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The Storm Overflows Discharge Reduction Plan: A missed opportunity to truly recover our waterways

Link's Matt Browne & Ellie Ward highlight the shortfalls in the Government's the Storm Overflows Discharge Reduction Plan.

August 2022

Last week saw the publication of the long-awaited Storm Overflows Discharge Reduction Plan, which aims to reduce the release of sewage into our waterways.

On a positive note, the Plan’s publication shows that Government is at last alive to the seriousness of the issue. Attention is now rightly focused on sewage across the political spectrum, thanks to the work of environmental campaigners both inside and outside of Parliament.

In response to this rising concern the Plan offers too little, too late. The release of sewage from storm overflows is not a static problem, now picked up on and resolved by the Plan – rather it constitutes a growing crisis, which the Government’s solutions fail to scale up to.

Climate change and increased urbanisation means that storm overflows, originally an emergency measure to avoid sewage systems being overwhelmed at times of exceptional rainfall, are now occurring much more frequently. 2021 saw sewage pumped into waterways for 2.6 million hours in England, contributing towards rapid declines in the health of our freshwater environments. Increases in pollution from storm overflows in recent years have contributed to 0% of English rivers, lakes and streams being classed as being in good health. As the climate continues to change and existing sewer systems creak further under surging demand, we can expect these impacts to worsen.

Sadly, the ambition in the Storm Overflows Reduction Plan falls well short of matching and overcoming these growing harms. Key shortcomings include:

- Overall timescale: The Plan would cut the annual average spill frequency of storm overflows from the current 29 per year to 10 by 2050. A lot of the work will be left to the end of that period, with 48% of storm overflows being completely unimproved by 2040. Allowing significant quantities of sewage to enter English waterways for a quarter of a century more does not constitute swift and effective action.
- Timescale for high-priority nature sites: Rightly, the Plan states that the storm overflows that impact nature the most should be improved first. However, the timescale for this is again much too slow, with only 38% of the storm overflows that cause the most ecological harm due to be improved by 2030, and only 75% by 2035. This means that, in the latter year, sewage could still be spilling into well over 1000 priority wildlife sites as late as 2035. The Environment Act contains a crucial target to halt the decline in species abundance by 2030. Having sewage from most of the storm overflows affecting high priority nature sites continuing to pollute up to and beyond 2030 will make that target, and wider Environment Act nature recovery goals, much harder to hit.
- The omission of marine overflows: The Plan does not include storm overflows in estuarine and coastal waters (unless they are near to a bathing water or some shellfish fisheries). There were over 66,000 sewage spills into the sea in 2021, the majority of which will go unaddressed even when the Government’s Plan is fully implemented. The effect of these sustained spills on marine habitats, coastal water quality and on the viability of some fisheries will be significant, especially given the diffuse nature of pollution at sea.

The Government has defended these omissions on the grounds that action on this scale would too expensive. This argument goes to the heart of the problems in the Plan; it relies on data, including cost estimates, provided by the very water companies responsible for operating storm overflows.

These water company estimates are, in Link’s view, far too pessimistic about the costs of action. Projected costs for Sustainable Urban Drainage solutions (SuDS) provide an illustrative example of this flawed approach. SuDS offer nature-based solutions to storm overflows, using nature to store excess water, providing a more nature and climate friendly alternative to concrete based storm overflow systems. The experience of countries that have enthusiastically embraced SuDS also suggest that these greener alternatives are significantly cheaper when delivered at scale. Despite this, the Plan raises concerns about the costs of SuDS, based on snapshot data provided by water companies, based on the costs of SuDS projects they were pursuing at that time (2020/21). These tended to be small in scale and therefore expensive. SuDS delivered in the years to come will benefit from economies of scale, as other Government policies such as Biodiversity Net Gain schemes will mean many more SuDS will be delivered (regardless of what happens with storm overflows), leading to big contractors driving unit costs down. These highly relevant cost factors are ignored in the Plan.

This narrow focus on limited water company material, and the exclusion of wider evidence, can be seen throughout the Plan. As stated the Rivers Trust response, the Plan constitutes the ‘‘government deferring to the water companies’ figures on potential cost increases as a justification for weak action’’. The Rivers Trust has also raised serious concerns about shortfalls in engagement with nature organisations during the development of the Plan.

As result of these factors, the Storm Overflows Discharge Reduction Plan is a sadly stumbling start to efforts to reduce sewage pollution in our waterways. An over-reliance on the perspective of water companies has led to proposals that fall well short of what is required. An ambitious rewrite, informed by a more holistic appraisal of the benefits and reduced costs of SuDS, could provide an effective route map to reducing sewage spills to the earlier timescale nature needs.

Until such a rewrite is delivered, the Reduction Plan will remain a well-intentioned but fundamentally flawed document, which misses a key opportunity to address the growing freshwater ecological crisis. An uplift in storm overflows ambition needs to be matched by action on other significant key contributors to freshwater decline, including pollution from agricultural runoff and insufficient regulation of the chemicals that reach waterways. Measures to address the damaging harms from these three sources, combined with increased support for Catchment Plans and River Basin Management Plans to drive proactive action to recover river health, could benefit nature and people alike.

In the absence of such a programme, the reasonable demand from the public that our rivers and coasts be restored to health will go unmet.

Matt Browne, Head of Policy & Advocacy, Wildlife & Countryside Link

 Ellie Ward, Policy and Information Coordinator & Blueprint Lead, Wildlife & Countryside Link

The opinions expressed in this blog are the author's and not necessarily those of the wider Link membership.