Solent Protection Society                            WQR0008

Written evidence submitted by the Solent Protection Society

The Solent Protection Society (SPS) is a charitable incorporated organisation founded in 1956 to protect all aspects of the Solent, its waters and shoreline, including views of the coast from the sea.

The Council of the Society has a number of members with an ecological, marine biology or environmental background and has become increasingly

concerned at pollution levels in the Solent and its rivers over the last few years.

 

1.              Role of drainage and sewerage management plans.

These plans should place more emphasis on the management of environmental and health risks and the impact of discharges on waters covered by the Water Framework Regulations including estuary and coastal waters.

Regulations relating to the content of plans and water company performance compliance with plans should be introduced to ensure consistency.

The resources of the Environment Agency should be increased to enable it to respond to incidents reported by water companies.

2.              Adequacy of monitoring and reporting.

Tighter control is needed on volumes of untreated waste water.

History shows that water company reporting has not been satisfactory. Powers to improve the provision of information are required along with increased resources for enforcement and monitoring by EA and local authorities.

More performance data should be readily available to the public and should cover all CSOs.

It is evident that the inadequacy of monitoring and reporting has made it difficult to enforce both consented and non- consented discharges.

 

3.              Use of Technology

Real time monitoring of flows and discharges should enable swifter responses to incidents and better enforcement. Better use of technology should be made to inform stakeholders and the wider public. Web based Initiatives of the type used Southern Water’s Beach Buoy scheme could be more widely developed to cover all CSOs.

 

4.              Changing consumer behaviour.

Publicity campaigns have a role in this but these need to be backed up with measures which influence change. Such as -

Impact on water charges – Fully identifying the cost of dealing with pollution events (including penalties) and blockages and providing customers with information as to how this impacts on water charges.

Cross connections – the environmental and health effects of wrong sewer connections and the potential for penalties.

Product choice – Product labelling to provide more information on the polluting impact of products.

Product pricing – pollution tax of polluting products and substances.

Disposal of polluting substances provision of facilities for disposal.

 

5.              Investment to minimise storm water overflows.

This must be approached in two ways, improving the capacity of treatment works and sewerage systems to deal with storm flows and reducing the flows reaching the works by separating surface water from waste water. It is not a simple choice of investment in one or the other.

Current levels of investment are inadequate for both solutions.

Water companies must be required to plan for the impact of climate change on flows in drainage and sewerage plans.

Development must make proper contribution to its impact on drainage and sewerage provision and new development must be required to meet and demonstrate it can maintain sustainable drainage systems.

 

6.              Planning policy.

Planning policy needs to be strengthened to ensure that all development includes provision for sustainable drainage and makes a contribution to improving storm capacity.

 

7.              Local authorities and highway authorities

Highway and surface water discharges are a significant source of pollution. HAs and LAs should be required to manage and maintain drainage systems to minimise pollution to watercourses.

 

8.              Investment in adaption to climate change.

The system does not seem to be able to cope with existing weather events so there is a clear need for significant investment in dealing with future increased storms to avoid storm discharges from CSOs.

 

9.              Designation of inland bathing waters.

The scheme for the designation of bathing waters needs to be reviewed to provide for the designation of all waters where significant bathing is regularly taking place. In view of the changes in how these waters are now used other recreational water uses such as paddle boarding should be a factor in designation. This would drive up water quality and protect public health.

 

January 2021