Skip to main content

Data and Facts - Gaps

It isn’t just holes in sewage infrastructure!infrastructure we need to act on!

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.us and there are lots of gaps in data, information is legally inaccessible, or takes wading through bureaucratic systems and obfuscation. Here's just a few of the sink holes and eddy pools to watch out for...

  • 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. Elsewhere, letters to local authorities can result in only partial information sharing, or even incompetence, lost records, or historical memory loss as staff retire and leave.

    • Environment Agency failing to monitor water firms in England, data suggests

    • Given this 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. Check out the website 'What Do They Know' (read on) for template letters and existing examples and case studies to back up your campaign. FoI requests are not always effectively responded to, particularly if you miss any tricks on how to exercise your rights. Fortunately, What Do They Know helps you avoid the pitfalls, offering existing case studies and template letters.

  • Selective water testing by water companies, local and national authorities may solelyonly takemean water samples being taken from mid-depth,depth of rivers, excluding silt deposits,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 canselectively dispense with water testing results, which will probablycan suit their purposes. In sewage overflow incidents, they may fail to provide representative data to regulators on licence breaches,breaches. orMore improvementrecently, plans.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. This practice is a question you might want to ask of your water company.

    • Surfers Against Sewage 2022-23 Water Quality Report
    • SAS webpage about Water Quality Testing

  • Water company improvement plans may be completely unfit for purpose and lack public input. Inviting water companies to a 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.

  • Sites formerly used for military testing are subject to secrecy laws and confidentiality practices (e.g. Confidentiality 'D Notices', which forbid public access on the basis of ‘national security’).

    See:

  • See more about the legacy of our military on our environment here:

  • 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,interest whichwith contracts with local authorities or water companies, for instance. Check if they have such contracts, or have had in the past; this could mean compromisingthat if you hire them, your data could be compromised by pre-existing confidentiality and riskingnon-disclosure agreements, limiting your available data. That risks 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 youryou group asksask them in advance if they obtain any more than 10% of their work from authorities or companies you seek to challenge.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,interest. so short change you because of parameters and constraints of contractsIf they are legally bound by in working for those bodies you want to hold to account!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.
    • Do you trust the information being provided by a potential engineer, environmental auditor, or other contractor? If not, talk to independent bodiesallies such as Greenpeace, who have their own laboratories for testing, or to Friends of the Earth,Earth, who may have historic documentation or community connections that couldto bring more information or local connections to light.
    • Alternatively, check out previous cases fromsimilar to your local situation by searching for your issue on What Do They Know. A case study on this site, for instance, refers to local Wales resident who has put in a Freedom of Information request to the regulatory body, Natural Resources Wales. Anyone searching the site for "leachate" will bring this and similar example cases up, which means your local group will not have to reinvent the wheel and can avoid missing essential questions to ask in your Freedom of Information request.
    • If you haven't got the funds to source an independent report, might a crowd-funder help?

  • Data availablefrom water companies on sewage overflow 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?strategy? If so, does it include recommendations for supporttree ofplanting? If your local disabledauthority has that documented, are financial constraints hindering implementing and elderlymeeting people?targets? HowIs mightthis threateneda speciespotential becommunity protected?assembly in the making to bring local people together behind such projects?
    • What provision is made for e.g. rewilding areas through upstream tree-planting,land works to let straightened river stretches go back to historic natural paths? Is there scope for beaver population releases forto achieve natural landscape engineering,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:
    • Where local landfillslandfill sites have a toxic legacy, has your local authority declared a Climate Emergency? If so, what remediation strategiesand aremitigation provision is made for leachate risks from heavy rainfall? Are there buffer mechanisms between buried toxic waste and water courses? Some plants reabsorb toxic elements in placesoils. Are these options for excessyour rainfalllocal periods?community to request?
    • So many questions.questions arise around toxic landfill... PerhapsPlease wecontact needthe aDirty pageWater justcrew foron thisyour issue!local issue to share knowledge and experience! If this is an area of interestconcern for you, we would love to hear from you!you via our Telegram and Mattermost channels!

    • Plastic pollution So much to say and so many organisations already operating in this space, for now, check out our sources of pollution page for links and watch out for spreadsheets of potential allies, coming soon.
Back to top