# Data Stream Oppor-tuna-ties to make your actions effective # Data and Facts - Wading Through Murk The deeper you go, the murkier the waters, the easier it is to lose your way. Information is your antidote and YOUR lighthouse in the dark. If your local group wants to dive deeper into local water issues but is drowning in overwhelm, grab the Dirty Water lifeboat to help you navigate the information dead zones and the high tide of bureaucratic BS. As we all know, the scale of water horror stories and data is massive. We cannot possibly cover everything, but this information will help launch your metaphorical Pink Boat to reach the Tell the Truth and Act Now island. For instance, Freedom of Information (FoI) requests are a useful tool to obtain information of any kind from those in power, be they regulatory authorities, government departments, local and unitary authorities, or private companies. However, these requests are not always effectively responded to, particularly if you miss any tricks on how to exercise your rights.
Our **Data and Fact - Gaps** **MAKES SURE NO TRICK GOES UNTICKED**. Share your links and suggestions with the Dirty Water crew and each other to inform your outreach and community assemblies. You can do this in two ways: - **Email dirtywatercampaign@proton.me** with any information you feel is useful and requests for support - Add your suggestions to this resource **DOES THIS NEED A LINK TO THE SPREADSHEET?** # Data and Facts - Gaps ### **Not Just Sewage Infrastructure Holes To Act On!** Knowing **what we don’t or cannot know** is just as important as the data that is available to us. There are limits to what government departments or private industry are willing to be transparent about. Knowing these limits means that anyone campaigning in these areas will be able to inform others of the limits of their ability to help **Tell the Truth**. Knowing what we need to know more about can provide opportunities to campaign to get the responsible bodies to do the right thing. We cannot **Act Now** on what we do not or cannot know. Understanding our limitations as active and concerned citizens is important because this can point the way to **building connections between those organisations that have pieces of the jigsaw**. Where there are data and knkowledge gaps, it is important for NGOs, reporters, legal professionals, whistleblowers, influencers and other conscientious protectors to collaborate to help us act on the environmental destruction happening. Surprise, surprise, there are **lots of gaps in data**; information can be inaccessible due to how laws protect the powerful, or finding information you need means wading through bureaucratic systems, or persisting against stonewalling, obfuscation and resource short-comings. Here's just a few of the darker sink holes and eddy pools to watch out for and begin to think about who else might help... Or skirt the dark pools for now and head straight for the Lighthouse section to plan your campaign route a little more clearly- show me the Lighthouse route. #### **All Hands on Deck** We would love for you to contact the Dirty Water crew on your local issue to **share knowledge and experience!** You can contact us via our Telegram or Mattermost channels or by email dirtywatercampaign@proton.me. # Data & Facts - Gaps: The Law, Makers & Breakers This is a start in terms of learning where the power lies and where laws are being broken by those who have power to help us improve a key element of our quality of life: healthy and safe places to thrive.

#### Water Framework Directive Regulations In England and Wales, the Water Framework Directive Regulations (WFD) form the overarching statutory framework for our water environment. Despite Brexit, this remains in place in terms of regulatory frameworks. Other regulatory frameworks, such as the Urban Waste Water Treatment Regulations 1994 and the Bathing Waters Regulations 2013, also impact environments. However, the WFD provides the overarching targets on conditions of our waters and the framework for achieving them. WFD Regulations oblige the creation of a River Basin Management Plan for each river basin catchment area. This covers environmental objectives, plus a summary of measures required to achieve those objectives. Current River Basin Management Plans were published in December 2022. The **WFD requires governments to ‘aim to achieve’ Good Ecological Status (GES) for all surface water bodies by 2027**. There are currently no published plans (as at April 2025) for these objectives beyond 2027. While the regulations implementing the WFD will still apply then, they do not provide scenarios beyond 2027. The UK and Welsh governments need to decide what, if anything, should follow this objective after 2027. The Directive has been described as a "demanding and timely ‘identification and rectification’... requirement" by the Windrush Against Sewage Pollution (**WASP**) campaign, "but has been inexplicably ignored". Instead, lobbying by the water industry has led to this being sidelined in favour of weaker implementation measures, such as the **Storm Overflow Assessment Framework** (SOAF). SOAF has been referred to at an OFWAT consultation meeting, as "the mechanism relied on as the means for the rectification of failing storm overflows", according to page 4 of a WASP report linked to elsewhere on this page. (Use: CTRL,F / COMMAND F to search on their name). More recently, The UK government and EU parliament, under **Directives 2005/29/EC** and **2011/83/EU**, have put forward plans to prevent greenwashing by the commercial sector. Let's watch that space and share updates on our Telegram chat. #### Water Industries Act 1991 - Citizens are not prevented by the Water Industries Act 1991 from bringing a claim for nuisance or trespass over pollution caused by sewage discharges, even if there has been no negligence or deliberate misconduct. More to follow here since a landmark case brought against a (sewerage element of) water bill boycotter in Spring 2025. We will also be updating our page on Boycott Dirty Water and ditching your Direct Debit. Check back at the end of April 2025. #### Environmental Protection Act (EPA) - The EPA obliges local authorities (LA's) to identify contaminated sites, but there is a fear of peering under rocks here by LA's, because of potential costs of remediation and public outcry of health implications for communities, to say nothing of identifying responsible bodies involved, when sites are legacy landfills, for instance. This legislation also points to methodologies for dealing with contamination. In terms of short-comings, the Chester case study is useful for anyone concerned about sites near their communities flagged for development. - **Environmental Protection Act Part II** is almost unenforceable and **unfit for conservation and restoration purposes**; this explains some of the campaigns now happening to strengthen regulatory powers against the polluters. - For instance, the **Environment Agency** (England) can **downgrade pollution events** from Category 2 or 3 to Cat. 4’s, which involve no enforcement actions. Minimising the significance of a pollution incident is a disturbingly commonplace practice and often happens without the public understanding how the benchmarking process works (or, more accurately, doesn't). - Land classified as **contaminated land** legally triggers some level of remediation by a local authority, so do not take a 'nothing to see here' at face value if your local authority claims that land you suspect has been contaminated is not within the parameters. There are experts around who can navigate you through digging deeper to see if there is potential negligence. Whilst tricky, freedom of information (foI) requests can be a good lever here (see FoI section below). - **Industrial legacy**. Furthermore, don't be deceived if at the site of a previous gasworks, paint factory, or other toxic manufacturing industry, **legacy topsoil pollution** under investigation is superficially investigated and subsequent recommended remediations are inadequate as a result. Some communities, living in 'new-build' properties in particular, have been advised not to grow food in their gardens due to deeper levels of contamination, which can be drawn up through plant tissue; such notified risks are purely because of what that land was used for before redevelopment. - Some residents have had to find out the hard way, where public information on **previous land use** has been scant, due to **commercial** or **national security** sensitivities. - Even where industrial history is well-known, local knowledge of risk may still be minimal. Southall gasworks is a case in point. - Similarly, residents around Porton Down are advised not to eat any fruit or food they grow. In the 1950's the War office (now Dept. of Defence) agreed to the spraying of toxic chemical agents from airplanes flying over the area to observe impacts on human health. What legacy has this left on the land and the health of those subjected to this horror show? This story only recently came to light in recent years after the expiry of a **'D' Notice**, preventing the public from finding some information out. (These are now called 'Defence Advisory Notices') - If the local authority have informed housing developers that the topsoil isn’t 'clean' or safe and recommended its removal, and a building contractor then just spreads e.g. 60cm of clean soil onto that site for topsoil, what happens when a keen gardener grows fruit trees, which root deeper and unwittingly start drawing up contaminants through their vascular systems into their fruit? - What do you know about the **history** and **natural landscape** of where you live? - Local **geology** can also be significant. Contamination can remain either within soils, or aquifers. Some foundation rock types will pose greater risks than others. For example, porosity / permeability of Triassic sandstone may mean that site investigations miss key chemical contaminants from former process residues. Compare this with eg granite, where permeability is less of a risk. - Which of these scenarios is then considered as a pathway for e.g. **EPA Part 2A purposes**? It's important to know which sections of the EPA trigger obligatory remedial action; Part 2A obliges remedial action on the part of a local authority. - Then, assuming you have achieved recognition of land being contaminated, where are the nearby watercourses potentially at risk of leachate? Are there any local geology maps of acquifers? If your local authority is obliged to undertake works, be ready for deliberate obfuscation, given their increasingly constrained finances. Your group may need to really be persistent to bridge any gaps of officer expertise lost over time. It has been estimated that on average a UK citizen lives no further than 2km from a landfill. It has also been shown that increasing precipitation with our climate crisis will exacerbate problems. These are the complex dilemmas communities now face in protecting their family and neighbourhood well-being. - Digging deeper into detail can get complicated in terms of local history, chemistry, biology and engineering. We recommend you come together as a community and build allies where you can, wherever you can. Make connections with relevant academics, scientists, technicians, especially those who are retired, having no remaining constraints on their expert openness!

#### Water Resources Act - **The Water Resources Act**, 1991 may mean that your local river has been designated as a **Water Protection Zone**. It is worth checking this out with your local authority, because this legislation obliges companies in the locality to apply for consent where certain substances are used or stored at specific sites anywhere within the designated area, such as local industrial estates. Water regulators will also have responsibilities here. However, sadly, such protective designations do not guarantee business best practices in pollution prevention. It is down to the public knowing these protections exist, being the eyes and nose on the ground and knowing where to take their concerns. - Is it enough for people to have to go online when they witness potentially serious pollution incidents, or to form **river watch groups**? Do you have any idea about any legal protections for your local watercourses? Chances are that you don't, because the regulators do not see it as their role to pro-actively engage the very people who are likely to blow the whistle when businesses systems fail, resulting in catastrophes. In the words of one regulatory officer, Elizabeth Felton, NRW Environment Team Leader for Wrexham: “Pollution incidents from industrial estates can happen every day because of spills, accidents, negligence, or vandalism....Such incidents can then put human health at risk and devastate wildlife habitats on rivers..."

#### Freedom of Information Act (FoI) - In terms of the **Freedom of Information Act**, letters from the public, seeking information from **local authorities responsible for remediation of pollution sources** can result in only partial information sharing, buck passing, legal loopholes or downright misrepresentation. Being aware of what the organisational pitfalls you might face can all feel demotivating, but it's helpful to know what holes in the system you are navigating to keep records for any subsequent legal proceedings your campaign group might take up. Forewarned is forearmed. - Here are some of the common FoI pitfalls: - Lack of funding for thorough investigation by NGOs, local authorities or regulators. - Deprioritisation of environmental obligations. - Limits to Environmental Information Regulations 2004 (EIR - see below). - Poor oversight of engineering contractors. - Lack of adequate staff training and incompetence. - Scientific illiteracy. - Lost records. - Historical memory loss as staff retire and leave. - Deliberate obfuscation due to fear of repercussions and fall out of disclosure (also: more than my jobsworth / arse covering). - Misuse of **Re-Use of Public Sector Information Regulations** (see section below). - Appealing to the **Information Commissioner's Office** by campaign groups to obtain information from institutions may or may not bear fruit. See the **Windrush Against Sewage Pollution** campaign's downloadable report. For a great example of how to avoid obfuscation and avoidance by the recipient of an FoI request, take a look here. If this intrigues you, whet's your appetite, do check out more of the Reverend's FoI requests, by searching his name on this website. Chances are he will have tested water somewhere not too far from where you are.

#### Environmental Information Regulations (EIR) - Water companies are subject to legislation requiring them to disclose pollution data, one key example being the Environmental Information Regulations 2004 (“EIR”). However, water companies frequently seek to avoid their legal obligations. A case in point is United Utilities, which was issued with a practice recommendation by the Information Commissioner’s Office (“ICO”). The ICO found that the company had repeatedly **failed to categorise information as “environmental” in order to avoid disclosing it under the EIR**; the ICO suggested that the company leadership needed to “review its culture around proactive disclosure”. United Utilities is not the only company using such underhand and corrupt practices, so is worth looking into where you are and checking **Regulation 16**. - **Environmental Information Regulations 2004 (EIR)** contain **exemptions** to the public's rights to access information held by some public bodies, including local authorities. For example: **[1]Exception 12(5)(d)** states: “Confidentiality of proceedings where confidentiality is provided by law”. One particular FoI rejection case involving Spelthorne Council to be aware of is as follows: **12(5)(d)** states: "**(5) a public authority may refuse to disclose information** to the extent that its disclosure would adversely affect – (d) "the confidentiality of the proceedings of that or any other public authority where such confidentiality is provided by law;" This legalese was deployed by Spelthorne Council in response to a 2024 FoI request. Here, the confidentiality obligation cited refers to outcomes of a **Coroner's Court**, which by law can impose confidentiality instructions on a local authority impacted by their proceedings.

Thus we are in a situation where Environmental Information Request responses by water companies **border on the criminal**. "Academics and campaign groups wanting to understand the frequency, severity and risks posed by sewage discharges in England have routinely had environmental information requests (EIRs) denied or incomplete datasets provided after prolonged delay." Deflect, Distract, Delay, Deny tactics are commonplace, according to this 'Nature' Journal article. #### Re-Use of Public Sector Information Regulations - A further constraint imposed by local authorities on sharing information with the public comes under **Re-Use of Public Sector Information Regulations**. Shocking as it may seem, a local authority may say that information shared with you under your FoI request is solely **"for your personal use"**. It is important, therefore when asking for information from a local authority that you also **seek permission to share with interested parties**; name them if you can. Alternately, use the WhatDoTheyKnow.com website for FoI requests; this limits institutional divide and rule tactics. - The following response has been made to someone making a FoI request: "Any re-use of this information will be subject to the **Re-Use of Public Sector Information Regulations (2015) and authorisation from the Council** will be required. In the event of any re-use, the information must be reproduced accurately and not used in a misleading manner." This is a difficult pill to swallow if someone becomes seriously ill or dies through water contamination. If anyone can share effective rebuttals the Dirty Water team would love to hear from you.

#### Bathing Water Regulations 2013 - **Defra's designated 'bathing water' status** is an opaque application process. While the designation does require closer monitoring by the authorities when achieved, the idea is deeply flawed. See: - 'The Great Washout: The Futility of Bathing Water Status' - Public applications generally result in a rejection. - You cannot trust a Blue Flag bathing beach safety categorisation, even those beaches with apparent 'excellent' rating. Raw sewage contamination is still a risk, especially after heavy rain. - The government refused to provide the Guardian newspaper with a list of the rivers and coastal areas **where bathing water status had been turned down since January 2022**. Campaigners have attacked the lack of transparency around this process. **Freedom of Information requests** to find out why an application for a local river has been turned down have been refused by DEFRA. - The bathing water application process also minimises the number of local people who may use local waters, because the application asks for number of bathers using the water, but does not include boaters such as paddleboarders & kayakers, let alone dog walkers and paddlers. - Signs on-site, warning bathers of hazards can be risible at best, and virtually invisible at worst! Be sure to share the worst 'box-ticking' examples on our Dirty Water Live Content Telegram chat.

#### The Stockholm Convention on Persistent Organic Pollutants (POPS) This convention is one of a number of international regulatory tools. The Stockholm Convention is a global treaty to protect human health and the environment from chemicals that remain intact in the environment for long periods, become widely distributed geographically, accumulate in the fatty tissue of humans and wildlife, and have harmful impacts on human health or on the environment. You will find other international conventions on the above website. #### Industrial Emissions Directive (IED) - Best Available Techniques (BAT) Note- this is copied verbatim from the government web page: The EU’s Industrial Emissions Directive (IED) takes an integrated approach to controlling pollution to air, water and land, and sets challenging industry standards for the most polluting industries. The IED aims to prevent and reduce harmful industrial emissions, while promoting the use of techniques that reduce pollutant emissions and that are energy and resource efficient. Larger industrial facilities undertaking specific types of activity are required to use BAT to reduce emissions to air, water and land. BAT means the available techniques which are the best for preventing or minimising emissions and impacts on the environment. ‘Techniques’ include both the technology used and the way the installation is designed, built, maintained, operated and decommissioned. BAT reference documents (BREFs) include BAT Conclusions that contain emission limits associated with BAT, which must not be exceeded unless agreed by the relevant competent authority. #### 2024 Water (Special Measures) Bill Government web page on new bill "To clean up the Water Sector" This Bill has attracted critics, who maintain it contains loopholes. One firm of environmental solicitors provide a good analysis of the current overall situation in relation to this, the wider legal landscape and other litigation actions. (XR do not endorse the company posting this article, but welcome the discussion): Strategic Litigation and the Water Crisis Steve Reed, MP's Water (Special Measures) Bill is, according to commentators inadequate, focusing pretty much entirely on sewage, while saying nothing on landfill/chemicals and leachate. There will be amendments brought forward to try to improve its environmental aspects (e.g. addressing issues such as the River Wye, where 70% of pollution is from farms). There is also the question of whether fines imposed on companies will merely be viewed as a cost of doing business and ultimately be passed onto customers. Dirty Water and other groups claim the Bill needs to promote the cessation of water pollution, but not stop there; we need a Citizens' Assembly on Water, given the widespread concerns of the public and failures of existing business models. #### Lack of Regulatory Powers - **Regulatory bodies** can be toothless. For example, data suggests the **Environment Agency** is failing to monitor water firms in England. Similar criticisms are made of **Natural Resources Wales** and other regulatory bodies and departments of government. - Scotland's water is **not privatised**, but pollution management, accountability and transparency still persist. Find out more at Scotland Sewage Dumps 2023.

The point here is that power to withhold information or limit its uses means that pollution of our waterways continues. Fragmentation of responsibilities between faceless bureaucrats and boardroom members make our push for clear waters an upstream struggle... Those very agencies we rely on or water companies we pay to endanger our lives seem to be getting away with ... well... even murder... If you don't know how bad abuse of the law by those who hold it can get, just read Zane Gbangbola's story.

#### Citizens Turning the Legal Tide The tide of abuse of power may be turning. More communities are tackling our current corrupt systems of water management. Dirty Water Campaign will be steadily adding important cases that empower communities to fight back here as time goes on. Please share any you become aware of with us on our Telegram Chat. - The **Gbangbola family's fight for justice** for a public enquiry regarding the **preventable death of their little boy** - the UK's first climate crisis victim. Numerous councils have now passed a motion to back the proposed 'Zane's Law'; more are coming onboard as the months pass, through dedicated campaigning of the family and their supporters. - Leigh Day **class action in Wales** against agricultural and water industries due to pollution of the iconic AONB, the River Wye catchment area. The Wye crosses the English Welsh border and flows to the Severn. Companies include Cargill PLC, Avara Foods Limited (often referred to as 'Avara Cargill', to recognise the interconnected parent and UK brand links) and Freemans of Newent. - More here about **the River Wye** catchment class action. - Read about the Supreme Court decision that **private citizens have the right to sue for nuisance or trespass** caused by sewage pollution. This is not precluded by the Water Industries Act of 1991. This legal recourse has been strengthened by the **Manchester Ship Canal Company Ltd v United Utilities Water Ltd** (No 2) case. - **River Action** took government departments on with the support of The Good Law Project. - 2025's **Legal and Statutory Outlook** The **Pickering Fishery Association** have won a Appeal Court judgement against the Government. The group of Anglers said Government river clean up plans were too weak to be workable. Despite the Government appealing against their case, this is another victory for people and planet at the **Upper Costa Beck, N. Yorkshire**. This strengthens citizens wanting to use the EU Water Framework Directive to reverse pollution of local rivers, lakes, coastal waters and streams. Is it time to resurrect the Public Trust Doctrine, which could be used to underpin the right of protection of commons? There are records of it being invoked in the thirteenth centruy and has been lost, but never negated fully, in the mists of time. - **Julianna the Washerwoman versus the Mayor of Winchester could bring us back to basics** post Brexit.
#### Ongoing investigations into the water industry and regulators - The environmental regulator, the Environment Agency (for England), and the UK water industry regulator, Ofwat, are investigating the Water and Sewerage Companies in relation to pricing. - The UK **House of Lords** has also been investigating Ofwat via the **Industry and Regulators Committee** inquiry into the work of the Water Services Regulation Authority. The Committee will consider Ofwat’s performance against its statutory objectives and whether it has the powers and resources needed to meet those objectives. The Committee will also consider the regulator’s relationship with the Government and other regulators. - House of Lords precis **2023 report on the Water Industry** - The **Office for Environmental Protection (OEP)**, (formed only in 2021), is investigating the performance of the EA, Ofwat and DEFRA. # Data & Facts - Gaps: Corporate Scum #### **Corporate Scum** - **Water companies** currently have too much power, and are unwilling to act responsibly. One example of this is **selective water testing** by water companies, local and national authorities, which means water samples are only taken from mid-depth of rivers, excluding **silt deposits**, where most toxic industrial legacy cocktails lie.

- Water companies can selectively **dispense with water testing results**, which can suit their purposes. In sewage overflow incidents, they may fail to provide representative data to regulators on licence breaches. More recently, most water companies now have monitoring devices at combined sewage overflow outlets, but the efficacy of the technology and the interpretation of the data flowing from these needs scrutiny.

- Water companies can also **stop sewage outflow** at treatment plants to avoid Environment Agency monitoring effectively during site checks. Having advance notice of checks, rather than spot checks allows this. You may want to ask your water company if this is a practice they use.

- **Water company improvement plans** may be completely unfit for purpose and lack public input. Inviting water companies to a Water Assembly, a water-management themed community assembly to increase accountability and transparency can be a useful way for your local community to ensure they stay on track. - A recent **community assembly** in Wrexham was hailed by local rebels as really useful and the beginning of good connections made with the local water company and the regulatory body. Keep an eye on this section of Community Assemblies case studies for examples of local groups addressing water issues!

- **Sewage overflow incident data** from water companies may not be **real-time**. For instance, water companies share information with the Rivers Trust, who produce a sewage map of overflow event numbers and volume. Valuable as that resource is, it isn't yet ideal until real-time monitoring data is available there.

- One option is writing a **Freedom of Information (FoI)** request to water companies to get exact data. Wording needs to be well-crafted, to prevent your responder from side-stepping a question. See Lighthouse (What can we actually do?) for FoI letter template help,

- The above are only a few of the more well-known issues, but if you really want to get to get to work with your water industry microscope, or to come up with some stinking questions to rattle the PR person at your local water company, here are a couple of good analyses of the issues: - **Windrush Against Sewage Pollution** response to a government consultation (Scroll to download link) - Written evidence submission to a Government commission by **Professor Peter Hammond BA MSc PhD MSc**

- Let's just be clear, though, it isn't just sewage we need to be mindful of, there is also **licensed industrial effluent**. For local information on incidents in England, email **pollution.inventory@environment-agency.gov.uk** . This automated reporting inventory (pollution inventory electronic data capture / PIEDC) "provides information about releases and transfers of substances from regulated industrial activities." Cautionary note: read with a sceptical frame of mind; there may be gaps and ommissions. (HINT: Keeping up with Dirty Water campaign chat will help you fill in the gaps!) - For Scotland, Ireland and Wales, you will need to check with your regulatory authority. **(More info coming)**

- The questions your community or local group might want to ask include many of the issues covered in the two submissions to government above, but here are some starter questions: - What are the thresholds that trigger reporting? - Reporting obligations for which chemicals? - How do those thresholds compare with permitted levels in other parts of the world? - Are the licensing laws adequate, or do they need updating? - Are safety assessments purely about human health, for which an adult male is the standard and which downplays impacts on children, pregnant women and unborn foetuses? - What are the ecological implications of licensing where you are? - Are water extraction licenses adequate to reflect changing weather and ecology patterns? - Can we trust profiteers or the Environment Agency and other authorities to tell the whole truth, or is it another case of lies, damn lies and statistics?

#### The Public is overwhelmingly behind us - A YouGov survey conducted in 2023 found that 69% of the 5,930 adults surveyed want water companies to be nationalised.

YouGov Survey

- This support for nationalisation is ubiquitous across age, gender, political leaning and social grade. #### The Corporate's Playbook - Research into **disinformation tactics of English Water and Sewerage Companies (WaSCs)** # Data & Facts - Gaps: War on Water #### **The War on Water** Where there is contaminated land, there are unmapped aquifers and vectors for pollution transmission through soils, ineffective landfill solutions, wildlife and wind. Given the long legacy of military usage of toxins for a variety of purposes, there is evidence to suggest that as with other branches of government, human failure, legislative shortcomings and mistakes will also be endemic to military practice. When it comes to land owned or previously owned by the Ministry of Defence (MoD), bear in mind that these are areas where technical and chemical 'innovations' will be initially tested. To be clear, it is the MoD that will tend to be on the 'cutting edge', trying out new tools and toxic chemical compounds to undermine the 'enemy'. The public are not permitted to enter MoD designated zones, so external oversight of practices is minimal. Only if concerns reach a government committee, whose discussions are behind closed doors, might there be any accountability for mistakes made. Given the lack of technical and scientific expertise among ministers scrutinising this government department, achieving any level of balance in 'public interest' versus 'strategic imperative' seems unlikely. Do we trust our leaders to always act in the best interests of people and planet, despite whatever best efforts? What little evidence we share here is no doubt the tip of the iceberg. Look at the track record (That is on those pages that did not get deleted off the internet during the production of this page..!) - **Ministry of Defence** sites formerly used for **weapons testing** are subject to secrecy laws and confidentiality practices (e.g. 'D Notices', which forbid public access on the basis of ‘national security’). Find out more about the legacy of our military on our environment here: - Radioactivity - Site History - MoD Land Contamination History Stalls Forthside Land Transfer - WWII MoD Legacy - Note that limits to the Freedom of Information legislation apply when asking about toxic pollution on ex military sites, specifically: Sections 24 and 26 are exemptions in the FoI process; the Ministry of Defence may argue that the Public Interest Case is not met weighed against national security and the safeguarding of defence capabilities. - There is an interesting '**Declassified**' report that offers some insight into the scale of **military pollution** in the UK. While the Scientists for Global Responsibility (SGR) and Declassified UK (DUK) have mostly reported on Greenhouse Gas Emissions being hugely underreported, they do raise concerns also the MoD's performance on environmental damage from pollution, particularly radioactive waste management. They also say the following: "The MOD also seems to ignore the latest scientific research showing the catastrophic global environmental impacts which would result if it launched its nuclear weapons."

# Data & Facts - Gaps: Our Anthropocene #### **Our Anthropocene** - **Plastic pollution** is one of the reasons that archeologists now argue that we are no longer in the Holocene, as our plastic footprint means that our earth's surface is now littered with long term plastic pollution (together with human created climate change escalation). Now we need to call our current phase of history the 'Anthropocene'.

- So much to say and so many organisations are already operating in the plastic pollution space, for now, check out our [sources of pollution page](https://rebeltoolkit.extinctionrebellion.uk/books/dirty-water/page/sources-of-water-pollution) for links.

- If you are looking to build plastic pollution campaigns at the local level and feel bewildered at the amount of possible allies, Dirty Water crew are currently creating digital armbands to keep you afloat. An interactive spreadsheet of contacts is on our list of resources!

- Meantime, if the **circular economy** and **reduced consumption rather than recycling** is your swim style, the **Ellen McArthur Foundation** is a good start.

# Data & Facts - Gaps: Seeking Nature Based Solutions? - Across the UK local planning regimes still leave much to be desired. For instance: - Does your local authority have a **flood risk mitigation strategy**? If so, does it include recommendations for tree planting? If your local authority has that documented, are financial constraints hindering implementing and meeting targets? Is this a potential [community assembly](https://rebeltoolkit.extinctionrebellion.uk/link/1494#bkmrk-page-title) in the making to bring local people together behind such projects?

- What provision is made for: - **Rewilding** areas including grouse moors, common land, or parkland. Water catchment areas are key habitats, not only in terms of the wildlife populations they sustain, but also in terms of downriver impacts during heavy rainfall. Upstream land works to let straightened river stretches go back to historic natural paths - otherwise known as **'re-wiggling'** - using landscape engineering species, such as beavers can enhance water filtration systems, mitigating pollution impacts. They can also alleviate flooding and attract biodiverse species. - Is there scope for beaver population releases to achieve natural landscape engineering affordably and at scale? - Does your **local nature partnership (LNP)**, or other national network which involves local communities and lay experts recommend other habitat management plans to mitigate impacts? You may already have connections with local NGO's, but also check out: - **England** LNPs - **Wales** LNPs - **Scotland** Local Biodiversity Partnerships - **Northern Ireland** Nature Recovery Networks - **Republic of Ireland** Rights of Nature Public Participation Network
- You have a chance to make waves if your local authority has **declared** a **Climate Emergency**. - If they have, wherever local **landfill sites** have a toxic legacy, you can reasonably ask what remediation and mitigation provision is made for **leachate risks** following heavy rainfall. Is that part of that climate emergency planning process? For example, are there buffer mechanisms between buried toxic waste and water courses? Some plants reabsorb toxic elements in soils. Are these possible options for your local community to request? Worms have been found to offer some natural remediation in areas of contamination; has your local authority looked at such nature solutions?

- So many questions still arise around natural solutions for**toxic landfill**. It may be that some issues will never be resolved, but being able to make choices to keep you and yours safe from local risks is essential. Be sure to check out our Dirty Water **Social Justice** page if you have concerns about legacy landfill sites and local watercourse pollution. Follow in the footsteps of other campaigners referred to around Dirty Water resource pages. - Be sure to contact the Dirty Water team to share information on those you are already aware of too... **Dirty Water Chat and Live Content**

### Water Restoration Projects - Nature Based - **Sussex Sea Kelp Restoration** - **Swansea Seagrass Restoration** - **Sealife Research** # Data & Facts: Where's The Nearest Lighthouse (What Can We Do?) Given a general lack of transparency and availability of information from authorities and companies, one lever for your group to find information you need is to submit a **Freedom of Information** (FoI) request. FoI requests are a useful tool to obtain information of any kind from those in power, be they regulatory authorities, government departments, local and unitary authorities, or private companies. That said, FoI requests are not always effectively responded to, particularly if you miss any tricks on how to exercise your rights. FoI requests are a skill worth developing as a group.

- Fortunately, **What Do They Know** helps you avoid wipeout, offering existing case studies and template letters. Surf the constant tide of **previous cases** similar to your local situation. Find your clear horizon via their website, then share your information with others entering those waters after you via [Dirty Water's Live Content channel]((https://t.me/+qNs5LCA8pu1lYWJk).) on Telegram. - A case study on their website, for instance, refers to a resident who has put in a Freedom of Information request to the national regulatory body, Natural Resources Wales. Now, anyone searching the site for "leachate" will bring this request and similar example cases up. This invaluable resource means your local group will not have to be put off by having to reinvent the wheel and can avoid missing essential questions and exactly **how to ask** them in your **Freedom of Information request**.

- If your FoI request leaves you dissatisfied, you do have the right to take up your dispute with the **Information Commissioner**.

- Commissioning **independent scientific analysis or reports** from consultants becomes inevitable if you **seek redress** where the pollution issues your community faces are complex and require specialist expertise, e.g.: biology, chemistry, engineering, or any such combination. In order to hold local authorities, water companies or regulators accountable, your information needs to be credible and as accurate as possible; independent reports provide the weight you need. - This research and reporting work may either be a discreet project or potentially longer term systematised testing and analysis. - As such, it's helpful to know how feasible an option this is in terms of analysis and reporting costs. Some NGO and university laboratories will provide free services. (See the contacts spreadsheet, where we will build that list of experts). - Then potentially if there are legal implications, whether your group want to seek **legal counsel** is a further consideration and whether pro bono services are on offer, or whether a 'class action' is needed. - Diving into these currents means knowing **what questions to ask** your potential contractor. Most importantly, you need to avoid their **conflicts of interest** such as previous or on-going contract works provided for local authorities or water companies, for instance. Check if they have existing contracts, or have had in the past; this could mean that if you hire them, your data could be compromised by **pre-existing confidentiality and non-disclosure agreements**, limiting your available data and limiting the credibility of any subsequent reports. That risks your group not getting the information you need to hold bodies to account. - It is helpful if an independent contractor is to be commissioned to provide your local group with any scientific or engineering report, that you ask them in advance if they obtain any **more than 10% of their work from authorities or companies you seek to challenge**. If they do significant amounts of work for e.g. a water company, a local council, or a water regulator, that could mean they will have a conflict of interest. If they are legally constrained in working for your group because of pre-conditions of contracts previously held with those bodies you want to hold to account, then go elsewhere! **Greenpeace** labs and some **university engineering and chemistry departments** have been known to support local groups in their research. We'd love to hear of your experiences here.

- **Allies Ahoy!** Do you trust the information being provided by your identified engineer, environmental auditor, or other contractor? If not, talk to independent allies such as **Friends of the Earth**, who may have **historic documentation or community connections** to bring more information to light. If there is a local environmental umbrella group, this is also a good place to start to find any pre-existing, relevant information available. - More power to your paddleboarding elbow from Surfers Against Sewage here: **Surfers Against Sewage** 2022-23 **Water Quality Report**
- SAS webpage about **Water Quality Testing**

- **Fundraising?** You will want to check any cost implications out before you fundraise for such an important fact-finding project. Let's not burn out on such an involved deep dive. If you haven't got the funds to source an independent report: - Might a crowd-funder help? - Get in touch with our **Fundraising Team**. # Information Resources | Reports, Maps, Data & More #### Maps Please be aware that data catchment and sharing is still evolving. We have been made aware of specific sites, including some which have resulted in death, from contaminated flood water. If you are aware of sites which are missing from this data, please get in touch with us, so we can pass your story onto whomever is working on that issue. - Interactive Pollution Map (England) | Watershed Investigations - Evolving PFAS (Forever Chemicals) Pollution Map of Europe | Forever Pollution Project - Safer Rivers and Seas Map | Surfers Against Sewage - 2024 Report on the State of UK Rivers | The Rivers Trust - Live sewage pollution data | Surfers Against Sewage (SAS) - Surfers Against Sewage 2023 Water Quality Reports SAS natoin-based reports; check drop down menu for yours. - Raw Sewage in Our Rivers. Monitor sewage in your local area | The Rivers Trust - Real time Event Duration Monitoring (EDM) Map for English Companies. - Same info, National Storm Overflow in England map | Water UK - Developments of National Significance in Wales | Council for the Protection of Rural Wales (CPRW) - Flood Risks in Wales | Natural Resources Wales (NRW) - Map of Historic Landfills in England | Dr. James H. Brand - Historic Mining Risk Sites, Wales | Coal Authority - Hereford,Shropshire & Powys Intensive Poultry units | Council for the Protection of Rural Wales (CPRW) - Top of the Poops Easy to view sewage information; impactful imaging - Most sewage polluted rivers in England 2023. Local river info | The Guardian - The Forever Pollution Project | Journalists tracking PFAS across Europe - Sewage Pollution Map of England - Real Time- Dr Lipp, University College London
--- #### Generic Resources Background Sources of Information for Outreach, Community Assemblies, Campaigns: - Water Basin Catchment Areas | Environment Agency - XR's Position on Extreme flooding 2024 January 2024 blog helping rebels Tell the Truth. Further resource links below the article - Support Pollution Watch campaign to register leachate into watercourses - 'Dead shellfish littering our beaches tell you a lot about safety and secrecy in Britain’ George Monbiot article in the Guardian - See how water company leakages are only slowly fixed An “urgent and significant reduction of the amount of drinking water wasted every day” - Brown Flag Awards - Guardian article on eradicating forever chemicals in the home --- #### Videos - What Makes Up Flood Water? (Youtube 12 mins) - Rivercide (Youtube 56 mins)
- Rivers Trust State of our Rivers (Youtube 2 mins)
There is a link below the video to download for the written report. - Joe Lycett vs Sewage Dark humour, but factsy video (Youtube 50 mins) - Where Does Our Rubbish Go (Youtube 30 mins) - Stop The Stink: Walleys Quarry, Newcastle Under Lyne (Youtube 30 mins)
--- #### Podcasts - Impact of Pollution includes impacts on the body 2 part BBC podcast series - Inside Science: Forever Chemicals 30 minute BBC podcast - Buried 10 part podcast on the case of illegal toxic landfill in Ireland
--- #### Government Reports and Information - House of Commons Environmental Audit Committee heard evidence on the Water Quality in Rivers - House of Commons Environmental Audit Committee Report on Environmental Sustainability of the Ministry of Defence - Government Report on sewage in water: Prof. Chris Whitty, Chief Medical Officer for England, Jonson Cox, Ofwat Chair and Emma Howard Boyd, Environment Agency chair. (Published 27 June 2022) - DEFRA 25 Year Plan on Water Use - DEFRA 25 Year Environment Plan. Annual Progress Report 2023 - Government Implementation Plan for the Chalkstream Strategy 25/11/22 - DEFRA statement Response to Paul Whitehouse's 'Our Troubled Waters' aired on BBC2, 5/3/23 - UN Water Conference 2023 | Department of Economic and Social Affairs - Flooding and Health: an overview, UK Health Security Agency - Hansard: ‘Orphan Sites’ Hazardous waste sites - Hansard: Waste Industry - Criminality & Regulation - The National Archives Official historic records not subject to secrecy ‘D’ Notices - House of Lords Library. Sewage Pollution in England's Waters - Remember too that sewage is only one among other contaminants that pose a risk to your family's health. Check this government guidance on swimming outdoors. Beware, however, this says nothing of **chemical pollution**, which could be particularly risky if a beach borders a historic landfill or industrial sites. - Exposure and Adverse Effects of Chemicals on Wildlife in the Environment
--- #### Organisations and Allies We will be making a spreadsheet of possible contacts available to view, make a copy of and add your local contacts to, so they can be shared with rebels coming on board and stepping into Dirty Water actions, e.g. outreach events, ceremonies, or assembly organisation. More about this in time, but meantime, here's the current state of play with our Restore Nature Now supporters. Aside from the Restore Nature Now supporting organisations, you will have your own local links, be they allies, or connections with regulatory bodies and their officers, water company employees and board members and more. We want you to bring us your contacts, to help the movement grow our campaigning power for the future. Check in with the Dirty Water Campaign to find out more about building XR's connections with influencers from the grassroots to suited power brokers and corporate players.
--- #### Celebrity Connections. Who Are You Following and Engaging With? - Feargal Sharkey on Twitter: For all the latest information about what the water companies and the UK government are doing about our waterways and seas. - Chris Packham on Twitter or [Bluesky](https://bsky.app/profile/chrisgpackham.bsky.social) - Michael Sheen on Twitter - Iolo Williams on Twitter For news and useful information around Cymru Wales from the nation's wildlife and conservation hero
--- #### Want to Organise Locally? - Find Out Who Owns Your Water Supply - Deep Water: Water and Sewage companies and Telegram links