Urban Water 4 (2002) 191–198

www.elsevier.com/locate/urbwat

A review of the UK approach to measuring the performance of

combined sewer overflows
John Blanksby *

Department of Civil and Environmental Engineering, University of Bradford, West Yorkshire BD7 1DP, UK
Received 31 January 2001; received in revised form 5 February 2002; accepted 28 February 2002

Abstract
Two current research projects have recently investigated post-project appraisal and flow measurement at combined sewer
overflows. The paper sets out the context in which these projects were carried out and specifically identifies the current performance
measures and measurement procedures used within the United Kingdom.
2002 Published by Elsevier Science Ltd.

Keywords: Combined sewer overflows; Combined sewer overflows impact; Performance measures

1. Introduction reinforced by the separation of the role of regulator and

There is a growing perception within the water
industry, that the use of performance measures will
enhance understanding of combined sewer overflows
(CSO) performance and facilitate the achievement of
environmental regulators’ requirements at minimum
cost. This is reflected in a recently published UK Water
Industry Research Ltd project report (UKWIR, 2001),
the aim of which is to provide a report identifying best
practice for simple, cost effective methods of post-pro-
ject appraisal. At the same time, the UK Government’s
National Measurement Systems Policy Unit has also
carried out a research project into the measurement of
flows at CSOs (NMSPU, 2001). It is not the purpose of
this paper to repeat the publication of the results of the
research. However, it is appropriate to reflect on the
context in which these studies were carried out, and
identify the issues that made them necessary.
The demand for performance measures is driven
by technological and organisational changes. From the
technological perspective, there is an increasing under-
standing of processes and the means by which they can
be measured. From the organisational perspective, the
culture of objectivity and the quantifiable demonstration
of achievement has taken a firm hold. This has been
*
Tel.: +44-1274-233-848; fax: +44-1274-233-888.
E-mail address: j.r.blanksby@bradford.ac.uk (J. Blanksby).
service provider which, in England and Wales, has re-
quired that the financial regulator (OFWAT) sets limits
on the amount that service providers can charge their
customers in each of the five year asset management
plan (AMP) periods. In this climate, there is a need to
have performance indicators and to measure perfor-
mance, irrespective of the difficulties that might occur in
application.
Over the past 40 years, performance measures relat-
ing to CSO operation have developed from the simple
value of six times dry weather flow for the setting,
through Formula A, to include consent conditions based
on spill volume, frequency and quality. However, con-
sent conditions are themselves a simple representation of
more complex design and performance objectives that
reflect the way in which CSOs interact with receiving
waters. It should also be noted that failure to meet the
formal consent conditions was only one of the measures
used to assess CSO performance in the reviews carried
out for the determination of sewerage charges for the
AMP periods two and three (AMP2 and AMP3). Other
measures relating to operational performance and the
quality of the receiving waters were also used in this
process to identify the extent of the CSO problem and
the cost of rectification within each of the asset man-
agement planning periods. In all some 1200 unsatisfac-
tory CSOs were improved during the five years of the
AMP2 period, 4800 will be improved by 2005, the end of
the AMP3 period, and a further 700 will be improved
between 2005 and 2010 in the AMP4 period.

1462-0758/02/$ - see front matter
2002 Published by Elsevier Science Ltd.

PII: S 1 4 6 2 - 0 7 5 8 ( 0 2 ) 0 0 0 1 2 - 2
192 J. Blanksby / Urban Water 4 (2002) 191–198

The use of performance measures in identifying per-
formance deficiencies and setting consents implies that
there is an ability to measure CSO performance with
sufficient accuracy and to identify and quantify the
contribution that they make to the quality of the re-
ceiving waters. Without this ability, objectivity is lost
and expectations that performance measures can be used
as part of a one pass procedure for identifying and up-
grading unsatisfactory CSOs will prove to be unrealistic.
In addition to identifying problems and demonstrat-
ing compliance, the measurement of the performance of
CSOs and their component parts provides an under-
standing that may be used to improve the effectiveness
of design, and to revise expectations of performance,
thus allowing inclusion, exclusion or amendment of
different types of CSO design or components. This in
turn allows costs to be minimised and procedures to be
simplified while still achieving the design objectives.
In subsequent sections, this paper summarises and
discusses: the performance measures currently used by
the UK industry to measure the quality of receiving
waters, identify unsatisfactory CSOs, set design objec-
tives and consent their operation; and the accuracy of
the methods of measuring performance.
2. Performance measures
The definitions of unsatisfactory CSOs in Section 4.4
of the General Guidance Note for Preparatory Work for
AMP2 (National Rivers Authority, 1993) provides the
basis for a hierachy of measures which may be used to
define CSO performance. Effective measures and pro-
cedures have been developed for each of the criteria,
allowing objective appraisal of performance. The six
criteria are set out in Table 1 below, together with
methods of assessing current performance and perfor-
mance measures associated with each method. Each of
these criteria is discussed in further detail below.
2.1. Aesthetic impact
GQA Aesthetic (Environment Agency, 1998a) [ra1]
and FWR report FR0466 ‘‘User Guide For Assessing

Table 1
Criteria, methods and measures for assessing CSO performance
Criteria Method of measuring Performance measure
current performance
Causes significant visual or aesthetic impact due to solids, GQA Aesthetic Quantitative assessment and ranking of measures of
fungus and has a history of justified public complaint aesthetic quality of rivers
FWR report FR0466 Quantitative assessment and ranking of measures of
aesthetic quality of rivers
Incident records Historical record of public complaint
EA/NLG assessment Quantitative assessment and ranking of measures of
protocol aesthetic quality of beaches
Causes or makes a significant contribution to GQA chemical Quantitative assessment based on chemical testing of
a deterioration in river chemical or biological class predominantly dry weather sampling regime
GQA biological Quantitative assessment based on low frequency
sampling of biological parameters
Fundamental standards Quantitative assessment based on chemical testing of
for intermittent wet weather samples and frequency analysis of events
discharges causing the river quality
Causes or makes a significant contribution to EC Bathing Water Environmental Quality Standards for coliform bacte-
a failure to comply with Bathing Water Quality Directive standards ria set out in Table 2.5 of the UPM manual
Standards for identified bathing waters
Spill frequency Spill frequency standards based on the location of the
standards CSO outfall
Operates in dry weather conditions Incident records Historic record of incidents

Operates in breach of consent conditions provided Assessment against Quantifiable consent conditions reflecting design ob-
that they are still appropriate consent conditions jectives, typical examples of which are set out in Table
2 below
Causes a breach of water quality standards (EQS) Environmental Quantitative assessment based on chemical testing of
and other EC directives quality standards predominantly dry weather sampling regime

Assessment against Quantitative assessment based on procedures appro-

appropriate EC priate to individual directives
directive standards
 J. Blanksby / Urban Water 4 (2002) 191–198 193

The Impact Of Combined Sewer Overflows’’ (Founda- system from A: very good, to D: poor. The procedure
tion for Water Research, 1994a) are methods based on provides an effective measure of the relative importance
river surveys and involve the identification and ranking of different types of litter, and the general impact of
of categories of pollutants. The GQA Aesthetic [ra2] CSOs, but is limited by the frequency of surveys and
provides a general review of a river reach, and although the effects of tides and currents affecting the dispersal
not specifically targeted at CSOs does measure the of persistent solids. Therefore, in all but the simplest of
presence of sewer related material in greater detail than situations, it is not an effective measure for an individual
FR0466, which focuses on CSO performance by sur- CSO.
veying the river immediately upstream and downstream
of the point of discharge.
2.2. River class
The categories utilized in the GQA Aesthetic are:
litter, including sewage litter and faeces; deposits on
In England and Wales, the environmental standards
rocks, including oil, sewage fungus, and scum; colour
for river quality are set out in terms of percentile con-
and odour. Each category is ranked into classes de-
centrations for a set of chemical determinants (Depart-
pending on quantity and coverage in the case of litter,
ment of the Environment, 1994). The quality of rivers
and deposits on rocks and strength in the case of colour
is assessed by means of a statutory programme of
and odour. This classification is highly sensitive to the
sampling and analysis, the results of which determine
presence of sewage. Scores are then set against each
the river ecosystem classification. The principal mea-
classification to produce an overall grade.
sures used to identify the effects of CSO discharges are
FWR report FR0466 and its parent report FR0465
biochemical oxygen demand (BOD), dissolved oxygen
Development Of A Procedure For Assessing The Impact
(DO), total ammonia and unionized ammonia. The
Of Combined Sewer Overflows’’ (Foundation for Water
percentile based river quality standards are shown in
Research, 1994b) were both jointly funded by the Na-
Table 2. In this table RE1 is the highest quality and RE5
tional Rivers Authority (NRA) and the Foundation for
the lowest.
Water Research (FWR) and published in April 1994.
The statutory sampling and testing programme is
The procedure combines visual inspection with archived
commonly termed the GQA Chemical. Samples are
data on CSO performance to produce an assessment of
taken during normal working hours, randomly within
CSO performance. The visual inspections, which may be
monthly, two weekly or weekly periods. However, the
repeated over a period of time, focus on sewage litter
frequency of the sampling programme is not sufficient
and sewage fungus in the vicinity of the CSO and take
to highlight the effect of wet weather flow, and con-
account of the upstream conditions. The archived data
sequently the classification is predominated by dry
includes history of justified complaints, dry weather
weather conditions (Balmforth, Simpson, Blanksby,
discharge and performance measured against the long
Gadsden, & Stewart, 1999).
term river quality objectives. The individual perfor-
The GQA Biological (Environment Agency, 1998b)
mance measures are scored on a continuum A–E and a
overcomes this problem by establishing the presence of a
grading of satisfactory, unsatisfactory or very unsatis-
range of microinvertebrate species and comparing these
factory is based on either a combination of the scores or
with standards for the different river ecosystem classes.
a single overriding factor.
The standards are based on the tolerance of the different
Although FR0466 focuses on CSO performance ra-
species to pollution and provide an impression of overall
ther than the general quality of a reach of river, it can-
river quality in both wet and dry weather. However, the
not differentiate between the performance of individual
drawbacks of this approach are that the survey process
CSOs where several discharges are made to the receiving
is time consuming and expensive, involving surveys in
water at a single point. Nor does it quantify the effects of
the spring and autumn of every fifth year; and that the
odour and the impact of oil, which rank equally with
sewage litter and sewage fungus in the GQA Aesthetic.
Despite differences in detail, both these methods provide Table 2
a basis for measuring the impact of CSO on inland Percentile based river quality standards (Department of the Environ-
ment, 1994)
waters and are capable of demonstrating improvement
4.1 DO % BOD Total Unionized
in performance following CSO upgrading works.
Class saturation (ATU) ammonia ammonia
A similar methodology is available for the assessment 10 mg/l mg N/l mg N/l
of the aesthetic quality of beaches (Environment Agency, percentile 90 percentile 90 percentile 95 percentile
1998b). The procedure developed by the Environment RE1 80 2.5 0.25 0.021
Agency and the National Aquatic Litter Group assesses RE2 70 4.0 0.6 0.021
sewage-related debris, gross and general litter, poten- RE3 60 6.0 1.3 0.21
tially harmful litter, oil pollution, dog faeces and accu- RE4 50 8.0 2.5 –
RE5 20 15.0 9.0 –
mulations of litter using a four grade classification
194 J. Blanksby / Urban Water 4 (2002) 191–198
procedure is not normally capable of identifying the
effects of individual CSOs.
The 90 and 95 percentile chemical standards have
been extrapolated to 99 percentile criteria for the assess-
ment of intermittent discharges (DETR, 1997). How-
ever, the application of these standards is still dependent
on sufficiently frequent sampling to allow the effect of
wet weather flows to be established. In terms of design,
the 99 percentile standards would be used in conjunction
with the application of long series rainfall using verified
sewer quality and river quality models.
Another approach to establishing the effects of CSO
discharges is to use the fundamental intermittent stan-
dards for DO and unionized ammonia as set out in Part
2 of the Urban Pollution Management Manual (UPM)
(Foundation for Water Research, 1998). These stan-
dards quantify the duration, frequency and intensity of
DO sags and ammonia peaks which will sustain popu-
lations of different types of fish. As with the 99 percentile
standards, the normal design methodology is to use
verified sewer quality and river quality models. This is
because long-term sampling of sewer and river flows and
quality is cost prohibitive.
The design procedures for application of the inter-
mittent and 99 percentile standards are set out in the
UPM. As well as setting out generic design methods, the
manual provides detailed procedures for problem defi-
nition and designing CSO improvements for highly
sensitive and complex drainage systems, but in less sen-
sitive areas, empirical design methods are used. How-
ever, these are design methods, which at best use limited
monitoring and sampling of flows for model verification.
Consequently, there are no currently available
methods of directly assessing the impacts of individual
CSOs on river quality. GQA chemical sampling is
skewed towards dry weather quality. GQA biological is
only carried out once in five years and may be affected
by individual pollution incidents. The sampling associ-
ated with UPM studies is short term and is carried out
for model verification purposes, rather than to directly
assess CSO performance. It is evident that the GQA
Chemical and Biological methods can be used to show
changes in river quality. However, if they are to be used
to quantify the performance of individual CSO, then
changes in the method of application are required.
2.3. Bathing water quality
Bathing water quality is assessed by taking water
samples at pre-ordained locations immediately prior to
and throughout the bathing season. These samples are
analysed to identify the presence of total coliform bac-
teria and faecal coliform bacteria. The EC Bathing
Water Directive (EC, 1976a) requires that 19 out of the
20 samples taken must have <10,000 [ra3] total coli-
forms per 100 ml of water and <2000 faecal coliforms
per 100 ml of water.
It has been assessed that by limiting the number of
CSO discharges to three per bathing season, the re-
quired standard will be met, providing that the point of
discharge is below the mean low water level for spring
tides. However, the frequency of discharges may be in-
creased, if appropriate modeling is carried out. The use
of the spill frequency standard provides a relatively
simple method of measuring long-term performance.
Even so, it is difficult to assess the impact of individual
CSOs in terms of the presence of coliforms because,
except in the most simple of cases, the source of the
coliforms in samples cannot be determined
2.4. Operation in dry weather
This is an objective performance indicator that ef-
fectively demonstrates the capacity of the CSO control
and downstream network in relationship to the dry
weather flow, and self-cleansing. Complaints systems
and operational records provide adequate information
providing that they are properly kept.
2.5. Breach of consent
The CSO consent is a legal document which sets out
specific conditions under which the CSO must operate.
The terms of the consent are agreed between the Envi-
ronment Agency and the operator and are derived from
the design process which in turn satisfies the design
objectives. The consent conditions should be measur-
able. However, this is not always the case. Table 3 sets
out typical consent conditions, appropriate performance
measures and methods of measurement. These typical
conditions should be considered in the context of the
Environment Agency’s Consents Manual (Environment
Agency, 1997), which sets out the normal requirements
for consent conditions as follows:
• Consents issued must include necessary conditions
such as overflow location, type, weir setting, storage
requirements etc., and aesthetic performance stan-
dards as appropriate to the receiving water uses.
• It will not be necessary to apply numeric, chemical
and bacteriological quality conditions in the consent.
• The requirements may in certain circumstances be for
the provision of a storm event/duration monitor, the
results from which would normally be presented in
the form of an annual report from the discharger.
The performance measures identified in Table 3 have
different degrees of complexity. In order to express
performance with respect to time it is necessary to es-
tablish the return period of the events experienced over
the period of measurement. This is not simply a matter
 J. Blanksby / Urban Water 4 (2002) 191–198 195

Table 3
Typical performance measures associated with consent conditions
Consent conditions
CSO setting: the flow to treatment
at first spill
Storage volume: the volume that must be
stored in excess of the continuation flow
prior to the operation of the overflow
Spill frequency: the average annual
permissible number of spills, or other period
such as a defined bathing season
Spill volume: the average annual
spill volume, or other period such
as a defined bathing season
Spill duration: the average annual
spill duration, or other period such
as a defined bathing season
Peak spill rate: the maximum spill
rate expressed as an absolute value
Solids retention: expressed in terms of
the regulatory requirements
(6 and 10 mm) and capacity
Performance measure
Depth/discharge relationship
for control
Volume of storage including CSO,
storage chamber, oversized upstream
pipe and other associated storage
Number of spills per unit time
Volume of spill per unit time
Duration of spill per unit time
Rate of discharge
Screen type, capacity and excedence
(or equivalent). Measurement of depth/
area of flow through screen together
with measurement of discharge
Method of measurement
Measure depth in chamber and discharge in continua-
tion pipe by means of:
• flow survey
• block off test
• pre-installation test
Determine using:
• as-constructed drawings
• survey of chamber
Determine number of spills using simple event logger
(proximity, depth, etc.) in overflow pipe. If necessary
use rainfall data to assess frequency of events causing
the spills.
Measurement of flow in overflow pipe using depth/
velocity measurement. Measurement of flow in overflow
pipe using depth/weir/flume arrangement. If necessary
use rainfall data to assess frequency of events causing
the spills.
Determine spill duration using simple event logger
(proximity, depth, etc.) in overflow pipe. If necessary
use rainfall data to assess frequency of events causing
the spills.
Measurement of flow in overflow pipe using depth/
velocity measurement. Measurement of flow in overflow
pipe using depth/weir/ flume arrangement
Measurement of flow in overflow pipe and depth in
chamber to indicate operation of screen bypasses so
that these can be related to flow

of measuring performance of a single bathing season,
for example. Spill frequency, duration and volume are,
in turn, increasingly more complex to measure. The
measurement of spill frequency and duration require
simple event loggers, or typical telemetry installations.
However, the measurement of volume requires the ac-
curate measurement of velocity and area of flow by
means of hydraulic structures or velocity and depth
sensors.
Pre-installation tests for the CSO control must rep-
licate the hydraulic conditions in the CSO chamber in
order to form a true representation of performance. This
means that benching must be accurately represented and
the effect of surcharge from downstream restrictions
should also be simulated. Post-completion block off tests
are not practical in small chambers or in those with large
storage volumes. These tests require the CSO chamber
to be filled to weir level by means of blocking the control
pipe and then measuring the change in level in the tank
at fixed time intervals as it empties. The head discharge
relationship of the control is then determined by estab-
lishing the change in volume for each time period and
the volume of dry weather flow entering the chamber in
the same time period. The dry weather flow is measured
at the end of the test. In the case of small chambers,
there may not be sufficient time to carry out the test. In
large chambers, the protracted filling and emptying
of the tank may have adverse effects on downstream
treatment processes and it will be difficult to establish
the dry weather flow, because it may vary considerably
over the period of emptying.
Flow measurement using velocity and depth sensors
is affected by the presence of bed load and near bed
sediment. These materials travel at a lower velocity than
the liquid sewage, especially in flat pipes and those af-
fected by back waters which reduce velocities and cause
the sediments to settle. For flow measurement to be ef-
fective, the pipe should be sufficiently steep so as to
avoid deposition of sediments, but not so steep that
transitional flow occurs at the point of measurement.
However, it should be recognized that if the sediment is
not detected, its impact on the performance of the CSOs
cannot be assessed.
Hydraulic structures can be costly to build into
a sewer and may be affected by the deposition of sedi-
ment. However, depth measurement using pressure
196 J. Blanksby / Urban Water 4 (2002) 191–198
transducers and ultra sonic devices has been demon-
strated to be reliable, so the construction of flumes and
weirs may become a viable option where the perfor-
mance of a new CSO or screen has to be demonstrated.
The simplest of the measures included in Table 3 are
those that demonstrate that the storage volume utilized
prior to CSO operation is correct. A simple survey or a
check of the as constructed drawings will suffice where
the storage and CSO form a single chamber. However,
even this measure becomes more difficult to achieve
where some of the storage is provided in upstream off
line tanks, or where a restriction prevents recirculation
from a downstream storage tank. In such cases, dem-
onstration of compliance may be achieved by the use of
proximity meters, or if more detailed information is re-
quired, depth monitors.
All the above measures may be achieved at a cost.
However, not all the consent conditions identified pro-
vide an appropriate basis for measuring performance,
because they cannot be proven to be achieved within a
reasonable period of time. The specification of a peak
rate of discharge is particularly difficult to measure.
2.6. Breaches of water quality standards and other
directives
In coastal and estuarine waters the EU Shellfish
Waters Directive (EC, 1979) has a significant impact on
the performance of CSOs. In this case, the measures for
coliforms are the guideline rather than the imperative
standards, but in addition, the presence of the discharge
must not cause a deterioration in class as reported
by the Department of Environment, Food and Rural
Affairs. In inland waters, standards for the abstraction of
drinking water and environmental quality standards
specified in the EU Dangerous Substances Directives
(EC, 1976b) are also factors. However, all these mea-
sures are aimed at identifying the quality of the receiving
waters and as with the standards associated with river
class and bathing water quality, they are not specifically
aimed at the performance of individual CSOs.
3. Discussion
The above summary identifies that there are wide
ranging measures for the identification of CSO impacts
on receiving waters and specific aspects of CSO perfor-
mance. However, disparate objectives and inconsisten-
cies between methodologies suggest that the effectiveness
of these measures may be improved. An example of the
inconsistencies that occur is the inclusion of odour and
oil in the classification of rivers in the GQA Aesthetic,
but the exclusion of these parameters in FWR report
FR0466. Although these parameters are transitory in
nature, and may be either missed or over emphasised in
the inspections required by the latter, failure to assess
and attend to the performance of CSOs in these respects
may lead to future conflict between operators, regula-
tors, customers and the public.
A measure of performance that is not currently used,
but that has a potential benefit is the containment of
heavier sediments and faecal material within the collec-
tion system, which has benefits for aesthetic and water
quality.
Other aspects that have been identified in the sum-
mary are the expense of the methodologies associated
with measures such as GQA Biological and the funda-
mental intermittent standards. Resource implications
have a propensity to limit the frequency of their appli-
cation and make their deliverables susceptible to short
duration conditions. Yorkshire Water Services have re-
cently conducted a review of their CSOs using FR0466
and macro-invertebrate surveys to identify unsatisfac-
tory intermittent discharges (WaPUG, 2001a). How-
ever, this was done at considerable expence. Certainly, if
the impact of climate change and the implementation of
improved technologies such as ‘so called’ sustainable
drainage systems are to be assessed at regular intervals,
cost effective and appropriately focused procedures are
required.
Experience gained in assessing CSO impacts and
performance using the current methods is now sufficient
for a comprehensive review with the aim of developing a
suite of complementary measures and procedures that
will minimise cost and maximise the return of informa-
tion. The benefit of such a review will be that the
industry will be able to progress into the AMP 4
(2005–2010) in the knowledge that the range of mea-
sures is unlikely to change dramatically in the future.
Unfortunately, this does not mean that the standards
will not change, but even so, the public, including cus-
tomers, shareholders and users of the aquatic environ-
ment, would no doubt welcome the degree of certainty
that consistency of approach would bring.
A review would also enable the performance mea-
sures to be brought in line with the EC Water Frame-
work Directive (EC, 2000) which places emphasis
on amenity, balanced and sustainable ecosystems and
feedback on performance from local communities. It is
evident that the measures included in the GQA Aes-
thetic and GQA Biological will be central to the as-
sessment of river quality and CSO impact. However, it
has been previously identified that these measures may
be influenced by short term local factors and that they
are generally not able to quantify the impact of indi-
vidual CSO and surface water outfalls or the specific
pollutants causing the problem.
In order to overcome this problem, a second level of
more detailed measures is required. The basis for these
may be found in the GQA Chemical sampling and
 J. Blanksby / Urban Water 4 (2002) 191–198
FR0466 surveys, but there are shortcomings in these
approaches. By their very nature, the impact of CSOs is
greatest during wet weather. This means that sampling
to identify how they are performing should be focused
on wet weather periods. Surveys involving flow and
depth measurement and event based quality sampling
provide a degree of information on wet weather per-
formance at specific sites. However, broad brush GQA
Chemical sampling and FR0466 surveys are generally
carried out in dry weather and so miss the specific effects
of CSO discharges. In order to rectify this situation
there is a need to either increase the amount of effort and
expenditure on these methods, or to place greater em-
phasis on wet weather sampling, along the lines of UPM
methodologies and observation.
Having discussed the use of performance measures in
the assessment of CSO performance by direct and in-
direct methods, it is also appropriate to review their use
in design procedures. In this respect, research has been
directed at developing procedures and tools for the
design of CSO to meet water quality requirements for
inland and coastal waters and aesthetic control re-
quirements.
From the water quality perspective, a range of em-
pirical methods has been developed over the past 30
years and has culminated in the development of the
procedures for the application of the fundamental in-
termittent standards as set out in the UPM manual.
These methods are based on limited local data, which
coupled with the limitations of the modelling tools
available may produce sub-optimized solutions resulting
in either excessive cost or unsatisfactory performance.
This problem may be easily controlled by the applica-
tion of appropriate management strategies. However,
the highly differentiated structure of the water industry
(government, regulators and service providers) and the
tensions between the organizations within it make this
difficult to achieve in practice.
The same may be said from the perspective of aest-
heic control. In this case, the drive to minimize costs and
to reduce uncertainty in the AMP3 period is resulting
in verbatim application of the AMP2 guidelines, even
though UKWIR (1994) identified that
‘‘The AMP2 Guidelines themselves were seen as a
starting point, but that need for screens should
be avoided as much as possible by designing out
through location of point of discharge, reduction
of discharges through storage provision and im-
proved overflow design’’.
‘‘The wording of the guidelines has changed from
time to time. The key point seems to be the use
of the word significant when applied to quantity
of solids discharging to watercourses and it is here
that flexibility will be applied. Significant quantities
197
can de defined as a value lying somewhere between
existing and ideal performance’’.
‘‘The regulators all expressed the need for co-oper-
ation in interpretation and application, but that if
necessary the guidelines as stated were always there
as a last resort’’.
‘‘To conclude it is clear that the regulators regard
that the industry is at the start of the process and
that they wish to develop a spirit of openness and
co-operation. They are aware of their roles and ob-
jectives (current and future) and those of others, in-
cluding service providers. . .. The regulators have no
desire to see screens located at every overflow. They
are fully aware of the cost implications and the po-
tential operational problems. However they do
want to see the achievement of reasonable pollution
standards’’.
The Wastewater Planning User Group (WaPUG)
design guide (WaPUG, 2001b) seeks to reduce the cost
of CSO chambers incorporating screens. However, ‘‘the
Guide is limited to the design of CSO chambers where
screens are to be used to control aesthetic pollutants’’. The
intentionally strict interpretation of the regulatory re-
quirements for aesthetic pollutants minimises the size
of the chamber and removes scumboards, leaving the
screen to provide the solids control. Therefore it has
limitations in the retention of fat, grease, oils, soft faecal
material and polluted sediments compared with current
best engineering design. These latter substances affect
both aesthetic and water quality of receiving waters.
This interpretation of the AMP2 guidelines highlights
that there has been little change in the regulatory re-
quirements since the publication of the AMP2 guide-
lines, even though they were only seen as a starting
point. It also results in a design procedure and strategy
which has both high risk and high consequence of fail-
ure. As fat, grease, oils, faecal material and sediments all
have a propensity to adversely affect the operation of
screens.
4. Conclusion
Despite the potential benefits of rationalising the
approaches to performance measurement, the difficulties
of measuring flows in sewers and rivers and collect-
ing the representative samples needed to measure per-
formance mean that it remains difficult to accurately
quantify performance. It is perhaps more realistic to
regard performance measures as performance indicators
and to adopt suitably risk averse design strategies that
will allow CSOs to be further improved where necessary.
This pragmatic approach will allow the significant
198 J. Blanksby / Urban Water 4 (2002) 191–198
improvements that will be made during the AMP3 pe-
riod to be reviewed during the period 2004–2007, when
commissioning of the current programme of improve-
ments is completed. It also allows time for assessing the
impact of the Water Framework Directive (EC, 2000),
which requires phasing out of discharges to water of
Priority Hazardous Substances such as poly aromatic
hydrocarbons. Although it precludes CSO improve-
ments over and above the 700 already identified as part
of the AMP4 period, it will allow the industry time to
gear up to completing the programme of improvements
in the run up to the operators license review due to be
completed during AMP5. In order to achieve this it will
be necessary for designers and decision makers to un-
derstand the processes that they are attempting to rep-
resent so that they can adopt appropriate strategic
approaches rather than rigid bureaucratic responses.
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