The Catchment Partnerships in London Group (CPiL)              WQR0061

 

Written evidence from The Catchment Partnerships in London Group

 

 

The Catchment Partnerships in London Group (CPiL) consists of the catchment hosting organisations operating within Greater London and reaches out to stakeholders across the capital.  Our purpose is to support the work of Catchment Partnerships, facilitate shared working towards solutions to the environmental challenges faced by rivers and to provide a more powerful combined voice to champion water quality and river catchment issues.

 

The Inquiry into water quality in rivers is integral to our work and our responses to the questions raised are as follows:-

 

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

 

The best indicators are the priority water chemistry parameters (dissolved oxygen, phosphate, suspended solids, coliforms and ammonia) plus ecological indicators including invertebrates, plants, fish and larger animals which are sensitive to changes in water quality.  Targets under the Environment Bill should be set for social pressures in urban catchments including plastics, litter and fly-tipping; and heavy metals & PAHs from road run off pollution. 

The effectiveness of indicators in demonstrating water quality depends upon data collection. CPiL believes that live, web-published continuous monitoring (as opposed to current practice of infrequent spot sampling) will allow for more accurate and transparent assessment together with visual surveys and on site testing / sampling including Riverfly monitoring which can be done more extensively and on a more regular basis by trained and supported catchment volunteers.

Monitoring using targeted indicators should be designed at the catchment scale and tailored for water bodies dominated by rural / urban pressures to tackle pressures more effectively and identify pathways / sources more specificallyMore investment in better targeted monitoring should be the priority for achieving more cost-effective, consistent and sustained environmental benefit. An increase in funding to LLFAs or direct funding to support Catchment host organisations is vital. 

Plastic litter monitoring in rivers should be standardised across the country with Thames21 and other trusts from the national Rivers Trust movement taking a lead in development of a partnership with the EA and relevant stakeholders. The data gathered should shed light both on the overall amounts (e.g. volumes of litter removed) and the sources (via the quantification of specific litter items). Data collection is well suited to citizen scientists, as demonstrated by the Thames21’s Thames River Watch project in London, but requires funding for training and ongoing support. Identification of items should use the OSPAR litter classification so as to conform to standards adopted in coastal regions (e.g. by the Marine Conservation Society). Methods for estuaries will differ to those of freshwater and will resemble more closely those adopted in coastal areas.

Recent changes to the Flood Defence Grant-In-Aid process do not go far enough in delivering of environmental benefit.  There must be greater inclusion of water quality, habitat and other outcomes in the PFC to encourage flood risk / defence projects to take a multiple benefit approach.

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

 

Better resourced CaBA, private-public-NGO partnership and collaborative working practices will be essential to realising the benefits of the new Drainage Water Management Plans and other water company initiatives (e.g. Water Resources Management Plans; Water Industry National Environment Programme etc).

 

Joined-up engagement via liaison between water companies and ongoing CaBA partnerships at the local scale will provide better results, efficiencies and effective outcomes for initiatives seeking to reduce sewer dischargesPilots for integrated approaches to similarly complex challenges around the country have demonstrated that this is achievable when investment is forthcoming.

 

Thames Water via the new AMP and Drainage Water Management Plan are looking at multiple solution options such as creating space for water in partnerships with other RMAs that could reduce the frequency and risk of foul and surface water flooding during storm conditions due to dual manholes.

 

The private members Sewage (Inland Waters) Bill 2019 – 21 has the full backing of the Catchment Partnerships in London and is widely supported across the eNGO sector.   Integrating the private members into the Environment Bill would help to bring elements together.

 

3.              How adequate are the monitoring and reporting requirements around water company discharges? How can technology improve and assist with transparency and enforcement?

 

The current requirements date back decades and following Defra/EA cutbacks they have been reduced to the bare minimum.  Today, they are woefully inadequate. While efficiency may be justified, progress on tackling pollution cannot be achieved without targeting a proportional approach to monitoring.

 

Real-time monitoring is essential for known ‘hot-spots’. Modern instrumentation and telemetry allow for real time continuous monitoring and web-based publishing of results in near real time, for both transparency and to enable recreational river users to time their activities according to risk. Event Duration Monitoring (EDM) should be in place on all discharging assets - although this does not capture all intermittent discharges, only the legal ones.  Illegal discharges occur frequently from surcharging man-holes and other leaky infrastructure.

 

In addition there should be greater investment in NGO CaBA partners to engage with local ‘eyes and ears’ through citizen science, essential for effective ‘Sentinel’ type data collection. Use of local volunteer-gathered data is viable where those involved are supported and see the value of their contributions, resulting in long term commitment. 

The costs of providing this support, through training, mentoring and co-ordination, should not be under-estimated, but can provide proportionately beneficial results, not only in data gathering, but disseminating awareness of water quality issues.

 

While the monitoring and reporting of discharges is crucial, CPiL is keen to emphasise that it becomes pointless if the data obtained is not used to make improvements. This requires legislative changes to planning and building control.  Current arrangements are inadequate and clarification is required with regards to ownership of misconnection problems.  What appears not to be accepted by local authorities is implementing enforcement legislation through the Building Act to tackle those who refuse to correct misconnections. Clarification is needed regarding potential for water companies to use powers through the s.16 Water Act 1991.

 

There should be investment in water company developer services to ensure new development connections are tested, approved and signed off.  Misconnected drains is not just an historical but a continuing problem that sees pollution returning to water courses that had previously been cleared of misconnections. 

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?

 

From micro-plastics to large trash and everything floating and sinking in between, plastic pollution represents a significant pressure on a very high proportion of our water courses especially in urbanised catchments.

Plastics are a durable material and therefore lead to long term pollution of the natural environment. Major effects are visible both physically (as anthropogenic geomorphological impacts) upon habitats, as well as upon drainage; and bio-chemically upon water quality. 

Plastic pollution harms our wildlife.  It kills or injures some vertebrates (especially waterfowl) as well as invertebrates as shown by recent work at the University of Royal Holloway and the Natural History Museum, demonstrating the presence of plastic fibres in two species of crab, fish and clams in the Thames estuary.[1] Associated toxic micro-particles and leachates are poisoning wildlife.

Plastics have the ability to remain intact for decades.  When they do fragment due to level of exposure to ultraviolet (UV) and mechanical forces, what remains are micro and nano plastics which have been found in various food sources and even in tapwater. In addition to the ecological implications of microplastics for aquatic wildlife, plastics can compromise food security, human health and food safety.

In urban areas plastic debris is known to clog drains and other hydraulic infrastructure, increasing flood risk in these areas. It is known that plastic debris transport rates increase with precipitation and river discharge. Blockages of urban drainage systems during such events can have catastrophic effects, such as a major flooding event and resultant impact on neighbourhoods and communities.

In addition heavily littered rivers and their environs reinforce negative public perceptions of them. Many urban watercourses have been subject to decades of plastic and other littering, which is costly and time-consuming to remove, let alone sustain their clearance. Once litter becomes visible – plastic often being the most visible – it becomes a magnet for more to accumulate (the ‘broken window’ principle)

Mitigating plastic pollution:-

Reduction of plastic in the water environment must start with the manufacturing industry, with manufacturers taking responsibility for the amount of plastic they produce. Non-recyclable plastic packaging is used excessively and unnecessarily, particularly within the food industry. The use of non-recyclable, single use plastics should be dis-incentivised, possibly via a plastic tax, with the funds generated used for developing new technologies in packaging and recycling, and investing in improvements to recycling facilities.

Investment and encouragement should be given to SMEs in particular to accelerate the implementation of biodegradable packaging for all products.

Micro-fibre pollution in waters shed by plastic clothing during washing could be mitigated by the roll out of filters in washing machines.

Across the UK there is disparity between the recycling services provided by local councils which accept different materials and process them in different ways. This is especially acute in Greater London, with 33 local authorities; despite some sub-regional co-ordination, this relates to disposal rather than approaches to recycling & collection. 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 in one item which presents a further barrier to recycling for the general public.

There should be investment in the use of enforcement powers by local authorities on littering and fly tipping. Examples of false economies in local authorities include locking public parks and open spaces leave them vulnerable to later night visitors, causing littering problems which require more time and resource to clear making parks and green teams less efficient in managing parks, open spaces and rivers.

Addressing fly-tipping and littering would go a long way to reducing plastic (and other waste) entering the water environment. The current waste disposal system for businesses such as small household clearance and builders’ firms should be reviewed, with alternative solutions proposed. More resources are needed for preventative measures and the enforcement of fines, including the investigation of fly-tipping incidents.

Volunteering litter clean-up programmes help provide some short term mitigation, however volunteering programmes are currently too small-scale and fragmented to have the level of impact required to address plastic pollution in rivers.

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

Existing Government strategies to reduce littering by the general public should be adequately resourced and applied more effectively to provide a step change in the way that people view the natural environment so that littering becomes socially unacceptable.  This starts with education in schools and includes undertaking major campaigns to raise public awareness of the impacts on all water environments (not just on oceans) and supported by practical solutions, such as more bins and clearer packaging, to encourage better behaviours.

Practical engagement and volunteering programmes on rivers in local communities connect the public directly with pollution issues and their impact - providing ‘ground-truthing’, social context, impetus and incentive required for sustainable behaviour change.  An emphasis on shared values, pride in local quality and ownership of shared spaces receiving greater use and appreciation, especially as part of Covid green-recovery, will help persuade consumers.

Messages around behaviour change must 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 reduce littering. More thought needs to be given to the materials used in promotional campaigns, especially those directed at children, which often include disposable plastic toys.  Plastic waste should be added to UK legislation emerging from the Water Framework Directive. 

Stronger sanctions against those who litter and pollute should be introduced with greater regulations, fines and enforcement to deter public littering and fly-tipping.

 

 

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

 

This question is challenging to answer. Clearly considerable investment is needed to improve capacity of the wastewater network and reduce surface water input by utilising more sustainable drainage systems. However, all options require investment.

 

The investment required isn’t just about capital works to make space for water; it is to address many years of austerity preventing local authorities from carrying out their statutory duties properly together with growth resulting in less space for water.  We suggest that Defra read their report Making Space for Water  https://webarchive.nationalarchives.gov.uk/20090731131803/http://www.defra.gov.uk/environ/fcd/policy/strategy.htm . Over the last 30 years there have been changes to  planning legislation, increased housing targets, the loss of due diligence of sewerage undertaker developer services in water companies).  There must be a firm commitment by Local Authority Inspectors to visit all new developments to check and test new drainage equipment / connections.

 

Sustainable drainage and nature based solutions deliver other additional benefits and are therefore investable by other organisations/sectors, as they achieve on others’ objectives. These mixed finance solutions would spread the costs and so be more cost effective and achievable.

 

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

These policies and standards are good for best practice – however, they will not be effective unless they become mandatory, rather than optional.

Currently SuDS delivery is piecemeal, SABs were abandoned.  There are good examples of improvement from many LLFAs but it is a struggle, reliant on good partnerships and lacks a consistent and coordinated approach.

There should be introduction of tighter and more ambitious regulations for developers on building housing to make new builds water neutral. Other initiatives such as effluent re-use etc. all need regulator support.

Budgets must be linked up in local authorities to allow the planning, delivery, maintenance and benefit of Green Infrastructure to match up. Local authorities and others own substantial areas of urban land such as car parks and schools. Retrofitting of SuDS in these situations should be strongly supported and funded to address urban pollution loads. Regulation and enforcement may be required to achieve this. Very few local authorities have an integrated public works delivery model which would enable all public highway, public realm, parks and open spaces works to be delivered with a multiple benefit approach. 

Delivery around planning policy and standards needs investment enabled by mechanisms linked to more diverse funding sources (especially for urban catchments). Investment is needed to develop stronger mechanisms and case studies to demonstrate to the private sector that investment is essential for businesses across all sectors - that it is not a ‘nice to do’ or a drain on resources.

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

Yes, in accordance with the well-established ‘Polluter Pays’ principle. 

Support for greater collaboration between local authorities and highways agencies should be a priority for central and regional governments, especially in fully urbanised catchments.

We should be doing everything possible to reduce road run off from highways to watercourses and rivers but this would require a major redesign of how water is collected from the highway including silt management.  There are good examples re recycling road gulley arisings and the dirty water https://www.fmconway.co.uk/our-services/water-and-drainage-management/liquid-waste-management.

 

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

 

There is a basic contradiction between Ofwat’s position and achieving the government's environmental aims. Ofwat final determinations do not give adequate consideration to environmental protection or mprovement.  Ofwat’s focus appears to be on driving water bill prices down, whereas considerable investment is required to address the water industry’s environmental impact and build resilience in the degraded ecosystems that water provision relies on. 

 

Nevertheless in some cases Ofwat has demonstrated an effective role in driving forward water environment improvements through targeted investment, demonstrating that it can be achieved, in particular for Restoring Sustainable Abstraction (RSA) in chalk stream catchments.  A similar approach is needed for Sustainable Urban Drainage and Nature-based Solutions whereby funding is allocated for targeted partnership programmes that include both EA and CaBA NGOs in collaborative planning and delivery.

 

Given the level of potential impact on the environment of the water industry, investment to meet environmental responsibilities should be prioritised ahead of shareholder dividends. Improved investment was sold as a benefit of privatisation, and while investment has increased, the environment is still heavily impacted by the industry and the general public are not seeing the benefits. The Government should advise Ofwat more strongly about the level of investment required for water companies to meet their statutory environmental responsibilities, and secure this investment so the water industry can become environmentally respected.

 

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

Investment is generally inadequate as full consideration is generally regarded only in ‘best practice’ approaches. To deliver future climate change resilience greater investment and recognition of the role of ecosystem services across all sectors is fundamental to consistent and cumulative benefits   It should be considered in drainage water management plans and be accounted for in the Ofwat price review process. 

Consideration of climate change should currently be included in all project proposals and inclusion made mandatory via permitting process – as noted above, this is currently part of policy ‘best or good practice’, and should be made more robust with statutory status.

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

This assumes that the designation will be made by water companies.  The designation of inland bathing waters should be made by public authorities rather than private sector to reflect the broader benefits and value of outdoors exercise and healthy condition of the natural environment to public health and wellbeing

The costs of achieving the water quality standards that would ensure safe access to water at historic and highly popular bathing locations should be met by the polluter in line with the ‘polluter pays’ principle. The level of treatment would need to higher to meet inland bathing water site standards, so it would require significant investment in the sewerage network and STW to achieve this. Water company shareholders might expect this cost to be spread across water company customers and reflected in an increase in cost of water supply and treatment services; however moderation of profits for shareholders would be more ethical rather than for shareholders to profit at the expense of either the natural environment, or of customers’ health and wellbeing.

 

Greater encouragement of companies’ participation and achievement of Water Stewardship Standards should be driven via the requirements of the Environment Bill 2021.

 

February 2021


 

 

APPENDIX

 

Members of the Catchment Partnerships in London Group

 

CPiL consist of the hosts of the catchment partnerships operating within the Greater London boundary, and other interested organisations that operate on a London-wide or national basis:

 

Others attending who are not members of CPiL include:-

 

 

The Catchment Partnerships in London Group is hosted by Thames21

Guildhall, Aldermanbury, London EC2V 7HH

Registered Charity Number: 1103997  

 

 

 

 

 

 


[1] https://www.bbc.co.uk/news/science-environment-53479635