WASP Letter to the CEO of the Environment Agency.
Following on from the BBC South Today item presented by Angie Walker, WASP had to challenge the dismissive and misleading comments made by the Environment Agency.
We asked them to come up with the evidence to support their claim that all is good, based mainly it seems from evidence obtained upstream of the start of the problem!
I have highlighted comments not highlighted in the original to help bring out the important points for you.
We appreciate this type of post is not for everyone but we like to be as open as we can and keep you in the loop.
If you like to watch a good story unfold, read on!
Windrush Against Sewage Pollution
Sir James Bevan
Dear Sir James
I am writing on behalf of the Windrush Against Sewage Pollution (WASP) campaign group to you, as head of your organisation, to raise some serious issues affecting public confidence in the Environment Agency (EA).
WASP recently participated in a BBC news story (https://www.youtube.com/watch?v=zyjorO_rdQk) about the River Windrush in Oxfordshire. The Environment Agency responded to the BBC with a statement which we found to be extraordinarily misleading and that is the reason for my letter.
We have been engaging constructively with the EA for about two years and we are one of a number of voices which have raised serious concerns about the River Windrush in Gloucestershire and Oxfordshire over many years. We have been challenging and critical friends to the local staff and have developed some good relationships with people who are battling against the odds to do a good job. The point being that the EA, at least up to Director level, has had plenty of time to understand the situation here, so could not have been caught off guard.
Over recent weeks, the turbidity of the river, which has been an issue for many years, has reached a very high level, is now quite shocking and is illustrated by billowing brown water flowing into a relatively clear Thames at Newbridge. This seems to be a downstream progression and there is no evidence of a single source. The BBC news story and photographs below demonstrate this quite vividly.
We contacted the local EA to alert them to this issue on 12 July and were told that EA staff had been out to investigate but have not yet been told what they found.
We then raised the turbidity issue with the BBC which ran the story on BBC South Today on 17th July.
The EA put up the following statement which was read out on the BBC news item:
The River Windrush appears cloudy at times, but this is probably because of prolonged dry weather and natural conditions… In the 12 months since we installed monitoring equipment… we’ve seen no evidence of pollution.
Let’s look at this in detail:
The EA has been promoting the idea of the ’natural colour of the Windrush’ since a turbidity study was completed in 1996 in response to concerns, even back then when the river around Witney and Newbridge ran quite clear. The situation has worsened dramatically since those days and is a constant feature rather than intermittent as I believe it was when that study was conducted.
At the West Oxfordshire District Council ‘Water Day’ in October 2018, after being challenged about the validity of the evidence from 1996, the EA decided to conduct another study into the cause of the current levels of Windrush Turbidity.
Thames Water and the EA joined together to establish terms for tenders to be submitted and after that failed to produce what they wanted they are making plans for the EA to do the work ‘in house’. However, it seems that according to the press statement, there is already evidence to render that study pointless as the Windrush has taken on this extreme turbidity ‘due to prolonged dry weather and natural conditions.’
May I request the evidence to back this up, please?
Turning to the second part of that statement; … In the 12 months since we installed monitoring equipment… we’ve seen no evidence of pollution.
It is my understanding that this refers to water monitoring equipment placed near Bourton on the Water to monitor an untreated sewage outfall which was revealed on BBC Countryfile in 2018. I believe that Thames Water was notified of the meters and there were no discharges during the monitoring period, possibly due to an absence of heavy rain events.
The main point here is that the EA is representing the state of the River Windrush based on evidence obtained from monitoring devices placed for 12 months upstream of all of the major sewage outfalls on the river and upstream of almost all of the evidence of deterioration and poor water quality. Please take a look at and the images below and the WASP Turbidity map which is enclosed.
This is the Windrush about 200m downstream of the lower monitoring site for the 12-month period but upstream of the confluence with the River Dikler:
This is the river on the Sherborne Estate in July 2019
Here is Standlake in July 2019
This is the River Windrush joining the Thames at Newbridge in July this year with a turbidity reading of about 31 NTU compared to 5 NTU in the Thames. The Windrush can be seen billowing clouds of turbid water into the Thames and in turn negatively affecting the main river. It has been like this for many weeks.
When considering evidence of pollution, the EA must be averting its eyes from the startlingly obvious point sources of pollution on this river: there are seven sewage treatment works, all contributing a variety of pollutants as a consequence of treating trade effluent, domestic cleaning products, biocides, surface run off contaminants as well as the inevitably excreted hormones, bugs and drugs from human sewage, now shown to contribute to anti-microbial resistance. These are in addition to the often highly polluting levels of phosphate in the permitted effluent and storm discharges of untreated sewage.
River ecology has no interest in whether the EA thinks pollution is legal or illegal, things just die.
Turbidity is only one of the factors indicating a serious decline in the ecology of this river but it is a very obvious visual one.
Windrush Against Sewage Pollution is conducting a serious campaign to address concerns about a river dear to many people’s hearts and central to many aspects of the local economy, and we believe that the population of this country deserves to be provided with accurate information by the EA, not to be carelessly and contemptuously misled.
Is this a matter of incompetence, wilful ignorance, or a deliberate attempt to deceive the public?
We remain committed to cooperating with the EA where we can but our confidence is waning, particularly as we still hear Thames Water staff telling us they cannot do any better because the EA will not ask them to.
We have evidence that the EA is routinely issuing permits to sewage works with illegal infrastructure and glossing over breaches of permits and unreported sewage spills. To say that the EA, as an organisation, has been complicit in building in routine and chronic pollution to our rivers would seem to me to be an easily justified statement. This has put some of your dedicated and caring staff in an unenviable position and must damage their morale terribly.
I invite you or a senior member of your team to join us in the Windrush Valley for an accurate presentation of our findings and to see the real evidence first hand.
If you accept our offer, you will meet a dedicated team of people, keen to talk constructively with you and willing to do all they can to help save our rivers, but totally unwilling to stand by and watch them being destroyed.
Windrush Against Sewage Pollution
Letter and response will be published on our website and social media.
cc. Rachel Fletcher, CEO Ofwat.
Robert Courts, MP for Witney.
Sir Geoffrey Clifton-Brown, MP.
Encl - Turbidity Map:
THE EA REPLY IS BELOW - We have noticed that the EA senior management have a habit of sending complaints like this straight back to the people directly involved and so their organisation never learns or moves forward.
We thought that with so much public interest, council support and media attention, this time might be
different - Wrong!
We have not altered this response or highlighted anything and you are seeing it first hand and can make up your own minds on the content. Feel free to challenge us. We always try to present the evidence clearly, not to distort it.
We will be addressing the obvious issues in this reponse and in the response to the recent Oxford Mail/Witney Gazette journalist James Roberts.
However, enough reading for one session! Here you go...
FROM THE ENVIRONMENT AGENCY AS IT CAME, VIA EMAIL.
Dear Mr Smith,
Thank you for your email of 23 July 2019 attaching a letter, to our Chief Executive, Sir James Bevan, regarding the River Windrush. James has read your email and letter and asked me to respond on his behalf. He will receive a copy of this response.
I am aware of numerous meetings and correspondence between your campaign group, Windrush Against Sewage Pollution (WASP) and our local officers about your ongoing concerns on the state of the River Windrush. I am also aware of the recent story on the BBC South today news bulletin. Our statements to the BBC were provided on the basis of the evidence we have to date and referred specifically to the monitoring at Bourton-on-the-Water. How the BBC choose to relay our statement is wholly within their remit.
As you know we have been asked to provide information about storm sewage discharges at Bourton-on-the-Water and separately about turbidity on the River Windrush more widely. It is important to recognise that these are very likely to be different issues.
I think it is very important not to conflate storm sewage discharges with the turbidity witnessed on parts of the River Windrush. Our position is that these are separate issues. We understand your concerns about turbidity and do not rule out the influence that treated effluent from the various wastewater treatment works or phosphate levels – which can come from sewage as well as other sources – can have on the River Windrush.
We recognise that the River Windrush has appeared turbid for longer periods of time in the last few years and understand your concerns about this. However, whilst the causes of this may not be fully established and there may or may not be a link with treated sewage discharges, we do not believe the turbidity is the direct result of storm sewage from the wastewater treatment works on the Windrush.
There have been many previous studies looking to understand the causes of turbidity in the River Windrush. Currently the evidence we have collated to date suggest that the turbidity was most likely to be inorganic calcite precipitate from the underlying geology and that flow conditions play a part in this. We are undertaking further investigations to help understand the situation in 2019. We retain an open mind about the causes of turbidity but evidence from these studies, the fact that we are in a period of prolonged dry weather and the absence of indicator pollutants of storm sewage (e.g. ammonia), lead us to believe that storm sewage discharges are not the cause.
We are an evidence based organisation and use the information and data available to us to inform our understanding of the situation. We cannot depart from what the evidence shows, but we will keep an open mind in terms of the many challenges and pressures the River Windrush, like all rivers in England, face. We also recognise that our evidence is subject to the limitations and extent of our monitoring network. At the same time as recognising that the evidence we have is limited to the geographical extent throughout the whole River Windrush catchment.
The evidence we have does not show the river to be seriously polluted with sewage, nor does it show it to be in state of rapid decline. Our evidence consists of the previous studies on turbidity of the River Windrush and extensive monitoring data we hold, alongside water quality readings taken in the field and laboratory analysed water samples. This information is publically available and officers have continued to reply to your enquiries and have, I understand, provided you with any information you have requested. If there are any enquiries you have made which you believe have not been answered, please let me know.
We have told you that our officers have recently carried out additional sampling on the River Windrush. We have already committed to share the results with you.
I can confirm that the results received to date have not identified anything that changes our understanding of the cause of the turbidity of the River Windrush. It has indicated generally good water quality along the length of the River Windrush for parameters that would normally be affected by sewage pollution. An increase in turbidity was detected in the lower reaches of the river but his was not accompanied by a change in other parameters associated with sewage. This means we can be confident there is no acute sewage pollution causing the discolouration of the River Windrush. The more recent water quality sampling has indicated potentially elevated iron levels which we are looking into further.
Through monitoring over the long-term we have identified various issues that do affect the River Windrush. This includes the presence of phosphate which modelling indicates is linked to point source discharges from the water industry as well as from other sources such as diffuse agricultural pollution. We are constantly driving for improvements to these known issues to try and prevent any deterioration of the River Windrush and to work towards delivering Water Framework Directive objectives.
We have always said we will keep an open mind on the cause(s) of the turbidity but this is subject to the evidence we have available. We will continue to share the results of future monitoring with you in the same way as we have provided all of our historic data. We would welcome and consider any evidence or information WASP, or any other party, provide in terms of any water quality issues in the River Windrush. We wish to work constructively together with WASP and others to protect this valuable watercourse.
I understand you discussed the results from the monitoring equipment we installed at Bourton-on-the-Water at the meeting of 2 August. This was installed following the BBC Country File programme in 2018, to monitor the impacts of the Combined Sewer Overflow, (CSO) primarily in response to concerns raised by WASP. We did inform Thames Water the monitoring was taking place. The monitors (Sondes) were placed on the River Windrush to measure upstream of the CSO outfall, as a control, as well as downstream. I understand the reasons for the locations were explained to WASP at a meeting in July 2018 and I understand a demonstration was given at this meeting. Since then members of WASP have been able to view the data live on a 24/7 basis. A third monitor was placed for a short period of time at the confluence of the River Dikler and the River Windrush to investigate any differences between the two rivers.
The water quality monitors were in place for around a 10 month period and there was no discernible difference between the water quality (for those parameters we have tested against relevant to indicators for sewage pollution) of the upstream monitoring point and the downstream monitoring or in the monitoring at the confluence of the River Dikler and the River Windrush.
Whilst there was no repeat of the sustained rainfall event and long lasting combined sewer overflow of April 2018, during the monitoring period, there were a number of significant rainfall events and operations of the CSO but no impact was detected. We did not see any evidence of discharges being made at times when there had not been heavy rain. We would ideally like to measure impact on water quality during a sustained event like that of April 2018 and subject to resources, we would be willing to deploy water quality monitoring equipment to better understand if larger more sustained discharges impact water quality in the River Windrush. In addition to not detecting an impact on water quality from the CSO the water quality monitoring has also shown very good background water quality in the River Windrush over the period of monitoring.
I understand your photographs and turbidity are consistent with the monitoring results and observations by my officers. We will continue to review our data and observations of the River Windrush. As you are aware, there are discharges of storm sewage and treated effluent from Water Company discharges alongside a range of other private discharges into the River Windrush. There are also many other discharges to the river as well as other factors that may have an impact such as diffuse agricultural and urban pollution. We do not have the evidence at this stage that the turbidity is caused by sewage or that the water quality of the river is deteriorating.
I am concerned you have said that we are routinely issuing permits to sewage works with illegal infrastructure. I would refute your statement but if you have evidence to support your allegations then I would be happy to receive the evidence. I have been made aware of a specific issue at Bourton-on-the-Water sewage works and our officers have required Thames Water to rectify it. We have taken a firm stance on what is a complex regulatory issue. Spills are currently being measured through event duration monitoring and we will continue to assess the risk presented which we currently believe to be low.
Please continue to report any pollution incidents to us on 0800-80-70-60. We assess all reports and respond on a risk based approach. If anyone causes a serious or significant pollution we will take action.
You will be aware of the recent prosecutions, the most recent of which was last month when Thames Water were ordered to pay fines and costs of £707,000 at Aylesbury Crown Court for a pollution of the Maidenhead Ditch which included an illegal storm discharge. The prosecutions we took against Thames Water in 2017 resulted in a record fine and costs in excess of £20 million. In 2018 we prosecuted for a discharge at Milton-under-Wychwood which resulted in £1.8 million fine and costs and a further £200,000 being voluntarily given by the Water Company to three environmental charities who work in the local area. As a direct result of the action we have taken in recent years Thames Water have made a number of improvements and we hope one effect of the prosecutions will be to push the environment higher up the Thames Water agenda reducing the risk of pollution in much of the Thames Area. My officers are taking strong and proportionate action where Thames Water have caused significant pollution events.
We will continue to take action in line with our Enforcement and Sanctions Policy. I understand you are aware of the report recently published:
In the accompanying press release we issued it said: “Environment Agency Chair Emma Howard Boyd, who has previously warned water companies they would face a tougher regulatory approach with increasing inspections, is pledging that the Environment Agency will continue to work with Ofwat to look at financial penalties to drive better environmental performance given fines are currently only a fraction of turnover. Writing in the report’s foreword she said:
“Companies should be reflecting on their environmental performance and long-term resilience, if this is poor they should be asking themselves whether dividends are justifiable.”
Lastly, we would like to reiterate our commitment to protecting the environment which is something we care passionately about. Please rest assured our local officers will continue to work tirelessly to protect and improve the River Windrush and more widely the watercourses in the Thames Area.
Acting Area Director
On behalf of Julia Simpson
Area Director – Thames