Without one, how will we measure success? At a minimum, its aim should be to secure immediate action to ensure that the burdens on the Wye do not increase from here. Success measures should include: improving trends in water quality, and improving status of the Wye’s Site of Special Scientific Interest units.

The plan aims to stop the decline of the Wye, transforming how manure is managed and supporting the creation of new habitat to keep nutrients and sediment in the field whilst also making space for nature. This aim meets our minimum test and provides a welcome building block in the longer-term recovery of the Wye. As a ‘catchment pilot’ in a river system where nutrient neutrality applies, it will also be valuable to test approaches here that can then be employed across other failing sites. However, the ambition of the plan beyond simply ‘stopping the decline’ is unclear; as such it is a welcome first step to start the river’s recovery, rather than the complete solution.

Does it include measures that will see the reasons for decline resolved? These are water quality (requiring reduced phosphate inputs) and species declines requiring projects to mitigate the impacts of climate change that exacerbate the harms caused by pollution.

The plan highlights the state of the river’s Atlantic salmon, river invertebrate and aquatic plant communities as indicators of its decline. It does set out actions that will benefit these species, but it is not specific about whether, or how quickly, it might bring about their recovery.

As a causal factor in their decline, actions in the plan focus on reducing phosphate pollution. But without setting a timebound target on water quality, it will be difficult to judge whether the plan is progressing towards its aim. When the Taskforce is established, setting explicit and ambitious goals agreed by key partners will be an important first move.

The UK is signed up to the COP15 Global Biodiversity Framework, with a goal to protect 30% of the world's lands, oceans, coastal areas and inland waters by 2030. Target seven of the framework requires us to reduce ‘excess nutrients lost to the environment by at least half’, because of their severe impacts upon nature. How does the plan ensure the nutrients generated in the Wye catchment will not continue to cause harm there or anywhere else?

The reduction of phosphate pollution is a welcome focus of UK Government’s plan. Central to the plan’s ambition is a proposal to amend permitting regulations to require farms to only export their manure where it will not result in the application of excess nutrients. This will place the onus on the producer to ensure that their product does not cause environmental pollution, complementing the responsibility, which would already apply to the recipient. However, given that existing requirements are not adhered to, simply adding additional requirements is, alone, unlikely to resolve the problem. This action will need to be backed up with advice and inspection - including across the numerous smaller farms that fall outside of the permitting regime, and which produce 20% of the poultry mature generated in the catchment.

In addition, the piloting of Micro Anaerobic Digesters and a grant scheme of £35m for on-farm poultry litter incinerators in the Wye Special Area of Conservation (SAC) catchment are proposed, to facilitate the export of poultry manure as a valuable product, and enable local energy generation. However, this also risks perpetuating high chicken numbers, along with the unsustainable practices and enablers associated with intensive farming, such as imported feed. The micro-AD trial must therefore ensure that localised pollution events related to anaerobic digestors are eliminated, and both schemes must establish best practice around the generation, transport and onward use of their product. 

Beyond nature targets, the plan should also be mindful of the wider benefits that can be secured by rapid action. The Wye is important to walkers, canoeists, boaters, anglers, wild swimmers and others, and their thousands of visits bring economic benefit to the area; a benefit which is placed at risk by perpetual pollution. Meanwhile, inaction sees growing costs to the taxpayer of managing the impacts of pollution. Recognition of these risks and burdens should underpin the setting of ambitious goals for the catchment plan.    

At The Wildlife Trusts’ Roundtable, attendees endorsed the key recommendations in the report by the Universities of Leeds and Lancaster, which considered the scale of phosphate pollution, and concluded that: the phosphate input pressure needs to be reduced (we cannot continue to focus just on mitigation), that livestock manure loadings to the catchment must be reduced, that existing regulations need to be better enforced, that incentives are needed to encourage farmers to draw down ‘legacy’ phosphate reserves from high-risk soils, that improvements to monitoring and data sharing are needed to aid decision-making and transparency, and that substantial scaling-up of coordination, engagement and support is needed to secure all of this. Does the plan recognise all of these challenges? Does it provide a platform for action?

The plan is light on reducing nutrient input pressure (as opposed to impacts), only highlighting existing farm diversification options for those who may wish to de-intensify, which is a missed opportunity. The focus on improving regulations draws attention away from criticism over how existing regulations are enforced, yet the concerns of stakeholders over regulators’ capacity and approach to enforcement are unlikely to be fully resolved by these announcements. The plan is also silent over monitoring needs (although it does recognise the value of the citizen scientists that have helped to shine a light on the state of the Wye) – given that data disputes have been a cause for inaction, this is an area where the plan should go much further. Evidence rather than incentives is the focus when it comes to thinking about how farmers can begin to draw down legacy phosphate from the soil; so any trials should focus on high-risk areas to make the greatest difference.

In all, the plan is light on detail of exactly what will be achieved regarding water quality, prioritising phosphate reduction (as is necessary) but without setting out to what extent it aims to do this. However, it does at least provide a platform for action which has political backing; something that has been absent, and which we hope will secure concerted effort to restore the Wye.

Does the plan speak to how agencies on either side of the border can work more effectively together, and how regulation and policy can be better aligned?  Does it ensure that decisions taken in Wales will not have adverse impacts for parts of the river in England, and vice versa?

The very first line of the plan notes the cross-border nature of the river, and dotted throughout this Defra document are mentions of Wales. The appointment of a River Champion who will report directly to the Secretary of State gives a welcome political focus, and she will establish and lead a River Wye taskforce to develop and implement a Catchment Plan to restore the Wye. This is a welcome mechanism, although the plan provides no specific detail of how collaboration and cohesive cross-border management will be secured, and many of the actions and the majority of the projects and funding sources referred to are specific to England. Will this process also report to the Welsh Assembly? How will actions and funding that relate to the Welsh parts of the catchment be ensured? These are challenges that have so-far proven difficult to resolve, so it will be crucial to rapidly set out the detail of how the taskforce will meet the cross-border needs of the catchment.