Our priorities as a Wildlife Trust are to conserve and enhance habitats and declining native species in Gloucestershire. Therefore, Gloucestershire Wildlife Trust determines its position on issues on nature conservation grounds.
Rivers are the lifeblood of all species. All life needs water and rivers support flourishing landscapes and wildlife, while also being vital for human survival and the economy.
We are lucky to work in a county with some of the UK’s most iconic, important and beautiful rivers and freshwater habitats.
The Trust works to protect our rivers through delivering projects on the ground, supporting and empowering other stakeholders, and campaigning for change. Through our conservation, advocacy, campaigning and communications activities, locally and nationally, we stand alongside the many individuals, organisations, groups and wider riparian community in speaking up and taking action to stop the pollution of our waterways and protect our rivers and seas.
However, despite the efforts of the Trust and many others who work tirelessly for our rivers, the condition of these wonderful waterways is increasingly a cause for huge concern. Our rivers are facing multiple threats which are having a devastating impact on water quality, our natural heritage and the wildlife which dearly depends on it.
As the recent State of our Rivers report laid bare, the situation continues to get worse. None of England’s rivers stretches are in good or high overall health – 0% are in good overall status, 0% are in high overall status, 23% are classed as in poor or bad overall status, and 85% of rivers stretches fall below good ecological standards.
In Gloucestershire, we are witnessing the direct impact from deteriorating conditions. Atlantic Salmon have now (Dec 2023) been classified as ‘Endangered’ by the IUCN and Eels are ‘Critically Endangered’ with numbers entering the Severn now reduced by at least 95%. Run-off from poor land management has led to rivers such as the Wye making national headlines, for all the wrong reasons.
This situation is totally unacceptable; our rivers are suffering due to systemic failures, a lack of investment, poor regulation and a lack of joined-up policy. Over many years, we’ve seen:
- Failure by the water industry to properly invest in the infrastructure needed to treat wastewater and manage water resources sustainably.
- Failure by government to set ambitious and stringent targets for water and ensure regulation is fit for purpose to drive improvements.
- Poorly resourced enforcement agencies who have failed to monitor water quality and hold polluters to account.
- A lack of appropriate funding and regulation to deal with agricultural pollution.
- A lack of joined-up policy when it comes to the planning system and development and its impact on water.
To achieve our vision and strategy for a wilder Gloucestershire, which includes restoring our rivers, it is vital that we use a variety of different levers and work with a wide range of people and organisations.
The Trust achieves impact in three main ways:
- through delivering projects, like restoring rivers and wetlands, buying land for wilding or creating new habitats;
- through supporting and empowering others, such as providing land advice or training communities;
- through our policy and evidence work. Our 2024 General Election top 5 asks of the new government included the demand that they act to stop river pollution, and we continue to campaign for change through campaigns such as Clean Water Now.
Over decades, the Trust has continually evolved its approach to focus our limited resources into areas that have the greatest impact, often relying on partnerships with others to amplify our efforts.
Water companies are one of the many different organisations that we work with and have done so for many years. We understand that for many people, working with water companies is a contentious and increasingly controversial issue, particularly in light of the high-profile incidents around sewage discharges. However, even in the light of this and actually, because of this, we think it is important to work with water companies to achieve a better future.
Given the scale of operation and impact of water companies, they have a crucial role to play in solving the many complex issues facing our rivers. We are very clear in our position that water companies must urgently improve their practices, invest in infrastructure and clean up their act, while also investing in vital projects like river restoration, wetland creation and catchment resilience as a matter of urgency. Conservation charities such as the Trust are well-placed with the expertise to deliver these projects.
By working with water companies to deliver meaningful improvements on the ground, we use the opportunity to influence their practices and push them to invest. These collaborations help to strengthen the Trust’s capacity to address water-related challenges in the local area, promote responsible water usage, and craft holistic solutions for environmental protection and sustainability.
However, that is not to say the Trust won’t criticise water companies, nor does any partnership-working with them stop us from calling out poor practice, campaigning for change or supporting groups and individuals in their own campaigning to protect our waterways.
The Trust works with water companies on a variety of projects, delivering contracted work, managing land that water companies own to create and protect amazing places for people and nature, and on advocacy and engagement, for example to promote water efficiency. Examples include Wildtowns and Water Guardians.
Alongside other partners, we deliver projects and contract work which significantly improves the health and quality of our waterways, and water companies work in partnership and/or provide funding for some of these specific activities.
The Trust has been at the forefront in the county focussing on work to protect and restore our rivers and wetlands. This work has included:
- Cotswold Rivers Living Landscape, a project that secured and enhanced the habitats and species assemblages in the land adjoining the river systems of the Cotswold Hills.
- Leading the a wide scale water vole project in the county in the early 2000s
- Overseeing a long running non-native plant eradication project on some of our most important streams.
- Working on various river restoration projects - most recently restoring the Holy Brook and its floodplain back to its original state. Our river restoration work has continued to improve fish passage, instream habitat enhancements and enhancing riparian zones.
- Delivering Natural Flood Management (NFM) projects across the county, providing better resilience to storm events, improving water quality, and enhancing biodiversity.
- Enhancing and reintroducing populations of White Clawed Crayfish to suitable stretches of river.
In addition to the daily activities, we currently carry out across our nature reserves to protect and restore wildlife, the Trust has a number of other projects which improve river health, hold polluters to account and seek to secure protection.
We currently jointly Chair and host the Severn Vale CaBA partnership. The catchment partnership with the Severn Rivers Trust which aims to facilitate and champion joint working between riparian owners, fishing interests, local communities, charities, government agencies, local planning authorities, and water companies to deliver catchment scale improvements. As part of this group we recently co-authored the Strategic Plan for the River Frome and are helping develop strategies for other priority rivers in Gloucestershire.
And together with our national policy team, we are continuing to lobby government to improve regulation of polluting industries and ensure that polluters are properly held to account.
Nationally, we work with The Wildlife Trusts’ policy team to lobby for stronger regulation of polluting industries, including through Wildlife & Countryside Link’s Blueprint for Water group. The Wildlife Trusts has made water its core policy focus for 2026, due to expected major reforms in England and Wales following the responses of the Westminster and Welsh Governments to the Cunliffe Review (Independent Water Commission)
Although we will work in partnership with various companies this does not mean that we endorse poor practice, and we always maintain the freedom to publicly criticise failings and damaging practices, regardless of any partnership or funding agreements which may be in place.
We would never compromise on this position and we have frequently shone a light on incidents such as pollution in recent years, through our communications, campaigning and conservation activities, both locally and nationally e.g. our asks during and since the general election.
Sometimes when companies (including water companies) are guilty of environmental infringements the Environment Agency, may decide that instead of prosecuting through the courts that an alternative method of recompense is acceptable. This generally requires the company to pay towards improvements in the water course or catchment where the infringement has occurred and ideally put right and improve the situation.
Where requirements for these types of actions aligns with work that Gloucestershire Wildlife Trust would like to carry out, and where we consider the work to be desirable and an improvement for biodiversity then we may agree to receive a payment from the company to undertake conservation projects. Payments arising in this way are termed “enforcement undertakings”. Below is a brief description but further information can be found on the Environment Agency website here.
“An enforcement undertaking is a voluntary offer made by an offender to:
- put right the effects of their offending
- put right the impact on third parties
- make sure the offence cannot happen again
it forms a legally binding agreement.”.
These payments to projects can only be made following assessment and agreement by the Environment Agency (EA) that they would be suitable in place of fines generated via prosecution. Therefore as Enforcement Undertaking as a resolution is only available to the polluter when the EA deem the following to be true:
- it is not in the public interest to prosecute
- the offer itself addresses the cause and effect of the offending
- the offer protects, restores or enhances the natural capital of England
Gloucestershire Wildlife Trust will consider any approach to deliver Enforcement Undertakings work on a case by case basis. We have accepted funds where we have had a project available that would clearly address elements of the impacts of the breach within the actual catchment involved. In all cases any proposed projects are put forward by the company to the Environment Agency (EA) who will agree (or not) that the project or certain elements of the project are a suitable alternative to the EA pursuing a prosecution and redress through the courts.
In an ideal world the original infringements wouldn’t occur, the environmental damage wouldn’t happen and there would be no need to spend the money making improvements, but where there are such occurrences we believe that the best use must be made of those monies and we are prepared to consider individual approaches on a case by case basis.