Catchment-Based Approach Urban Water Group (CUWG)              WQR0037

Written evidence submitted by The Catchment-Based Approach Urban Water Group


The Catchment-Based Approach Urban Water Group

The CaBA Urban Water Group (CUWG) is a cross-organisational, cross sector working group of the Catchment Based Approach which champions a collaborative, partnership approach to urban water management, engaging and raising awareness across a range of key stakeholders to drive improvements to water quality and biodiversity, reduce flood risk, enhance health and well-being and build community cohesion.


The CUWG supports CaBA partnerships nationwide by helping them to build capacity and expertise and to engage more effectively with key stakeholders, including local authorities, communities, businesses and developers, on urban water management issues, driving collaborative delivery on the ground. CUWG is helping to drive the delivery of urban water management under the Government’s 25-year Environment Plan, including through the promotion of green-blue infrastructure and the multiple benefits that can be realised.


The group is chaired by Peter Bide (formerly of DGLC) with a membership encompassing Environmental NGOs (Rivers Trusts, Groundwork, Wildfowl and Wetland Trust), Environment Agency, Natural England, Water UK, Local Government and CIRIA.


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

The suite of ecological, physico-chemical and chemical parameters long established under the Water Framework Directive provides for a comprehensive framework for monitoring the ecological and chemical health of rivers and reporting it against an agreed classification system. Importantly, at a high enough spatial scale this monitoring can underpin water quality indicators and discriminate between differing sources of pollution (e.g. rural versus urban). However, currently the monitoring is not intensive enough to facilitate this and there are many water bodies where there is no monitoring at all e.g. the Salt Hill stream in Slough. The Environment Agency’s monitoring is reducing significantly which will reduce the national evidence base further. Because of this, understanding pressures and solutions is becoming increasingly challenging. Often, these watercourses are in urban areas where, as water quality declines, other problems often ensue such as littering and other gross pollution. A significant expansion of this capability is needed to meet the objectives of the WFD.

Additionally, the current WFD approach with its one out all out approach also masks the progress which is being made in improving waterbody status.

Assuming that this question is seeking views on the selection of a few broad indicators for communication purposes then the ‘water’ indicators (extending beyond quality) provide a good starting point to reflect the major pressures upon freshwater and coastal environments. Of these (list below), 4 directly address water quality, although the close interlinkage between water quality and quantity  is critical.

Water quality in the urban environment has received disproportionately limited attention and it is critical that it is the focus for one of the indicators. It impacts the largest proportion of the UK population, and nature-based solutions in towns and cities provide multiple benefits for the environment and local communities.  These indicators are difficult for a non-technical audience to understand, so for communication purposes indicators could be condensed into a shorter and more comprehensible list e.g.:

In addition to these, an indicator addressing Bathing Water is desirable, for coastal and inland waters.


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

If the plans are drawn up and implemented catchment-wide and genuinely consider drainage and the impacts of this and are collaborative, then they can identify catchment schemes that help manage sewer networks and treatment and also improve water quality. Inclusion of nature based solutions (including SuDS) would provide opportunity to intercept runoff and attenuate pollution long before the point at which it combines with and overwhelms the capacity of sewer systems during heavy rainfall. This will help to reduce the magnitude and frequency of storm overflows.

Flexible plans that allow for the pooling of resources and funds from multiple stakeholders (not just water industry) can result in partnership solutions and a greater number of nature-based schemes being implemented that realise multiple benefits. These plans need to be medium-long term (5-10 years) and based on strong local partnerships.


4. 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?

Plastics of all sizes are now ubiquitous in rivers (and their bed sediments) and in the oceans too. Plastics ingested by aquatic life can cause starvation and affect reproduction and growth. Potentially toxic contaminants released as plastic degrades can move up the food chain. Plastic debris blocks drains and other hydraulic infrastructure increasing flood risk.

A whole range of pollutants in addition to plastic are generated in the urban environment and are often present in rivers, including PAHs, heavy metals and hydrocarbons that give rise to a range of detrimental ecotoxicological effects.

Nature based solutions such as wetlands and reedbeds have a key role in attenuating these pollutants prior to their discharge to a watercourse and provide other benefits, including reduced flood risk, enhanced biodiversity and improved health and wellbeing of local communities. The Broomfield Park wetland in Enfield, North London is a recent example that captures surface runoff from an urban estate and has a high (> 75%) efficacy in attenuating both nutrients and heavy metals. Where space is at a premium in the urban environment, other innovative approaches are possible. The ‘downstream defender’ is a large centrifugal drum sunk into the pavement that traps sediment and associated particulate pollutants as they discharge from an urban drain, preventing pollution of the nearby river by metals hydrocarbons and other pollutants.

Mitigation is important.  However, much more needs to be done to reduce the input of plastic into the water environment, starting with manufacturing. Non-recyclable plastic packaging and non-recyclable, single use plastics should be disincentivised, possibly via a plastic tax, with the funds generated used for developing new packaging and recycling technology, and investing in improvements to recycling facilities.

There is disparity between the recycling services provided by local councils, who accept different materials and process them in different ways. There needs to be a national strategy for recycling with more ambitious targets and local plans for bringing all authorities up to the same standard. Packaging often combines both recyclable and non-recyclable plastics which presents a further barrier to recycling.

Addressing fly-tipping and littering will go a long way to reducing plastic (and other waste) entering the water environment. More resources are needed for preventative measures and the enforcement of fines, including the investigation of fly-tipping incidents. A clear strategy for reducing littering would also be beneficial. Awareness of the natural environment and the pressures on it must be improved, starting with education in schools and awareness campaigns, and supported by practical solutions that encourage better behaviours. Messages around behaviour change need to be consistent and maintained, and companies whose waste contributes significantly to the problem, such as fast-food chains and drinks manufacturers, should go further in their efforts to change behaviour and reduce littering. 


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

Engagement and awareness raising are a key mechanism for driving behavioural change. CUWG recognises that the 106 Catchment Based Approach (CaBA) river catchment partnerships in England which bring together multiple organisations with an interest in working in partnership to improve the water environment, have direct links to their local communities and engage with them on a range of education and engagement, volunteering and citizen science activities. Additionally, many within these networks engage with schools, running courses that integrate with STEM subjects including on SuDS, aquatic pollution and the biological health of rivers.

A framework readily exists, therefore, to directly engage the general public and local businesses on several pollution related issues including the use of and disposal of chemicals in the home and garden, medicine take-back schemes, and the disposal of fats, oils and greases. Experience shows that raising awareness within communities of their river, builds local ownership of environmental issues, leading to sustained behavioural change.

For example WWT’s Transforming Slough – saving the Salt hill stream project has proven that local people, when given the opportunity and support are willing to take action for their local stream. This engagement and participation only works if sustained over years and delivered at the grassroots level.

People need to feel connected to the areas where they live and to understand how their actions affect the environment. The creation of blue spaces with significant community engagement could help create this connectedness. WWT are proposing a network of urban blue spaces to support wellbeing as part of their Blue Recovery Programme . Good quality, accessible and attractive urban blue space can be provided, where people live and work, and can be targeted at areas in greatest need. Urban wetlands provide benefits beyond wellbeing and can be designed to address multiple issues. These include facilitating active travel, improving water quality, reducing surface water flooding, strengthening community cohesion, reducing urban heating and increasing biodiversity. Globally, the UK could follow the best practice of 18 'Wetland Cities', recognised by the Ramsar Convention as pioneers in the conservation and wise use of urban and peri-urban wetlands and the socioeconomic benefits they bring for local people.


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

The use of the term ‘versus’ in this question is not appropriate. Whilst ‘hard’ civil engineering solution will be required in some circumstances, sustainable drainage and nature-based solutions are effective to attenuate urban runoff. By capturing this flow, allowing some of it to infiltrate and the rest to be released more slowly, these features help to reduce the magnitude and impact of storm overflows. SuDS/Nature-based solutions should be a key part of the approach and hence investment. The multiple benefits of nature-based solutions should be recognised and included in cost/benefit analyses at project design stage. Resources need to be applied to ensure that design teams include appropriate expertise from nature-based solution/SuDS fields.


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

Planning policy and standards for the installation and adoption of SuDS in England are not fit for purpose. 


A major block to increased use of SuDS is a lack of coherent and consistently interpreted and applied national policy (both within the National Planning Policy Framework (NPPF) and its supporting policy guidance and across policy responsibilities of other government departments) (


The issue of insufficient policy and regulatory support for SuDS was addressed in the Flood and Water Management Act 2010 (FWMA), particularly Schedule 3 of that Act.  Section 3 introduced mandatory standards for SuDS, the introduction of SuDS Approval Bodies (SABs) in local authorities to approve and adopt SuDS, and (through schedule 42) amended Section 106 of water Industry Act 1991 to make the right to connect surface water to the public sewer conditional on the SAB approving the drainage of the site (prior to this, a developer has an automatic right to have the drainage from a site connected to the public sewer, making it very difficult for the water company to require SuDS).


Following intense lobbying from the major house builders, the Government did not implement Schedule 3, but instead made amendments to the NPPF such that decisions on planning applications relating to major developments should ensure that SuDS are put in place, unless demonstrated to be inappropriate. This clause makes it relatively easy for developers to argue for the use of conventional piped drainage with which they are more familiar.


The approval of drainage schemes (in line with non-statutory standards issued in 2015) currently falls to the Local Planning Authority in consultation with the Lead Local Flood Authority.  There are no formal arrangements for the adoption of SuDS.


The situation is much better in Wales, where Schedule 3 of the FWMA has now been implemented, supported by mandatory national standards for SuDS.


The situation in England is not as bad as it was immediately following the non-implementation of Schedule 3. However, the Government’s review of surface water and drainage (the Jenkins review) (, published in May 2020, highlights the widely and strongly held view among flood risk management practitioners and many of the organisations that the present approach put in place instead if implementing Schedule 3 of the FWMA is not working.


The water industry has gone some way to address the issue of adoption of SuDS through the new Sewerage Sector Guidance, which in 2020 provided new rules for the adoption of SuDS.  These rules allow English water and sewerage companies to adopt a wider range of sewer types, including SuDS.  This is being supported by a recent Government announcement that Section 42 of the FWMA to make the right to connect surface water to the public sewer conditional on approval of the drainage of the site will be implemented.


Whilst improving the situation, this does not address the issue of effectiveness of planning policy and standards.  The NPPF and its supporting Planning Policy Guidance needs to be strengthened in line with the recommendations of the Jenkins’ review, with less opportunity for developers to argue that SuDS are not appropriate.


This strengthening of planning policy, and the increased ability of water companies to require and adopt SuDS, and to ensure that SuDS are appropriately designed to deliver multiple benefits to the environment and local communities, needs to be underpinned by statutory national standards for SuDS, as in Wales. Defra commissioned research in late 2020 to examine the case for updating the English Non-statutory technical standards for SuDS. This update must include the water quality functions of SuDS.


For this to work, local planning authorities (LPAs) must have the knowledge/resources to ensure high quality SuDS. Experience of CUWG members on the Welsh SuDS Implementation Group is that although the twin-track approach to permitting SuDS (planning permission and a SuDS approval) is in place, the new approach needs a substantial increase in LPA/SAB resources and expertise to deliver high quality SuDS. A much stronger regulatory framework is required with adequate resources.


If the new Sewerage Sector Guidance, along with the implementation of Section 42 of the FWMA, succeeds in increasing the use of SuDS by getting SuDS approved and adopted by water companies, then there is probably no need to implement the Schedule 3 requirement to create SABs in England. However, this should be kept under review.


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

Yes. Road runoff delivers significant contamination (heavy metals, fuel, sediment etc) into watercourses that can remain locked into river sediments for many years, a fundamental reason urban rivers fail to meet WFD objectives. Remedial action requires a duty on LPAs and highway authorities to prevent this. This then necessitates significant funding being allocated. Here, both Nature-based solutions and civil engineering approaches (e.g. downstream defenders) will be needed to intercept and clean up road runoff. Appropriately sited and designed urban wetlands can treat this runoff whilst providing other important benefits too.


9. 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?

Ofwat’s regulatory approach together with that of the EA stifles such approaches. The review of WINEP may help with a link to catchment outcomes and reduced compliance risk, but where it does, enhancements are limited in company plans to keep bills low, and even where customers are willing to pay companies may not be allowed to include schemes. There is a question over how these should these be paid for.

There needs to be a shift for next WINEP (and beyond) to focus a greater % of the affordable investment “pot” on the wastewater network (rather than continuing to seek very minor – but very expensive – improvements to wastewater treatment works discharges which will have proportionally less benefit to river water quality).


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

Waste water treatment works are coming under increasing pressure and will require expansion. Waste water treatment works, where feasible, should introduce treatment wetlands as tertiary treatment.  Nature-based solutions such as this improve water quality, address capacity issues and provide other benefits.

There is no incentive or enabler for wastewater treatment to be sustainable in the application of new treatment requirements, and carbon and chemicals requirements are exceptionally high e.g. for phosphorus removal. Delivery costs and compliance requirements and deadlines trump a sustainable approach in the majority of cases.


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

The designation of inland bathing waters is provided by Defra, not water companies.

Costs should not be evaluated in isolation but together with the benefits arising, including: reductions in microbial and chemical pollution; improved amenity and aesthetic value and health and wellbeing; reduced risk of waterborne disease; and increased biodiversity.

Currently, the EA do not monitor bacterial quality in inland rivers, as they do for designated bathing waters, therefore new designations would require additional EA monitoring at a time when this is reducing due to financial and resource pressures.

There are currently very limited formal measures in place (Framing Rules for Water) and no enforcement to ensure that the agricultural sector protect watercourses from pollution.  However, designating inland bathing waters would see more cost-effective delivery of related agendas e.g. Government’s 25 year environment plan.


February 2021