**London Waterkeeper Trustees' Annual Report 1[st] January – 31[st] December 2024**
Market Workspace, 133a Rye Lane, Peckham London SE15 4BQ Charity number 1165862
## **Names of the charity trustees who manage the charity:**
|1
2
3
4
5|**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|
||Charles Law|Treasurer|Allyear|AGM and Trustees|
||Sarah Saunders|ActingSecretary|To 3/9/24, then Trustee|AGM and Trustees|
||Alex Worth|Secretary|From 3/9/24|AGM and Trustees|
||Kevin Koon|Trustee|From 3/9/24|AGM and Trustees|
## **Name of chief executive:**
Theo Thomas
## **Structure, governance and management**
Constitution
Type of governing document How the charity is constituted[ CIO ]
As set out in the constitution, trustees shall be elected by members at the Trustee selection methods 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.
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## 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.
Aims for the year and activities
## **Sewer overflows** .
The deteriorating state of Thames Water increasingly dominated the context of our work. This is within the weak regulatory framework which has exacerbated the problems in the water sector.
We were determined to continue to push at the lack of accountability and transparency around sewer overflows to rivers. This ranges from permits to investment in infrastructure.
We continued to focus on the solutions needed to reduce pollution to London’s rivers. This is the key part of the debate, not just raising awareness. The reason why sewers in London spill to rivers is because too much of the Capital is paved. With so many impermeable surfaces rain quickly flows down drains and into sewers, overwhelming them. Rather than conventional grey engineering investment (concrete), we need to slow rain down across large areas of the city. This is called green infrastructure. Non-porous surfaces are removed or ‘depaved’ and replaced with vegetated areas. This is accepted as the best option by Government and water companies.
In March 2024 Thames Water’s Storm Overflows Action Plan was published. In common with our approach to other announcements we investigate and challenge them to determine how effective they will be.
## **Stormwater pollution** .
This continues to be an unquantified and unregulated source of pollution. On its own it would see all of London’s river fail water quality standards. In dry weather contaminants build up on roads and paved surfaces. When it rains these are washed into rivers, via surface water pipes. There has been some progress on runoff from roads – the most damaging have been identified. However, rectifying this will be a lengthy process as it is expensive and disruptive. Fundamentally we want to see the Environment Agency using permits to regulate discharges from paved surfaces. Unfortunately, it refuses to do so. We planned to investigate the issue further and start to put into place the evidence needed to initiate legal action.
Achievements and performance
## **Sewer Overflows** .
We highlighted the fact that more than half of the worst sewer overflows have permits that were more than 13 years old. The Government announced that it wanted tougher permits issued to water companies. We asked members of the public to send our request for the Government to strengthen the new permits.
We demonstrated that the overflows that had been hidden from the public are not new infrastructure, or rarely used, but significant assets that were “off the books”. This is further evidence that there is still much information to be uncovered.
Thames Water placed its unmonitored, unpermitted sewer overflows on its sewer map in December 2023. While the monitors were not switched on the greyed-out icons showed their exact location. In March 2024 the grey icons on the Event Duration Map were activated. Another level of accountability was achieved.
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We highlighted Thames Water’s asset health deficit. The lack of investment is estimated by the company as amounting £19bn to rectify. This is in addition to its financial debts of £18bn. In its Business Plan for 2025-30 Thames Water says “We want to break the cycle of sweating assets...the implications of not increasing capital maintenance spend to manage asset health concerns are severe. They include public safety, water quality and compliance with environmental permits”. This aspect of Thames Water’s malaise is under-reported and under-recognised. But it may well see pollution problems worsen over the next 5-10 years, as creaking infrastructure fails faster than it can be replaced. The resulting pollution would be in addition to sewer overflows.
Thames Water published its Storm Overflow Action Plan in March 2024. Unfortunately, just 6% of the solutions will use green infrastructure. None of the most frequent spillers to rivers have green infrastructure proposed as an option.
In the wake of the publication of the Action Plan we established that much of the work that Thames Water needs to undertake to deliver a cost-effective plan was incomplete or contradictory. Our investigations revealed that in most cases Thames Water has not modelled using green infrastructure to reduce sewer overflows and this won’t be completed until 2027.
There is a divergence between public declarations and reality. The great risk is that the company green-lights investment with poor data, resulting in projects that are costly and inadequate.
Manchester Ship Canal vs United Utilities
London Waterkeeper was an intervener in a court case led by the Environmental Law Foundation, backed by Good Law Project and represented by Hausfeld. At a hearing it was demonstrated that sewage pollution was a significant problem for river and marine communities across the country and not just the Manchester Ship canal. The judgment sets a significant precedent that has implications far beyond the Manchester Ship Canal. Polluting water companies could now be open to private legal action, as well as tougher action and fines from regulators.
Via our lawyers, Leigh Day, we wrote to the Secretary of State for the Environment asking when the Government would activate section 83 of the Environment Act 2021, which would: “(i) place a duty on sewerage undertakers to secure a progressive reduction in the adverse impacts of discharges from storm overflows (the “Duty”); and (ii) give the Secretary of State the power to enforce compliance with the Duty.” That provision was not in force. That is despite section 81 of the EA 2021, which inserted section 141DA into the WDA 1991 and placed a duty on sewerage undertakers to publish certain information concerning discharges from storm overflows, coming into force on 17 May 2024. The Government replied “The Secretary of State is continuing to consider an appropriate date on which to commence this provision. As such, the Secretary of State is complying with Parliament’s instructions as set out in s.147(3)(n) of the EA 2021, which allows him to appoint the date on which the provision should come into force by way of regulations.” We will continue to monitor when/if the section is activated.
## **Stormwater pollution** .
While reducing runoff from roads is a long-term challenge, we believe targeting the pollution from industrial estates is a more promising option.
We carried out extensive research into the ownership and operation of industrial estates in London. We held a training event with the Legal Clinic at King’s College London. This was the start of a process to find out how aware the operators of these sites are of the problem.
We established that the Environment Agency’s position is contradictory and undermines their own guidance. This will be at the core of our complaint to the Office of Environmental Protection that the EA is failing in its statutory duty.
## **Rights of Nature Toolkit**
In January 2024, with the Legal Clinic of King’s College London we launched the ‘Rights of Nature Toolkit: How to protect Rivers in England and Wales.” This powerful document brings together all the relevant laws that grassroots groups could use to protect rivers. It also suggests ways they can be more effective campaigners.
The Law Works charity made the student team that worked on it joint award winners, “ _It’s no exaggeration to say the toolkit has taken the environmental law community by storm, with leading_
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_environmental lawyers and NGOs commenting on its usefulness.”_ We carried out two training events using this resource.
## **Other work** .
We welcomed two new Trustees to the Board; Alex Worth who became our Secretary, and Kevin Koon.
In May 2024 the Mayor of London committed to making London's waterways swimmable by 2034 The London Assembly’s Environment Committee scrutinises the Mayor’s plans. It held a series of panels. London Waterkeeper’s CEO gave evidence at the first one, alongside the Environment Agency’s London Area Director.
London Waterkeeper was chosen by Waterscan to be their Charity of the Year for 2025.
In September our CEO attended the global gathering of Waterkeeper groups in Milwaukee, Wisconsin.
## **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. In terms of our work, there is a direct public benefit. For example, we are now focusing on making Thames Water’s investment plans value for money and effective in reducing pollution to London’s rivers.
## **Financial review**
**The charity’s policy on reserves:**
The trustees consider that three months reserves are appropriate and are working to maintain that level of reserves.
**Details of any funds materially in deficit**
None
## **Financial activities for the year ending 31[st] December 2024:**
We were awarded grants from Patagonia, Anne Robbins, Garfield Weston and All Aboard Shops. Individual donations held steady for the year.
## **Funds held as a custodian trustee on behalf of others**
No funds were held as a custodian trustee.
## **Exemptions from disclosure**
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None.
## **Declaration**
**The trustees declare that they have approved the trustees’ report above.**
**Signed on behalf of the charity’s trustees**
|**Signature(s)**
**Full name(s)**
**Position**
**Date**|||
|---|---|---|
||||
||Dee O’Connell|Kevin Koon|
||Chair|Treasurer|
||||
||….. October 2025
30|….. October 2025
30|
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**No 1165862 London Waterkeeper Receipts and payments accounts CC16a For the period** Period start date Period end date **To from 01/01/2024 31/12/2024**
## **Section A Receipts and payments**
**----- Start of picture text -----**
Unrestricted Restricted Endowment
Total funds Last year
funds funds funds
to the nearest
to the nearest £ to the nearest £ to the nearest £ to the nearest £
£
A1 Receipts
- - - - -
Donations 50,255 - - 50,255 27,792
Grant - - - - -
- - - - -
- - - - -
- - - - -
- - - - -
- - - - -
50,255 - - 50,255 27,792
Sub total (Gross income for AR)
A2 Asset and investment sales,
(see table).
- - - - -
- - - - -
Sub total - - - - -
Total receipts 50,255 - - 50,255 27,792
A3 Payments
Salary 37,399 - - 37,399 36,788
NI 5,945 - - 5,945 6,519
Pension 3,158 - - 3,158 3,158
Suppliers 432 - - 432 972
Accommodation 3,600 - - 3,600 4,800
Insurance 157 - 157 155
General Expenses 1,117 - - 1,117 1,300
Mobile Phone 300 - - 300 279
Travel 395 - - 395 1,183
Membership and fees 188 - - 188 80
Postage & Stationary - - - - -
Technology 2,881 - - 2,881 2,718
Interest (19) - - (19) (49)
Charges 60 - - 60 60
VAT (950) - - (950) (1,350)
Sub total 54,662 - - 54,662 56,613
A4 Asset and investment
purchases, (see table)
- - - - -
- - - - -
Sub total - - - - -
Total payments 54,662 - - 54,662 56,613
Net of receipts/(payments) (4,407) - - (4,407) (28,821)
A5 Transfers between funds - - - - -
A6 Cash funds last year end 15,321 - - 15,321 44,142
Cash funds this year end 10,914 - - 10,914 15,321
**----- End of picture text -----**
CCXX R1 accounts (SS)
29/08/2025
1
CCXX R2 accounts ISSI
2910812025
**Section B Statement of assets and liabilities at the end of the period**
|**Categories**
Signed by one or two trustees on behalf
of all the trustees
**B5 Liabilities**
**B4 Assets retained for the**
**charity’s own use**
**B3 Investment assets**
**B2 Other monetary assets**
**B1 Cash funds**|Signature
**Details**
**Details**
**Details**
**Details**
(agree balances with receipts and payments
account(s))
**Details**
**_Total cash funds_**
CAF|**Unrestricted**
**funds**
**Restricted**
**funds**
**to nearest £**
**to nearest £**
**10,914**
**-**
**-**
**-**
**-**
**10,914**
**-**
OK
OK
**Unrestricted**
**funds**
**Restricted**
**funds**
**to nearest £**
**to nearest £**
**-**
**-**
**-**
**-**
**-**
**-**
**-**
**-**
**-**
**-**
**-**
**-**
**Fund to which**
**asset belongs**
**Cost (optional)**
**-**
**-**
**-**
**-**
**-**
**Fund to which**
**asset belongs**
**Cost (optional)**
**-**
**-**
**-**
**-**
**-**
**-**
**-**
**-**
**Fund to which**
**liability relates**
**Amount due**
**(optional)**
**-**
**-**
**-**
**-**
Print Name
K Koon
D O'Connell|**Endowment**
**funds**
**to nearest £**
**-**
**-**
**-**
**-**
OK
**Endowment**
**funds**
**to nearest £**
**-**
**-**
**-**
**-**
**-**
**-**
**Current value**
**(optional)**
**-**
**-**
**-**
**-**
**-**
**Current value**
**(optional)**
**-**
**-**
**-**
**-**
**-**
**-**
**-**
**-**
**When due**
**(optional)**
Date of
approval
30/10/25
30/10/25|
|---|---|---|---|
CCXX R3 accounts (SS)
29/08/2025
3
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 2024
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 {"th8 Trust") for the year ended 3111212024.
Responsibilities and
basls of report
As the charity's trustees, you are responsible for the preparation of the
accounts in accordance with the requirements of the Charities Act 2011
I the Act i.
I report in respect of my examination of the Trust's accounts Garried out
under section 145 of the 2011 Act and in carrying out my examination, I
have followed all the applicable Directions given by the Charity Commission
under seGlion 145151(bl of the Act.
Independent IThe charity's gross incom& exceeded £250,000 and l am qualified to
examiner's statement undertake the examination by being a qualified member of linsert name of
applicable listed bodyll, Delete I l if not 8ppIiG8ble.
I have completed my examinalion l confirm Ihat no material matters have
come to my attention in connection with the examination lolher than that
disclosed below '} which gives me cause to believe that in, any malerial
respect..
the accounting records were not kept in acGordance with section 130
of the Charilies Act., or
the accounts did not acGord with the accounting records., or
the accounts did not comply with the applicable requirements
concerning the form and content of accounts set out in the Charities
(Accounts and Reports) Regulations 2008 olher than any requirement
that the accounts give a 'lrue 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 connedion
with the examinalion to which attention should be drawn in Ihis report in
order lo enable a proper understanding of the accounts to be reached.
Pleasg delete the words in the braGk8ts if they do not apply.
Signed:
Date:
24iogiiois
Name:
AthR11 mo
Relevant professional
qualificationls) or body
ACA, ÉFP
IER
Oct 2018
{if any):
Address:
2 * 42 04L£ CLOSE
HALfot4)r PeTeRS
SL4 b&6
Section B
Disclosure
Only complete if the examiner needs to highlight material tnatlers of concern
(see CC32, Independent examination of charity accounts.. directions and
guidance for examiners).
Glve here brlef details of
any iterns that the
examiner wlshes to
disclose.
IER
Oct 2018