Policy Connect                            WQR0017

Written evidence submitted by Policy Connect

This document forms Policy Connect’s response to the Environmental Audit Committee’s call for evidence to inform their forthcoming inquiry on water quality in rivers.

Policy Connect is a membership-based, not-for-profit, cross-party think tank. We bring together parliamentarians and government in collaboration with academia, business and civil society to inform, influence and improve UK public policy through debate, research and innovative thinking, so as to improve people’s lives.

We lead and manage an extensive network of seventeen all-party parliamentary groups, research commissions, forums and campaigns in key policy areas including: health; education & skills; industry, technology & innovation; and sustainability. We shape policy in Westminster through meetings, events, research and impact work. 

Policy Connect is submitting written evidence to the committee based on our longstanding expertise in Sustainability.  We have drawn on wide-ranging evidence and stakeholder input from industry, academia, and the third sector. We combine this evidence from different sectors by managing the All-Party Parliamentary Sustainable Resource Group (APSRG); the Sustainable Resource Forum (SRF); the All-Party Parliamentary Climate Change Group (APPCCG); and the Westminster Sustainable Business Forum (WSBF). We have responded to the questions within the call for evidence that are most relevant to our work across these areas, in particular, our recent reports Plastic Packaging Plan: Achieving Zero ‘Waste’ Exports and Bricks and Water: Building Resilience for England’s Homes. These reports had wide support from the sectors that would need to implement the recommendations.

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?

Reducing the amount of plastic that is used in packaging would subsequently decrease the amount of plastic that ends up polluting rivers. 

Current regulations that make over-packaging illegal are intrinsically weak as they contain a ‘consumer acceptability’ clause that allows over-packaging for commercial purposes. Furthermore, they are often overlooked by Trading Standards, who lack the resources or inclination to enforce them.

In the first instance, manufacturers should switch to zero or reusable packaging options in order to reduce pollution.  Light weight packaging is often cited a solution to decrease the environmental impact of transportation and wastage.  However, light-weighting can affect recyclability as multi-layer composite packaging is harder to recycle and therefore more likely to pollute the natural environment.

Our Plastic Packaging Plan made the following recommendations, which would cut-down plastic use and reduce the amount of plastic pollution entering rivers, these have yet to be implemented:

  1. A Plastic Packaging Taskforce should be established within the Environment Agency, funded through registration fees for packaging compliance schemes.


  1. Enforcement of the Packaging (Essential Requirements) Regulations should be transferred from Trading Standards to the Environment Agency Plastic Packaging Taskforce.
  2. Large retailers should demonstrate leadership by introducing zero packaging or reusable packaging options for appropriate products.

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

Consumers have a key role to play in reducing pollution in rivers, particularly with regard to littered plastics.  Increasingly, people interact with packaging on-the-go, where they are far less likely to recycle it or even dispose of it correctly.  Currently only 42% of local authorities offer on-the-go recycling collection infrastructure[1].  Policy Connect has put forward a system to address this, which includes improved recycling infrastructure, clear on-pack labelling, and consistent messaging about recycling and littering.  A well-designed Deposit Return Scheme (DRS) focused on plastic beverage containers will also be crucial to improving on-the-go recycling rates and avoid these plastics ending up in rivers.

Our Plastic Packaging Plan made the following recommendations, to engage consumers to litter less and recycle more, and we believe these are as relevant now:

  1. Sustained, long-term pro-recycling and anti-littering communication campaigns should be coordinated between the Environment Agency Plastic Packaging Taskforce and WRAP’s established ‘Recycle Now’ campaign.


  1. Westminster should work with devolved administrations to introduce a world-class UK-wide Deposit Return Scheme (DRS) focused on plastic beverage containers.

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

As the Committee is aware, Combined Sewer Overflows (CSOs) occur when the capacity of the combined sewerage system is exceeded and dilute effluent is discharged to rivers and streams. Even new developments, which must have separate surface and foul sewer networks, may exacerbate this problem if the surface water from the properties connects into the combined system downstream.

Discharge of surface water to Sustainable Drainage Systems (SuDS) is possible in almost all scenarios and has been demonstrated to be cheaper than installation of traditional drainage systems[2].  Current planning and regulatory systems also fail to incentivise new developments to discharge surface water to SuDS and wastewater into local, community-based wastewater treatment and resource recovery centres.

Our Bricks and Water inquiry, which has the support of water and sewerage companies, housebuilders, and drainage engineers has therefore recommended:

  1. That the automatic right for new developments to discharge surface water to existing public sewers should be removed (in accordance with Recommendation 10, made within the 2008 Pitt Review).  Since the Pitt Review the use of SuDS has become more cost effective, making this easily implementable for developers.




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

The specification of SuDS is currently delivered through local policy on a non-statutory basis, using DEFRA’s Non Statutory Technical Standards[3] and the Construction Industry Research and Information Association SuDS manual[4] as guidance.  Whilst the use of these standards should in principle lead to the creation of compliant SuDS that do not receive pollutants associated with sewerage or highway runoff, in practice there remains wide variability in local SuDS policy across England.  For example, 25% of Lead Local Flood Authorities have no formal policy and no plans to implement one[5].  We therefore continue to strongly recommend that:

  1. Minimum standards setting out the design and maintenance of SuDS to ensure that diffuse urban pollution is minimised should be introduced on a statutory basis.


In sum, our research recommends reducing the amount of pollution that enters rivers through reducing littering and encouraging recycling.  Where new development is proposed, we have recommended that pollution is further prevented through the use of well-designed sustainable drainage systems. These are both good for removing the source of river pollution but also create additional space for both nature and people’s well-being. 

Policy Connect would be happy to give evidence to provide further detail and offer solutions to the Committee.

February 2021


[1] Local Authority disposal ‘on the go’ survey, RECOUP, 2017

[2] Water availability and quality programme: comparative costings for surface water sewers and SuDS, DEFRA, February 2011

[3] Non-statutory technical standards for sustainable drainage systems, DEFRA, March 2015

[4] The SuDS manual, CIRIA, December 2015

[5] Achieving sustainable drainage: a review of delivery by lead local flood authorities, Landscape Institute, January 2019