Aqueous Effluent Discharge into Hay-a-Park SSSI at Breary Flat Lane, Knaresborough (Grid Reference - SE 35978 57978)

James Illingworth made this Environmental Information Regulations request to Yorkshire Water Services Limited
You only have a right in law to access information about the environment from this authority
This request has been closed to new correspondence. Contact us if you think it should be reopened.

The request was successful.

James Illingworth

Dear Yorkshire Water Services Limited,

Freedom of Information Request Concerning Aqueous Effluent Discharge into Hay-a-Park SSSI via pipe at Breary Flat Lane, Knaresborough (Grid Reference - SE 35978 57978)

During the summer of 2019, there were a number of pollution incidents at the Hay-a-Park SSSI arising from the effluent discharge pipe at Breary Flat Lane, Knaresborough (Grid Reference SE 35978 57978). The pollution has been reported and is under investigation by Natural England, the Environment Agency and Yorkshire Water. I would like to request environmental information in respect of effluent discharges into the Hay-a-park SSSI at the aforementioned location. This is an important issue given the proposals for further housing development adjacent to the site and the likelihood of increasing aqueous pollution loads into the Hay-a-Park SSSI. I have listed the information required below.

1. Information regarding consent to discharge permits into the SSSI via the pipe at grid ref. SE 35978 57978. For example, dates of issue, permitted volume and composition etc.
2. Source of discharges – Is the effluent solely surface water drainage or is combined sewer overflow effluent being discharged? Visual evidence suggests raw sewage is being released into the site regularly.
3. Who is responsible for monitoring the effluent and ensuring compliance with discharge consents?
4. Are discharge consent conditions being regularly exceeded?
5. Information from any sampling and analysis regimes. Yorkshire Water were water sampling at the site on or around 30th October 2019.
6. Information regarding the maintenance and monitoring of the SuDS system serving the Hay-a-Park housing development.
7. Has any assessment been made on the current impacts of water pollution at the SSSI and its potential effects on the notable species of the site? If so, what conclusions were reached.
8. Further housing development close to the SSSI will lead to increasing effluent discharge. Has any assessment been carried out regarding the future impacts of increased aqueous effluent inputs on the notable features of the SSSI?
9. Has there been any increase in the capacity of Knaresborough Sewage Treatment Works over the last 20 years to compensate for the increased population of the town or are any future works proposed in this respect?

Yours Sincerely

James Illingworth

EIR Compliance, Yorkshire Water Services Limited

Reference Number: EIR 222

 

Dear James Illingworth,

 

The Yorkshire Water Services Ltd Data Protection Team acknowledges your
request on 9 February 2020 for information regarding Concerning Aqueous
Effluent Discharge into Hay-a-Park SSSI via pipe at Breary Flat Lane,
Knaresborough (Grid Reference - SE 35978 57978).

 

You have made your request for information citing the Freedom of
Information Act 2000.  As a private water utility company Yorkshire Water
is not bound by the terms of this Act.  We will instead respond to your
request in compliance with the Environmental Information Regulations 2004,
which do apply to Yorkshire Water.

 

The Regulations allow us 20 working days to respond to a request from the
date of its receipt.  However, occasionally it is necessary to extend the
20-working-day time limit for issuing a response if the complexity and
volume of the information makes it impractical for us to respond within
the original deadline.  If this is the case we will notify you of this
delay.

 

You will be informed in advance if there is a charge for supplying copies
of the information. We will also provide you with an explanation if we are
unable to disclose and respond to your request.  If the requested
information contains references to any third parties, we may need to
consult with them before deciding whether to release the information.

Should you have any queries regarding your request, please feel free to
contact us quoting reference EIR 222.

 

Yours sincerely,

 

Rebecca Dovener

Data Protection Team

 

Email: [1][email address]

 

 

 

Yorkshire Water customers can get in touch for free via live chat or by
requesting a free call back at [2]https://www.yorkshirewater.com

Save money on your utility bills and help conserve water by requesting a
free water saving pack [3]https://www.yorkshirewater.com/savewater

The information in this e-mail, and any files transmitted with it, is
confidential and may also be legally privileged. The contents are intended
solely for the addressee only and are subject to the legal notice
available at http://www.keldagroup.com/email.htm. This email does not
constitute a binding offer, acceptance, amendment, waiver or other
agreement, or create any obligation whatsoever, unless such intention is
clearly stated in the body of the email. If you are not the intended
recipient, please return the message by replying to it and then delete the
message from your computer. Any disclosure, copying, distribution or
action taken in reliance on its contents is prohibited and may be
unlawful.

Yorkshire Water Services Limited
Registered Office Western House, Halifax Road, Bradford, BD6 2SZ
Registered in England and Wales No 2366682

References

Visible links
1. mailto:[Yorkshire Water request email]
2. https://www.yorkshirewater.com/
3. https://www.yorkshirewater.com/savewater

EIR Compliance, Yorkshire Water Services Limited

Reference Number: EIR 222

 

Dear James Illingworth,

 

I refer to your request for information submitted to Yorkshire Water dated
10 February 2020.

 

Please find attached the data which you have requested.  Included with
this email are the answers to your questions in red.

 

1.             Information regarding consent to discharge permits into the
SSSI via the pipe at grid ref. SE 35978 57978. For example, dates of
issue, permitted volume and composition etc.

The outlet SE35579902 receives Surface Water flows only from the Scriven
area. And as such, does not require an Environmental Permit to discharge.
Environment Agency guidance states that you do not need a permit:

o to discharge uncontaminated water, for example, clean rainwater from
roofs or small areas of hardstanding to surface water
o to discharge uncontaminated water collected from public roads and
small parking areas (that’s been through a maintained oil separator or
sustainable urban drainage system) to surface water

 

2.             Source of discharges – Is the effluent solely surface water
drainage or is combined sewer overflow effluent being discharged? Visual
evidence suggests raw sewage is being released into the site regularly.

o There are no Combined Sewer Overflows mapped as entering this Surface
Water System. The Foul and Surface Water networks are separate in
this area.

 

3.             Who is responsible for monitoring the effluent and ensuring
compliance with discharge consents?

o The system is designed for Surface Water only, there are no foul or
combined sewer assets with environmental permits to discharge feeding
into the Surface Water system discharging at this location, and
therefore no proactive monitoring is in place.

 

4.             Are discharge consent conditions being regularly exceeded?

o There are no foul or combined sewer assets with environmental permits
to discharge feeding into the Surface Water system discharging at
this location

 

5.             Information from any sampling and analysis regimes.
Yorkshire Water were water sampling at the site on or around 30th October
2019.

o Samples obtained on the 30/10/19 taken in response to a reported
pollution showed 0.00mg/l ammonia. There was visibly no impact or any
build-up of sewage fungus around the outfall apron which would
normally indicate a severe misconnection. The event was recorded as
unsubstantiated as at the point of attendance as there was no
evidence of a pollution event occurring. It was noted however, that
there was a high level of algae in standing water suggesting effects
of natural Eutrophication.

 

6.             Information regarding the maintenance and monitoring of the
SuDS system serving the Hay-a-Park housing development.

o We have not adopted any SuDS in the area of the SSSI.  

 

7.             Has any assessment been made on the current impacts of
water pollution at the SSSI and its potential effects on the notable
species of the site? If so, what conclusions were reached.

o Samples obtained on the 30/10/19 taken in response to a reported
pollution showed 0.00mg/l ammonia. There was visibly no impact or any
build-up of sewage fungus around the outfall apron which would
normally indicate a severe misconnection. The event was recorded as
unsubstantiated as at the point of attendance as there was no
evidence of a pollution event occurring. It was noted however, that
there was a high level of algae in standing water suggesting effects
of natural Eutrophication.
o Yorkshire Water would suggest the Environment Agency or Natural
England are best placed to undertake an Ecology Study around the
SSSI.

 

8.             Further housing development close to the SSSI will lead to
increasing effluent discharge. Has any assessment been carried out
regarding the future impacts of increased aqueous effluent inputs on the
notable features of the SSSI?

o Yorkshire Water would not conduct any impact assessments on aqueous
effluent from new developments to the SSSI. This responsibility would
be undertaken by the developer and approved by the local Planning
Authority.

 

9.             Has there been any increase in the capacity of
Knaresborough Sewage Treatment Works over the last 20 years to compensate
for the increased population of the town or are any future works proposed
in this respect?

o The last works upgrade was in 1998 when a tighter Ammonia standard
was introduced.  The works has no capacity issues and our growth
models suggest the site will not require any investment for growth
impacts within the next 5 years (and well beyond).  The current
population at the site is approx. 16000 and our projection to 2025 is
an increase to approximately 16500. The site currently has
significant headroom (>33%) on its flow permit (we assess actual dry
weather flow against the permit) and this will reduce to 30% headroom
by 2025. Site compliance is generally good.  We have an ongoing
programme of base maintenance to ensure assets are refurbished or
replaced as they reach the end of their serviceable lives. 

 

I trust that the provision of this data satisfies your request.  In
accordance with the Environmental Information Regulations 2004, if you are
not satisfied with this reply to your request you can ask for an internal
review.  A request for an internal review must be submitted within 40
working days by contacting the Data Protection Team.

 

Thank you for contacting Yorkshire Water.

 

Yours sincerely,

 

Rebecca Dovener

Data Protection Team

 

Email: [1][email address]

 

Yorkshire Water customers can get in touch for free via live chat or by
requesting a free call back at [2]https://www.yorkshirewater.com

Save money on your utility bills and help conserve water by requesting a
free water saving pack [3]https://www.yorkshirewater.com/savewater

The information in this e-mail, and any files transmitted with it, is
confidential and may also be legally privileged. The contents are intended
solely for the addressee only and are subject to the legal notice
available at http://www.keldagroup.com/email.htm. This email does not
constitute a binding offer, acceptance, amendment, waiver or other
agreement, or create any obligation whatsoever, unless such intention is
clearly stated in the body of the email. If you are not the intended
recipient, please return the message by replying to it and then delete the
message from your computer. Any disclosure, copying, distribution or
action taken in reliance on its contents is prohibited and may be
unlawful.

Yorkshire Water Services Limited
Registered Office Western House, Halifax Road, Bradford, BD6 2SZ
Registered in England and Wales No 2366682

References

Visible links
1. mailto:[Yorkshire Water request email]
2. https://www.yorkshirewater.com/
3. https://www.yorkshirewater.com/savewater

James Illingworth

Dear EIR Compliance,

Thankyou for your recent response to my Freedom of Information request concerning aqueous effluent discharge into the Hay-a-Park SSSI at Knaresborough. I appreciate the time and effort taken to compile the requested information.
However, I have a number of queries regarding the responses to my questions and have set these out below:-

1. In your answer to question 1 you say that 'Environment Agency guidance states that you do not need a permit to discharge uncontaminated water, for example, clean rainwater from roofs or small areas of hardstanding to surface water or to discharge uncontaminated water collected from public roads and small parking areas (that’s been through a maintained oil separator or sustainable urban drainage system) to surface water'.
It seems improbable that effluent that regularly contains high levels of suspended solids including plastic fragments, wet wipes and cotton bud stems can be classified as 'uncontaminated'. In addition the presence of surface foam at the inflow exit suggests frequent contamination with detergent. Can you therefore explain how this effluent can be classified as uncontaminated?

2. The information in answers 5 and 7 states that analysis of samples obtained on 30/10/2019 contained 0.00 mg/l ammonia. This contradicts information provided by Natural England who state that ' Yorkshire Water sampled the inflow on the 30th October and that ammonia was 0.9mg/l and on 11/10/2019 ammonia readings were all between 1 & 2 mg/l '. Can you please confirm which of this information is correct?

3. Answers 5 and 7 state that the high level of algae is indicative of natural eutrophication. Can you explain how this conclusion was reached during a one off visit to the site and how the possibility of nutrient enrichment from the outflow was so readily discounted? On your own website you include a list of 6 factors which are signs of suspected pollution in surface water bodies (https://www.yorkshirewater.com/pollution/). At least 4 of these factors are regularly observed at the inflow (extensive photographic evidence is available) .

4. Is it standard procedure to analyse for ammonia in isolation at pollution investigations? Other parameters such as BOD, COD, nitrate and phosphate would seem appropriate for this site given the severe eutrophication observed throughout the summer months

5. Answer 9 states that the population equivalent of Knaresborough STW is projected to increase from a current figure of 16,000 up to 16,500 by 2025. Can you explain this assessment as the projected figure seems very low considering that in excess of 1000 homes have already been granted planning permission in Knaresborough? With reference to the provision of new homes, the Harrogate District Local Plan Infrastructure Capacity Study (Stage 3 Report – October 2016) stated that ‘some reinforcement to the Knaresborough works may be required, along with sewer upgrades.’

6. Answer 9 states that site compliance for the Knaresborough STW is 'generally good'. This seems to infer that discharge consents are being exceeded at times. Can you please expand on this statement in terms of percentile compliance?

Yours sincerely

James Illingworth

EIR Compliance, Yorkshire Water Services Limited

Reference Number: EIR 222

 

Dear James Illingworth,

 

The Yorkshire Water Services Ltd Data Protection Team acknowledges your
request on 9 March 2020 for an internal review of your case.

 

We will action and respond to your request within 40 working days in
compliance with the Environmental Information Regulations 2004.

 

Should you have any queries regarding your request, please feel free to
contact us quoting reference EIR 222.

 

Yours sincerely,

 

Rebecca Dovener

Data Protection Team

 

Email: [1][email address]

 

Yorkshire Water customers can get in touch for free via live chat or by
requesting a free call back at [2]https://www.yorkshirewater.com

Save money on your utility bills and help conserve water by requesting a
free water saving pack [3]https://www.yorkshirewater.com/savewater

The information in this e-mail, and any files transmitted with it, is
confidential and may also be legally privileged. The contents are intended
solely for the addressee only and are subject to the legal notice
available at http://www.keldagroup.com/email.htm. This email does not
constitute a binding offer, acceptance, amendment, waiver or other
agreement, or create any obligation whatsoever, unless such intention is
clearly stated in the body of the email. If you are not the intended
recipient, please return the message by replying to it and then delete the
message from your computer. Any disclosure, copying, distribution or
action taken in reliance on its contents is prohibited and may be
unlawful.

Yorkshire Water Services Limited
Registered Office Western House, Halifax Road, Bradford, BD6 2SZ
Registered in England and Wales No 2366682

References

Visible links
1. mailto:[Yorkshire Water request email]
2. https://www.yorkshirewater.com/
3. https://www.yorkshirewater.com/savewater

EIR Compliance, Yorkshire Water Services Limited

1 Attachment

Reference Number: EIR 222

 

Dear James Illingworth,

 

I refer to your request for further information submitted to Yorkshire
Water dated 9 March 2020.

 

Please find attached the data which you have requested.  Included with
this email is the answers to your questions in red.

 

1. In your answer to question 1 you say that 'Environment Agency guidance
states that you do not need a permit to discharge uncontaminated water,
for example, clean rainwater from roofs or small areas of hardstanding to
surface water or to discharge uncontaminated water collected from public
roads and small parking areas (that’s been through a maintained oil
separator or sustainable urban drainage system) to surface water'.

It seems improbable that effluent that regularly contains high levels of
suspended solids including plastic fragments, wet wipes and cotton bud
stems  can be classified as 'uncontaminated'. In addition the presence of
surface foam at the inflow exit suggests frequent contamination with
detergent. Can you therefore explain  how this effluent can be classified
as uncontaminated?

 

The data we hold about this location does not indicate sewage pollution.
However, we recognise that you have reported 'un-flushable' items that
have been present which potentially indicates a misconnection and sewer
abuse. Therefore, our Customer Field Service team have commissioned a
misconnection survey to check for misconnected properties. I will provide
the information from that survey to you.

 

2. The information in answers 5 and 7 states that analysis of samples
obtained on 30/10/2019 contained 0.00 mg/l ammonia. This contradicts
information provided by Natural England who state that ' Yorkshire Water
sampled the inflow on the 30th October and that ammonia was 0.9mg/l and on
11/10/2019 ammonia readings were all between 1 & 2 mg/l '. Can you please
confirm which of this information is correct?

 

When YW attended site on 30/10/2019 a sample was taken at the surface
water outfall to the lake that had a 0.0 Ammonia reading. As part of the
investigation YW also checked the surface water pumping station known as
Mint Garth. This surface water pumping station looked clean and a sample
was taken that gave 0.9mg/l ammonia. The readings taken previously on
11/10/2019 that were between 1mg/l and 2mg/l were taken at points on the
lake. YW supplied the environment agency with information on 30/10/2019
stating  “We have sent someone out this morning. They have checked the
outfall again finding no ammonia present in their readings. I asked them
specifically to inspect the recently (3 years ago) adopted surface water
pumping station on Mint Garth to the south of the outfall. The well looked
clean and as you would expect a SW pumping station to -ammonia was
0.9mg/l.” “Previously when we visited on 11/10/2019 ammonia readings were
all between 1 & 2 mg/l” None of the information passed by YW has been
incorrect there has just been confusion around where the readings were
taken. The information supplied to the EA regarding the visit on
11/10/2019 should have perhaps specified the readings were taken on the
lake.

 

3. Answers 5 and 7 state that the high level of algae is indicative of
natural eutrophication. Can you explain how this conclusion was reached
during a one off visit to the site and how the possibility of nutrient
enrichment from the outflow was so readily discounted? On your own website
you include a list of 6 factors which are signs of suspected pollution in
surface water bodies ([1]https://www.yorkshirewater.com/pollution/). At
least 4 of these factors are regularly observed at the inflow (extensive
photographic evidence is available).

 

We recognise that you have reported 'un-flushable' items that have been
present which potentially indicates a misconnection and sewer abuse.
Therefore, we have commissioned a misconnection survey to check for
obvious signs of misconnected properties.

 

4. Is it standard procedure to analyse for ammonia in isolation at
pollution investigations? Other parameters such as BOD, COD, nitrate and
phosphate would seem appropriate for this site given the severe
eutrophication observed throughout the summer months

 

It is standard procedure for Yorkshire Water to gather visual evidence and
instantaneous Total Ammonia samples for Pollution investigation purposes
in line with EA CICS guidance.

 

5. Answer 9 states that the population equivalent of Knaresborough STW is
projected to increase from a current figure of 16,000 up to 16,500 by
2025. Can you explain this assessment as the projected figure seems very
low considering that in excess of 1000 homes have already been granted
planning permission in Knaresborough? With reference to the provision of
new homes, the Harrogate District Local Plan Infrastructure Capacity Study
(Stage 3 Report – October 2016) stated that ‘some reinforcement to the
Knaresborough works may be required, along with sewer upgrades.’

 

In the first instance, for general planning purposes, we use trend based
population forecasts.  Population forecasting is never an exact science
but the data we used is broadly in line with the growth scenarios in the
town.  The Harrogate local plan has just been adopted but given that a
number of the site allocations already have planning permission so were
included in our forecast then our 2025 figure will not be too far away
from the reality.  Housing developments rarely complete their full build
out of properties within a 5 year period so some increase will be
attributable to these beyond 2025.  It is important to consider these
numbers in the context of the spare capacity at the site, which is
sufficient for populations beyond 20,000.

 

The comment ‘reinforcement to the works may be required’ is a fairly
standard comment within Local Plan documents.  Our review has concluded
that the works does not require any capacity upgrade in the foreseeable
future.

 

6. Answer 9 states that site compliance for the Knaresborough STW is
'generally good'.  This seems to infer that discharge consents are being
exceeded at times. Can you please expand on this statement in terms of
percentile compliance?

 

Knaresborough STW is monitored for compliance on Biochemical Oxygen
Demand, solids and ammonia. The 95%ile consent limit, actual 95%ile and
actual maximum values recorded during the period of 1 January 2010 and 8
February 2020 are shown in the table below for all regulatory (Operator
Self-Monitoring) samples. During this period, there was a single ammonia
exceedance, which was taken on 10 July 2019. The cause of this exceedance
was due to a mechanical failure, which impacted biological treatment but
was quickly recovered.  The exceedance was not due to capacity of the
site.

 

[2]A screenshot of a cell phone Description automatically generated

 

The Site also has a total copper limit of 205 ug/l. The site has never had
a copper exceedance and has had a maximum level of 150 ug/l recorded
during the same 2010-2020 period.

 

As part of regulatory standards, the site is also subject to composite
samples being taken on the inlet and outlet. This is taken as part of the
Urban Wastewater Directive and ensures a sample passes either a set limit
(Biochemical Oxygen Demand 25mg/l/ Chemical Oxygen Demand 125mg/l) or
passes a given % removal of (Biochemical Oxygen Demand 70% removal and
Chemical Oxygen Demand 75% removal). There has never been an UWW sample
during this 2010-2020 period that failed to meet the required % removal
standards.

 

I trust that the provision of this data satisfies your request.  In
accordance with the Environmental Information Regulations 2004, if you are
not satisfied with this reply to your request you can ask for an internal
review.  A request for an internal review must be submitted within 40
working days by contacting the Data Protection Team.

 

Thank you for contacting Yorkshire Water.

 

Yours sincerely,

 

Rebecca Dovener

Data Protection Team

 

Email: [3][email address]

 

Yorkshire Water customers can get in touch for free via live chat or by
requesting a free call back at [4]https://www.yorkshirewater.com

Save money on your utility bills and help conserve water by requesting a
free water saving pack [5]https://www.yorkshirewater.com/savewater

The information in this e-mail, and any files transmitted with it, is
confidential and may also be legally privileged. The contents are intended
solely for the addressee only and are subject to the legal notice
available at http://www.keldagroup.com/email.htm. This email does not
constitute a binding offer, acceptance, amendment, waiver or other
agreement, or create any obligation whatsoever, unless such intention is
clearly stated in the body of the email. If you are not the intended
recipient, please return the message by replying to it and then delete the
message from your computer. Any disclosure, copying, distribution or
action taken in reliance on its contents is prohibited and may be
unlawful.

Yorkshire Water Services Limited
Registered Office Western House, Halifax Road, Bradford, BD6 2SZ
Registered in England and Wales No 2366682

References

Visible links
1. https://www.yorkshirewater.com/pollution/
3. mailto:[Yorkshire Water request email]
4. https://www.yorkshirewater.com/
5. https://www.yorkshirewater.com/savewater

James Illingworth

Dear Yorkshire Water Services

Thank you for your latest response (22nd April 2020) to my Freedom of Information Request. I appreciate the time and effort taken to reply, especially in the context of the coronavirus crisis.
I would like to raise a few further points regarding the information provided and I have set these out below:

1. I welcome the fact that Yorkshire Water, Natural England and the Environment Agency have now recognised there is a problem with the water quality in the large lake at the Hay-a-Park SSSI and have proposed action to address the issue. I look forward to seeing the results of the ‘misconnection survey’, but in the absence of evidence of ‘misconnection or sewer abuse’ the fact remains that the effluent entering via the inflow pipe cannot be considered uncontaminated. The discharge regularly contains rotting vegetation, plastic fragments, wet wipes, and tissue paper and I have an extensive library of photographic and video evidence to demonstrate this situation. Surely these contaminants would fall within the definition of ‘polluting matter’ as defined in section 3.5 of the Environmental Permitting Guidance (Water Discharge Activities for the Environmental Permitting (England and Wales) Regulations 2010).

2. I note that your response fails to answer the question as to whether you would regard an effluent containing the substances listed above as uncontaminated. Your website clearly states your commitment to ‘protecting the environment and reducing pollution’ so it seems reasonable to expect some sort of treatment (screening and/or settlement) of the discharge into the Hay-a-Park SSSI regardless of ‘misconnection and/or sewer abuse’. The sensitive nature of the site, along with the current poor water quality, should surely make this a priority if YW is serious about its environmental credentials. A failure to act could presumably lead to the discharge being regulated as a ‘water discharge activity’ by notice served under section 3.9 and 3.10 of the Environmental Permitting Guidance (Water Discharge Activities for the Environmental Permitting (England and Wales) Regulations 2010).

3. With regard to the ammonia readings from the lake water samples, (1-2mg/l on 11/10/2019) I am assuming that they refer to total ammonia (NH4+ and NH3 combined). Do you have any information on the proportion of un-ionised ammonia (NH3) and/or the pH of the lake water from these samples?

Yours sincerely

James Illingworth

EIR Compliance, Yorkshire Water Services Limited

Reference Number: EIR 236

 

 

Dear James Illingworth,

 

The Yorkshire Water Services Ltd Data Protection Team acknowledges your
request on 5 May 2020 for information regarding Hay-a-Park SSSI and the
ammonia readings from the lake.

 

We will respond to your request for information in compliance with the
Environmental Information Regulations 2004.

 

The Regulations allow us 20 working days to respond to a request from the
date of its receipt.  However, occasionally it is necessary to extend the
20-working-day time limit for issuing a response if the complexity and
volume of the information makes it impractical for us to respond within
the original deadline.  If this is the case we will notify you of this
delay. As an organisation, like many others, we are also currently facing
unprecedented challenges as a result of the Coronavirus (COVID-19)
pandemic. Whilst every effort is being made to respond to requests within
the statutory 20-working-day timeframe, it is likely that delays may
occur. We apologise for any inconvenience this causes, but hope you can
appreciate that resources are being diverted to deal with operational
requirements as a first priority.

 

You will be informed in advance if there is a charge for supplying copies
of the information. We will also provide you with an explanation if we are
unable to disclose and respond to your request.  If the requested
information contains references to any third parties, we may need to
consult with them before deciding whether to release the information.

Should you have any queries regarding your request, please feel free to
contact us quoting reference  EIR 236.

 

Yours sincerely,

 

Rebecca Dovener

Data Protection Team

 

Email: [1][email address]

 

 

 

Yorkshire Water customers can get in touch for free via live chat or by
requesting a free call back at [2]https://www.yorkshirewater.com

Save money on your utility bills and help conserve water by requesting a
free water saving pack [3]https://www.yorkshirewater.com/savewater

The information in this e-mail, and any files transmitted with it, is
confidential and may also be legally privileged. The contents are intended
solely for the addressee only and are subject to the legal notice
available at http://www.keldagroup.com/email.htm. This email does not
constitute a binding offer, acceptance, amendment, waiver or other
agreement, or create any obligation whatsoever, unless such intention is
clearly stated in the body of the email. If you are not the intended
recipient, please return the message by replying to it and then delete the
message from your computer. Any disclosure, copying, distribution or
action taken in reliance on its contents is prohibited and may be
unlawful.

Yorkshire Water Services Limited
Registered Office Western House, Halifax Road, Bradford, BD6 2SZ
Registered in England and Wales No 2366682

References

Visible links
1. mailto:[Yorkshire Water request email]
2. https://www.yorkshirewater.com/
3. https://www.yorkshirewater.com/savewater

EIR Compliance, Yorkshire Water Services Limited

Reference Number: EIR 236

 

Dear James Illingworth,

 

I refer to your request for information submitted to Yorkshire Water dated
3 May 2020.

 

Please find attached the data which you have requested.  Included with
this email is the answer to your question in red.

 

1.       I welcome the fact that Yorkshire Water, Natural England and the
Environment Agency have now recognised there is a problem with the water
quality in the large lake at the Hay-a-Park SSSI and have proposed action
to address the issue. I look forward to seeing the results of the
‘misconnection survey’, but in the absence of evidence of ‘misconnection
or sewer abuse’ the fact remains that the effluent entering via the inflow
pipe cannot be considered uncontaminated. The discharge regularly contains
rotting vegetation, plastic fragments, wet wipes, and tissue paper and I
have an extensive library of photographic and video evidence to
demonstrate this situation. Surely these contaminants would fall within
the definition of ‘polluting matter’ as defined in section 3.5 of the
Environmental Permitting Guidance (Water Discharge Activities for the
Environmental Permitting (England and Wales) Regulations 2010).  As per
the previous response YW recognises that you have reported materials that
should not be present in a surface water sewer and YW is investigating the
source of these materials.

 

2.       I note that your response fails to answer the question as to
whether you would regard an effluent containing the substances listed
above as uncontaminated. Your website clearly states your commitment to
‘protecting the environment and reducing pollution’ so it seems reasonable
to expect some sort of treatment (screening and/or settlement) of the
discharge into the Hay-a-Park SSSI regardless of ‘misconnection and/or
sewer abuse’. The sensitive nature of the site, along with the current
poor water quality, should surely make this a priority if YW is serious
about its environmental credentials. A failure to act could presumably
lead to the discharge being regulated as a ‘water discharge activity’ by
notice served under section 3.9 and 3.10 of the Environmental Permitting
Guidance (Water Discharge Activities for the Environmental Permitting
(England and Wales) Regulations 2010). YW takes reports of pollution
seriously and acts to investigate appropriately. The primary focus with
this issue is to locate source so the issue can be addressed with whoever
is found to be responsible.

 

3.       With regard to the ammonia readings from the lake water samples,
(1-2mg/l on 11/10/2019) I am assuming that they refer to total ammonia
(NH4+ and NH3 combined). Do you have any information on the proportion of
un-ionised ammonia (NH3) and/or the pH of the lake water from these
samples? YW ammonia meters only measure total ammonia and no other
parameters. Un-ionised ammonia is not measured directly and would require
separate measurement and calculation using pH and temperature data. YW
believe the ammonia meters in use have a range, resolution and accuracy
appropriate for Yorkshire Water’s analytical purposes in assessing
pollution events, and is compact, portable, waterproof and is appropriate
for non specialists carrying out work in the field.

 

I trust that the provision of this data satisfies your request.  In
accordance with the Environmental Information Regulations 2004, if you are
not satisfied with this reply to your request you can ask for an internal
review.  A request for an internal review must be submitted within 40
working days by contacting the Data Protection Team.

 

Thank you for contacting Yorkshire Water.

 

Yours sincerely,

 

Rebecca Dovener

Data Protection Team

 

Email: [1][email address]

 

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References

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James Illingworth

Dear EIR Compliance

Thankyou for taking the time to respond to my original FOI submission and subsequent requests for clarification. Hopefully some improvements to the water quality at the SSSI can be achieved in the near future.

Yours sincerely,

James Illingworth