National Highways has declined to confirm that it will meet a pledge to mitigate by 2030 all outfalls that pose a “high-risk” of polluting the environment with toxic road runoff.
The company has published a document that its director of environmental sustainability, Stephen Elderkin, described on LinkedIn, as “detailing 182 confirmed high priority locations where outfalls or soakaways present a high-risk of pollution”.
But, while the locations are confirmed, the pledge to mitigate them appears far less certain.
The detailed document and map represent the next stage of the government-owned company’s 2030 Water Quality Plan, which:
sets out a high-level programme of work that achieves the plan to mitigate all high risk outfalls by 2030
However, that document also emphasizes that:
Delivery in RP3 will be subject to funding being agreed through RIS3.
Such funding has still not been formally agreed, although National Highways’ chief executive told Parliament that it is “proceeding on the basis that we will be funded” and the plan appears to be part of a funded National Programme.
Elderkin’s statement National Highways has “committed to mitigate the risk at high-risk locations by 2030 with the installation of new or upgraded treatment facilities” conspicuously lacks the word “all”.
The new document states that it:
contains details of sites confirmed through these processes as having an confirmed risk of pollution at the end of August 2025. These high priority locations include a total of 182 assets.
It adds:
We expect that, in all, approximately 250 outfalls and soakaways will be confirmed as requiring new or upgraded treatment systems by 2030.
While Elderkin stated that:
In total, we expect to deliver improvements to around 250 locations
this is a statement of expectation without a date.

Similarly, the new document conspicuously avoids making firm commitments. It lists for each location:
When we expect to deliver improvements work at each location, subject to funding and delivery constraints.
The timeline has four phases:
Tranche 0 – Planned for 2025/26 and 2026/27 Delivery
Tranche 1 – Planned for 2027/28 Delivery
Tranche 2 – Planned for 2027/28 and 2028/29 Delivery
Future Tranche – Delivery before 2030
The introduction to the document appears deliberately vague, delivering two matches in a game of PR word bingo:
National Highways is committed to minimising the impact of the Strategic Road Network on the water environment.
Organisations often say they are “committed” to doing something as an expression more of willing than an actual commitment and, if the company was committed to “minimising” the impact of road runoff, it would go beyond just identified high-risk outfalls.
As I wrote after Harris appeared before the Environmental Audit Committee:
Jo Bradley, director of operations at Stormwater Shepherds, appearing at an earlier part of the session, told the committee that all 25,000 outlets on the company’s network were discharging toxic chemicals and was very sceptical of the effectiveness of some of the mitigation equipment that it is putting in.
A further commitment “to improve water quality around our road network” is just as meaningless.
I asked National Highways to clarify whether the funding is in place and whether it is still committed to mitigating “all” high priority locations by 2030.
It declined to clarify either point.

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