4. Updating objectives

This section describes the processes followed to review and update water body objectives and explains the approach to economic appraisals.

4.1. Reviewing and updating water body status objectives

Water body status objectives describe the long-term aim for specific parts of the water environment. Identifying appropriate water body status objectives and the measures that are needed to achieve them is at the heart of the river basin planning process.

Water body status objectives are legally binding; that is, the Secretary of State and Environment Agency must exercise their relevant functions so as to secure compliance with the requirements of the WFD Regulations and this includes the environmental objectives in river basin management plans.

All public bodies must have regard to the river basin management plans, including the water body status objectives, when exercising their functions that could affect the quality of the water environment.

Water body status objectives consist of two pieces of information: the target status (such as good) and the target date by which that status is planned to be achieved (for example, by 2021).

The target status is based on a prediction of the future status that would be achieved if technically feasible measures are implemented and, when implemented, would give rise to more benefits than they cost. The objective also takes into account the requirement to prevent deterioration.

The target date is the year by which the future status is predicted to be achieved. The date is determined by considering when the measures needed to achieve the planned status were, or will be, in place and, once implemented, the time taken for ecology or the groundwater to recover.

In general, the target date can only be extended beyond 2027 in specific and limited circumstances (different timescales apply to some priority substances as described below). Whilst many water bodies have an objective of reaching good by 2027, the confidence of achieving good by this date varies depending on the level of confidence that all the necessary measures will be in place before that date. To be clear and transparent about this level of confidence, the objectives set for 2027 are expressed in two ways:

  • ‘good by 2027’ where there is confidence that the target status will be met by 2027, based on a reasonable expectation that all the necessary measures will be in place
  • ‘good by 2027 (low)’ where there is still uncertainty about whether all the necessary measures will be in place to achieve the target status by 2027

For the following priority substances, the overall objective is to aim to achieve good status by 2021, with extended deadlines on the grounds of technical feasibility or disproportionate cost being possible until 2033: anthracene, brominated diphenylethers (PBDEs), fluoranthene, lead and its compounds, naphthalene, nickel and its compounds, and polyaromatic hydrocarbons (PAHs).

For the following priority substances, the overall objective is to aim to achieve good status by 2027, with extended deadlines on the grounds of technical feasibility or disproportionate cost being possible until 2039: dicofol, perfluorooctane sulfonic acid and its derivatives, quinoxyfen, dioxins and dioxin-like compounds, aclonifen, bifenox, cybutryne, cypermethrin, dichlorvos, hexabromocyclododecanes, heptachlor and heptachlor epoxide, and terbutryn.

For surface waters, objectives were reviewed and updated for ecological and chemical status. For artificial or heavily modified water bodies, objectives were reviewed and updated for ecological potential and chemical status. For groundwater, objectives were reviewed and updated for quantitative and chemical status.

The requirement to prevent deterioration was considered when reviewing and updating water body status objectives. This applies to a water body’s overall status objective and to the objective for each element used in classification. For example, if a water body was at good ecological status in 2015, and therefore was set an objective of good ecological status by 2015 but has deteriorated in status since then due to a real change in the environment, the objective of good ecological status by 2015 has been retained in the updated plans. However, if the change in ecological status since 2015 is due to a change in how the water body’s ecological status is assessed (for example a new element was classified in 2019, or there has been a change to the monitoring sites used to assess the water body) then the objective will have been updated to reflect this new understanding of the status of the water body.

Objectives for water bodies in England can be downloaded from the catchment data explorer.

4.2. Circumstances for setting alternative water body status objectives

The circumstances in which alternative objectives have been set for water bodies under regulations 16 and 17 of the WFD Regulations are described below. The general circumstances in which each reason has been applied are described with, where relevant, more specific circumstances for particular elements.

4.2.1 Technically infeasible – no known technical solution is available

General approach

This reason has been used to justify setting less stringent objectives for water bodies under Regulation 17. It has also been used to justify extending the deadline for achieving good chemical status for some substances under Regulation 16.

As well as being applied where there is no known practical technique for making the necessary improvement, this reason has also been used in cases where:

  • techniques are under development but are not yet known to be effective in practice
  • there is a known technical solution, but that solution cannot be applied in a specific location due to specific local conditions

Biological elements

Invasive non-native species (INNS) may impact upon biological elements resulting in them being at less than good status.

For many established INNS, such as American signal crayfish, there is no known technical solution to eradicate them. In these circumstances a less stringent objective is set for the impacted biological element under Regulation 17, provided that the water body is not also a habitats site protected area (see the section named ‘Biological elements - habitats sites protected areas’).

Biological elements and hydrological regime

Flows in some rivers and streams can vary naturally on a seasonal basis (for example ephemeral streams and winterbournes) or due to features like swallow holes. These natural phenomena can result in a water body being classified at less than good status. In these instances, there is no technical solution to the failure to reach good status and a less stringent objective is set under Regulation 17.

Fish

Natural barriers to fish migration sometimes result in fish being classified at less than good status in a water body. In these situations, there is no technical solution to the fish failure since natural barriers do not require removal or easement and a less stringent objective is set under Regulation 17.

The natural physical characteristics of a water body may be unsuitable for certain fish species which, although expected to be present by the fish classification tools, are in fact absent, resulting in fish being reported at less than good status. There is no technical solution in these circumstances since the absence is due to the natural characteristics of the water body and therefore a less stringent objective is set under Regulation 17.

Groundwater quantity

In some areas public water supply is mainly by abstraction from groundwater. Although the groundwater may be at poor quantitative status as a result of the abstraction it may not be technically possible to transfer the abstraction to another groundwater body, surface waters or an area of low environmental sensitivity. In such cases a less stringent objective has been set under Regulation 17.

This exemption has been used when the environmental and socioeconomic needs served by the supply of public water cannot be achieved by other means which are a significantly better environmental option not entailing disproportionate costs, as required by Regulation 17(2).

Groundwater chemical

There is not always a technical solution to improve a groundwater body to good chemical status where:

  • there are multiple small diffuse discharges from abandoned mines stretching across a groundwater body which are causing it to be at poor status. These discharges can be so numerous that it is technically infeasible to put in place measures to improve all the discharges to get to good chemical status
  • a large mining discharge is in a highly constrained location, such as in the middle of a village, and land is not available for treatment schemes. In these circumstances a less stringent objective has been set under Regulation 17

Phosphate, phytobenthos and macrophytes

In England, it is generally currently considered to be technically infeasible to build a sewage treatment works that will reduce phosphate in discharges to less than 0.25mg/l.

If a water body requires discharges of less than 0.25mg/l phosphate to achieve good status, then this reason has been used to justify a less stringent objective under Regulation 17.

The exemptions apply to the phosphate and the impacted biological elements such as phytobenthos and macrophytes.

This exemption has been used when the environmental and socioeconomic needs served by the sewage treatment works to dispose of sewage cannot be achieved by other means which are a significantly better environmental option not entailing disproportionate costs, as required by Regulation 17(2).

4.2.2 Technically infeasible – cause of adverse impact unknown

General approach

This reason has been used to justify setting extended deadlines for achieving objectives for water bodies under Regulation 16.

It has been applied when a water body is at less than good status and the evidence is insufficient to identify the reason or reasons for not achieving good status with the required level of certainty to support identification of the measures needed to improve status.

This exemption has been used where:

  • genuine scientific uncertainty remains despite investigation work having been carried out
  • there has been insufficient time to complete the necessary investigation work since the water body was classified at less than good status

An investigation in this context includes desk studies drawing on existing data and knowledge about the water body and wider catchment, engagement and consultation with catchment partners and bespoke field investigations.

Metals

Some groundwater bodies are at poor status because of polluted mine waters entering the groundwater. Whilst it is known that abandoned mines are the general source of the metals more investigations are needed to determine exactly where the metals are coming from so that the necessary measures can be identified and appraised.

In these circumstances an extended deadline for achieving good status has been set under Regulation 16.

4.2.3 Technically infeasible – practical constraints of a technical nature prevent implementation of the measure by an earlier deadline

General approach

This reason has been used to justify setting extended deadlines for achieving objectives for water bodies under Regulation 16.

In some cases, although the appropriate measures to achieve the water body objectives have been identified, there are constraints on commissioning and undertaking the necessary works that will extend the time taken to achieve the objectives.

This exemption has only been applied where the appropriate measure has been identified, funding has been agreed and there is a mechanism in place to deliver it.

Hydrological regime

Some water company schemes are large and complex, for example building a new reservoir, and so installation will happen over an extended timescale. A water company measure may have been programmed for implementation during cycle 2, but the measure will not be delivered until after 2021 because it involves the installation of a large complex scheme.

In these circumstances an extended deadline of good by 2027 has set under Regulation 16.

Total phosphorus (lakes)

Physical habitat restoration in lakes can be complex, large-scale and often involves more than one organisation. It often requires significant work to secure partner consensus and cooperation. Actions may need to happen in a specific order to be effective, such as tackling diffuse sources of pollution before carrying out physical restoration works to the lake. Implementation of lake restoration action plans may therefore take place over several years.

In these circumstances an extended deadline for achieving good status has been set under Regulation 16.

4.2.4 Disproportionately expensive – unfavourable balance of costs and benefits

General approach

This reason has been used to justify setting less stringent objectives for water bodies under Regulation 17.

This exemption has been used in situations where:

  • there is no environmental problem to solve and therefore the costs of taking any action would exceed the benefits.
  • although water body classification tools and the monitoring programme represent best science, due to the varied nature of the environment they sometimes flag a problem where no problem exists. Additional information including risk assessments and information from third parties can be used to establish if there is an environmental problem
  • economic appraisal has determined that the costs of implementing the most cost effective and technically feasible measures needed to reach good status are greater than the benefits to be gained from achieving good status

In some cases, although a less stringent objective has been set action will still happen to improve the water body to the best possible status, as required by Regulation 17(3) and (4). Measures will be implemented up to the point where doing more would be disproportionately expensive. In these cases, pressures may be partially resolved or, where there are multiple sources in a catchment, some may be addressed whilst others are not.

Fish

In some cases, the fish classification tool gives a result of less than good status due to the absence of a certain species, but it is known from other data, such as angling match records, that the species is both present and at expected densities in the water body. Therefore, there is no environmental problem to solve and action to take.

In these circumstances a less stringent objective has been set under Regulation 17.

Hydrological regime

In some water bodies there are multiple small abstractions or a large abstraction from either groundwater or surface water, or a combination of the two, which is affecting surface water flows. The potential compensation costs of changing abstractions, either the abstraction regime or decreasing abstraction volumes overall, can be disproportionately expensive.

In these circumstances a less stringent objective has been set under Regulation 17.

This exemption has been used when the environmental and socioeconomic needs served by the supply of public water cannot be achieved by other means which are a significantly better environmental option not entailing disproportionate costs, as required by Regulation 17(2).

Fish, invertebrates, mitigation measures assessment

The costs of implementing some mitigation measures to address pressures from physical modifications are very high and disproportionately expensive. For example, in urban areas where improvement works are often technically and spatially challenging there are increased costs for ground works and securing land availability as well as spatial limitations.

In these circumstances a less stringent objective has been set under regulation 17. The exemption applies to the Mitigation Measures Assessment and the impacted biological elements.

This exemption has been used when the environmental and socioeconomic needs served by the physical modifications cannot be achieved by other means which are a significantly better environmental option not entailing disproportionate costs, as required by Regulation 17(2).

Groundwater quantitative

The groundwater body is at poor status but the groundwater is a confined aquifer that has no direct or indirect link to environmental features or problems. Measures to restore the groundwater body to good status (for example, stopping the abstraction and/or pumping water into the aquifer) would result in no environmental benefits.

In these circumstances a less stringent objective has been set under Regulation 17.

Groundwater chemical

In some groundwater bodies which are failing the General Chemical Test for nitrates, farming would need to stop across a very wide area of land in order to meet the good status objective. The costs of implementing such measures have been judged to exceed the benefits and therefore disproportionately expensive.

In these circumstances a less stringent objective has been set under Regulation 17.

Phosphorus, ammonia, dissolved oxygen, macrophytes, phytobenthos

Engineering measures and technologies to improve water quality of discharges from sewage treatment works can have high costs relative to other measures within a catchment bundle of measures. Although these measures can be technically feasible, the cost of implementation can exceed the benefits to be gained from achieving good status. This is especially true in cases where improvements are limited to an individual water body which limits the overall relative benefit in the catchment.

In these circumstances a less stringent objective has been set under Regulation 17.

This exemption has been used when the environmental and socioeconomic needs served by the sewage treatment works to dispose of sewage cannot be achieved by other means which are a significantly better environmental option not entailing disproportionate costs, as required by Regulation 17(2).

Nutrients

When phosphate in freshwater or dissolved inorganic nitrogen in estuaries and coastal waters are at less than good status, targeted regulatory measures (for example, water industry nutrient removal schemes) require sufficient evidence of a eutrophication problem to justify the measure. If a water industry sewage works is a major source of relevant nutrients, and nutrient removal would be required to improve status to good but there is insufficient evidence of biological eutrophication impacts within the downstream water body or catchment, then there is no ecological problem to solve and the costs of taking action would exceed the benefits.

In these circumstances a less stringent objective has been set under Regulation 17.

Less certainty of eutrophication does not preclude consideration of non-regulatory or voluntary approaches to address other nutrient sources.

Hydrological regime

If the hydrological regime is classified as not supporting good status but investigations have not shown any evidence of impacts upon biological elements, then there is no environmental problem to solve and the costs of taking action would exceed the benefits.

In these circumstances a less stringent objective has been set under Regulation 17.

Metals

The cost of mine remediation measures is often relatively high within a catchment bundle of measures and in some cases, where the extent of the benefits is less certain and limited to specific water bodies, the cost of implementation exceeds the benefits.

In these circumstances a less stringent objective has been set under Regulation 17.

Physico-chemical elements, chemicals

The complex nature of pressures and pollutant pathways in urban areas along with spatial challenges mean that the costs of implementing successful and worthwhile sustainable urban drainage measures can be high. These costs can exceed the benefits, especially if the benefits are limited to specific, small urban water bodies.

In these circumstances a less stringent objective has been set under Regulation 17.

4.2.5 Disproportionately expensive – disproportionate burdens

This reason has been used to justify setting extended deadlines for achieving objectives for water bodies under Regulation 16 for the purposes of phased achievement of the objectives.

Through its legal, administrative, and funding frameworks to protect and improve the water environment, the government must decide on the overall economic impact and distribution of the costs of measures (who pays). In doing so it makes political judgements, informed by economic (costs and benefits of measures) and other evidence, to balance often conflicting policy needs. This governs how much funding is available for measures. This includes government funding paid for through taxes or borrowing, or private funding incentivised by regulation, advice, guidance, financial gain, or altruism.

Where funding for measures was not confirmed, it is assumed that the measures fell outside the government’s legal, administrative, and funding frameworks and were therefore unaffordable to implement before 2021 without creating a disproportionate burden on the relevant sector or wider society or fell outside government spending limits.

In these circumstances an extended deadline for achieving the objectives has been set under Regulation 16.

4.2.6 Natural conditions – ecological recovery time

General approach

This reason has been used to justify setting extended deadlines for achieving water body objectives under Regulation 16.

Generally speaking, the ecology of aquatic systems recovers quickly when pressures are removed. However, in some cases there may be a delay before the biological quality of the water body recovers.

The delay may be due to the time taken for the plants and animals to re-colonise and become established after the hydromorphological, chemical or physicochemical conditions have been restored or the time taken for the habitat conditions to stabilise after improvement works.

The natural recovery of biological populations is typically achieved through re-colonisation. Where impacted habitats are hydrologically connected to un-impacted locations, recovery can occur quickly. This is particularly true for species that show mobility through their life history (for example, fish and invertebrates). Here, recovery can happen within a limited number of generations and therefore years. Where habitats lack this connectivity, or where species are no longer present, recovery may take much longer.

Other circumstances where ecological recovery time may be delayed are as follows:

  • measures to remove the activity giving rise to a pressure are successful, but the pressure takes time to reduce. Here the ecology cannot recover quickly as it is still impacted by a pressure, albeit reducing in magnitude. Recovery of ecosystems from prolonged exposure to increased nutrients provides a good example. In such cases it may take tens of years for the plant communities to return to those expected under near reference conditions once all improvement measures are implemented. In such cases deadlines can be extended beyond 2027
  • measures to remove pressures are successful, but the ecology does not return to the community expected to be seen under near reference conditions. Instead, the ecology assumes a different ecological stable state. In these cases, further management of the ecosystem may be needed to trigger a change back to good status

Ecological recovery time is only used as a justification for an extended deadline if there is confidence that the measures necessary to achieve the improvement in status have already been implemented, or will be implemented by 2027.

In these circumstances an extended deadline for achieving the objectives has been set under Regulation 16.

4.2.7 Natural conditions – groundwater status recovery time

General approach

This reason has been used to justify setting extended deadlines for achieving water body objectives under Regulation 16.

Groundwater bodies can take many decades to recover from chemical pressures once measures to reduce the pressures are in place. This is mainly because of the delay as water travels downwards through the unsaturated zone to the water table. The length of this delay will depend on many factors including the rate of recharge, properties of the pollutant and the nature of the hydrogeological setting.

The recovery time delay can vary between several years to many decades. In the majority of cases where this exemption has been used the substance causing poor status was nitrate. Groundwater status recovery time has mainly been used for groundwater chemical pressures.

In these circumstances an extended deadline for achieving the objectives has been set under Regulation 16.

Dissolved inorganic nitrogen

In some cases, nitrates from groundwater bodies are leaching into surface water bodies such as estuaries resulting in dissolved inorganic nitrogen failures. As nitrate can take a long time to move through groundwater, it will correspondingly take a long time for the surface water to recover.

In these circumstances an extended deadline for achieving the objectives has been set under Regulation 16.

4.2.8 Natural conditions – chemical status recovery time

General approach

Persistent, bioaccumulative and toxic (PBT) substances can be found for decades in the water environment at levels exceeding the biota environmental quality standard, even when measures to reduce or eliminate the emissions of these substances are already in place.

Mercury and its compounds and polybrominated diphenylethers (PBDEs) are PBT substances where national and international measures to achieve good status are in place. To account for the long recovery time once measures are in place for these substances the objective deadline has been extended under Regulation 16.

4.3. Reviewing and updating objectives for habitats sites protected areas

The WFD Regulations require the objectives for habitats sites protected areas to be met. Under the Regulations, this must be achieved by 2021 if not already achieved. The objective for the national site network of habitats sites is to contribute to maintaining or restoring their habitats and species at favourable conservation status across their natural range in the United Kingdom. Each habitats site must contribute to this objective. The provisions of the WFD Regulations only relate water-dependent habitats sites.

In England, Natural England provides formal advice as to the conservation objectives for terrestrial and inshore habitats sites. Conservation objectives relate to each of the habitats and species for which a habitats site is designated. They set out the broad aims or requirements needed to conserve, restore and enhance the habitats and species.

In addition, there are targets for monitoring specific attributes linked to the objectives for all habitats sites that are described in United Kingdom Common Standards Monitoring Guidance issued by the Joint Nature Conservation Committee. Natural England uses the Common Standards Monitoring Guidance targets to periodically assess and report on the condition of the designated features of habitats sites. This monitoring provides an indication of whether a site’s conservation objectives are being met or not.

Where habitats sites are rivers, lakes, coastal or estuarine waters, they may need to meet specific water quality and flow targets set out in the Common Standards Monitoring Guidance. If they do, they will be assessed as being in favourable condition and the habitats and species will be contributing to favourable conservation status. These specific water targets are not embedded in water body status objectives. Therefore, in making water management decisions on these sites, measures must be designed to meet both the water body status objectives and the specific water targets for the habitats sites.

The specific water targets for habitats sites are published as part of this river basin management plan and can be downloaded from the catchment data explorer.

These tables also include specific water targets for rivers and lakes that are notified as SSSIs, where those targets have been agreed locally. SSSIs are not protected areas under the WFD Regulations. However, meeting the water quality and flow needs of SSSIs will contribute to achieving the targets for ‘thriving plants and wildlife’ in the 25 Year Environment Plan.

4.4. Circumstances for setting alternative objectives for habitats sites

Not all water-dependent habitats sites met their water-related objectives by December 2021. Natural England holds information on the issues and risks affecting each SSSI that underpins a habitats site. This information shows that water pollution and water levels are among the top five reasons for SSSIs being in unfavourable condition. The reasons each specific habitats site has not yet met its objectives are not reported in the river basin management plans. However, the general circumstances are described below.

For many habitats sites, the measures to address the water challenges are in place, but it will take time for the environment to respond and for favourable condition to be achieved. Natural England report this as ‘favourable recovering’ condition. 46% of the area of water-dependent habitats sites in England are reported as being in favourable recovering condition for water-related impacts. Where the measures are in place, the deadlines for achieving the objectives for habitats site protected areas can be extended to reflect this natural recovery time, including beyond 2027.

Habitats sites are impacted by several challenges. For some of these it is not currently technically feasible to fully resolve the problem. This includes circumstances where:

  • there is no known practical solution to the problem
  • techniques are under development but are not yet known to be effective in practice
  • there is a known technical solution, but that solution cannot be applied in a specific location due to specific local conditions

Examples include:

  • availability of methods to control some invasive non-native species
  • technically achievable nutrient limits at waste water treatment works
  • feasibility of effectively removing and disposing of nutrient rich lake sediments
  • need for complex and large-scale physical habitat restoration in rivers, lakes and wetlands
  • where further investigation is needed to identify the precise causes of impacts before solutions can be identified

Deadlines for water dependent habitats sites cannot be extended beyond 2027 using the justification of technical feasibility.

4.5. Economic appraisals

In 2005, in preparation for the 2009 plans, a wide-ranging economic analysis was carried out and reported through a collaborative research programme overseen by United Kingdom authorities (in England this was undertaken by Defra) and partner organisations. As a result, Article 5 WFD Economic Analysis of Water use reports were produced that describe the socio-economic characteristics of each river basin district and sectors’ use of water. These reports have been reviewed for the river basin management plans but not updated as the socio-economic characteristics have not significantly changed.

Defra and the Environment Agency will continue to develop an economic analysis to provide evidence for water policy development. Future economic analysis will include projections of bills for water and sewerage services for household and non-household customers using a commissioned model. Where new policies or changes in water-related policy are considered, in line with government practice, appropriate economic analysis will be carried out.

The Environment Agency, as a public body seeks to identify those areas where money could be spent to achieve the best outcomes for society.

Catchment economic appraisals were undertaken to assess the benefits, cost and any negative impacts of implementing measures to improve the water environment. The Environment Agency designed a robust approach, based on HM Treasury guidelines, that is proportionate and fit for purpose. The approach is designed to aid decision making on setting objectives. Specifically, those instances where there is sufficient evidence to justify setting a less stringent water body objective on the grounds of disproportionate expense.

Water appraisal guidance and associated cost benefit analysis tools have been developed in consultation with a range of partners. The features of the economic appraisal approach are that:

  • it is catchment based, covering all water body types. This is important to help achieve integrated and cross pressure management of the water environment
  • it is about identifying the greatest level of improvement that is justified where the benefits to the environment and society outweigh the cost of implementing measures
  • it builds up a broad picture of the environmental outcomes and benefits of measures in a descriptive way, using an ecosystem services framework, and includes a monetary estimation of the major benefits
  • it is a systematic and transparent framework that helps engagement with others in managing the water environment

The results of the economic appraisals help ensure that wider benefits and the value of the water environment are considered in decision making.

4.5.1. Measures assessed in economic appraisals

The measures included in economic appraisals are considered to be technically feasible and the most cost-effective way of improving the water environment. Measures for a catchment are grouped together into a bundle so all costs and the range of benefits can be taken account of and assessed together. This approach recognises the interdependencies within a catchment.

The catchment economic appraisals focused particularly on measures to achieve improvements in water body status, where information on costs and benefits are required to inform objective setting. Other measures (and their costs and benefits) relating to certain protected area objectives and measures that specifically prevent a water body deteriorating were considered at national level rather than in the catchment economic appraisals. Different considerations apply to different categories of protected areas.

Costs were from local and national sources and are based on previous experience of implementing similar measures. Where more specific, local cost information is available this has been used in place of national estimates.

If the bundle of measures to improve all water bodies in the catchment to good status or good potential is not considered to be justified (the cost of implementing the measures outweighs the benefits to the environment and society) or would have significant adverse effects on the wider environment, an alternative bundle of measures has been appraised.

4.5.2. Consideration of disproportionate expense

In some cases, it is considered disproportionately expensive to get water bodies to good status or good potential by 2027. Disproportionate expense is a political judgement informed by economic information. Among the economic information relevant to assessing disproportionate expense are costs, benefits and ‘affordability’ or available resources.

Evidence that the negative consequences of actions (compliance costs, impacts on non-water outcomes) outweigh the positive consequences (benefits of water environment improvements) tends to suggest disproportionate expense.

Consideration of costs and benefits of a bundle of measures is used to identify the long-term objectives that are justified. Availability of resources is more relevant to the speed at which the objectives can be achieved. In some cases, even if the benefits are greater than costs for a bundle of measures, an extended deadline has been set because of affordability issues. Therefore, consideration of costs and benefits helps to determine the status part of a water body objective and information on affordability helps to determine the date by which that status can be achieved.

Where affordability is an issue, alternative financing mechanisms are considered. This might mean moving from the preferred option of the ‘polluter pays’ approach to a ‘beneficiary pays’ approach. If the beneficiary (those who directly benefit from the improved water status) is unable or unwilling to pay, other sources of funding may need to be considered.

The hierarchy for funding measures to resolve or mitigate an environmental problem is:

  1. Polluter pays. The person whose activity causes (is at risk of causing or has caused) an environmental problem pays.
  2. Beneficiary pays. The person who will benefit from the improvement (or reduced risk) to the environment pays (sometimes called payment for ecosystem services; PES).
  3. Government pays. The United Kingdom government directly or indirectly (via central and local government) pays.