River Thames Evidence & Representation Programme

1 Overview — the case in brief

This programme brings together, in one place, the evidence and the actions needed to hold decision-makers to a proper, evidence-based standard for the River Thames between Teddington and Richmond. It exists to do two things, in order: prove what we are saying with official, sourced data, and then secure agreement on the asks — the specific things that need doing, and by whom.

What the evidence shows

The stretch of river in question spans two officially classified water bodies. The non-tidal reach at Kingston (Thames, Egham to Teddington) holds an ecological status: Poor classification; the tidal reach through Ham, Richmond and Isleworth (Thames Middle / Upper, a transitional water body) is Moderate. Both fail chemical status. The single largest local pressure is sewage: Mogden Sewage Treatment Works at Isleworth — the second-largest works in the country, serving ~2 million people — discharges continuous treated effluent plus storm sewage into the tidal Thames just downstream of Richmond, and London's new "super sewer" (the Thames Tideway Tunnel) does not serve this reach — it begins downstream at Acton.

Against that backdrop, Thames Water is proposing the Teddington Direct River Abstraction (TDRA) scheme — taking up to 75 million litres a day out of the river above Teddington Weir during droughts and replacing it with tertiary-treated effluent from Mogden, discharged into the same reach now designated for public swimming. The company itself is rated the worst environmental performer of the nine water companies, is carrying roughly £20 billion of debt, and has been penalised for paying executive bonuses and unjustified dividends while its pollution record deteriorated.

What we are asking for (the asks — to be refined with partners)

• Full disclosure of the evidence base — raw survey data, methods and known gaps — from the Environment Agency (via the live EIR request) and coordination with ZSL's State of the Thames programme, so decisions rest on data, not summaries.
• Honest public information at the bathing site — clear signage and QR codes on water quality, storm-overflow status and safety, so "designated bathing water" is not mistaken for "always safe."
• A precautionary, independently reviewed decision on TDRA — no discharge of recycled effluent into a designated bathing and ecologically sensitive reach without robust, independent scientific scrutiny.
• Accountability for Thames Water — investment in storm capacity to a standard at least matching the updated EU requirements, not fines treated as a cost of doing business, and no rewards for executives while performance fails.
• Public awareness — get the petitions that can actually change things in front of the people who use the river, so they reach the thresholds for a government response and a parliamentary debate.

Each ask is backed by the evidence in sections 3–5, the data-ownership map in section 5, and the live actions in sections 7–9.

2 Programme of work

The work is organised into seven workstreams. Each has an objective, the bodies that own or influence it, a status, and the immediate next action. Together they run in parallel; the correspondence tracker (section 7) records live cases against them.

3 The evidence — proving what we are saying

This section is the substantive evidence base, organised by theme. Everything here is drawn from official or peer-reviewed sources listed in section 11. Where a figure still needs confirming against primary data, it is flagged verify.

3.1 · The bathing-water designation

On 15 May 2026 the Thames at Ham and Kingston — sampling point on Lower Ham Road, Kingston — became London's first designated river bathing water, following an application by the Ham & Kingston Bathers and a Defra consultation that drew roughly 500 responses in support to 2 against. (It was proposed in February 2026; the widely repeated "designated in February" is incorrect — the legal designation took effect on 15 May.) Designation obliges the Environment Agency to sample through the season (15 May–30 September) for E. coli and intestinal enterococci and to classify the site.

3.2 · Official water-quality status (Water Framework Directive)

The reach spans two classified water bodies. Teddington Lock is the tidal limit, so the classifications — and the assessment methods — change here.

3.3 · Sewage and storm overflows — Mogden

Mogden Sewage Treatment Works (Isleworth) is the second-largest in the UK, serving a population equivalent of ~1.9–2.1 million. It discharges continuous treated effluent plus intermittent storm sewage into the tidal Thames just downstream of Richmond. Storm-spill duration has risen despite a 2011–13 extension that added ~50% process capacity:

Volumes in extreme events are very large: on 3–4 October 2020, Mogden released more than two billion litres over roughly 48 hours, prompting an Environment Agency investigation; the then-CEO conceded the eight storm tanks were "unable to cope." Crucially, the Thames Tideway Tunnel ("super sewer," fully operational February 2025) runs from Acton to Abbey Mills — it protects central and east London and does nothing for the Teddington–Richmond reach. Mogden is not connected to it.

3.4 · The Teddington Direct River Abstraction (TDRA) scheme

Thames Water proposes, for drought resilience, to abstract up to 75 million litres/day from the Thames about 350 m above Teddington Weir, and to offset that by discharging tertiary-treated final effluent from Mogden — piped ~4.5 km — into the river about 180 m above the weir. It is a Nationally Significant Infrastructure Project; a Development Consent Order application is expected in early 2027 (slipped from 2026), and Ofwat's RAPID process allowed £22.6m of development funding in July 2025 while keeping a Beckton alternative in reserve.

3.5 · The ecology — ZSL's State of the Thames

ZSL (Zoological Society of London) published the first State of the Thames in 2021 and an updated edition on 19 January 2026 (21 indicators, data to end-2024). The tidal Thames is a genuine recovery story — dissolved oxygen, phosphorus and toxic metals have improved, waders and grey seals are up — but the report warns the recovery is fragile. For this reach the load-bearing findings are:

• Warming fastest here. The upper tidal Thames is warming at roughly 0.19 °C/year — the fastest of any reach — directly relevant to Teddington–Richmond and to any warm-effluent discharge.
• European eel — Critically Endangered. Recruitment is down ~90–95% since the 1980s; ZSL's citizen-science eel project monitors passes at weirs including on the Hogsmill at Kingston.
• European smelt, a pollution-sensitive indicator, spawns in the low-salinity upper tideway and is highly exposed to warming, salinity change and abstraction.
• Invasive quagga mussel was first recorded in the Thames at Richmond in 2014, threatening rare native mussels; ZSL runs annual riverbed surveys at Richmond Lock.
• Harbour seals declining since ~2018; sea level rising ~5 mm/year at Tower Pier; nitrate rising even as phosphate falls.

Data and contacts for coordination: ZSL marine & freshwater team — marineandfreshwater@zsl.org. (Note: the sharks recorded in the tidal Thames are tope, starry smooth-hound and spurdog; ZSL's angel-shark work is in Wales and the Canaries, not the Thames — worth getting right.)

4 Thames Water accountability

Your core argument is that Thames Water is not meeting its obligations to the public or the environment — that it pays comparatively cheap fines instead of fixing infrastructure, and rewards executives while pollution worsens. The record below supports that argument with sourced figures. It is presented straight, with the company's own defence set out, so it survives scrutiny.

4.1 · A sustained record of pollution convictions

These are proven criminal convictions (guilty pleas / convictions in the Crown Court), all for sewage-pollution offences:

By 2021 the BBC reported Thames Water had faced £24.4m in fines for comparable offences since 2017. Several further Environment Agency criminal investigations are open (see 4.2).

4.2 · Performance is getting worse, not better

Pollution incidents rose sharply in 2024 — the opposite of what escalating fines were meant to achieve:

4.3 · The record regulatory penalty

In May 2025 Ofwat imposed its largest-ever penalty — £122.7m on Thames Water, from two investigations: £104.5m for wastewater and storm-overflow failings (three-quarters of its storm overflows were found to be spilling routinely, not exceptionally) and £18.2m for unjustified dividends. Ofwat directed that the penalty fall on the company and its investors, not customers.

4.4 · Bonuses while the river suffered

As pollution rose and debt mounted, the company continued to reward executives. The CEO's basic salary rose 14% to £995,000 in the year to March 2026 (total package ~£1.16m, including a deferred £99,000 retention payment awarded before the ban bit), and the bonus pool for other senior managers rose from £2.8m to £4.09m. Separately, a multi-year “management retention plan” for ~21 senior managers — reported at between £15.7m and £18.5m (sources vary) — caused a political row; Ofwat said it was not consulted and only learned of it afterwards. The Environment Secretary called the payouts “outrageous” and a case of “bonuses by any other name.”

4.5 · Money out, debt up

Under Macquarie's ownership (2006–2017), roughly £2.7bn was extracted from the regulated company and debt rose toward £11bn. Ofwat found two dividends — £37.5m (Oct 2023) and £158.3m (Mar 2024) — breached licence conditions, penalised £18.2m and clawed back £131.3m. The company now carries roughly £20 billion of debt, entered cash lock-up, saw its preferred equity partner (KKR) withdraw in June 2025, and is funded only to around November 2026 — with temporary public ownership (Special Administration) the fallback if the creditor-led rescue fails.

4.6 · The infrastructure-standards argument

Your point about "expansion tanks" being substandard and below EU requirements needs to be framed precisely so it can't be dismissed. Here is the accurate version:

• The domestic design minimum for storm-tank storage at a treatment works is modest — broadly 68 litres per head served, or about two hours of flow — and a works can be fully permit-compliant and still spill in heavy rain. Independent research found ~79% of large works have treatment capacity below the "3× dry-weather-flow" benchmark.
• The EU has moved ahead. The recast Urban Waste Water Treatment Directive (EU 2024/3019, in force January 2025) tightens the regime — lower size thresholds, and new “quaternary” treatment for micropollutants including PFAS by ~2045, funded partly by polluting industries. Post-Brexit England is not bound to adopt it, and an independent analysis (IEEP, 2024) documents the concrete divergence. So "England is falling below EU standards" is accurate as a specific, directional claim — on thresholds, micropollutants and integrated storm planning — not as a blanket assertion.
• Mogden specifically: flow to full treatment is ~1,064 Ml/day across eight storm tanks; the 2011–13 extension added ~50% capacity, yet spills still rose. The aggregate storm-tank storage volume is not published and should be requested from the EA/Thames Water permit file — a genuine evidence gap (section 10). Treat "substandard" as an advocacy framing until that figure and a benchmark are in hand; "does not meet the updated EU standard" is the defensible line.

4.7 · Are fines cheaper than fixing? The official verdict

The evidence that the deterrent has been too weak is now on the public record from Parliament's own bodies:

5 Who holds — and interprets — the data

One of your central questions is who is officially responsible for collecting, holding and interpreting the evidence, and whether it is good enough to base decisions on. This is the map. "Decision-grade?" is a candid assessment of whether the dataset, as held, is strong enough to support decisions about abstraction, discharge, bathing and habitat — or whether raw data and metadata still need to be obtained.

6 Stakeholders & contacts

Live contacts — already engaged

Target bodies & data holders — to approach

7 Correspondence & action tracker

An auditable record of every case, so nothing slips and each approach can be evidenced. Update this as replies arrive.

Immediate action list

1. Today — send the reply to Peter Gray keeping EIR2026/31287 live and asking for raw data (draft in section 8).
2. This week — write to Cllr Julia Neden-Watts on signage (draft in section 8).
3. This week — email ZSL (marineandfreshwater@zsl.org) to coordinate with the State of the Thames team and avoid duplication.
4. Ongoing — verify Mogden EDM figures and request the storm-tank storage capacity (EA/Thames Water permit file).
5. Ongoing — request WeBS bird-count data for the reach (Penny Williams / BTO).
6. By 1 Nov — drive petition 763721 toward 100,000; support the 14 Sept debate on public ownership (763721 & 762640, section 9).
7. Ahead of early 2027 — register as an interested party for the TDRA Development Consent Order.

8 Draft communications — ready to send

Two drafts you can use now. They are written in your voice from the record so far; edit freely. Tell me and I'll turn either into a formal Word letter on headed layout.

9 Petitions & public awareness

You've identified the real bottleneck: these campaigns don't fail for lack of support — they fail because people never see the petitions they could sign. The key strategic fact is that only petitions on the official UK Government & Parliament site (petition.parliament.uk) carry procedural force: 10,000 signatures compels a government response, and 100,000 means it is considered for a debate. Change.org and 38 Degrees petitions are useful for momentum and mailing lists, but carry no parliamentary weight. So awareness effort should point first at the official petitions below.

⭐ “Ensure new sewage treatment infrastructure meets higher standards as in the EU” Parliament · 763721
The Save Our Lands and River petition — the main Westminster vehicle for the Teddington fight. This is the one you flagged.

10,699

Scan to sign 763721

10k ✓ response

100k debate

Passed 10,000 on 27 July 2026 — a government response is now required. It needs 100,000 by ~1 November 2026 to be considered for a debate. Priority — push toward 100k
petition.parliament.uk/petitions/763721 · count observed 28 Jul 2026

“Hold a referendum to bring the water industry into public ownership” Parliament · 762640

161,852

Scan to sign 762640

10k

100k ✓

Passed both thresholds. Government responded 23 Apr 2026 (declined nationalisation); scheduled for debate on 14 September 2026. The single largest live petition in this space — worth amplifying around the debate date. Debate 14 Sept

“Stop the Abstraction Plant at Teddington Weir and releasing treated sewage into the river” Change.org · campaigning

34,121

Scan to sign

The TDRA-specific mass petition (Save Our Lands and River). ~34,000 signatures show real public strength — useful for media and for demonstrating opposition in the DCO process — but as a Change.org petition it does not trigger a government response or debate. Pair it with petition 763721, which does. Momentum, not procedure

Also open on Parliament's site (below the 10k response threshold): 757426 “Nationalise water companies…” (~29,900); 762503 “Ban dividends if they pollute in dry weather”; 764048 “Public inquiry into raw sewage.” These need visibility to matter.

A printable one-page QR flyer for these petitions can be produced on request (workstream G).

10 Evidence gaps — what to obtain next

A credible representation is honest about what it does not yet have. These are the open items; closing them is built into the action list (section 7).

• Raw EA datasets — fish, water quality, invertebrates and habitat surveys for the reach, with methods and metadata (being requested via EIR2026/31287).
• Mogden storm capacity — the aggregate storm-tank storage volume is not published; request it from the EA/Thames Water permit file, and verify the EDM spill figures (438/164/221/471 hrs) against the raw EA annual returns rather than the aggregator.
• Bird data — confirm the exact WeBS count sector(s) and the north (Middlesex) bank organiser; obtain the count series (BTO/WeBS).
• Fish counter — confirm whether any automated fish counter operates on this reach (not verified).
• ZSL figures — confirm the State of the Thames headline numbers against the published PDF, and coordinate directly to avoid duplication.
• Verification items — the retention-plan total (£15.7m vs £18.5m), the current Environment Secretary's name/quote, the recast EU Directive's exact per-plant deadlines, and the BBC article you sent (link could not be opened here — worth re-checking).
• Your own primary evidence — your weekly observations, photographs, catch/sighting logs and dated notes. First-hand, time-stamped local evidence from a 20-year river user is exactly what official datasets lack. Drop these into the Thames Water folder and I'll turn them into dated exhibits.

11 Sources

Grouped for reference. Official and regulatory sources are prioritised. Items flagged “verify” in the text should be confirmed against these primary sources before formal submission.