgment means that people and communities can now use private law nuisance and trespass actions to hold polluting water companies to account – and it is heartening to see claims being formulated off the back of this judgment and the law continuing to develop to provide clear avenues for challenge and protections for rivers and communities.

It was a joy and education throughout my time at GLP to meet so many inspiring people across the social justice, climate and environmental movements. It was through participating in a water strategy group that I first met Charles and James at River Action and started working with them, impressed by their focused and generous approach to environmental campaigning.

  Q3. Tell us about your new position as River Action’s first Head of Legal.  What can we expect to see from your role in 2025?

There is huge potential to use the law together with other forms of influence to move the dial on rivers in 2025 and beyond, especially with the newly formed Water Commission, public awareness at an all-time high, multiple routes of challenge available, and great opportunities for collective and community action across the country.

In my role, I expect to work with government to strengthen laws and policy. I expect to push organisations and companies to stop their polluting and environmentally damaging practices. And I also expect to take legal action to enforce the law or to make sure that others do, while recognising that you don’t need to bring or win every legal case in order to make people think harder about the decisions they make and what they choose to do.

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

Rescuing the UK’s rivers is a big and complicated challenge that requires a big and committed ecosystem of actors. Collaboration will be key.

It will require government, agricultural producers, industry, supply chain participants and water companies to make systemic changes and for them to be held to account by regulators and civil society. It is essential that the government sets ambitious policy and that regulators are effective after decades of inaction and underfunding. There are plenty of water and environmental laws that exist already and they would be good laws if they were adhered to and enforced. Now more than ever it is vital that we hold feet to the fire over failures and push for sustainable solutions to be identified and implemented.

Ultimately I think the power to deliver change comes from political and corporate will. But there is plenty that can be done to influence and apply pressure – and I’m excited to be at an organisation that is able to do that using a full toolbox, including by using the law and litigation when necessary.