Claire Pillman

Natural Resources Wales

Ty Cambria

29 Newport Road,

Cardiff

CF24 0TP

20th December 2021

Re: Recognition of the value of Citizen Science Data for Water Quality Testing

Dear Claire,

Radnorshire Wildlife Trust are supporting Friends of the Upper Wye and Friends of the Lugg (FOL) with their citizen science monitoring on the Wye SAC and Lugg SSSI in Wales.  Together, we are covering the whole Wye catchment in Powys.

These community lead groups have been formed out of a grave concern for the River Wye.  A concern that Radnorshire Wildlife Trust share, hence our recent and on-going campaign which will evolve over the coming years until a suitable resolution is reached and the state of the Wye and its waters vastly improved.

The Wye citizen science initiative is catchment wide so also operates in England.  The Environment Agency have given start-up funding  for work in England and produced a briefing note on 18th November (Appendix 1) outlining how they will use the data to complement their own monitoring, working toward improving water quality and better directing resource to pollution incident management and monitoring.

Natural resources Wales have been actively engaged in discussions on citizen science data with the groups, with representatives often attending local meetings, and through Cardiff University Wye Catchment citizen science meetings. To date NRW have not been able to confirm what their position is on the use of citizen science data and have advised the Forum today that they will not make a statement until the end of January.  This disparity across the border is hugely disappointing.

Could you please issue a clear statement on NRW’s position regarding the use of Citizen Science data, detailing how you will support this vital and timely work.  60% of the river Wye SAC is failing on its water quality targets under the Habitats Directive.   

Natural Resources Wales are generating feelings of frustration and anger at a local level as they are perceived to show little concern for the scale of the problem and little will to take action to  return the River Wye to the biodiverse rich river it once was.

We trust that NRW will welcome the data and work closely with citizen science groups to extend the understanding about the state of the Wye and how regulatory measures and nature-based solutions can be targeted to help nature recovery.

If you wish to arrange a meeting to discuss this issue, please do not hesitate to contact us.  We would very much welcome the chance to walk the Wye and its tributaries with you to show you the scale of the problem and how important it is for NRW to tackle monitoring and enforcement, publicly, proactively and with efficiency.  Statutory duties aside, the public are willing you to help.  Fear, loss, anger, grief, and sadness prevail.  We must act now to ensure the Wye and its beauty is there for future generations.

Yours sincerely,

James Hitchcock

CEO

Radnorshire Wildlife Trust

Adam Taylor

CEO

Gwent Wildlife Trust

Sarah Kessel

CEO

Wildlife Trust of South and West Wales

Clive Faulkner

CEO

Montgomeryshire Wildlife Trust

Rachel Sharp

Director

Wildlife Trust Wales

Dear James,

Thank you for your letter dated 20^th December 2021.  As your letter particularly relates to the River Wye, Clare has asked me to respond on her behalf.

NRW has a long relationship with citizen science, particularly in biodiversity monitoring, where long-established schemes provide key evidence on the state of nature and inform policy and management.  We work with a range of partners, including NGOs, to develop and implement biodiversity recording schemes.

NRW is already exploring the potential of citizen science and collaborative partnerships to address the shared challenge of bringing protected sites, including the River Wye, into good condition through improved monitoring activity.  In November 2021, NRW met with Wildlife Trusts Wales (Senior Policy and Advocacy Manager), to explore options and we hope to have further discussions in the near future. 

Since its formation, NRW has been a member of the UK Environmental Observation Framework working group on citizen science, helping to steer the development of best practice guidance and resources. 

We recognise that the relationship and set of schemes is less well developed in the water environment than it is for biodiversity.  We are keen to explore how this might be developed and to enter into partnerships to develop processes which mean we use the evidence appropriately.  Our intention is to develop a broader approach to evidence that allows us to make best use of such data, including understanding the status of our rivers, the pressures affecting them and how they change over time.  During January, when we are clearer on the processes and resources needed to ensure a successful outcome, we will be publishing a statement detailing our position on the use of the data and our contribution to it.  We expect this to be similar in content and ambition to the Environment Agency position.

We are looking into increasing our contribution to an integrated monitoring programme for SAC rivers in Wales.  This could include the use of long-term instrumentation and portable meters to supplement our routine sampling and analytical programme.  We will explore how that evidence can be better built into our evidence processes to ensure that it is considered in our assessments.  An integrated collaborative programme will ideally include our routine chemical and biological sampling, citizen science, earth observation and instrumentation.  

Our work in this area, at a national level, is in the early stages of development and we would be keen to discuss it with potential partners in the near future.

We appreciate and share the desire for greater pace in this area, but it is also important that we develop the frameworks and context to ensure that data collected by different stakeholders can be better utilised and build confidence in the application and use of such methods.

We are committed to addressing the issues on the River Wye, and other failing SAC rivers in Wales, including the range of measures and solutions you mention in your letter.  We are also clear that in order to make the progress required, we will require many different stakeholders, including citizen science groups, to work together.  We see the Nutrient Management Plan Boards as providing an important point for helping to coordinate information and knowledge sharing and action.

I would welcome the opportunity to discuss these matters further with you, whether online or on the river bank.

Kind regards,

Gavin Bown

Pennaeth Gweithrediadau Canolbarth Cymru ​ / Head of Mid Wales Operations

Dear Gavin,
Thank you for your email response. 

I am pleased to have confirmation that a position statement on the use of Citizen Science data is imminent and look forward to seeing this.  We will publicly support this if it is of the ambition and intent you mention. 

We do understand the constraints you are under and the context, which is why we have made increasing NRW’s budget to 2013 levels with immediate effect one of our main campaign asks for the Wye. 

However, we do feel that the problems on the Wye have been building for many years now and the response from the Welsh agencies and Government has been slow, with your voice and presence often absent from the most crucial of debates and media coverage.  We really do need to move to a position where there is a costed, strategic, multi-partner, cross country plan, which is made public, to save the Wye.  And this plan needs an independent Chair that can hold all parties to account on delivery.  The NMP has failed to do this to the level required and with 2 years left until a possible trophic tipping point of no return the impetus to do this is more pressing than ever.  We await the outcome of the legal challenge against the NMP with interest. 

I am also very pleased to hear of your plans to increase the monitoring programme and would ask that flow pathways and run-off monitoring is also part of this.  The pending research publication from Lancaster University (RePhoKUs) makes this need very clear. 

We would also very much welcome a further statement from NRW on the causes of pollution on the River Wye.  The RePhoKUs research makes it very clear that agriculture plays the most significant role in the ailing phosphate levels, with a significant proportion of the nutrients being derived from chicken manure.  To not have acknowledged this firmly and clearly is not helping the move to a solution from the government and policy side as it allows a constant deflection from the biggest source of the issue.

I would very much welcome the opportunity to discuss these options with you.  If we can meet on the river, that would be excellent.  I have availability on the 3^rd Feb from 2pm onwards and then in the morning of 8^th Feb and afternoon of the 9^th.  If co-ordinating diaries is tricky, an online meeting to begin discussions would be welcome. 

We would welcome working together with you on solutions, but we do feel that given the situation and the urgent need for action, we must continue our calls for change and a more purposeful action plan, via our public campaign across the coming year.   

I look forward to hearing further from you.

Kind regards,

James Hitchcock

Chief Executive Officer/Prif Swyddog Gweithredol

Radnorshire Wildlife Trust / Ymddiriedolaeth Natur Maesyfed