Friends of the Somerset River Frome                            WQR0015

Written evidence submitted by Friends of the Somerset River Frome


  1. What are the best indicators for river water quality that could be used as targets being developed under the Environment Bill?

1.1.            Aquatic invertebrates

1.2.            Faecal Indicator Organisms (for both human sewage and livestock waste (the latter being the primary cause of the poor quality of our river)

1.3.            Phosphate, ammonia, BOD, dissolved oxygen, particulate (suspended sediment)

1.4.            Plastics: microfibres, microplastics

1.5.            Other water quality elements as already monitored for WFD assessments must continue to be monitored.


  1. How could drainage and sewage management plans, introduced by the Environment Bill, play a role in reduced sewer discharges?

2.1.            By requiring water companies to fund regular river monitoring carried out by independent bodies with the results placed in the public domain for inspection

2.2.            By requiring water companies to publish full details of discharges on a regular basis: duration, dates, frequency, treated, untreated. And for realtime data to be made available for all untreated sewage discharges.

2.3.            By requiring all sewage discharges to be ranked by their impact (environmental, aesthetic, public health) and for priority discharges to be eradicated within an agreed timescale. Drainage plans will need to set out generic steps including monitoring, investigation and identifying solutions, consultations and implementation of infrastructure / asset upgrades.

2.4.            By requiring local planning authorities with water companies to:

2.4.1.            Assess the adequacy (current state) of waste water management and infrastructure

2.4.2.            Assess future housing and development growth requirements upon drainage treatment and infrastructure, public and environmental health

2.4.3.            Put in place a plan for improvement that will ensure additional growth will not put an extra burden on existing inadequate infrastructure

2.4.4.            By introducing a technical planning reason to refuse or object to a planning application by virtue of it likely to increase damage to the ecological and environmental quality of receiving watercourses and/or for it will likely increase adverse impacts on public health (where the watercourse is utilised by the public for bathing or other close-contact recreation such as canoeing or kayaking) and/or it will cause an increase in the frequency and / or volume of discharge of untreated sewage via a Combined Sewer Overflow.


  1. How adequate are the monitoring and reporting requirements around water company discharges?

3.1.            Inadequate - other organisations will offer detailed evidence on this matter.


  1. How can technology improve and assist with transparency and enforcement?

4.1.            Having technology able to sample and analyse the water column for faecal indicator organisms presence and load, BOD, dissolved oxygen, phosphate and ammonia (nitrates) and be able to give an instantaneous reading that can be reported in real time to the public.

4.2.            EDNA monitoring for aquatic organisms.


  1. What is the impact of plastic pollution and other materials on drainage and water quality in rivers and what should be done to mitigate it?

5.1.            Impact on water quality: plastic is not yet a monitored metric but needs to be. Because it is not monitored, river quality indices do not yet consider this within the regular assessments carried out (currently on EU water framework directive criteria). It is important that standards for assessment of plastics in fresh and coastal waters (and the marine environment) are formulated (ideally on an internationally agreed standard) and included in regular monitoring and an updated assessment scheme for fresh, coastal and marine waters. The impacts of plastic particles on ecosystems is becoming evident as new research evidence is coming forward. Endocrine disruption and impacts on reproductive ability of aquatic organisms is a significant concern.

5.2.            What should be done to mitigate it: Regulation to reduce plastic at source for all non essential uses. To date regulation has been too little and ineffective.


  1. How can consumers be persuaded to change their behaviour to minimise pollution?

6.1.            Regulation is required. Consumers are relatively helpless without effective governance and regulation in this matter. Reliance on voluntary initiatives has been proven time after time to fail. Governance and leadership from Government is a priority.


  1. What is the required investment level needed to minimise storm overflows vs the scope for sustainable drainage and nature-based solutions?

7.1.            This is something we are unable to answer but, in our town (Frome), there are few options for sustainable drainage and nature based solutions, within the built up old town, that would reduce untreated sewage discharges from Combined Sewer Overflows. The only solution is to upgrade legacy infrastructure that is outdated and is unable to cope with an increasing drainage load owing to housing growth, urban creep and infill.


  1. How effective are the planning policy and standards around sustainable drainage systems to reduce urban diffuse pollution in England?

8.1.            Poor. And when SUDS structures are built there seems to be no comeback on developers if they are found to be unfit for purpose. A report from Somerset was recently published - see The process for approving SUDS also appears to be opaque. We were unable to see detailed designs and engineering calculations for a recent scheme (Edmund Park) approved for a development in Frome in a sensitive location adjacent to the River Frome. Details were not on the Planning Portal (because it was not a ‘planning ‘ matter, being dealt with by another authority, and it was hard to find which officer was dealing with the application and had approved it. After repeated requests no detailed drawings or calculations were made available to us and we are sure that the scheme is neither designed nor working correctly. We are not aware of any SuDS schemes that have been designed to manage runoff volume as well as runoff rates.  Water quality measures are not explicitly considered either.


  1. Should local authorities and highways agencies be given a duty to prevent pollution to watercourses without prior treatment?

9.1.            Ideally one agency ought to be given this duty BUT it would be extremely complex to implement. A priority is for all highways drainage that currently enters a watercourse, wetland or Site of Special Scientific Interest to be put on notice and remediated within a given timetable. Ringfenced funding should be provided via income from vehicle excise duty, and this will need to increase to pay for the new drainage infrastructure. No new duty should be given to highway authorities unless such ringfenced funding became available.


  1. How effective is Ofwat’s remit and regulation of water companies? Does it facilitate sufficient investment in improvements to water quality, including sustainable drainage systems and nature-based solutions such as constructed wetlands?

10.1.            Ofwat is widely considered by river campaign groups as unfit for purpose, primarily operating to maintain low water prices for consumers and failing to require water companies to invest sufficiently in vital improvements to reduce the impacts of wastewater discharges on the environment.


  1. Is adequate investment being made in adapting water treatment systems to future climate change?

11.1.            We are unaware of any such investment being made insofar as it affects the main town in our catchment, Frome.


  1. How could the designation of inland bathing waters by water companies affect the costs of achieving the associated water quality standards?

12.1.            That would depend upon the details of each situation: river characteristics, flow, volume, discharge types, volumes and frequencies and location in relation to the proposed bathing water. But it needs to be borne in mind that many stretches of river, although not currently designated as bathing waters, are used by close contact sports or are otherwise accessed by people and should NOW be of sufficient quality that they do not constitute a public health hazard. In our town, Frome, the stretch through the town centre is immediately downstream (within 50m) of a major CSO which at times of high rainfall discharges into the river. This happens at any time of a year, e.g. this video shows it in 2020 on 12 June during a sudden rainstorm. In another location, the Adderwell Stream runs through a public park into which a CSO upstream regularly discharges. Children and dogs regularly access this stream which is a clear public health hazard. Sewage litter clings to the concrete sides of the stream and collects on the trash screen at the outflow to a culvert which then discharges into the river.



Sue Everett MCIEEM (Ret) PgDip Arch (AEES) for Friends of the Somerset Frome


February 2021