Three months ago, Defra opened a consultation on a suite of targets which will help deliver the government’s vision of “leaving the environment in a better state than it was found”. The targets, a key commitment in the Environment Act, set long-term ambitions for successive governments to restore, protect and clean-up our natural world  

The current precarious state of our rivers, lakes, estuaries and coasts means that the water environment is in dire need of such targets. Statistics demonstrating this are now depressingly familiar: none of our waters achieve standards for chemical pollutants and less than a fifth meet ecological standardsⁱ; untreated sewage was released from storm overflows in England over 300,000 times last year_ⁱⁱ, and 13% of freshwater species are now threatened with extinctionⁱⁱⁱ. 

That four water targets are proposed, instead of the minimum requirement of one, shows that this need is well recognised. But will these targets add up to a coherent whole?   

None of our waters achieve standards for chemical pollutants

What are the targets? 

One target proposes to reduce metal mine pollution by 50% - yet if the Government would commit to better funding, it’d be possible to improve around 75% of rivers blighted by this issue.

Another target is set for reducing water abstraction – taking water from rivers for our own use – because this has left many waterways with low flows and little wildlife. The water demand target aims to reduce domestic and business water use by 20%, but it’s worrying that the target is measured ‘per head of population’ rather than being set as a defined quantity of water. This leaves nature having to bear the risk that, as the population increases, any water savings per head could be more than offset by growth in population, and we could end up with more water being taken from rivers in future than there is today.  

The remaining two targets tackle nutrient pollution from sewage and from agriculture.  Phosphorus from treated wastewater will be reduced by 80%, and phosphorus, nitrogen and sediment from agriculture by 40%. Collectively, these offer the opportunity to see phosphorus levels brought down to within ecologically acceptable limits, particularly if the water sector can work beyond the confines of wastewater treatment works to support reductions elsewhere in the catchment. But for nitrogen and sediment the picture is less clear.  

Agriculture is now the sector responsible for the greatest number of ‘reasons for failure’ against water targets, having taken the unwelcome title from the water industry. In what could be an end-result that satisfies no-one, 40% reductions in agricultural pollution are likely to be both extremely difficult to achieve, and insufficient to allow our waters to recover – expert advisors to Defra suggested 50% may be closer to what the environment needs.  

Agriculture is now the sector responsible for the greatest number of ‘reasons for failure’ against water targets

One welcome proposal is to target by catchment, rather than trying to achieve a blanket 40% reduction everywhere. In some areas we may already be close to the kinds of pollution levels that the environment can tolerate, needing only limited additional reductions, whilst elsewhere we may need huge improvements; this would target effort where it really matters. The evidence pack accompanying the consultation says that to enable us to meet these targets, we will also need: 

• High compliance with regulation: although this will require resourcing for advice and enforcement, it doesn’t seem unreasonable that businesses should comply with the law. 

• Targeted land use change: around 20% of agricultural land will need to be converted to semi-natural habitat. If this is targeted at the most polluting land uses, improvement in excess of the 40% target could even be achieved.  

Land use change is the aspect that will most likely divide opinion. With a cost-of-living crisis and unstable global supply chains, to take land out of agricultural production could seem counter to food security aspirations. But that is to over-simplify a complex discussion.  

It’s not as black & white as delivering food or protecting nature.

The Independent Review of the National Food Strategy noted that “much of the land that is best suited to nature restoration and carbon removal produces little food”, with the least productive 20% of our land producing only 3% of our calories. Of course, that is not necessarily the same polluting parcels of land where we might need to make changes to prevent water pollution, but it serves to illustrate the point that it’s not as black & white as delivering food or protecting nature. Indeed the UK Food Security Report published last year identified the biggest threat to the UK’s domestic production as coming “from climate change and other environmental pressures like soil degradation, water quality and biodiversity [loss].” 

This means that we need now, more than ever, continued commitment to ensuring that farming subsidies are redirected to secure the delivery of ‘public goods’ like nature recovery and carbon storage – a prospect that seems increasingly under threat as funding pledges are watered down. This U-turn from Government seems at odds with the ambition to reduce water pollution, as well as to halt the decline of species – both activities which the government knows are essential to the resilience and prosperity of British farming.  

Collectively, the proposed water targets will serve to tackle problems which have proven difficult to solve until now, but the ambition could be much higher, and the delivery mechanisms are looking under threat before we have even started.  

And then, even if met, would this mean that the water environment had recovered? Sadly the answer is ‘No’. Wastewater and agricultural pollution are major pressures, excessive abstraction is an ever-present threat, and mine pollution causes severe problems where it occurs, but these are not the only pressure our waters face. A cocktail of chemicals, a history of modification that prevents waters functioning naturally, and invasion by non-native species are all problems that must also be tackled.  

 The complexity of these threats mean that we also need an overarching target for the health of the water environment. Without it, we could see improvement in a few specific issues whilst overall our waters continue, tragically, to decline.