Sewage Disposal in Rivers and Coastal Waters

“the deterioration of our chalk streams through appalling neglect, to the extent that many see streams’ diverse ecosystems under severe threat to their very survival.”—[Official Report, 13/9/21; col. 1193.]

He talked about his work with organisations across the south-east of England, and from Hertfordshire to the north to Kent in the east and Dorset in the west. These organisations represent thousands of people who are all deeply concerned about the threats to our unique chalk streams.

I am lucky enough to live about a mile away from the Hogsmill river, one of those rare and precious chalk streams in south-west London. On 26 May last year, Judge Francis Sheridan fined Thames Water £4 million for what he described as the “utterly disgusting” pollution caused by Thames Water when untreated sewage was discharged into the Hogsmill river and a local park. The discharge occurred because of a night-time power failure at the local sewage works. Over a period of five hours almost 50 alarms went off, which should have immediately led to an engineer being sent to the treatment works to fix the problem—but every one of those alarms went unchecked and ignored. As a result, 79 million litres of sludge escaped, which took 30 people over a month to clean up and caused huge damage to local wildlife and much distress to the local community,

Although the power failure may not have been the water company’s fault, the lack of investment in back-up generation and the company’s failure to respond to the alarms most certainly was. The judge in this case was no stranger to Thames Water’s record of polluting waterways. Earlier in 2021, he fined it £2.3 million for equipment failures at a sewage treatment plant in Oxfordshire in 2016, which killed thousands of fish and other water life. Four years earlier, Thames Water was prosecuted for illegally allowing huge amounts of untreated sewage to enter the Thames in Buckinghamshire and Oxfordshire in 2013 and 2014. Judge Sheridan found that Thames Water had demonstrated

“a continual failure to report incidents”,

which he described as

“a shocking and disgraceful state of affairs”.

Although the judge imposed a record-breaking £20 million fine, this represented just two weeks of Thames Water’s profits at the time.

Of course, Thames Water is not alone in discharging raw sewage into our rivers and coastal waters. Every water company does it, and indeed much of the huge volume of untreated wastewater and raw sewage that they discharge is done so perfectly legally, despite its devastating impact on the environment. As the summer holidays approach and people head to the beach, parents will be horrified to learn of the level of discharges into our coastal waters. Last year, the water companies were collectively responsible for 24,822 spills into the sea over a period of 161,623 hours, including one spill on to Ilfracombe Wildersmouth beach by South West Water that lasted 1,883 hours, and a spill by United Utilities at Morecambe that lasted a breathtaking 5,352 hours.

Of course, many contributing factors and actors have led to this appalling state of affairs in both coastal and inland waters, but the water companies cannot escape their central share of the blame. Their failure to invest sufficiently in reducing these outflows comes at the same time as having paid eye-watering sums in pay and bonuses to their senior executives. Anglian Water, responsible for 21,351 spills lasting a total of 194,594 hours in 2021, provided a total remuneration package to its chief executive of more than £2 million—nearly 100 times the pay of one of its meter technicians. Northumbrian Water, responsible for 220,560 hours of discharges, provided more modest remuneration—a mere £628,000—but this was still more than 20 times the starting salary of one of its wastewater production operators. Severn Trent, responsible for 461,135 hours of discharges, provided remuneration of more than £2.8 million to its CEO—again, more than 100 times the starting salary of one of its water treatment operatives. Southern Water: 160,984 hours of discharges; remuneration to CEO, more than £1 million. South West Water: 351,875 hours of discharges; remuneration to CEO, £863,000. Thames Water: 163,000 hours of discharges; remuneration to CEO, £1.2 million. United Utilities, responsible for 540,000 hours of discharges, including that 5,000-hour spill at Morecambe: remuneration to CEO, £2.9 million—112 times the pay of one of its process operators. Wessex Water: 151,258 hours of discharges; CEO remuneration, £520,000. Finally, Yorkshire Water: 406,000 hours of discharges; total remuneration for the CEO, more than £1.3 million.

In total, water company executives have paid themselves nearly £27 million in bonuses over the past two years, while pumping sewage into waterways 1,000 times a day. The greed is gobsmacking, the multiples of their salary over that of crucial employees shocking, and the disparity between their renumeration and performance regarding our natural environment utterly staggering. By way of comparison, the chief executive of NHS England is paid somewhere in the region of £260,000 to run an organisation with a turnover in excess of £130 billion. The largest of these water companies, by contrast, has a total annual revenue of around £2 billion. This is of course part of a much wider scandal of excessive corporate pay and ever-increasing pay differentials between top executives and the staff they employ. It is particularly jarring that such rewards are being provided at companies that daily pollute our rivers and marine environment.

At the heart of this scandal is not only a failure of leadership in the private sector, but a failure of government. The institutions charged with enforcing environmental protection go underresourced and targets for improvements are unambitious—and all the while developers continue to have a legal right to connect wastewater to the system, regardless of its constraints, instead of the Government imposing tough requirements on sustainable urban drainage. The Government need to get a grip and they should start by showing a red card to water company bosses and adopting Liberal Democrat plans for a sewage bonus ban, which would stop water company executives being paid a penny in bonuses until our waterways are protected from sewage dumps.

The public have had enough of their rivers, lakes and coastal waters being despoiled by a mixture of government inaction, regulatory failure and corporate irresponsibility and greed. It is well past time for the Government and their agencies to act decisively and bring an end to this sewage scandal.

“it is vital that the public can trust regulators to ensure … high levels of water quality in rivers”.

The committee also confirmed that placing a new statutory duty on water companies, to secure a progressive reduction in the adverse impact of discharges from their storm overflows, is a positive step. It recommended that the Government should ensure that the Environment Agency set “specific targets and timetables” for water companies’ statutory drainage and sewage management plans, and also said that Ofwat must prioritise long-term investments, such as storm overflows, in its price review process, especially championing the idea of nature-based solutions—quite right too. The actions of many of our water companies are truly shameful and investment is long overdue, with the fines for illegal sewage discharges often seen as an acceptable cost of doing business, rather than a shameful example of corporate behaviour.

I focus on the fact that it is not just human sewage disposal causing problems. A considerable element of the pollution is caused by agricultural sewage, often from factory farms whose effluent contains antibiotic-resistant bacteria, caused by the overuse of antibiotics in these farms’ intensive livestock rearing. Sewage and wastewater affect 36% of water bodies, and urban diffuse pollution affects 18%. Consequently, our rivers are now failing quality tests due to not just human sewage, but agricultural, or some element of industrial, pollution. We need to address both the human and agricultural sewage discharges. Some 26,000 tonnes of phosphorous ends up in UK waters each year, and the Environment Agency found that agricultural run-off was responsible for 40% of the damage to waterways. So even if we reduced or eliminated all the water companies’ sewage discharges, there would still be a significant problem of pollution in our waterways.

I have three questions for my noble friend. First, will the Government set an overall target for restoration of water quality in our rivers to include both human and other elements of sewage and other pollution? Will the Government accept the need to ban flushable wet wipes, which all the water companies agree are a considerable problem in causing some of these overflows? Finally, will the Government strengthen the proposed target of just a 40% reduction in agricultural pollution of our rivers by 2037?

Let me quote from the Library article. Under “Timebound targets included”, it states:

“By 2050, water companies can only discharge from a storm overflow where they can demonstrate there is ‘no local adverse ecological impact’ … This target must be achieved for most … storm overflows spilling in or close to high priority sites. These sites include sites of special scientific interest, special areas of conservation … eutrophic sensitive areas and chalk streams.”

I ask: why 2050? That is nearly 30 years away. The document continues—I am quoting again from “targets”:

“By 2045, all ecological harmful discharges in or close to high priority sites must be eliminated.”

The Lake District is a very high priority site. Again, I simply cannot understand the delay. Why not speed up the whole process in environmentally sensitive areas such as the national parks?

A cynic would argue that the Government are ducking and weaving over sewage discharge problems because they fear damaging water company profits and, I suppose, ultimately pension funds. How else can they justify the 8,500-hour leak at the Sedbergh plant, the Budds Farm treatment plant leak and the Embleton leak in my former constituency? They are but a few from a long list to which the noble Lord, Lord Oates, very wisely referred in some detail and which are a product of a combination of water company profit protection and slack management, both accidental and on occasions deliberate.

For the purposes of attending Parliament, I live in Maidenhead in a flat on the towpath overlooking the Thames. I am ever conscious of damage to the riverbed arising out of effluent discharge from what I am told are storm overflows upstream. It is not unknown for those who swim in the river to contract respiratory conditions or infections out of—whatever you want to call it; I shall not use the term—effluent contamination.

The Daily Mail’s consumer correspondent, Sean Poulter, recently reported a hitherto little reported incident where Southern Water was fined £90 million for deliberately pouring sewage into the sea off the Kent and Hampshire coast. We also have reports of norovirus contamination of oyster beds, again blamed on sewage pollution. I am told that one company has paid a staggering £290 million in penalties since 2010, but, more worryingly, Southern Water is alleged to have paid £126 million in penalties and payments following a series of failures in treatment operations and, more importantly, for deliberately manipulating performance data. I am told that there is a whole list of companies which have similarly been subject to discharge failure penalties.

The scandal of illegal underreporting by licensed facilities requires scrutiny by government. The Environment Agency is reported to have clear evidence of massive underreporting of outfall failure. In almost every case, someone, somewhere, will have taken a decision to breach licensing approvals, and they will know they are breaking the law. My own view, perhaps a desperate one, is: prosecute the water company executives—they are responsible for these decisions—and threaten them with custodial sentences. They should be prosecuted where it can be shown beyond reasonable doubt that they have authorised illegal sewage discharges and agreed either the falsification of data or a decision to hide adverse data on discharge levels.

Levies or fines on water companies do not work, as they place the burden of penalty for malpractice on the back of both shareholders, who without institutional support are powerless at annual general meetings, and water companies themselves. If you want action and progress, go for the directors. The reporting failures will cease immediately. Deceit will be replaced by proposals for action. The threat of prosecution will concentrate minds. It will lead to a new emphasis on transparency, greater accountability and a far more informed public debate on the way forward.

That EU law is the snappily named urban wastewater treatment directive. In fact, this was passed more than 30 years ago, in 1991, and came into force, after the usual grace period for member states to comply, in 1998 for larger towns and cities and in 2005 for everywhere. So for nearly 20 years, it has been illegal to discharge raw sewage anywhere, including in the UK—as far as I know, this is either still retained EU law, subject to correction, or is being spilled over to the Environment Act. This directive marked a shift from legislation aimed at end-use standards—testing pollution levels in a river, for instance—to a stricter law regulating water quality at the source, whether domestic or industrial.

I admit that my knowledge of this subject acquired as a constituency MEP has not kept up with the times. My specialisation has always been in justice, home affairs, human rights, and equalities, so I am not knowledgeable about environmental and pollution matters, and my knowledge runs out in about 2012, the date of the judgment by the ECJ. I know that the European Commission has run a consultation on a review, and I think it will respond to the consultation later this year. However, both then and now, domestic regulators have been asleep on the job. I saw recently that Ofwat described the current situation of polluted rivers and seas as “shocking” a few weeks ago. Where on earth has it been for decades? I also know that the Environment Agency funding has fallen 70% in real terms in a decade, so enforcement is much undermined. In that case, the only real enforcement has been by the European Commission, which I will quote shortly.

As we know, the combined system of rainwater and sewage was state of the art—beginning with Bazalgette in the mid-19th century. Of course, this means that if both rainwater and sewage flows increase, so does the combined flow into the sewers. However, we need to keep up with that; we cannot have a static approach and say, “Well, it was okay 50 years ago, so we won’t provide any more investment or make any more changes.”

I wanted to speak today mainly to warn against the term “storm overflows”. The Government and water companies love us to use this expression, because it suggests that discharges are somehow exceptional—only when there is a kind of storm which produces the type of flooding that we have seen in the last few years in Shropshire, Worcestershire, Yorkshire and Lancashire. They want us to have that image in our minds, so that we say, “Oh well, how can they be expected to plan and invest for that sort of exceptional event?” I was tipped off about this by a staff member—who shall for ever remain anonymous—in one of the regulators.

That brings me to the 2012 judgment of the European Court of Justice. I was amused to note that the representation of the United Kingdom Government was led by one “D Anderson QC”—and I hope that he does not mind, in his absence, if I say that I assume that this QC was the noble Lord, Lord Anderson of Ipswich. Of course, I am not reproaching him for acting for the UK Government; he would have been acting on the cab rank principle, in the same way that the noble Lord, Lord Pannick, is acting for the Government on the Rwanda scheme.

This case was finally brought by the European Commission after years of argy-bargy with the UK Government. The Commission said that, under the directive, member states

“are obliged to ensure that a collecting system is designed and built so as to collect all the urban waste water generated”

by the town it serves. It continues:

“The capacity of the collecting system must therefore be able to take into account natural climatic conditions (dry weather, wet weather, even stormy weather) as well as seasonal variations … The directive must be interpreted as providing for an absolute obligation to avoid spills from storm water overflows save for exceptional circumstances.”

That is what water companies tell us all the time: “Oh, it’s exceptional.” Clearly, however, with climate change what was once exceptional is now routine. In this case, the Commission pointed out that

“the more an overflow spills, particularly during periods when there is only moderate rainfall, the more likely it is that the overflow’s operation is not in compliance”

with the directive under EU law. This is what that staff member in the regulator said to me: “Don’t be misled by the term ‘storm overflows’.” This is happening once a week into the Thames, purely when there is “moderate rainfall”. The staff member told me not to be fobbed off, and I suggest to noble colleagues that we continue not to be fobbed off.

The Commission continued by saying that the directive required

“waste water treatment plants … designed, constructed, operated and maintained to ensure sufficient performance under all normal local climatic conditions.”

That is the warning that I want to repeat today. The Commission went on to say that

“failure to treat urban waste water cannot be accepted under usual climatic and seasonal conditions, as otherwise Directive 91/271 would be rendered meaningless.”

This is the point: water companies come along and say, “Oh, it is all exceptional, so we cannot possibly be expected to invest in this.” But they are failing to invest for normal climatic conditions.

The court found against the UK, because it said that it is not exceptional that these discharges are happening. It also went on to say

“in accordance with settled case-law, a Member State may not plead practical or administrative difficulties in order to justify non-compliance … The same holds true of financial difficulties”.

So the Government and the water companies cannot say that there is a disproportionate cost; they have undertaken to stop these discharges and so they must. Indeed, in its judgment, the court found that there were

“60 waste water discharges from”—

it did not use the term “so-called” here, but I will add it—

“storm water overflows in London per year, even in periods of moderate rainfall”.

That is the situation we are facing.

Against the background of that 2012 judgment, I admit that I do not understand the system of permits for the discharge of raw, untreated sewage—this is my ignorance. Why are water companies being given permission to make these discharges? I do not see how this is legal under the directive I have mentioned, since this normalises the routine absence of treatment in unexceptional weather conditions.

I end by thanking my noble friend Lord Oates again for this debate, which has allowed me to go down memory lane. If I have achieved one thing, I hope it has been to put noble Lords on guard about the phrase “storm overflows”.

I am not going to get into the politics of the privatisation of water companies but it is deeply worrying that it looks as if our companies are not taking this with sufficient seriousness. Nine water companies recorded £2.8 billion in profits despite over 400,000 dumps of sewage in 2020. How can that be acceptable? There is a fundamental question of time, of course. We have to give them a period to get it sorted out. But unless we have really ambitious targets, nobody is going to move. It is quite clear from what has been happening that lack of enforcement and lack of targets are allowing our water companies to continue doing what they are doing.

We are talking not just about our chalk streams. I think somebody referred earlier to the Lake District and Lake Windermere, where last year there were reports of increasing algae feeding on the phosphates coming out of the local sewage treatment plant and so on. And it is not just sewage run-off. It is also to do with toxic loads of plastic tyres, heavy metals and silt. We had Questions earlier today about household waste being dumped and so on. Indeed, other problems have been referred to of chemicals coming from medicines and other treatments given to animals which are now affecting the health of organisms and ecosystems in our streams and rivers.

Part of the concern is with the farming industry. As someone who is particularly involved in that, I am aware that it is a problem. The noble Lord, Lord Benyon, who will respond to this debate, knows that there are some quick win-wins here with all the latest best practice in farming. I am proud to say much of it happens in Hertfordshire: I go and visit some of our farmers. We are now using computer systems. We are having precision drilling, which cuts down on the amount of grain you need hugely but also precision use of nitrates and fertilisers can really decrease amounts. This is a win-win when the costs are going up. One of the questions I want to ask the Minister is: what discussions are taking place with the NFU to try to roll out best practice which will both help the industry and make a tangible and significant improvement to this problem?

I also agree with the noble Lord, Lord Campbell-Savours, who pointed out compellingly that fines are not the answer—although I hope they will go on being imposed. It sounds to me as if they are simply being factored into the accounts because it is cheaper to pay fines than to do the fundamental work. For goodness’ sake, we now have to have an incentive which means that the money going into this has to be put into the long-term solutions. It must come back to a radical look at the bonuses paid to executives. I am not sufficiently close to the industry to know whether it is feasible to prosecute them. I certainly think that, if there are no bonuses paid until there are dramatic improvements each year, that will wake up a number of people in the industry.

Our river systems face an ecological crisis from multiple angles, all of which need to be tackled. Preventing sewage run-off is key to ensuring the safety of rivers such as the River Ver in St Albans, and my hope is that as we address that our biodiversity will be maintained—indeed, increased—and returned to what it was in the past and that we can really see a more confident future for our waterways in this country.

To dump sewage into water is a complete waste of an asset. Sewage is an asset; it contains phosphate, nitrates and organic matter. As we know, phosphate is a mined commodity and most of its deposits are in Russia, so it will be even more scarce. Sewage is a resource that should be utilised and put back on the land. There should be absolutely no need for any sewage to be discharged into waters in future.

The future is the key question. It cannot be done immediately; it is horrendously expensive. We discussed this during the Environment Bill and got quotes of hundreds of billions of pounds under one option and under £100 billion in another. A step change in the programme needs to be made to improve the situation. I once again have to thank our Victorian engineers for providing a sewerage system that still works, partly, in the 21st century. The way they did it is remarkable and we owe them a debt of gratitude.

The Motion refers only to sewage disposal, but there is a much wider issue: the whole issue of water needs to be looked at in context. I therefore turn to farmers. There is a big opportunity under the new environmental land management schemes to get farmers to work in clusters to improve a whole river system. Along with some other Peers, I was fortunate to have a briefing from the Minister yesterday on what will happen with ELMS. He gave the example of the Ridgeway, a walkway crossing lots of local authority areas. I suggest that, equally, there should be clusters of farmers not only in the catchment area but working together along the whole river. Unless farmers work together, we will not get the changes we want.

I also ask my noble friend about the role of the Environment Agency. I was very impressed yesterday when a lot of emphasis was given by the Minister and his officials to the necessity for Defra to work with farmers and gain their trust. Can the same be said of the Environment Agency? I have not found many farmers who trust it, yet they are an integral part of how we will manage wastewater. What was the role of the Environment Agency in the construction of the chicken farms along the Wye, where there has been so much pollution? Was it involved in that? Did it give an opinion on what the effect of the discharge of all this poultry manure would be? If it was not involved, ought we not tackle the planning system to make certain that it is?

This needs to be tackled holistically. It is no good just blaming water companies; it must be tackled at source by independent regulators such as the Environment Agency and farmers need to be more responsible. As your Lordships know, I am a great supporter of what farmers do. They will produce good food in the best way they can, but they have been directed by politicians to farm in a certain way. At long last, we might be getting into a much better system of farming for the future. There is hardly a farmer I know who does not want to work more closely with nature than they have been able to in the past months. Can my noble friend tell me about that and the Environment Agency? Will he instruct it to work as closely with farmers as Defra is, to try to gain some trust from them?

Another group of people who need educating and admonishing is us. We are the polluters—the people who, as my noble friend Lady Altmann said, put wet wipes in lavatories and throw things away that we should not—who help block up the water companies’ pipes, which causes some of the discharges. We waste far too much water. There needs to be a big education programme for us as individuals to realise what damage we are doing, because a lot of us are totally unaware of it.

I move to the question raised earlier of developers having the right to connect to existing sewerage systems—I am sure my noble friend Lady McIntosh will pick up on this, as we were on the same side on this during the Environment Bill. If the existing sewerage system is overloaded and there is a demand for new houses, with planning permission granted, we will get storm overflow systems. We have a real problem. If we do not discharge it into rivers or the sea, what will we do with it until we get a better system? The answer is that it will be put on to our streets and cause far worse pollution. We need to look at this much more holistically and stop the problem in all areas as well as giving the water companies the incentive and drive to produce answers at their end on a much quicker timetable.

My final point, looking at this holistically, is on our aquifers. Much of the problem we have in our rivers is due to them being so low, particularly our chalk streams. This is because the aquifers are being depleted. Until we can start refurbishing our aquifers to get them back to where they should be, we will always have a problem in our rivers. With less flow, you have more sedimentation and get smaller fish, less biodiversity in the river and more stormwater problems. One of the effects of climate change is that we will have many more localised storms: one area of the river might be perfectly fine, but if the river is at a low level, if you get a massive storm in another area, downstream you will have a stormwater problem.

We need to get our river flows up; that will be a huge task for my noble friend but I hope that, as part of the environment plan, the Government will look at this and take action so that we take less out of the aquifers and more out of the river as it gets towards the sea. In that way, we will benefit nature and the environment throughout the river and stop some of this quite unnecessary disposal of sewage into the water and seas.

Since 1989, water bills have increased by 40% above the rate of inflation. People have to pay them because there is no alternative. You cannot switch to an alternative supplier of these services, and the regulators simply wring their hands—they are very ineffective. As Michael Gove reminded us, since privatisation there has been no investment in new nationally significant supply infrastructure, such as major reservoirs. That is how bad privatisation has been. London and big cities now face a threat to their drinking water supply, as has been documented in the newspapers this week. Around 3 billion litres are lost every day due to leaks, which is further evidence that the companies are out of control and do not take their public duties very seriously.

Last year, water companies discharged raw sewage into English rivers 372,533 times, while the water companies covering England released untreated sewage for a combined total of 2.7 million hours. The Government’s storm overflows discharge reduction plan will seek to eliminate 40% of raw sewage overflows into rivers by 2040—that is not good enough. It is complacent and will wilfully inflict health hazards on people. In January 2022, the House of Commons Environmental Audit Committee Report said that,

“A ‘chemical cocktail’ of sewage, agricultural waste, and plastic is polluting the waters of many of the country’s rivers. Water companies appear to be dumping untreated or partially treated sewage in rivers on a regular basis, often breaching the terms of permits that on paper only allow them to do this in exceptional circumstances.”

Water companies, regulators and Ministers have defended the practice of allowing leaks into rivers and seas by claiming that it is better to allow the sewage to leak into waterways because otherwise it would back up into streets and homes. This is an indictment of the lack of investment and the way in which the Government and regulators indulge the water companies. Water companies have pocketed billions of pounds from sewage charges levied on customers but have not delivered the required service. This is organised fraud on a gigantic scale for which no corporate executive is called to account. The discharges kill fish and threaten biodiversity and marine life. The pollution may eventually find its way into the food chain—polio has already returned to the UK.

There are widespread illegal sewage discharges from treatment plants. On 12 May 2022, the Environment Agency said that

“Our initial analysis of the information collected to date has confirmed that there may have been widespread and serious non-compliance with the relevant regulations.”

Still, no executive is prosecuted, and there is no clawback of any executive bonus or pay. The Government continue to be complacent. Water companies face no action. There is a lack of any pressure points. Even when companies admit that they have not complied with the rules and regulations, they are still permitted to extract monopoly rents because people have nowhere else to go—they have to pay. We have no alternative infrastructure anywhere. The fines levied are puny and, so far, they have failed to bring about a desirable positive change. In a monopoly, they are simply passed on to the customers and that is why we end up paying higher and higher charges.

Profits form a key part of the executive key performance indicators in companies, and executive pay is linked to these indicators, which include profits. It is very easy for water companies to increase their profits by letting the leaks continue, which means they spend less on repair and maintenance, or by dumping raw sewage into rivers—that increases profits too. The Government continue to tell us that water companies are making huge profits, but they are doing so because they are not carrying out their obligations. Looking at profits alone does not tell us anything about the quality of their performance.

Last year, nine water industry CEOs received more than £15 million in pay and bonuses—bonuses for what? Polluting rivers? In the past, Ministers have said that shareholders can constrain these things. Well, their shareholders are abroad; are they really bothered about what goes on in this country? Many are just subsidiaries and affiliates of giant investment funds and other corporations; they have no incentive whatever to reduce these bonuses. So, the executives get fat cat pay while the public get health hazards, leaks and higher bills.

The Government can create pressure points to force companies to deliver, and I invite the Minister to consider at least the following five modest reforms. First, the directors of companies engaging in unlawful practices need to be made personally liable for the consequences. The spectre of personal liability should check predatory practices. At the very least, their bonuses and salaries should be clawed back because they have obtained them in fraudulent way.

Secondly, no dividends should be paid until the regulator certifies that water companies have met their statutory and regulatory duties.

Thirdly, customers should have direct representation on water company boards and a statutory right to vote on executive pay. With such arrangements, it is extremely unlikely that customers facing escalating charges, leaking pipes and polluted rivers would vote for a bonus or even a salary increase for any executive. Governments often talk about democracy in society. This is democratising these monopolies. Let them face the democracy of the customers.

Fourthly, the regulator itself should have direct representation of customers on its board. I am not talking about some toothless customer panels, but people actually sitting on the board and questioning the executives of the regulatory bodies about their failure to act.

Fifthly, the general public should be permitted to take legal action against negligent companies. After all, these companies are wilfully neglecting their public duty. Therefore, the public should have a right to take legal action against these companies and the regulators.

These are just some proposals for starters. As we are getting a new occupant at No. 10, maybe they will resonate with the new leader of the Conservative Party.