Royal Commission seeks more precautionary approach to water quality

The Royal Commission on Environmental Pollution (RCEP) took six years to produce its latest report, on freshwater quality.1 Some may complain that it contains little fresh thinking. But the report urges less reliance on the capacity of the environment to deal with waste, and more intensive monitoring and openness in reporting on water quality. Together the recommendations add up to a radically more protective approach to environmental protection.

The last three years saw the privatisation of the water authorities and the birth of the National Rivers Authority (NRA). So much attention has been directed towards water issues over this period that it is doubtful whether there is anything original left to say on water and the environment.

The RCEP's report is not therefore a major source of new ideas, but a synthesis pulling together many thoughts about the future improvement of the water environment which inevitably spills over into other areas, such as waste disposal and air pollution. It will both pressurise and support the Government in bringing about wide-ranging policy changes on issues ranging from effluent charging to contaminated land remediation. It also provides a view which is sufficiently different from the NRA's to give pause for thought.

New approach
The RCEP goes further than the NRA has yet done in promoting a more protective approach to the environment. At the launch of the report the RCEP's retiring Chairman, Lord Lewis, advocated a reappraisal of the long-standing view - endorsed in the past by the RCEP itself - that it is "acceptable and sensible" to make use of the environment's capacity to assimilate and degrade wastes.

Progressively less reliance should be placed on this capacity, the report says. "The question of how much waste can be disposed of to the environment without adverse impact should be preceded by asking how far the pollution from a process can be reduced," according to Lord Lewis.

In practice, this means moving away from the UK's traditional environmental quality objective (EQO) approach and replacing it with controls at source based on BATNEEC, the best available techniques not entailing excessive cost. Secondly, the report continues, EQOs should be tightened to reflect increasingly ambitious targets for water quality.

Incentive charges
The RCEP's most far-reaching recommendation is for the introduction of a charging scheme for liquid discharges. These would go beyond the cost-recovery schemes operated by the NRA and Scotland's River Purification Authorities (RPAs). Under the proposals industry could expect substantially increased charges, while the extra revenue would be diverted to a range of improvement projects such as contaminated land clean-up or grants for industrial effluent treatment.

Looking toward continental models, particularly in Germany, the RCEP recommends an incentive charging scheme based on the volume and content of the effluent, as specified in the discharge consent. Charges would be calculated on a "units of pollution" basis, with a fixed charge being set per unit but the size of the unit varying according to the pollutant.

The objective of the scheme would be to provide dischargers with a continuing incentive to reduce their discharges below consented limits. It would also encourage new technology and promote a more cost-effective approach to pollution abatement, because companies which could reduce pollution loads relatively cheaply would do so in preference to paying a fee.

Totally market-based approaches to pollution control, such as tradable permits, were rejected by the RCEP after studies showed that they would not guarantee compliance with statutory water quality objectives. They would also require regulators to know a great deal about pollution abatement costs and options, and involve complex charging formulas which varied enormously with location in a catchment.

The RCEP recommends that charges should be payable on all point source discharges, including sewerage outfalls. It also suggests charges for storm overflows, surface water run-off, accidental discharges and even activities which risk polluting water such as landfill.

Industry could expect considerable increases in costs under the proposals. The report notes that high charges have been needed in Germany and the Netherlands to provide dischargers with an adequate incentive to improve effluent quality. If the UK brought its charges up to current German levels, increases of a factor of two to four would be common, but the precise levels would be highly case-dependent. Increases would be particularly steep for more toxic effluents.

The RCEP is sensitive to industry's need for long-term planning, and recommends that any new charging scheme should start at existing levels and build up by pre-determined steps to the required level over five years.

Widespread eutrophication
A second area in which the report may have major cost implications is eutrophication. The RCEP concluded that eutrophication is "widespread over large parts of the country", especially central and south-eastern England. This is a sharp contrast with the Government's view that it is a local problem affecting a few areas such as the Norfolk Broads, Lough Neagh and some reservoirs (ENDS Report 201, pp 26-7).

The current level of enrichment of many lakes and rivers is undesirable, the RCEP says, and removal of phosphate at sewage treatment works will be necessary "in most cases". The UK is already subject to the 1991 EC wastewater treatment Directive, which requires phosphate stripping at all works discharging to sensitive waters or those treating effluent from over 10,000 people. The Water Services Association estimated in 1990 that this is likely to require investments of £740 million in England and Wales alone (ENDS Report 182, p 17).

But the RCEP advocates going further than the EC Directive. It may be necessary to remove phosphate at works serving less than 10,000 people or achieve lower phosphate limits at large works, it says. Phosphate removal may also be required at treatment plants which are currently unmanned, which will add considerably to costs unless new processes which do not require supervision are developed.

Where the original trophic state of waters can be identified, this should be the long-term EQO, the report recommends. If this was impracticable, EQOs should be set to secure "an acceptable level of both species diversity and amenity".

Sewerage
The Commission endorses the recommendations of the NRA's Kinnersley report (ENDS Report 186, pp 17-18/23-4) on discharge control policy. But it goes further in arguing for an end to descriptive consents for small sewage works, because these may have a pronounced effect on the small streams to which many discharge. Many small works also need improved storage to cope with intermittent high flows.

Storm overflows cause severe pollution of Britain's rivers, the RCEP notes. It approves of current research and modelling studies undertaken by the NRA and sewerage undertakers and recommends, in the short term, that ameliorative measures such as the removal of overflows and the construction of holding tanks continue.

Cleaning products
Although recognising that laundry detergents are a major source of phosphate in sewage effluents, the RCEP is cautious about phosphate-free alternatives. These should not be widely introduced, it recommends, until their environmental effects have been fully assessed and judged acceptable. According to the Soap and Detergent Industries Association (SDIA), over 40% of the laundry detergent market is currently satisfied by phosphate-free products, so the warning comes too late.

The RCEP echoes the concerns expressed in a report on the environmental impact of detergents produced by Consultants in Environmental Sciences for the Department of the Environment (ENDS Report 194, pp 22-23).But it also recommends that the Government and detergent industry explore the possibility of reducing phosphate use in soft water areas where smaller quantities of detergent are needed.

The SDIA's response was that the industry would "need to be convinced that the environmental benefits were significant", especially because soft water areas represent only 20% of the market. Special formulations for hard and soft water would double the number of products and consumers would need to be advised about which product was suitable for their area.

Household products
Contributions to water pollution from a variety of household chemicals were considered by the Commission. Studies contracted to the Water Research Centre (WRc) reported that further research was needed on the fate of many widely used chemicals.2The WRc noted the use of zinc chloride - a "grey list" substance - in toilet cleaners and the release of chlorinated organic compounds from the use of 1,4-dichlorobenzene as a toilet deodorant and hypochlorite as a disinfectant.

The WRc also found detectable levels of pharmaceuticals such as aspirin, caffeine, diazepam, methaqualone and methotrexate in sewage effluents. Many pharmaceuticals are not biodegraded during sewage treatment or may produce toxic metabolites, the WRc notes. Synthetic musks, used in soaps and cosmetics, have been found to accumulate in fish and their environmental effects are unknown. The RCEP recommends that these chemicals should be studied further even though their release from domestic sources has not been shown to be environmentally significant.

US studies have shown that paints and solvents form the major hazardous constituents of domestic waste. Again the WRc found little evidence that the disposal of such substances via household sewers is damaging, but remarks that there is a general lack of advice on how to dispose of potentially harmful residues. Better labelling and publicity through DIY outlets would help ensure that waste paint, white spirit, paint stripper or wallpaper paste - which may contain organotin fungicides - is disposed of with minimum risk to the environment.

Domestic sources of metals may comprise as much as 20% of total sewage inputs and may limit the use of sewage sludge in the long term, the WRc notes. Pipework is an obvious source, but many household products contain appreciable loads of metals (see below). Where inputs are significant, changes in product formulations may be needed to protect the environment, the RCEP warns.

Household products containing zinc compounds

Oils, transmission fluids, pesticides, fungicidal ointments, skin creams, antifreeze, toilet cleaners, mouthwash, paints and pigments, talcum powder, foot powder, baby powder, skin creams and make-up, deodorants, suppositories, aftershave, medicines, shampoo, floor cleaners, polishes, face packs.

Pesticides
One of the RCEP's more radical recommendations is for a timetabled reduction in overall pesticide use. This is already in place in Germany, the Netherlands and Scandinavia. The RCEP does not favour a global target, which could be manipulated by reducing heavily used substances rather than those which cause most environmental harm, though perhaps used in small quantities. Instead, it advocates targets for individual compounds, based on their environmental effects.

The report also recommends that pesticide producers improve their effluent treatment standards until only inert products leave their sites. The consequences of inadequate treatment can be severe for sewage works and the environment.

The Government has powers to make regulations on the storage of chemicals and fuels on industrial premises, similar to those already introduced for agricultural stores (ENDS Report 193, pp 35-36). The Government has been promising to draft such regulations for at least the past three years, and the RCEP says it should do so as soon as possible.

Agriculture
The report rejects the idea of taxes on fertilisers and pesticides to reduce excessive usage because demand for both products is relatively insensitive to price. But pollution from farm wastes should be addressed with tougher controls on intensive livestock production, recognising its industrial nature.

The RCEP proposes an authorisation scheme, run by the Agriculture Departments, under which approval would only be granted to farming operations which had sufficient storage and disposal facilities for slurries and yard and parlour washings. Current Government policy is that only installations housing more than 5,000 fattening pigs, 100,000 broilers or more than 100 tonnes of fish per year require assessment under the EC environmental assessment Directive. The RCEP believes these limits are too high and should be reviewed.

The Ministry of Agriculture's statutory code of good agricultural practice for the protection of water (ENDS Report 201, p 31) is too lax on the disposal of pesticide wastes, the Commission says. It does not stress the importance of avoiding water pollution sufficiently and gives confusing advice about the acceptability of soakaways.

Fish farming wastes also provoke comment. Cage farms should not be sited where wastes are likely to accumulate, and water authorities should ensure that river based farms treat their effluent if necessary to protect water quality.

The Commission also recommends that consents for fish farms should cover antibiotics and other compounds routinely released, such as the fungicide malachite green and the dye astaxanthin, whose environmental fates need further research.

Monitoring
Major improvements in monitoring practices will be needed to promote the widespread change in approach to water quality which the RCEP advocates. The standard determinands BOD, ammonia and suspended solids need to be extended to give a more detailed picture of the quality of waters. All types of pollution should be detectable, the report says, and heavy metals, pesticides, microbiology and nutrient levels should be routinely monitored.

A further recommendation is that biological monitoring, already proposed by the NRA (ENDS Report 203, pp 10-12), should be introduced. Unlike the NRA, the Commission believes this should not be combined to produce an overall classification of water quality but kept separate, with figures for biological and chemical quality both being quoted.

The RCEP also recommends a national groundwater monitoring network, to be based on existing boreholes. The network should include a cross-section of polluted and clean aquifers. It should be designed to provide a long-term picture of the state of Britain's groundwaters, particularly with respect to nitrate, pesticides and landfill leachates.

A major theme of the RCEP's recommendations on monitoring is that more information should be provided to the public. In particular, it urges the disclosure of information collected via the UK-wide Harmonised Monitoring Scheme. Few of the results from this have ever been published in 20 years.

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