Page 5 - Surface Water Management Guidance - 2023

2. Why Water Pollution Prevention Matters 2.1 Fines and Criminal Sanctions
In addition to the courts ability to hand out large fines for water pollution (UK record to date £20mil-
lion fine handed out to Thames Water for sewage pollution), the environmental regulator has the
A company who fails to plan for the presence of excess surface water and/or groundwater that it ability to impose a range of other penalties. For example:
needs to discharge, can suffer harm to their business via a variety of mechanisms. For instance:
Enforcement Undertaking:
• Project Risks and Programme Delays As an alternative to court action, the Regulator
• Fines and Criminal Sanctions agrees a payment with the offender to cover
• Brand Damage the cost of the damages to the environment;
and provide recompense to the people or
A successful company manages their operations to ensure that the risks associated with water organisation which have been affected by
pollution are minimised, allowing the them to operate in a cost-effective way, be successful and their actions.
profitable.
In the case of the Aberdeen Western Periphery
2.1 Project Risks and Programme Delays Route, the financial value of the silt pollution
Failure to plan in advance for the disposal of a site’s excess surface water can cause project costs caused was valued at £280,850.
overruns and program delays.

Stop Notices:
Programme Delays: Where the Regulator is of the opinion that site
The discharge of excess water into the environment requires a consent to be in place before the activities may pose a significant risk to the
discharge can commence. Obtaining the consents take time. For example: environment, they may issue a Stop Notice,
prohibiting works from proceeding.
Where the discharge is made into Controlled Waters (Groundwater or Surface) the Environmental
Regulator (EA, NRW, SEPA) may require an Environmental Permit (Construction Licence in Scotland)
to be in place. The process of agreeing the permit may take 6 months or more to obtain. As part of the Stop Notice, conditions relating
to the protection of the environment may be
Cost Overruns: included. The notice will remain in place until
In respect of the costs of treating excess site water, the main drivers are: such time as the stipulated measures have
been complied with.
• Volume and rate that the water is to be treated (size of treatment system)
• The location into which the water will be discharged 2.3 Brand Damage
• Treatment standard that needs to be achieved (How clean does the water need to be) In the past 12 months, mass public protects such as the campaign for Climate change and the
• Chosen method of treatment public outcry against plastic in our oceans has taken public awareness of the need to protect the
environment to new heights.
Obviously costs of water treatment increases
with volume and flow rate; but they are also Peak Flow Estimation The public have come to realise that social media campaigns, setting up site watch groups and
related to the location of the discharge. (CIRIA Method) the submission of letters of objection at the planning stage, is an effective way of ensuring that a

Peak Flow: 471 m /hr company minimises the environmental impacts of its activities; especially when they draw attention
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Where water is discharged to surface water or to a company’s previous performance.
groundwater, a high standard of treatment is Site Area: 26 Ha
required, so the cost will be greater.
Annual Average Rainfall: 600 to

For water that is discharged to a foul sewer, 800mm/year
whilst a lower treatment standard may be Storm Return Period: 1 10 Years
applied, the unit cost (per m3) for water
discharge will be greater than that for release to Soil Class: fine sands, silts and clays.
Permeable soils with shallow
the environment; frequently making discharge groundwater in low lying areas
to sewer a more expensive option.