**London Waterkeeper Trustees' Annual Report 1[st] January – 31[st] December 2022**
The Office Club, The Bussey Building, Unit B31
133 Copeland Road, Peckham
London SE15 3SN Charity number 1165862
## **Names of the charity trustees who manage the charity:**
|1
2
3
4|**Trustee name**|**Office (if any)**|**Dates acted if not for whole**
**year **|**Name of person (or body) entitled**
**to appoint trustee (ifany)**|
|---|---|---|---|---|
||Dee O’Connell|Chair|Allyear|AGM and Trustees|
||Chris Jones|Secretary|Until 21/6/22 end of term|AGM and Trustees|
||Sarah Saunders||Allyear|AGM and Trustees|
||Charles Law|Treasurer|Allyear|AGM and Trustees|
## **Name of chief executive:**
Theo Thomas
## **Structure, governance and management**
Type of governing document Constitution
Trustee selection methods[As set out in the constitution, trustees shall be elected by members at the ] AGM. A full term is 5 years. Once a term is complete, the trustee will retire at the AGM and may stand for re-election.
Vacancies so arising may be filled by members at an AGM. The members or the trustees may at any time decide to appoint a new trustee in accordance with the constitution.
## London Waterkeeper’s charitable objects
To promote for the benefit of the public the conservation, protection and improvement of the physical and natural environment, in particular the rivers and other water bodies within the London Watershed.
1
## Aims for the year and activities
**Sewer overflows** . We were determined to increase our ability to scrutinise Thames Water and the regulators. While there had been more awareness of the frequency of sewer spills there was less understanding of how and where improvements would be made. We believe there is a great risk that the ‘solutions’ that the authorities will develop could be too costly and rely on overly conventional engineering.
We had identified the Storm Overflow Assessment Framework as a way for the public to insert themselves into the process. The SOAF was developed by the water industry and Environment Agency to address overflows that discharge too frequently.
To this end we met with King’s College London’s Legal Clinic early in the year. A team of law students worked under the supervision of qualified lawyers to give us an opinion on using the SOAF to register public dissatisfaction with the number of sewer overflows and expose the efforts being made to resolve them (and how appropriate they were). This work was pro bono. This advice gave us an effective way to use the SOAF in our campaign, in conjunction with the Environmental Information Regulations 2004.
This method echoed our ‘Rainy Day’ campaign that had successfully seen Thames Water agree to put its sewer overflow monitors online, in real-time (this commitment was made in late 2021).
We also planned to look in more detail at the permits for sewer overflows. We had found some that dated back more than fifty years. This indicates that the Environment Agency is failing to regulate Thames Water effectively.
In January 2022, thanks to the generosity of funders, we were very happy to welcome Safiya Egeh as our first River Project Co-ordinator. The first part of the year saw training and site visits as part of the induction process. This role allowed the organisation to carry out more research, update our website, and respond to requests for help.
We planned to apply to Patagonia for grant funding, which we did in May 2022. The application was successful. After securing funding from the Network for Social Change in 2021, we were hopeful of being invited to apply again. Our sponsor informed us in the summer that we were able to submit a grant application (which was successful).
We continued to support the work of people that live close to the Wealdstone Brook in north Brent. The Friends of Woodcock Park are a highly effective grassroots campaign group, and we are able to bolster their efforts and increase their expertise when dealing with Thames Water, the Environment Agency and local councils.
**Stormwater pollution** . This is also known as road runoff. During dry periods of weather, pollution from vehicles builds up on roads and other paved surfaces. This is from tyres, brake pads, and engines. When it rains it is washed into drains. In two thirds of London they flow to rivers. This pollution source on its own is a reason why rivers fail water quality standards. The problem is unregulated.
The Government has consulted on this pollution source several times, but no action or policy has been developed.
In other countries permits are issued for drains that discharge runoff to waterbodies. While the Environment Agency has the option to do this under the Environmental Permitting Regulations 2016, no permits have been issued. The reason given for this is that it is too complex. We see this is a failure to use the law to protect the environment. We planned to explore the reasons for the lack of action in this area and create ways to challenge them.
2
## Achievements and performance
**Sewer Overflows** . From sending our ‘Rainy Day’ requests in 2021 it became apparent that not every sewer overflow was fitted with an Event Duration Monitor. When people sent our ‘Rainy Day’ emails Thames Water was legally obliged to tell them if a sewer had discharged to a river. Working with a trustee from the Brent River and Canal Society we were able to expose the fact that there were potentially double the number of sewer outfalls along rivers in the Brent catchment. This also meant that they were unconsented. It is illegal for a sewer overflow to operate without a permit. We were able to establish that some of these outfalls along the Brent were in operation. One example is the overflow that discharges into Brent Lodge Park. This means that the public have no idea they are at risk of coming into contact with sewage.
Channel 4’s documentary programme Dispatches contacted us and we gave the story to them as an exclusive. This was broadcast in August 2022. In the programme it was revealed that several water companies are operating sewers with no permits. In the wake of the broadcast we suspected that the number of Thames Water sewers that had no permit was much higher than they had admitted. They had told us there were 72. We started a campaign that allowed people to send a legal request for the information. Thames Water then admitted to there being 153. Ultimately the pressure led them to inform the Environment Agency that there were in fact 246 unconsented sewer overflows, or almost 40% of the total.
We further researched our plan to use the Storm Overflow Assessment Framework, to follow on from the unconsented sewer campaign. This saw us establish which were the worst performing sewers in London and that also had the greatest impact on the public realm. For example, the Capital’s most frequent spiller discharged into a river flowing through Mayesbrook Park, in Dagenham. We planned to launch the campaign in 2023.
Along with other organisations we were allowed to intervene in the legal action between the Manchester Ship Canal and United Utilities. UU were seeking a ruling that would prevent riparian owners from suing them for sewer overflows. This was pro bono.
**Stormwater pollution** . This issue saw us carry out large amounts of research and site visits. It became apparent early on that very little had been done to tackle the problem. While there had been academic research to determine the effect of the problem this work hadn’t resulted in policy development or enforcement action. In fact, the Defra team responsible for that work had been disbanded some years earlier.
Part of the research required us to gain an in-depth understanding of the surface water drainage networks in London. We focused on a range of locations across the city, and paid Thames Water for Asset Location Searches. These maps show where surface water drains and foul sewers run. In addition, they indicate where the polluted surface water enters rivers. We also researched different technologies that can be used to clean runoff before it reaches a river. The best option is to use natural drainage, or Sustainable Drainage Systems to filter the water of pollution by trapping the sediment. These vegetated areas can break down petrochemical pollutants too. We also looked at the more traditional use of Oil Interceptors. These large chambers are typically installed in car parks or petrol station forecourts to skim off the pollution before it reaches the river. The official guidance states that car parks of more than 50 spaces should have interceptors fitted. However, it was almost impossible to discover if they had been installed, and crucially, if they were maintained (without regular emptying they become a source of pollution).
We wrote legal letters to several suspected polluters to give them the opportunity to demonstrate they were legally compliant. We received a mix of relies from the sector. Some gave an indication that they were preventing pollution from reaching rivers, while others gave inadequate responses. It became clear that the Environment Agency does not check whether these businesses are causing pollution. We continue to develop this work.
**Community Action** . In the spring there was a serious pollution event in the Wealdstone Brook. Local residents were angered by yet another setback. We were able to support them as they pushed for greater investigations by Thames Water and the Environment Agency. Coincidentally the Friends of Woodcock Park had organised a meeting by the river with Thames Water. London Waterkeeper spoke at the event, strengthening the calls for action. London Waterkeeper connected the Friends with an urban creeks biologist from Seattle, Washington. The hope is that the river will be restored to a more natural state in the park.
3
After an approach from Havering Friends of the Earth, London Waterkeeper met with them at Harrow Lodge Park. Here the River Ravensbourne has suffered from pollution over several years. We were able to give FoE training on spotting pollution and how to report it to Thames Water and the Environment Agency. We also contacted Thames Water to check if the main sewer was obstructed – there was evidence that it had overflowed onto the grass in the park.
On World Water Day London Waterkeeper spoke at a conference ‘Reviving UK Waterways’ organised by the Environmental Law Foundation. As part of the EndSewagePollution Coalition, London Waterkeeper attended the Surfers Against Sewage Water Quality day of action in April. London Waterkeeper spoke at two meetings of CIWEM, their urban drainage conference, and to their Northern Ireland association. Talks were also given to the Bertha Foundation, Amersham Women’s Institute, Woodcock Park AGM, CPRE London AGM, Pesticide Action Network London. We were active member of the UnChecked coalition which works to protect the regulations underpinning public health and the environment.
We had online meetings to explore the creation of a Waterkeeper organisation in Dublin, Ireland. London Waterkeeper attended the global gathering of Waterkeeper groups in Washington DC. As part of that trip we visited Philadelphia to see the Sustainable Drainage Systems the city is building. This will see natural drainage used to cut the number of sewer overflows.
## **Public Benefit.**
We can confirm our trustees do have regard to the Charity Commission’s public benefit guidance when exercising any powers or duties to which the guidance is relevant. They are aware of the guidance and have taken it into account when making decisions to which it is relevant.
## **Financial review**
**The charity’s policy on** The trustees consider that three months reserves are appropriate and are **reserves:** working to maintain that level of reserves.
**Details of any funds materially** None **in deficit**
## **Financial activities for the year ending 31[st] December 2022:**
2022 was our most successful year so far in terms of funding. We secured grants from the Network for Social Change and Patagonia. As this was unrestricted funding it was a significant boost to our core functions.
## **Funds held as a custodian trustee on behalf of others**
No funds were held as a custodian trustee.
## **Exemptions from disclosure**
None.
4
##
|$ignature{s}|||
|---|---|---|
|Futrlnarne(s)|Dee O'Connell|CharlesLaw|
|Fosltion|Chair|Treasurer|
|Date|October 2023|ltO
¤4..October2A23|
CHARITY COMMISSION
FOR ENGLAND AND WALES
London Waterkeeper
Receipts and payments accounts
1165862
CC16a
For the period
from
0110112022
3111212022
Section A Receipts and payments
Unrestricted
funds
Restricted
funds
Endowmenl
fund8
Totsi funds
Last year
tothe neirest£
to the nearest É
to th• naawt£
to th• n•4i•¥t£
A1 Re1
tknation8
Grant
59,980
7.559
59,980
7,SSg
33,163
ross Income
or
67,539
67,539
95,153
A2 As8•t and Investm•nt sal¢$,
($90 tablo .
7.539
67,539
A3Pa
ment9
Salary
J5.875
6,J88
2.836
500
3S,675
6,3UB
2,836
000
14,973
1,879
826
P¥n¥ion
A¢¢(Knmod•llon
In$urAnC¢
Con8r81 ExpenBe8
MDbilo Pho
Tf8vel
Membership and fep¥
P0518ge 8 $18lion8ry
Yechno109y
Inloresl
Charg08
VAT
4,704
179
2,880
300
1,509
86
1,1J2
179
272
300
217
17$
2,A40
300
1,509
2,780
2.780
23
93
1,26T
56.641
1,438
93
98
426
21,017
Sub total
56,641
A4 A$set and Inve$lment
urchases,
see table
Sub tot81
66.641
56,611
21,017
Net of receipts/(payments)
AS Transferg belween funds
A6 Cash lunds last year ènd
Cash funds thls year end
10,899
10.899
12,146
33,243
44.142
33,243
44,142
21,097
33,243
CCXX Rl accounts ISSI
1210312023
Section B Statement of assets and liabilities at the end of the period
Unrestrtcted
funds
to tw8re$t£
Restricted
funds
to l)O•Wt E
Endowment
funds
to no#rg¥t E
Categories
Detalls
81 Cash fund$
CAF
44.142
Total cash funds
44.142
(agrar8Ib rec*pi8aDd paymen
acunI(SI1
Unre8trlcted
funds
Restrl¢te(I
fund8
to nearest É
Endowment
fund8
trj noar•Jt r
Details
to nearHtÉ
-- ••##
Fund to whlc
asB•I bolon
Details
Co•t Iop¢ion•ll
Curroni
B3 Investment assets
Fund 10 whl¢h
Is*b•t blllon
Coit loptlon•ll
Curr•nt ¥Jlu•
Detalls
64 A88ets retalned for the
charlty's own uso
Fund to whlch
li•bility rèl*t*8
Amouni du•
Wh•n duo
Details
85 Liabilities
Signed by one or two trusleè$ on bgha
of all the trustees
Date ol
proval
Signature
Print Name
D O'connell
CCXX R2 accounts ISSI
1210312023
CHARITY COMMISSION
FOR ENGLAND AND WALES
Independent examiner's report on the
accounts
Section A
Independent Examiner's Report
Report to the trustees
LONDON WATERKEEPER
On accounts for the year
ended
31 DECEMBER 2022
Charity no
(If any)
1165862
Set out on pages
1&2
I report to the trustees on my examination of the accounts of the above
charity {'the Trust") for the year ended 31112 12022.
Responsibilities and
basis of report
As the charity's trustees, you are responsible for the preparalion of the
accounts in accordance with the requirements of the Charilies Act 2011
{'the Act"}.
I report In respect of my examination of the Trust's accounts carried out
under section 145 oflhe 2011 Act and in ¢arrying out my examination, I
have followed all the applicable Directions given by the Charity Commission
under section 145151(b> of the Act.
Independent tT
examlner's statement
arity,
ake
inc
rnin
ed£
50,0
ualifi
and
am
alifi
ionb
/,°1 /../ /'i.I,./ I I i /'i./,/
me
able.
ins
app
icabl
liste
bod
lellrfn
appli
I have completed my examination. I confirm that no material matters have
come to my attention in connection with the examination {other than that
disclosed below ") which gives me cause to believe that in, any material
respect-
the accounting records were not kept In accordance with section 130
of the Charities Act., or
the accounts did not accord with the accounting records., or
the accounts did not comply with the applicable requirements
conceming the form and cont8nt of accounts set out in the Charities
(Accounts and Reports) Regulations 2008 other than any requirement
that the accounts give a 'true and fair, view which is not a matter
considered as part of an independent examination.
I have no concerns and have come across no other matters in connection
with the examination to which attention should be drawn in this report in
order to enable a proper understanding of the accounts to be reached.
Please delete the words in the brackets if they do not apply.
Signed:
Date:
27 Ioik 12023
Name:
AMRII MOOQ
Relevant professlonal
qualification(s) or body
ACA ,
IER
Oct 2018
Ilf any):
Address:
S 1H£ CHA Jr
UASRI OG£
U83 3RA
Section B
Disclosure
Only cornplete if the examiner needs to highlight material matters of conrn
(see CC32, Independent examination of charity accounts.. dir8Ctions and
guidance for examiners).
Glve here brief details of
any items that the
examiner wlshes to
dlsclose.
IER
Oct 2018