P-06-1398 To act to increase the effectiveness of Natural Resources Wales in halting pollution on the Teifi – Correspondence from the Petitioner to the Committee, 14 April 2024

 

 

 

Petitions Committee

Senedd Cymru

Cardiff Bay

Cardiff

CF99 1SN

 

Dear Petitions Committee Members

 

Many thanks for providing us with an opportunity to comment on the document provided by Julie James in her former role as Minister for Climate Change and to provide further comments related to the state of Welsh Rivers and the resources available to NRW.

 

The letter from Julie James has clearly summarised the work that is currently being undertaken along the Afon Teifi and other SAC Rivers in Wales and we agree that a wide range of stakeholders need to work together to resolve the issues Welsh rivers are facing.

 

The petition was submitted by the Save the Teifi Community Group in July 2023 and we have been actively working with NRW, Dwr Cymru/Welsh Water, the Teifi Nutrient Management Board, Local Councils and West Wales River Trust to raise awareness of the issues and seek collaborative solutions. During this time we have been involved in numerous meetings, listened to Senedd debates and seen some progress. However the rate of progress is very slow and we remain concerned that the rate of change may end up being too slow to save endangered species – atlantic salmon, otter, water crowsfoot and sea lamprey are all in critical decline. We would like to draw the committee’s attention to the following points.

 

1. The Teifi Demonstrator Catchment Project – We recognize that this is a positive development that it is producing collaborative working. In particular the farming community is starting to engage with the project – essential if agricultural pollution is to be tackled effectively.   At present however the project has no funding since the bid to the Ofwat Innovation Fund was not successful. It thus looks like this innovative 5 year project will have no funds to move it forward for the first 12 months or more. This is disappointing.  In other parts of the UK (e.g. Northern Ireland) SFS funds are being utilized to encourage changes that will support river quality, climate change resilience and natural ecosystems. Whilst we recognise that the proposed SFS changes are a contentious topic it highlights that trialing innovative policies in the Teifi catchment could provide a broader Team Wales approach rather than just rely on NRW using its experimental powers within the catchment. There needs to be an immediate ban on bare over-wintered fields (such as post-maize production) and an urgent display of innovative alternatives to slurry spreading and sewage treatment – eg dessication, biogas, fuel - creating solutions across the board that benefit more than just one sector

 

2. Dwr Cymru/Welsh Water Investment – It was good to see that Dwr Cymru/Welsh Water have been proactive in establishing plans to significantly reduce their contribution to phosphate levels over the next 6 years. This is however only one source of this nutrient and whilst it might be the largest contributor for the Teifi (66%) that is not true of any of the other SAC Rivers. Nutrients from landuse form a significant element and we need policies and collaboration that will reduce these sources but at the same time support our rural economies. We also need to be mindful of the fact that Wales contains many other rivers and we should be trying to enhance the quality in all our water bodies and not just the SAC Rivers. It should also be noted that Dwr Cymru/Welsh Water’s response to spills from Combined Sewage Outfalls is much slower despite the growing concern expressed by their customers. Whilst the issue can not be fixed in the short term the view that it will cost too much should not be accepted. Rather a long term plan needs to be agreed to produce a sewage system fit for the 21st Century rather than the 19th, with a focus on decoupling rainwater from the system to ease pressure and we would also urge them to install wetlands and SUDs to hold excess stormwater.

 

3. Funding for NRW – It is clear that funding for the Welsh Government and local councils is stretched and we are not surprised that it is having an impact on funding levels for NRW (a freeze on replacement posts, reduced sampling/monitoring, having to prioritise pollution incidents). We remained concerned that if there are insufficient funds then NRW as the national environmental regulator is unable to perform its key activities effectively. We would thus urge the Senedd to explore new ways to support NRW. At the recent Senedd debate it was noted that when NRW take a polluter to court the fines generated from a successful prosecution go to the Westminster Government rather than the Welsh Government. We would thus urge the Senedd to demand that such fines should be redistributed to NRW, not to just cover their costs involved in the case but to also help fund the activities of the regulator. We would also support the idea of the polluter being liable for habitat restoration and biodiversity enhancement.

 

4. NRW and Citizen Science – As Julie James notes NRW has recently published a policy document which outlines their approach to Citizen Science. Whilst we accept that the document provides groups with a clear mechanism to identify possible projects and gain approval from NRW it is a very bureaucratic process. The citizen science group have to be supported by a reputable organization (e.g. University, River Trust, Charitable Organisation), submit detailed paperwork outlining what they intend to do and then have to wait for approval or rejection. We believe that NRW have missed a significant opportunity here. They need to recognise that citizen science provides them with a real chance to access volunteers with a wide range of skills and thereby fill in numerous gaps in the existing monitoring framework. Rather than investing staff resources reviewing proposals it would be better to invite volunteers to provide details of their expertise and willingness to participate in a range of activities. NRW should be proactive and indicate what they would like the citizen scientists to do and to provide the appropriate training to complete the task (e.g. removing invasive species, analysing data, undertaking surveys).  It is a broader Team Wales approach, where NRW organizes volunteers to support their work rather than making it difficult for the community to engage.

 

5. Team Wales Approach – The letter from Julie James and recent Senedd discussions have made reference to the Team Wales approach. This has resulted in close working between NRW and Dwr Cymru/Welsh Water. We recognise that positive collaborative working between key stakeholders is beneficial but it needs to be a delicate balance. NRW is the environmental regulator with DC/WW being a key company that it needs to regulate. The Senedd and Welsh voters need to be confident that the relationship is appropriate and that decisive action will be taken where necessary. The water industry appears to have a complex array of regulators (NRW, Ofwat, DWI) and it is difficult to determine how effectively they work together. For example for the last two decades Ofwat appears to have placed emphasis on keeping customer bills low and allowing returns for investors rather than investment in updating capital assets which has had an impact on the environment and as a consequence working against the environmental regulator. The Senedd should be proactive to ensure the regulators are working for Wales and its future generations, not the water industry.

 

Best Wishes

 

 

Save the Teifi Community Group.