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Will the Storm Overflows Discharge Reduction Plan work?

Consultation response to the government consultation on the draft Storm Overflows Discharge Reduction Plan from Stormwater Shepherds UK

May 10th 2022

Prepared by Jo Bradley, UK Director of Operations

 

  1. The draft Storm Overflows Discharge Reduction Plan fails to recognise that this water pollution has been allowed to worsen over the last 20 years due to a failure of the Environment Agency to review and enforce the Permits that apply to the overflows. The catchments of the overflows have changed due to housebuilding, infrastructure projects, land-use changes and changes made by homeowners. These changes in the catchments often rendered the Permit to be ‘not-fit-for-purpose’ and this should have initiated a review of the Permit by the Agency. But this simply hasn’t been done, so, over time, the overflows have discharged more often, and the nature of sewage has become more polluting so the problem has evolved due to a failure to regulate.

 

  1. The Storm Overflow Discharge Reduction Plan must include a requirement for individual Permits (both new and existing) to be reviewed regularly, perhaps once every 5 years, so that they can be checked to make sure that they reflect the catchment that they serve. If we don’t do that, there is a risk that this problem will simply develop in more areas, and become more severe and we will only identify new problems when the Event Duration Monitors alert us to excess spills and the river pollution is already taking place. Regular Permit reviews will prevent the development of pollution before it happens.

 

  1. Where Overflows are operating excessively and causing measurable environmental harm right now, all development in that sewer catchment must halt until the spills from the overflow can be brought back to an acceptable level. It isn’t enough to ‘offset’ the volume of sewage from the new development by removing surface water from elsewhere in the catchment; there must be a commitment to introduce retro-fit SuDS on the catchment and to include SuDS-Manual-Compliant SuDS on the new development. And all development must be considered, be it a road widening scheme, a new conservatory, or the construction of a new AstroTurf pitch at a local school. It isn’t enough to target new residential & commercial developments alone.

 

  1. If the Water Companies are to monitor their own compliance against their Permits and measure water quality upstream & downstream of their discharges, should they be allowed to pay lower Permit fees to the Environment Agency who have wholly failed to regulate these overflows despite having had a duty to do so for decades?

 

  1. DEFRA must take care to check that the Environment Agency doesn’t allow this new work to divert even more of its staff away from front-line duties and the regulation of other polluters. The introduction of the Water Framework Directive created an entire ‘industry’ of plan-writing and spreadsheet management that took scores of excellent staff away from their environment protection roles and this is, in part, responsible for the evolution of the pollution from storm overflows. It would be a travesty if we now allowed these new plans and spreadsheets to divert them once again.

 

  1. The Discharge Reduction Plan should recognise the need for broader improvements in stormwater management across England. Other statutory bodies such as highway authorities and local authorities are also responsible for the management of huge volumes of stormwater from their assets and they should also be directed to improve their stormwater management. In part, this would reduce the amount of stormwater entering combined sewers, but it would also reduce flood risk and water pollution, and create new jobs for SuDS professionals.

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