London Waterkeeper                            WQR0054

Written evidence from London Waterkeeper

London Waterkeeper 5/2/21. Theo Thomas, Chief Executive.

The health of rivers and the quality of the water are dependent on a wide range of interconnected factors. Resolving the problems will take many years and great effort will have to be expended to maintain progress made.

London Waterkeeper focuses on the problems affecting rivers in and around the Capital. These issues will be common to other urban areas of course.

Every river in London fails the erstwhile Water Framework Directive (a branch of one river sometimes reaches Good standard; the Carshalton Arm, of the Wandle). We note the WFD gives a limited assessment of rivers, particularly from an urban perspective. The rivers are Highly Modified, the cost of improvements needed to raise standards are frequently deemed too high. This is no consolation to the thousands of people who appreciate their local river in London, and the many more that would visit them if they were in an acceptable condition.

Urban Diffuse Pollution

Diffuse pollution is a major reason why London’s rivers are in such poor health. There is, and continues to be, a lack of action to tackle the sources of this pollution. There has been a national policy failure with regards to Urban Diffuse Pollution. In this vacuum there’s an ad hoc approach from conservation organisations in terms of the creation of Sustainable Drainage Systems to mitigate road runoff (these projects are a recent development). This opportunism does see innovative work created. However, it is not at scale or comprehensive.

We would urge the EAC to investigate why Defra has still not produced a National Policy despite carrying out several consultations, in 2012 (https://www.gov.uk/government/consultations/tackling-water-pollution-from-the-urban-environment, and again in 2016 (http://gotw.nerc.ac.uk/list_full.asp?pcode=NE%2FN01264X%2F1&cookieConsent=A).

Many people are critical of the partial activation of Sustainable Drainage Systems via Schedule 3 in the Flood and Water Management Act 2010 and compare England with the fuller implementation in Wales. London Waterkeeper would argue that the gradual creation of SuDS is a result of a limited enactment of Schedule 3 AND a lack of national policy on diffuse pollution. As a result, water quantity and not water quality is primarily addressed by SuDS, most commonly as a way to reduce flood risk (which is important of course). Given there is no national policy on diffuse pollution there is a lack of impetus, and one less reason to use SuDS to mitigate it.

Sewer overflows from Water Company assets

This issue has been receiving more attention. The recent Storm Overflow Taskforce announcement (22/1/21) offered little of tangible value to London’s rivers (or in fact rivers in England). Only Designated Bathing Water sites will benefit from real-time sewer overflow alerts (many bathing sites have these already). So, the only river sites that will see this (at some point) are in Ilkley, on the River Wharfe.

We need to recognise that ‘live’ sewer overflow alerts are of value to all bodies of water, not simply those that are used for swimming. In truth, most rivers will never be given Bathing Water Status, they aren’t deep enough. However, many people visit them, splash around in them, and so risk coming into contact with sewage. In addition, these smaller rivers are in greater danger of being damaged by sewer overflows, less dilution and in the summer lower dissolved oxygen too.

London Waterkeeper sees the lack of accountability as the main reason why there is too little action on sewer overflows. Water companies are not transparent, and we need Government/regulator action to address this. London Waterkeeper is campaigning to have the Environmental Information Regulations 2004 fully activated, so that water companies report sewer overflows in real-time, and not 20 working days after receiving an information request. We have taken legal advice on this. Currently the Information Commissioner’s Office doesn’t think water companies need to issue real-time alerts. Our position is that by their nature sewer overflows necessitate real-time notifications – it is useless to be told three weeks later that a river someone entered was polluted with sewage. We are putting Thames Water under pressure to achieve this. We have just launched our ‘Rainy Day’s campaign. This urges people to email the water company every hour that it is raining and ask if sewers are overflowing. Clearly it would be more appropriate for Thames Water to put this online, in the same way Seattle does https://www.kingcounty.gov/services/environment/wastewater/cso-status.aspx.

Some sewer overflows are unavoidable, e.g. Storm Dennis etc. No one wants to see sewage inundating homes and streets. However, we should still be told when this is happening. We closely watch the Mulberry Court Combined Sewer Overflow which discharges to the Olympic Park wetlands (55 times in 2020). 35 overflows were due to extreme weather. We believe the remaining overflows could be reduced with investment. None is planned, currently.

The lack of accountability allows monopoly water companies to evade scrutiny. This breaches the Environmental Information Regulations 2004 and the Aarhus Convention, of which the UK is a signatory. We believe that greater accountability would see an informed and empowered population and create greater pressure for action on sewer overflows. It would also rebalance the power dynamic which currently sees water companies have too much influence on regulators and some conservation charities.

February 2021