The second panel of today’s event is with us now. I am very pleased to have Jo Bradley of Stormwater Shepherds and Catherine Moncrieff from the Chartered Institution of Environmental and Water Management. Jo, if I could start with you, can I ask you to introduce yourself, your organisation and what it is particularly you do that will be of relevance to this one-off inquiry?

My name is Jo Bradley. I work for a small charity called Stormwater Shepherds. I was with the Environment Agency for 28 years before that. My focus at the moment and for the last few years has been pollution from highway run-off. My entire career has been built on pollution control of various sorts and guises.

Good afternoon. My name is Catherine Moncrieff. I work for the Chartered Institution of Water and Environmental Management. I am head of policy and engagement, so I work to connect practice and policy, and to improve decision making on all aspects of water and environmental management.

I thought, Ms Bradley and Ms Moncrieff, I would begin by highlighting a news story that caught my attention recently. You may well be aware of recent reports in the press of chronic contamination of chalk streams by microplastics. Thousands of tonnes of these pollutants are entering our surface waters from tyre wear every year, and now we know that they are in what should be one of our most pristine habitats. In my constituency of North-East Hertfordshire, residents are desperate to see the River Rib, the River Ivel and the River Beane restored to what should be their natural glory. When our predecessor Committee looked at pollution in road run-off during its inquiry on water quality in rivers, the Government and National Highways accepted that more action was needed. That was in 2022. What is your assessment of the action since then? Do you think there have been improvements? Could you detail where those improvements have been and what they might still be lacking?

Since the previous report there has been some action; I can go into what that has been a little bit, but broadly, this issue of highway pollution is still flying under the radar. It has not had the media and political attention that, for example, sewage pollution and other forms of pollution have had. It is still the poorer cousin and we feel that it has not had the political attention, and it certainly does not have the level of funding committed to it, that sewage pollution has, for example. The issues are still very much there and increasing. We have had greater evidence about the issues, as you mentioned, associated with tyre abrasion, brake abrasion and the percentage of microplastics in our oceans and waterways that are derived from tyre wear. I think the science says that it is about 45%. With the onset of EVs, electric vehicles, that type of pollution is not getting any better. They are heavier, so the abrasion is greater. With more braking and heavier vehicles, you have more particles ending up in our waterways. Also, climate change and drier spells, such as we have seen this summer, followed by heavy rainfall mean you get these large flushes of pollution into waterways from roads. The issue is not going away; it is getting worse. I am aware that National Highways has made some progress tackling these issues. I am sure that you will be asking it questions in the next session. I am aware that it is putting a greater proportion of its environmental budget into the issue of water quality. It has set out targets and has been working with CIWEM and other stakeholders on a rapid prioritisation tool to look at how other highway outfalls or high-risk outfalls can be identified.

It is interesting that the sewage pollution has got all the press coverage and everybody wants to talk about sewage. There are, I think, between 15,000 and 18,000 storm sewer overflows, and the water companies have been allowed, or encouraged, to spend £56 billion improving the discharge from those between now and 2050. There are 25,000 outfalls from the strategic road network to watercourses or to ground and the investment in those is in the millions. I would argue that the pollution is as bad, if not worse, because it is toxic pollution, and the discharges are causing harm to the environment. One wonders why one of those topics has got £56 billion and the other one has got meagre millions by comparison.

For the sake of the record of the Committee and for any of our viewers, could you perhaps provide a bit of detail on the impact of sewage pollution as compared to pollution from our roads and what that is doing to our waterways?

It is difficult to know because nobody is measuring harm, but I will come back to that in a minute. Sewage pollution, particularly from a rural community or village, is largely organic. It is organic pollution. It is the things that we flush down the toilet and come out of our kitchen sinks. Highway run-off contains microplastic tyre wear particles, as Cat mentioned, but also hydrocarbons and toxic metals. Together, they create a toxic cocktail that goes into the water environment. Together, those pollutants are known to exert toxic effects. They are mutagenic—they create deformities in the creatures that live in the water, cause abortions, cause birth defects, prevent copulation in some species and cause deformities in fish eyes. They also have a narcotic effect, so the behaviour of the creatures that live in the river is changed; they are a bit spaced out and do not run away from their predators or chase their prey as they should. The behaviour of creatures in the water environment is massively affected by highway run-off. It is a nasty, insidious toxic effect. My work would be easier if it just killed everything, because we would have fixed this 30 years ago, but it has a sub-lethal effect on every part of the lives of those creatures. It affects their heart function, liver function and endocrine function. It has the effect of suppressing the population, preventing the creatures from thriving and reducing reproduction. It is that harm that is caused by highway run-off that we need to take seriously. Sadly, nobody is really measuring the harm. The monitors that the water companies have been told to introduce to measure storm overflows measure how often they go off and how long they go off for. They do not measure what harm that is causing in the water environment. There is a little river—well, quite a big river—near my house called the River Darwen. There is a storm overflow into the River Darwen, which United Utilities has on its list, and it will spend a million and a half quid fixing that so that it reduces the number of discharges. Just a mile upstream, the M6 crosses the same river and all the run-off from the M6 comes into that river with no treatment at all, causing toxic harm and toxic pollution. There is no investment there. There is no plan to invest in that outfall. There is no monitoring of that outfall. There is no measure of the impact of that outfall, so nothing is happening. It makes no sense from an environment protection point of view to not have a full and comprehensive understanding of what is causing harm in our water environment, but simply to spend money on one source of pollution is madness.

My final set of questions picks up specifically what you have just said, Ms Bradley. You have talked about how no one is measuring this properly. As a layperson, is that perhaps because it is a more diffuse problem and harder to track in the way that you can just go to a sewage outflow, or perhaps I am missing something? Who would you recommend should be doing that? Who can we recommend, as this Committee, should be doing that monitoring? Ms Moncrieff, do you have any essential recommendations that you think we should be making so that this pollution does not continue to fly under the radar?

To build on what I said, these outfalls are pipes—I could take you to them and we could stand and poke them. They are not diffuse. It is not diffuse pollution like landfill pollution, which sneaks into the river underground. These are big pipes. There is a photograph, I think, in your pack of one of them. Yes, you could regulate and monitor them. The Environment Agency has a statutory responsibility embedded in the legislation that says that, for all known discharges of priority hazardous substances, it has a duty to monitor, control and, ultimately, eliminate them. It knows that these discharges contain priority hazardous substances—I have told it; other people have told it; research has been telling it so for 30 years, and yet it does not monitor any highway outfalls in England. It has no monitoring points on its monitoring programme that are specifically located to measure pollution from highway run-off. There is a biggish outfall into a little tiny stream in the woods in Chorley in Lancashire. The run-off from the M6 comes out of a pipe into a little stream called Syd Brook. It should be a little babbling watercourse going through the woods with sparkling sunshine and hundreds of insects. It is not. It is just a black swamp. When we last swept it, we found water fleas, bloodworms and nothing else. That discharge is a strict liability criminal offence, no question, because it is breaching the environmental quality standards. The Environment Agency does not monitor it. When I have complained to it, it has done nothing. Its monitoring point is three miles downstream, so it looks at its monitoring data and goes, “We see no signature pollutants from highway run-off, so we have no problem”. Its river basin plan for that catchment does not include that outfall. It is not on its radar. It does not measure it. It is not interested in measuring it, and yet every time it rains—150 times a year in Chorley—it causes gross toxic pollution of that tiny stream. That is a criminal offence, but there is no measuring. Nobody knows, except me and a couple of dog walkers.

Jo has made the point very clearly there that there is not monitoring done by the Environment Agency specifically on highways outfalls. There absolutely should be, because it is one of the biggest, most toxic causes of pollution in this country, and we know that. There needs to be monitoring. At the moment, we do not even know the exact level of harm, as Jo says. We have the Environment Agency water framework directive monitoring points, but they are very sparse. They might be downstream and may not be measuring the right substances, so they are not picking up on this pollution. Monitoring is the first step to solving this problem.

Thank you to both of you for painting such a clear picture about the problem that we are here to talk about. The National Highways water quality plan focuses on sites identified as most high risk for pollution. What you have said already leads me to think that you are not satisfied, but I do not want to put words in your mouth, so are you satisfied that it is able to identify the right sites for priority mitigation? If not, what should it be doing instead?

I am rarely satisfied, sadly. There are 25,000 highway outfalls and soakaways on the strategic road network. National Highways water quality plan, I think, identifies 126 that it is intending to mitigate before 2030. I do not suppose you are surprised that I am not satisfied with that, bearing in mind I think all 25,000 are causing toxic pollution every time it rains. There is a massive gap between what the National Highways water quality plan says and what the water chemistry says. I have only taken 25 samples, but every one of them has failed the environmental quality standards for hydrocarbons. How can you have a risk assessment tool that says twenty-four thousand, nine hundred and whatever of them are fine, and every time I take a sample, and indeed every time National Highways has taken historical samples, they have failed the standard? There is a gaping chasm between those two things. I do not know how we bring that together. I recognise that we do not have a bottomless pit of money to fix all the outfalls. My other concern with the water quality plan is that, if you read the plan, it tells you which outfalls it is planning to remediate over the next so many years in steps. In its annual return for 2024, one of those outfalls was identified as the discharge off the M6 junctions 21a to 26, which was a smart motorway project. It was doing a smart motorway project. I think it was £260 million. On that stretch of motorway it said, “There are 14 outfalls. We are going to introduce some remediation on six of them”. One of them, network 5, discharges into Spittal Brook. Its risk assessment tool said, “This is a risk. We have a risk of pollution. We must remove 91% of the suspended solids in the run-off”. The designers selected a device called the vortex grit separator—it is marvellous, with a British manufacturer, and a lovely thing, but, with the best will in the world and a favourable wind, it removes only about 40% of the suspended solids. Immediately you have a gap between what its risk assessment said and what it is delivering. Then the designers said, “We need one that treats 350 litres per second”, but it bought one that treats 160 litres per second, so there is a gap between what they projected they needed and what they purchased. Actually, it is a 17-hectare catchment of motorway coming to that one pipe, so it should have been treating 1,300 litres per second, but the design guidance has a gap in it. The device they bought was not the right device anyway. It was eight times smaller than it should have been. It also has a capacity to capture 3 cubic metres of sediment, whereas that catchment will produce roughly, using National Highways’ own data, 17 cubic metres of sediment a year, so it would need emptying every eight weeks. Where the water quality plan says, “We will remediate 125 outfalls by 2030; we have done the M6 junction 21 to 26 and cleaned up 1.86 miles of river”, that is not the case. The device is too small, it is the wrong device and it will not be emptied often enough. My concern is not only that the water quality plan is not ambitious enough; my other concern is that, when it has ticked a box at an outfall and said, “We have done this one, tick”, it has not.

Would you recommend that it perhaps revisits its design guidance?

Absolutely, yes. I have told it of some gaps and said, “Fix that, please”, so that is a recommendation.

As Jo alluded to, there are some shortcomings with the risk assessment tool that is being used to identify the high-risk outfalls and set those targets in the water quality plan. Those shortcomings include the fact that it was built a long time ago. Science has moved on and some of the pollutants have changed. We have new emerging pollutants. It also depends on getting good data in. We do not necessarily always have good data. This is just basic things such as understanding where the outfall goes. Does it go to a drain or a sewer? Exactly which water body does it go to? Where does it emerge? As discussed already, we do not have the baseline data on water quality in the receiving water body either. It is a little bit of a case of “rubbish in, rubbish out”. That is slightly my concern with that tool, as well as the fact that it was built a long time ago. It needs a review.

That is really helpful. We recently started the inquiry about PFAS and forever chemicals. In my constituency in south-east Cornwall, the A38 had some work done and we were looking at road run-off. I know this is a concern to constituents. It is really good that the Committee is looking at this topic. You have outlined a bit about percentages and other really important bits, but, to the extent that you would speak about PFAS chemicals particularly, do you have anything that you want to tell the Committee on that front?

I do not have anything specifically on PFAS in relation to highways run-off.

The research that I have looked at suggests that highway run-off is not a major source of PFAS pollution. I do not worry about it too much because, if we deliver treatment schemes that treat the pollutants that we are conscious of, the metals, the hydrocarbons and the suspended solids, we can very easily augment them in the future with treatment systems that will deal with PFAS, if we find that it is a problem.

I do not, I am afraid.

I have spoken to a few colleagues around the world about highway run-off. Frankly, nobody is very good at this. There are parts of America that are better than we are. In Germany, they have some legislation about the treatment of highway run-off from certain roads going to certain receptors. I spoke to a gentleman in Vietnam who said they do not do anything at all. There are parts of the world where they are behind us and other parts of the world where they are ahead of us. The knowledge of harm in the water environment globally is still lacking. Fixing the problem is difficult, because we do not have enough information on the extent of the problem.

There is a little work going on in Sweden where they are talking about this and working together. A lady from Middlesex University is heavily involved in that. There are thousands of global papers researching pollutants in highway run-off. What is missing is effective research into effective treatment.

Absolutely, yes.

It is justified, given the level of harm that highways pollution causes. We know it is one of the major three sources of pollution. The fact that there is not even any monitoring going on within the Environment Agency on this issue is astounding, given that it is thought to cause 18% of failures against water quality. It is absolutely justified.

I agree. I understand that it would be very expensive and the money would have to come from the public purse. The Environment Agency should investigate ways to streamline it through something such as general binding rules or standard permits. In its response to the Committee last time, the Environment Agency said it used a collaborative and partnership approach to managing this problem. It has been doing that for 15 years and we have not moved forward at all, so we must end that voluntary approach and have a more regulatory approach.

I am not sure that is a question we can answer. I would perhaps put that back to the Committee. I don’t know. To me, it is water pollution. Ultimately, we will all pay for it anyway, whether it is through our water bills or our road tax. Somebody has to pay to reduce this water pollution. There are strategies that we described last time, and certainly in the report that CIWEM and we wrote. You could introduce a stormwater utility levy, as they have in Germany, where every household pays a levy associated with the impermeable surface in their home, which goes towards managing stormwater. Parts of America have that too. You could increase road tax and create a ring-fenced fund for dealing with this—perhaps that would not be particularly popular. You could levy on tyres, brake pads or car purchases. This is a massive problem and somebody has to pay to fix it.

I would really hope so. There are some good points made in the Cunliffe review about the need to focus on other forms of pollution and the fact that the water industry carries the heaviest burden in terms of addressing water quality issues. That point is really valid. The Cunliffe review was very focused on the water industry, however. It is proposing a super-regulator, which will be mainly focused on the water sector. My concern is that highway run-off will slip further under the radar because the focus is still on the water sector. Another welcome point made in the Cunliffe review was that we need to focus more on source control. That is really important for this form of pollution. There is a lot that can be done in this space. For example, in terms of tyre wear and the microplastic particles that are coming from tyres, the Euro 7 emission standards have been introduced into Europe this summer and will be in force in 2028. Europe is taking the lead here. We absolutely need to follow suit, but it is not clear at the moment whether the Government are going to do that.

Yes, absolutely. The other thing is managing rainwater where it falls. Before the water gets on to the roads and starts picking up pollution, let us manage rainfall where it falls. Let us spongify and make our urban and rural areas spongy, so that when it rains that water is absorbed, filtered and released slowly, which stops it getting on to the roads and causing problems with not only water pollution, but flooding.

If we miss it, I shall be blaming myself forever. We will lose another 10 years if we miss the opportunity to get highway run-off pollution included in the White Paper that will be prepared in response to the review. We would really like to see recognition of this pollution. Kat just mentioned spongifying cities. We are here to talk about national highways today, but rural roads, such as the cul-de-sac outside my house, can drain into nature-based solutions. They can go into swales, tree pits and rain gardens. The pollution load is low enough that nature-based solutions can cope with road run-off from those types of roads. That links in nicely with some of the recommendations of the Cunliffe review for sustainable drainage systems.

I did, yes—slightly grumpily.

You reflected on the big difference in terms of how much of an issue water company and sewage pollution is in comparison to road run-off. Clearly, one of the differences is that, when it comes to water companies, we have private companies, profit-making organisations, that the Government can go after and say, “Right, you have to sort this out”. Here we have something that is Government’s responsibility, and payment for it will come out of their coffers. Is that the reason why Government have been much more interested in sewage pollution than road run-off? If not, do you have any suggestions why one of these is so much more of an issue politically and in the news cycle than the other?

My instinct is that it has mostly been driven by social media, public noise, press coverage, Feargal Sharkey being interviewed on the radio all the time talking about sewage, the focus on the capitalist nature of water companies and firing people up to have this fury and anger about water companies and how they function. It is quite difficult to get that same attention for highway run-off. It is interesting because the river swimmers drove that interest in sewage pollution. Lots of people went river swimming during covid and said, “This is ridiculous. We are swimming through raw sewage”. I was hopping up and down saying, “You are also swimming through highway run-off, which is carcinogenic. You should get excited about that”. It just does not have the same—I do not know—attraction. It is not as emotive, is it? It is not poo. It does not capture public attention in the same way. The other problem is that it only happens when it is raining. People do not see highway run-off pollution because they are not out with the dog; they are not out for a wander up the riverbank. You have seen the photograph of that highway throwing dirty black run-off into the river, but nobody sees it.

It might also be that, in terms of our perception, when it comes to sewage we imagine water companies using the opportunity of rising water levels to pump sewage. It feels like it is an active process. When it comes to water run-off, it effectively feels like a passive process. It is something that happens accidentally; it is not something that has been deliberately created. That might be a reason why we have had less success getting people to care about this.

You are probably right, but the use of the word “pumped” is completely unfounded. Water companies do not pump sewage effluent into rivers—it is gravity. It is interesting. Sewer overflows function by gravity; highway run-off functions by gravity too. Everybody has wound themselves up and said that water companies are actively pumping out sewage to save money. The storm sewer overflow problem evolved from a failure to regulate. If storm sewer overflow permits had been reviewed every eight years by the Environment Agency, as they should have been, we would never have ended up where we are today. The pollution from highway run-off is equally a failure to regulate. If the Environment Agency had got a grip of this 25 years ago, we would not be here today.

Given that we have to write a report with recommendations to Government, should we recommend that there is greater enforcement of those periodic reviews of permits by the new super-environment agency that is going to emerge after Cunliffe?

They do not have permits. The first step would be for it to apply permits to a proportion of highway outfalls.

They do not even have permits.

There is not a single permit for highway discharge in England—well, I am aware of one, but it is not a National Highways one.

Was it seen as a heavy-handed approach?

Yes. Indeed, I had a conversation recently with the Environment Agency in which I complained about an outfall, and it said, “We do not regulate highway outfalls and we have no intention of changing our position on that”, so I complained to the OEP about it. We will see what happens with the OEP complaint. The EA will not serve notice on these outfalls. It just will not do it.

Before we finish, Ms Bradley, I should say that you quite rightly corrected me with regard to the way that the sewage process happens. I was trying to talk about how people perceived it, but I recognise that we should be careful with what we say. Thank you for that clarification. Jo Bradley and Catherine Moncrieff, thank you very much indeed for the evidence that we have heard today. I am sure the Highways Agency has been listening with great interest. We look forward to hearing its response to you and the first panel. Thank you very much.