30 July 2021
Rivers and sewage pollution

Notes taken from meeting of 2nd July 2021 to discuss rivers and sewage pollution.


We really do have some of the most beautiful chalk streams in the Country in the Cotswolds so we do all do need to do what we can to preserve them.

Ashley written an agenda he can act as coordinator for meeting, GCB as chairman.

(Ashley runs through agenda).

I’m going to take careful notes, particularly of action points and who is offering to do what. Will send out minutes of meeting to everyone who is attending so we have a written record of what has happened.

Ashley Smith:

Huge problem that’s getting worse. Nobody in disagreement that there is an issue here.

Some of us have been exposed to this issue for over 40 years now.

Extent of problem massive. For example, untreated sewage spills at Bourton-on-the-Water in region of 1300 hours in 2019 and 1600 hours in 2020. Mirrored across many sewage works.

Spectacular data collection work of Peter Hammond, introduction of eventuation monitors and use of artificial intelligence to expose the extent of the problem.

Thames Water engaging positively: recognition that there is a serious problem that needs to be gripped. Environment Agency, don’t have much dialogue, suggests this could be something Sir Geoffrey could help with. Where we have been expecting the EA to engage and lead that hasn’t happened.


Would be useful for everybody to introduce themselves:

Ashley Smith, founder of WASP

Cllr Andrew Docherty, cabinet member for Environment, Waste and Recycling at CDC

Joe Baker GCC flood risk management team, primarily lead on capital flood risk management projects

Richard Aylard sustainability director at Thames Water and responsible for leading on engagement on environmental issues with stakeholders

Karen Nelson regional network manager for Thames Water (Thames Valley Region) responsible for all the pipes in the network for waste side of the business

Dominic Collyer local Government lead for Thames Water

Andrew Hagger, Thames Water asset management looking after sewage networks treatment works and looking at investment needs

Lucy Bee, Team Leader for environment management, Evenlode and Coln under remit

Robert Davis, senior environment officer inland and water, main role regulating discharges to water

Nicholas Field Johnson, Cllr for Burford and Windrush Valley, Division covers all of Windrush between Burford and Witney, work Closely with Ashley, keen fisherman

Debbie Campbell, works with surfers against sewage and helping WASP

Mark Purvis, assistant river secretary for Cotswold Flyfishers club, 30 miles of fishing, see first-hand what’s happening to rivers

David Reinger, River Secretary for Cotswolds Flyfishers Club, hard to find a stream in Cotswolds which doesn’t appear to be affected.

Professor Peter Hammond, member of WASP, particular interest is detecting unpermitted discharges

Apologies received from Dr Richard Knowles

Nicholas Field Johnson:


Windrush significantly polluted last 10-12 years. It was a clear river in the year 2000, now a murky brown with no fish whatsoever

Reason is mainly raw sewage discharge. Seen constantly in river. Have testing equipment in river which show this to be the case.

What we really need is national legislation to stop the dumping in rivers.

Raw sewage dumped throughout the year, meant only when there’s excess rain

Particularly critical of EA, done absolutely nothing, should be totally reviewed in my view

Oxfordshire CC and district council have passed motions condemning water companies but ultimately need legislation to stop this practise.


Peter Hammond:


National level: Rivers Trust published data in 2019 on all parliamentary constituencies (total number of hours water for all CSO’s (Combined Sewer Overflows) discharged into rivers often untreated sewage) Cotswolds is 12 out of 533 with 10,086 hours. Robert Courts in Witney is number 6 on that list. Won’t just be Thames Water, Sir Geoffrey constituency also includes Wessex and Severn Trent. (Two thirds Thames Water)

Sewage Treatment works EDM data 2018 to 2020, Thames Water limited return for 2018, put in a bit later compared to Wessex and Severn Trent. Many did not work for a long time, not correctly installed.

Looked at 12 Treatment works discharging into Coln, Evenlode, Dikler, Leach, Key. 50 percent increase at least from 2019 to 2020, 8500 hours to 13,000 hours. These figures reported by TW in return to EA so are acknowledged figures.

Reflects trend from 100 sewage works I have looked at across the country.

In 2019 only 9 or 10 out of 12 returned figures.

These are what we call permitted spills as reported by Thames Water. Unpermitted spills which I think are breaching permits.

Asked EA about 2 ways of breaching permits. Firstly, that works often do not continue treating sewage even when they are spilling according to their permit-there is a minimum amount they are expected to treat before they are able to spill due to rain or snowfall. Second, they spill when there is no rain or minimal rainfall

EA told me that in the 10 years 2010 to 2020, there were 175 breaches. None of those were in treatment works in your constituency Sir Geoffrey.

I reckon from my survey there were at least 150 unpermitted spills that’s breaching either the minimum treatment during a spill or spilling during dry weather/minimal rainfall

Final point, discovered by accident illegal CSO Bourton Treatment works spilling into river Dikler where TW are blending treated and untreated sewage and then dumping into river. This has no permit and is not licensed.



Richard maybe one of your team could comment on those figures and give us an idea of what action you are taking to rectify discharge into rivers.


Richard Aylard:


Unacceptable that these discharges are necessary. Overflows designed to protect the network. We need to reduce amount of flow arriving at the works. Don’t want fresh water in sewage, its more difficult to treat and expensive and less energy at the end

3 things:

1. reduce infiltration- difficult because have to find how water is entering which you can only do when it is taking place, very narrow window when this is possible

2. Increase capacity at Sewage works more headroom to deal with climate change and growth. In this 5-year period we are increasing capacity by typically 30% plus (Bourton, Cirencester and Fairford)

3. Increase storm tank capacity-park some of extra flow until you can treat it when incoming volume has subsided. Useful for big summer thunderstorms, intensely wet weekend. Doesn’t work when the whole winter is wet as you fill your storm tanks and can never get them empty-they have limitations. In this 5-year period we are expanding storm tank capacity at Bourton, Cirencester and Moreton.

Next 5-year period big plan of work going to need support from councils, local communities etc. to make case with Ofwat.


Andrew Hagger:

Historically water companies have introduced things like tanks and overflows to deal with excess flow in the system. Mainly foul only systems. Not designed to take surface water.

Need to tackle unwanted flows at source. 3 key areas.

  1. Property misconnections, e.g. patio or extension connect a gully into a manhole cover
  2. Inundation, flooding
  3. Infiltration-should add not indicative of a system which is deteriorating, systems will leak and not designed to be completely watertight

Need to work with communities, map out where the issues are impacting system

Groundwater driving problem so need to seal sewers. Don’t have to replace pipes but can install liners in sewers than reduces groundwater infiltration. Plans published on website and based on high level groundwater.

Inundation-no longer install vent columns like Victorians but use gaps in manhole covers which are not airtight so get air circulation. That also means surface water can get into systems which could be equivalent of hundreds of houses wastewater. Need to seal these, but downside is increased surface water which will need to be managed.

Finally need to measure transparently successes and failures. We are putting monitors in strategic locations within system to detect problems, help explain how the improvements have improved performance and bear in mind other factors such as changing groundwater levels due to new developments. Need to have a system in place which detects problems early before there is an impact.



Writing notes frantically but we will send out each section to the relevant parties to correct or amend.

Robert Davis:

Few points to run through. First of all, would like to reply to a few things which have been said about EA which are inaccurate.

Firstly, recognise valuable work that WASP have done alerting us to a lot of issues and incidents and Peter Hammond’s valuable work providing intelligence and machine learning all of which really positive and raising public awareness about water quality etc. However, we have engaged with WASP, inaccurate to suggest otherwise. Have had several meetings at local level, national level and written correspondence. Over 300 requests for information we have responded to. Significant amount of time and resources which are limited.

Secondly, claim that EA not leading on compliance and investigatory approach simply not true. Perhaps not possible to communicate everything sometimes for legal reasons and do so better in certain situations. Conducting detailed compliance and gathering data at a number of different sites across Thames area including several in Cotswolds which have been talked about here today. Includes sites where groundwater infiltration is an issue. Have been doing for quite some time but in context of limited resources.

Eventuation monitoring is a major step forward, didn’t exist 5 years ago. Multiple benefits-helps water companies, water quality planning, compliance point of view. Further monitoring coming at a number of sites. Positive direction of travel.

Some cases compliance assessments depending on outcomes may lead to further investigations. Also conducting multiple criminal investigations in relation to sewage pollution across Thames area following various category 1 and 2 incidents.

EA proven track record consistently taking tough enforcement action-30 prosecutions in 10 years running into fines of many millions including relating to non-compliance storm overflows.

James Bevan our Chief Executive recently said at Environmental Audit Committee, lack of resources is an issue. Everybody knows that, like a stuck record but it is true. Do best we can we resources we have.

I know River Windrush extremely well and intimately-grew up in area and was member of Cotswold Flyfishers for many years. Have seen changes over the years but with professional knowledge and expertise, the challenges are multifaceted. Agriculture a big factor. Looking solely at sewage could be detrimental to river-like a patient if you focus on the wrong organ or ailment and don’t take holistic approach you could negate progress in recovery. My evidence from own monitoring, water discharges are a factor, however they are not the only factor and may not necessarily be the dominant factor. (Nicholas Field Johnson: absolute rubbish) EA point of view best understanding of turbidity issue, calcium precipitation is likely to be causing opacity as well as eutrophication nutrient enrichment from agriculture and water industry including storm overflows, sewage discharges. Product of everything that happens in catchment. Not saying water industry is not an issue as own evidence shows and some storm overflows concerned about from compliance point of view which we are investigating.

Hope that’s a helpful overview


Heard somebody saying rubbish, so think we might just come to whoever that was straightaway

Nicholas Field Johnson:

Agriculture has no impact on the Windrush whatsoever. EA as usual coming in too late, damage already been done in last 8 years and EA has done nothing about it.

One thing that hasn’t been mentioned is housing which has doubled in Oxfordshire, sewage capacity hasn’t. Answer is more investment through Thames Water and Government help.

To blame Windrush pollution on agriculture is a complete misnomer. EA puts out a lot of misleading facts.


Identified 3 main causes: discharges, agriculture and housing. Would like to explore with TW and EA issue of housing and how important an issue it is and extra investment is

Richard Aylard:

Real concern for us, constantly try to get developers automatic right to connect to our systems removed and have failed

More to it than that-If developers connect up exactly as they should then the foul flow coming in relatively small. Problem is they don’t.

Would like to bring in Karen who runs the network and to bring up an historic problem she found and resolved at a large house which is quite revealing then to talk about problems with new developments being poorly connected and consequences for network.

Karen Nelson:

Work undertaken in terms of our resources, fair to say not necessarily taken right approach in the past in the field, aspects of looking into infiltration. Over last 2 winters structured very differently. Given us much more insight into what’s happening. Haven’t fixed everything-constant cycle between investigating when weather is wet and almost working harder now than in winter preparing ourselves for what could be another wet winter.

As part of this we have field management specialists who are trying to control flows and utilise tankers. Need to use efficiently, effectively and big frustration to customers through noise and road disruption. Trying to streamline so we can cover more areas and protect more customers and environment.

Also have infiltration specialist who is coordinating tasks. Sunny weather, they are thinking wet weather constantly.

Approach-find it, fix it, review it.

Multitude of causes-misconnections, infiltration and inundation mentioned earlier but 2 other causes we have come across-new developments where developers not suitable standard or directed water to wrong location where it comes into our network. We are getting on top of this now on bigger developments where we see it happening and as soon as we find it, we engage and are using powers where we can, to get that water removed. Can’t see in summer months if there is infiltration so need to be all over everything during wet weather periods.

Would be great to have different standards in these hotspot areas for infiltration. Lots of areas where a bit of groundwater wouldn’t hurt us but there are very key hotspots where we do need to tighten standard and not receive any more than the foul flow.

Other route where water can get into network is customers protecting property. There is a village we have tankered every year without fail. For years and years as long as I can remember we have been out there tankering and during the winter of 2019 and 2020 through our investigations we stumbled across a large property with a basement. That basement was struggling with seepage and flooding in it. They had a private pump which they had connected up and were discharging into our network. We removed that on the basis of that’s groundwater getting in there so its safe to exist in the environment and directed it more to some land and to a local river area so it could come away from the sewage to stop any potential sewer flooding. From the day we removed that pump we have never tankered that village since, so that’s 18 months. We’ve just gone through one of the worst wet winters and that can show the impact that one private pump on a private property that was tucked away and wasn’t seen by any of us and that created one of our large tankers having to be on site in the village 24/7. We are not talking large volumes necessarily getting in but it’s the wrong flows getting in and it can cause us massive impact. That covers 2 of the areas where Richard highlighted.



Richard I would like to ask you about this automatic right to connect. That is one thing but who legally has the powers to make sure the developers do it correctly in accordance to your specifications. You or planning authorities?

Richard Aylard:

Technically I believe it’s the planning authority, but I would like to get expert help and write to you on that as its slightly outside my scope. Can send you briefing.


If you could as it’s something I need to take up with government

Richard Aylard:

We have a good briefing on that which I will send to you and perhaps we could circulate it via your office to the other attendees



Anybody who wants to put any slides or any information could you please send and we can attach to minutes electronically. Would be very happy if we could do that.

At this stage-anyone from EA want to comment on any of those aspects or whether we should move on? Perhaps I think we should hear from county and district councils then I want to get onto short term fixes and longer term plan. Quite a lot to do and time marching on.

Lucy Bee:

Just quickly I suppose conscious of time. We do review groundwater infiltration plans and drainage strategy’s with TW so we do have an input and have a large remit including extraction and incident response and inspection going back to the conversation where we have been criticised about our lack of action. TW are fully aware that we have taken a number of prosecutions and we are continuing with cases. We do best we can with resources, and we do discuss with TW at different levels their plans for the future. Won’t talk anymore on that, conscious of time.


Just going back to Richard-in brief to me you could put in some what sort of lobbying required to Owfat in terms of investment in next license term to deal with these problems

Richard Aylard:

There is only one point in the 5-year cycle where government can effectively direct Ofwat and that is when they issue Ofwat with a strategic policy statement. Of all the things Ofwat are responsible for, policy isn’t one of them. Government has reserved the right to decide policy. In the run up to a price review, Defra issue Ofwat with a strategic policy statement. This has often been done quite quietly and nobody takes much notice and frankly the guidance is consulted on with ofwat beforehand and not always all that strong. Key points are consulted on publicly which is an opportunity to go back to Defra and to persuade them to give Ofwat a very clear steer of what they need to do. Coming up in next 6 to 9 months and I can add a little note about the strategic policy statement with some links when I write to you Geoffrey


Real opportunity for everybody on this call to make representations. Very helpful indeed Richard, thank you. Keen to come now to County and district councils for their observations


Joe Baker:

Obviously, EA have enforcement powers Related to pollution and TW. We are not too directly involved. I guess more questions really: Do TW get consulted on about strategic planning applications to see where they will eventually discharge? And relating to planning process and discussed earlier about surface water getting into the TW systems because we look at it from a flood risk perspective in various locations around the county where we get a lot of surface water and does cause sewer issues and we are looking at some of those. Do you have any of those locations mapped and could you share that so we could have a look at it would be really helpful? In terms of planning obviously new developments should not be exasperating flood risk elsewhere but important point to mention schedule 3 of the flood and water management act in terms of pollution where we do get developers whop do storage element but not necessarily the treatment element and water quality. I know that’s not directly related to point source pollution, but it is pollution, so I thought it was worth mentioning. If you Geoffrey could look at the enacting of schedule 3 of the act and if that would be good for England. It has been for wales. We would have a bit more power at local authority level to keep surface water contained.



Bring in Andrew from CDC for observations and particularly perhaps some of those questions raised by Joe about what consultations just done with TW and EA and right to connect

Andrew Docherty:

General observations-ability to prevent things relatively limited. Most authorities use so called Grampian conditions-request additional storm tanks for particular development. That doesn’t tend to deal with major problem of somebody operating local treatment works and somebody needs to pay for so there is additional capacity.

We tend to get involved in basics of what needs to be done for this particular site but the planning process largely ignores what is going on in the rest of the environment around it. Fairford a good example. Got five separate developments happening over short number of years. Each of which have to be considered in isolation because that’s the way the system treats them by in large. Only place which they tend to get joined up is in terms of impact on TW infrastructure. Work going on at the moment to try and improve the way we police things such as the Grampian conditions. I have got people looking into other authorities who have perhaps manged to magic up more with existing regulatory and legal framework. But whenever you try to get creative on planning tends to go to planning inspectorate and then goes through on appeal, gets beaten back by more expensive layers than ones we’ve got who will argue that it is unreasonable, not required etc. cumulative effect on planning system. Absolute right to connect is problematic. I know that Scotland has different system and interestingly their water quality is notably better. Seems to take infrastructure requirements into account.

Have had a lot of discussions with TW about what they are allowed to charge for and what developers are and are not expected to pay for.

Have had exceptionally high groundwater levels in the churn valley area in particular and across the Cotswolds. Not slightly problematic flows, it blew the covers off the mains sewers from Cirencester to treatment works at Shorncote. That’s how over pressurised and overloaded the system was. Infiltration a major problem in the Cotswolds because we are seeing more of the high groundwater events and geology means particularly fast response in groundwater levels, drops fast and rises fast. Seems to be happening more for obvious reasons.

While I take on board the notes about building misconnected and these kinds of things, most concerned about groundwater infiltration causing most obvious and most significant problems at the minute both in terms of impact on rivers and residents.


What you’ve just said shows how complicated the whole picture is.

Andrew Docherty:

Just one observation because there have been a couple of things noted. Got appreciation for EA saying some of this is multifaceted. I do have concerns about agricultural impacts and do not believe it is realistic to say there is no agricultural impact. Dose of flea killing compound used on a Labrador for example is enough to kill 60 million bumble bees. Neonicotinoids break down into stuff which is very long lived in the environment. We have been using neonicotinoids on our agricultural sites for a long time. I’ve done 4 or 5 years surveying in a river and I’ve seen invertebrate, life decline over that time.

On sewage front, I have looked at the permits around Fairford and Ampney St Peter sites and I do not see how the EA can justify that those permits are not being breached when they talk about rainfall events and compare that to the number of hours going through on. There is not enforcement as far as I can see of permits for what TW are currently allowed to do. Fairly clearly being breached. EA turns up if you kill a river overnight by killing all the fish off, but if you slowly strangle it to death nothing much seems to happen. A lot of us in local Government getting exasperated.


We have done a lot of diagnosis of the problems; I’m interested in long term permanent improvement in the river quality.

Nicholas Field Johnson:

I would like to briefly make 2 points both short and long term. I think at national level we need legislation to stop dumping of raw sewage throughout the year and with constant growth of housing there has to be some linkage between increased investment in sewage. Would like to thank you afraid I have another meeting to attend now.


Just before you go, I would like to challenge you. I am a farmer and I know we are all sensitive about this but you said you didn’t think there was any contribution from agriculture. Are you still of that mind in view of what Andrew has just said.

Nicholas Field Johnson:

Was referring to Windrush particularly my stretch of river I’m absolutely convinced agriculture has very little to play. Andrew though quite right there are other rivers which do have cattle, chicken and other pollution. Not contradicting what Andrew said at all, in fact I am agreeing with him.


Anybody else want to address short term fixes, would like to get onto longer term item 4 and move whole thing forward

Ashley Smith:

Just briefly with short term fixes can very much be distilled by some work that WASP is doing with TW right now to look at really easy wins and I think we can probably report back to you. Being talking with Richard Aylard and his team and we should be able to deliver something in terms of something that works and works quickly.

Very constructive to hear what people have said today.

Failure of regulation to force the water industry as Defra has admitted investment has not kept up with need. Agencies prosecutions which take about 4 years to get to court haven’t done it. They have made pollution profitable and there has to be recognition from that point of view. I don’t want to counter what Robert Davis has said we will do that off screen but we have to accept that the communication and overall working aspect isn’t working.

Question of where it turns into making a plan. Good start to build around that is in the Windrush recovery plan that we are engaging with TW which can be extended out to the Cotswold rivers trust and a link that is now obviously establishing really well with wasp and hopefully with the rivers trust with the councils who all have powerful role to play in engaging with Defra to turn on money tap because this is an emergent as you can see. Not something that can be solved with a 5 or 10 year plan work needs to start now. Need to push boundaries or you can forget future of environment.



Perhaps one of the most positive things to come out of this meeting-all very well summoning TW and EA and beating around the head but what we are actually establishing is an element of goodwill from both of them but both mentioning resources. I think what we need too do is establish quite a powerful team to go and meet rebecca pow and demonstrate to her loud and clearly because an MP can do this but when you actually get practitioners like yourself on the ground like you (Ashley) and Peter, Debbie and others. Look this is what is happening on the ground you have to allow TW and EA more resources to deal with problem, I think we would make progress. If everybody is agreeable, I think this should be one of our next action points.


Richard Aylard:

If I could just chip in supporting what Ashley has said about the collaborative projects that we are working on. Added to that we are looking at 2 pilot catchments starting immediately. We have got 56 groundwater impacted catchments. We have picked 2 to fast track and one of them is the Windrush and we will be talking to WASP about that shortly and in terms of the surface water which Joe was talking about, local people know a lot more about that in many cases than we do so we want to engage particularly around Bourton on the Water actually helping us to implement that drainage strategy. Another thing is, if people see a problem somewhere and needs to be monitored report it and we will put a monitor/ investigate. We use monitors which WASP have access to. Every report has been fast tracked through our voice system and every incident is investigated within 2 hours and generally we get there within an hour. I get emails like last week there was some scum, this is a photo from Tuesday. When we get there, there is nothing to see Important for quick reporting then will get quick reaction. Speed is of essence.

Vaughan Lewis:

40 years ago, when I started in 80s-derogation of the sewage works for privatisation was awful. Government at time allowed sewage works to run down dramatically and Windrush was in terrible state. I have records of legal cases being prepared against the then TW by external bodies. I still have the correspondence if anyone’s interested. Period in 90s and early noughties where it was passably good. Since then we have noticed clear gradual deterioration. Clear to me agriculture an issue but look at eutrophication and point source pollution loading with effluent its clearly sewage industry. Something like 60 to 80 percent of phosphate in the Windrush comes from sewage treatment works. Can argue figures but is overwhelmingly the water companies’ contributions. Good start-need TW abiding by law and EA enforcing. Need investment, Defra have no control of situation but treasury men sitting over spreadsheet, we need to get to them. Changing legislative goalposts. Disgraceful situation, need to shape up in EA and TW who have been helpful and moving positively but needs much more effort.


Public attitude changing-younger more interested in environment. On the whole would be prepared to spend a little more on water bills if environment being improved. Ultimately seems to come down to resources.

Richard Aylard:

Investors no dividend for last 4 years, overspent 770 million in last 5 years and forecast to overspend by same amount this 5 years. With hindsight we didn’t do a very good job before the last price review because if we did Ofwat wouldn’t have brought prices down. If prices had stayed the same we would have had extra 1.5bn to spend. Need to make case to Ofwat for investment before next price review.


Aside from continuing work on discharges and enforcement etc. important strategic work to get delegation Rebecca Pow at Defra to impress on Government need for resources to solve problem. Anybody any quick points before I close the meeting?

Richard Aylard:

Interesting comments in the chat. Would your office be able to cut and paste and email around? There are some points I would like to follow up.

Robert Davis:

Bouton on the Water compliance issue we are dealing with. Not as quickly as we would like but resources again. Other sites planning on doing compliance assessments. Subject to resources, reality picked up on this meeting.

Agricultural point to be clear I think it is one of heavyweight factors in catchment as well as water industry discharges. More complicated than solely looking at sewage.



Whilst I will constantly campaign for resources, I don’t want to see that as an excuse for not taking matters forward regardless.

Is EA working with agriculture given you said its one of the heavyweights?

Robert Davis:

Again, acute Lack resources to investigate and boots on ground. James Bevan pointed out that we visit each farm 200 years on average. However, can still have positive impacts. Can do catchment work and farmers on the whole very knowledgeable about it. Don’t have all the answers, e.g. ammonium nitrate even if you follow best practise and rules by letter still using 30 percent to the catchment.

Richard Aylard:

Also incentives through ELM scheme for farmers to do things differently

Lucy Bee:

We target highest risk sites where biggest problems might be.



  1. Arrange meeting for delegation with Rebecca Pow
  2. Next meeting with everybody 6 months time-provisional date Friday 10th December  @10:30AM

(EA’s Lucy Bee and Rob Davis, TW’s Richard Aylard, Ashley etc. happy with preference for Cotswolds meeting place to London)

Ashley Smith suggests meeting place of Warwick Hall, Burford- good facilities and location.


Thanks everyone for participation and learnt a huge amount. All moving in right direction, in all our interests to improve biodiversity of rivers etc-just a question of how to get there