Data and Facts - Gaps

It isn’t just holes in sewage infrastructure!

Knowing what we don’t know, (i.e. gaps in data, or legally inaccessible data) is as important as the data that is available to us.

• Defra's designated 'bathing water' status is an opaque application process. While it does require closer monitoring by the authorities when achieved, the idea is deeply flawed. See: The Great Washout: The Futility of Bathing Water Status - and public applications generally result in a rejection.
  
  
• Environmental Protection Act Part II is almost unenforceable. The Environment Agency (England) can downgrade pollution events from Category 2 or 3 to Cat. 4’s, which involve no enforcement actions, a practice disturbingly commonplace.
  • Environment Agency failing to monitor water firms in England, data suggests
    
    
• Selective water testing by local and national authorities may solely take samples from mid-depth, excluding silt deposits, where most toxic industrial legacy cocktails lie.
  
  
• Water companies can stop sewage outflow at treatment plants to avoid Environment Agency monitoring spot checks.
  
  
• Water companies can dispense with water testing results which will probably suit their purposes. In overflow incidents, they may fail to provide representative data to regulators on licence breaches, or improvement plans.
  • Surfers Against Sewage 2022-23 Water Quality Report
    
  • SAS webpage about Water Quality Testing
    
    
• Sites formerly used for military testing are subject to secrecy (e.g. Confidentiality 'D Notices' on the basis of ‘national security’).
  See:
  • Radioactivity
  • Site History
  • Land Use
  • WWII MoD Legacy
    
    
• Commissioning independent scientific analysis or reports from consultants means knowing what questions to ask yourselves and your potential contractor. You need to avoid their conflicts of interest, which could mean compromising your data and risking getting the information you need to hold bodies to account.
  • It is helpful if an independent contractor is to be commissioned to provide any scientific or engineering report, that your group asks 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 eg a water company, a local council, or a water regulator, that could mean they will have a conflict of interest, so short change you because of parameters and constraints of contracts they are legally bound by in working for those bodies you want to hold to account!
  • Do you trust the information being provided by a potential engineer, environmental auditor, or other contractor? If not, talk to independent bodies such as Greenpeace, who have their own laboratories for testing, or to Friends of the Earth, who may have historic documentation or connections that could bring more information or local connections to light. Alternatively, check out previous cases from searching for your issue on What Do They Know
  • If you haven't got the funds to source an independent report, might a crowd-funder help?
    
    
• Data available may not be real-time, e.g. Rivers Trust sewage overflow map of event numbers and volume (valuable as that resource is, it isn't ideal!). We recommend 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. Fortunately, help is available: FoI letter template help here
  
  
• You cannot trust a Blue Flag bathing beach safety categorisation. Even those beaches with apparent 'excellent' rating, sadly raw sewage contamination is still a risk. Signs on-site, warning bathers of hazards can be risible at best, and virtually invisible at worst! Check this out!
  
  
• Nature-based solutions across 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 support of local disabled and elderly people? How might threatened species be protected?
  • What provision is made for e.g. rewilding areas through upstream tree-planting, beaver population releases for natural landscape engineering, or other habitat management plans to mitigate impacts?
  • Where local landfills have a toxic legacy, what remediation strategies are in place for excess rainfall periods?
  • So many questions... Perhaps we need a page just for this issue! If this is an area of interest for you, we would love to hear from you!