Delays and Dilution: The Government’s Underwhelming Environmental Improvement Plan

The Government has long promised a future with cleaner rivers, lakes, and seas.  After the general election, the then Secretary of State for the Environment, Steve Reed, promised a rapid review of the previous government’s Environment Improvement Plan (EIP). 15 months later, the government has finally produced their version of the EIP.  It is an underwhelming improvement on the 2023 version, which was widely criticised for its lack of specificity. Environmental Improvement Plans matter because they provide renewed versions of the government’s long-term environmental strategy and how they are going to meet the legally binding targets set out in the Environment Act 2021.

Gone are the days of the Prime Minister providing a foreword to the EIP. Instead, as the EIP was released, Kier Starmer delivered a speech perpetuating the myth that nature protection is holding back growth. Successful delivery of a clean water environment must involve a range of government departments, with wholehearted backing from No 10. The EIP makes little effort to distribute responsibilities across government departments beyond Defra, and the PM’s rhetoric doesn’t instil confidence in No 10’s commitment to protecting nature.

The EIP gave strong signals as to the government’s position on key reforms to the water sector following the Independent Water Commission’s report, released in July. We welcome the commitment to include ‘Regional Water Authorities’ within the new regulatory system, intended to tackle water governance at the catchment level and provide greater democratic involvement. However, contrary to the Angling Trust and the Independent Water Commission’s recommendations, the EIP indicates that the Regional Water Authorities will sit within the new super regulator. This means that the new regulator will mark its own homework – forming plans at the catchment level and submitting it to itself for approval.

There are also signals that the Government will embrace reforms to the Water Framework Directive (WFD), which the Angling Trust has consistently argued against. The WFD is a good piece of law whose failures lie in poor interpretation and implementation by the government and regulators, not in the law itself. Broadening the WFD’s scope to include public health considerations risks ‘mission creep’, where ecological health is subordinated to human health. As it stands, if a waterbody fails on one metric, then it fails to reach ‘good ecological status’ under the ‘one out all out principle.’ We urge the government not to abandon this principle, which would not improve waterbody conditions, but mislead the public about the health of our rivers.

Earlier this year, the government confirmed that it would not bring forward to long-awaited chalk stream recovery plan. This had been developed before the general election but not published in time for that election. So, including specific mention of the need for greater protection for chalk streams is welcome.

However, there is nothing new in the EIP. Its statements regurgitate existing announcements and commitments. This includes investing in chalk streams “through the Water Restoration Fund and the Water Improvement Fund”, and restating the priorities for investment and action through things such as the water companies investment plans and the storm overflow reduction plan, both of which had been previously announced.

There is a pattern of kicking the can down the road in the updated EIP, with commitments 25, 27 and 33 extending deadlines for crucial targets on phosphorous pollution reduction, heavy metal pollution reduction, and leakage reduction, each by 2 years.

Chemical pollution present huge risks to our waterways. The updated 2025 EIP is weaker than its predecessor, with a significant change of phrasing from significantly reducing “levels of harmful chemicals entering the environment (including from agriculture)” to ‘minimizing environmental risks’ from chemicals and pesticides. Shifting from ‘levels’ to ‘risk’ makes the target harder to monitor and enforce, despite widespread concern over chemical pollution’s impact on human and ecological health.

Post-Brexit, we have lagged behind Europe’s regulatory framework for chemicals. We welcome commitment 40 to align UK chemical regulations with to our closest trading partners (i.e. EU REACH) by 2028. However, the plan includes a provision allowing divergence for “compelling reasons,” which creates room for manoeuvre, rather than a strong commitment to embracing stronger environmental protections. EU REACH is  world-leading, combining expertise from all EU member states – a wealth of knowledge we would be remiss to diverge from.

Despite this overarching weakening of objectives, we welcome the commitment to a review into the regulatory framework for sewage sludge. The current approach is unsustainable, with sewage sludge being spread onto agricultural land as a cheap fertiliser, despite it being known to contain levels of ‘forever chemicals’ with health impacts for all of us at the point of food consumption, and for the environment, when sludge is washed into our waterways.

The previous conservative government created Schedule 3 of the Floods Act to make Sustainable Drainage Systems (SuDS) mandatory and ensure adoption by designated authorities. This was never enacted. The EIP 2025 makes no mention of Schedule 3, citing instead vague wording about ‘considering further planning reforms.’ This matters because schedule 3 would have ended the ‘automatic right to connect,’ whereby developers automatically can route surface water drainage into public sewers, increasing pressure on a broken water system – ultimately increasing inputs to our broken sewerage system.

Overall, the revised EIP lacks the urgency, clarity and ambition required to reverse the decline of our rivers and waterways. By delaying targets, weakening objectives and avoiding long-overdue structural reforms, the Government risks entrenching failure rather than delivering recovery. Without clear accountability, strong regulation and a genuine commitment across all of government to prioritise nature, the latest EIP will do little to restore public trust or secure the clean, healthy waters we all demand.