The ‘Diffuse Water Pollution Plan - River Wye Special Area of Conservation, November 2025’ document is attached for ease of reference; this is the same version distributed to board members on 24 November 2025.

[Environment Agency]

The main points of the discussion on the ‘Diffuse Water Pollution Plan - River Wye Special Area of Conservation, November 2025’ (DWPP) included:

a.           Pat Stirling made observations about the identified issues with diffuse agricultural pollution, particularly run-off, and the suite of mitigation measures, noting that a focus on regulatory compliance would not deliver the reductions needed.  Martin Quine said that the mitigation measures would contribute towards reductions but acknowledged that there would still be a gap, highlighting the need for further research to identify additional measures and mechanisms.  In response to a question about the level of commitment to deliver the range of options presented,  Martin Quine explained that: the DWPP was an updated evidence base which identified the actions needed to reduce nutrients, albeit it did not come with funding; there was delivery against some actions already and others required more investment or work with the supply chain; significant resources were already being deployed in this area; and the DWPP provided the evidence for the direction of travel.

b.           Pat Stirling requested that best efforts be made to produce a forecast of what would be achieved, based on the actions identified in the document, with specified timeframes.  Andrew McRobb supported this request, stating that the board needed to understand what was going to happen and by when, along with measurable impacts such as reductions in kilograms.  Councillor Maby endorsed this suggestion; comments were also made about the need to combine the English and Welsh evidence, and the need to identify and highlight resource issues.  At the discretion of the Chairperson, James Marsden reminded the board of the Environment Improvement Plan targets and said that it should be feasible to plot a trajectory to identify the extent of the gap; a comment was also made about the reductions to the budgets of environmental regulators over the past decade.

c.           Councillor Charlton said that it was clear from the DWPP and the Evidence Base for Wales that no single agency or authority could achieve the priorities on its own but there was currently a lack of a clear strategy for collaboration, to assign responsibilities, or to monitor progress; adding that, despite ongoing uncertainties, action was necessary and on a cross-border basis.

d.           Louise Bodnar questioned the extent to which the board was able to input into the strategic priorities and said that existing research pulled together by WWF into the effectiveness of different mechanisms to reduce diffuse pollution should be utilised.  Claire Minett noted that there was an item on the Nutrient Management Plan later in the agenda and outlined how Natural England used research and evidence to target advice on farming practices.

e.           Louise Bodnar commented on the effectiveness of buffers in reducing diffuse pollution into rivers, streams, and ditches but noted that this was not identified as a strategic priority.  Claire Minett commented on voluntary initiatives and need for collaboration across sectors.

f.             Merry Albright considered that: the DWPP did not say what actions were required and by when to bring the river into favourable condition; further assessment of a  Water Protection Zone was needed, as uptake and delivery of voluntary measures could not be relied upon; the work of Welsh Water had been acknowledged appropriately; developers had made significant contributions to offset nutrient loads from new housing but this could not remedy diffuse pollution from other sources; the ‘85% reduction of loads’ for the Lugg should be quantified in terms of kilograms; and targeted action may provide better value for money.

g.           Martin Quine clarified that the judicial review concerning the Water Framework Directive was distinct from the judicial review related to the Habitats Regulations, with each involving different legal frameworks and obligations.  Clarifications were also provided about the designations and targets in different parts of the catchment.

h.           In response to a question from David Gillam, Martin Quine commented on the potential for a feasibility study for a Water Protection Zone but a timeframe or indicative process for this could not be provided.

i.             The Chairperson noted that, in addition to Herefordshire Council’s motion in favour of a Water Protection Zone for the whole of the River Wye system (Full Council minute 31 of 28 January 2022 refers), the Wye Catchment Nutrient Management Board had voted to submit its own request in January 2022.

j.             The Chairperson commented on the need to explore the cost benefit analysis of potential actions, including broader opportunities such as flood prevention, flood alleviation, and biodiversity net gain.

k.           A request was re-iterated for an indication for the reduction that would be achieved and over what timeframe.  The Chairperson questioned whether it would be possible to expand the DWPP to include such a trajectory.  Martin Quine said that the DWPP had been developed jointly by the Environment Agency and Natural England, and that feedback would be provided to the agencies.

l.             Simon Evans commented on: the significance of other actions to meet water quality conservation objectives; the difference between phosphate and phosphorus; and the implications of soil loss in the vicinity of the Black Mountains.

m.         Councillor McDermid commented on the need to raise issues at a higher political level, including the constraints of voluntary approaches and concerns about strategic issues such as water supply into the future, housebuilding commitments, and wastewater management.

n.           The Chairperson questioned whether the number of Ground Water Source Protection Zones within the English portion of the catchment, as referenced at page 67 of the DWPP, had resulted in guidance being issued.  A response could not be provided in the meeting.