Call for action on pollution from run-off

Send the email below to the Environment Agency:

national.requests@environment-agency.gov.uk

Subject: Run-off pollution from industrial estates and large car parks

Dear Environment Agency,

Your Guidance says an environmental permit is needed if a discharge to a river contains “poisonous, noxious, polluting matter or polluting substances”

https://www.gov.uk/guidance/discharges-to-surface-water-and-groundwater-environmental-permits

The Environmental Permitting Regulations 2016 state that an offence has been committed if a person causes or knowingly permits a water discharge activity except under and to the extent authorised by an environmental permit.

Your Guidance only exempts the discharge of uncontaminated water collected from public roads and small parking areas (that’s been through a properly maintained oil separator) to surface water. And the discharge of uncontaminated water, such as clean rainwater from roofs or from small areas of hardstanding to surface water.

Large paved areas, for example on industrial estates and car parks will cause pollution when it rains, if the surface water drains are connected to a river, as the accumulated matter is washed into them.

Defra notes that “Highways drainage and urban diffuse pollution is a serious issue causing 18 percent of failures for water bodies in England under the Water Framework Directive”

Parliament’s Environmental Audit Committee in 2022 said “Diffuse pollution from highways, towns and cities can lead to chronic impacts on the quality of aquatic life in rivers as it accumulates in sediments.”

I believe the Environment Agency is failing in its statutory duty to protect rivers by not using the Environmental Permitting Regulations 2016 to control water discharges from the paved areas of industrial estates and large car parks (more than 50 spaces). And that this failure results in the lack of preventative measures like the installation of oil separators or Sustainable Drainage Systems. Additionally, in your reply to an information request from London Waterkeeper (NR280035), you confirmed that you do not keep a list of companies that have installed separators or if they are maintained.

Under the Environmental Information Regulations 2004, I would like to request the following information:

  1. Are you using the Environmental Information Regulations 2016 to permit water discharge activities from industrial estates and large car parks in London?
  2. If yes, can you send me a list or link to these permits?
  3. If no, can you send me the meeting notes or policy where this decision is detailed?
  4. With regards to reducing diffuse urban pollution to London’s rivers can you send me the evidence of action you have taken since 2015?

Electronic replies are fine,

Yours faithfully,