ICE submission to Defra consultation on the storm overflows discharge reduction plan

This response has been informed by experts on the ICE’s Water & Sanitation Community Advisory Board.

This submission outlines that:

An ecological standard for coastal and estuarine waters would help to protect these ecosystems and ensure that they can continue to provide environmental and societal benefits in years to come.

The development of an ecology standard for coastal and estuarine overflows should take into account a number of considerations, including:

• the types of pollutants discharged
• habitat management
• the impact of tides and currents on distribution of pollutants
• for any programme of works to account for net zero greenhouse gas emissions

Prevention is better than a cure: it's better to eliminate the root cause of pollutants than to remove pollutants afterwards.

All overflows, including those discharging into coastal and estuarine waters, should be included in the scope of the storm overflows discharge reduction plan.

Firstly, all overflows have the potential to pollute watercourses. It's important to understand the impacts of this pollution on the environment, public health, and the economy, whether positive or negative.

Second, by including all overflows in the scope of the plan, Defra can ensure a more comprehensive and effective approach is taken to reducing discharges.