Types of Prospective Class Members (Victims)
Based on the documents (e.g., ANNEX REPORTS_250426.txt, your FOIA correspondence) and web information, the following groups are likely affected by sewage discharges in UK coastal waters:
1. **Coastal Residents**: Individuals living in coastal communities impacted by sewage pollution, facing health risks, property damage, or reduced quality of life due to polluted beaches and waters.
2. **Tourists and Recreational Water Users**: Swimmers, surfers, kayakers, and other water sports enthusiasts who face health risks (e.g., infections from bacteria/viruses) or reduced access to safe bathing waters.
3. **Local Businesses**: Tourism-related businesses (e.g., hotels, restaurants, water sports rentals) and fishing industries suffering economic losses due to sewage-related beach closures or damaged marine ecosystems.
4. **Fishermen and Shellfish Harvesters**: Those whose livelihoods depend on clean coastal waters, impacted by sewage pollution affecting fish stocks or shellfish safety.
5. **Environmental Activists and Community Groups**: Individuals or groups advocating for cleaner waters, potentially affected by the environmental degradation caused by sewage discharges.
6. **Future Victims**: Individuals or businesses who may be impacted by ongoing or future sewage discharges if current practices continue, including potential health, economic, or environmental harm.
### Relevant Associations and How to Reach Them
To connect with these prospective class members, reaching out to organizations that represent or engage with affected communities is the most effective approach. Below is a list of relevant associations, their contact details, and recommended methods to reach them, based on web information and the context of your case.
1. **Surfers Against Sewage (SAS)**
– **Description**: A leading UK charity focused on tackling sewage pollution in coastal and river waters. They run the Safer Seas & Rivers Service, which tracks sewage discharges and collects sickness reports from water users. SAS engages with swimmers, surfers, and coastal communities, making them a key contact for identifying affected individuals. They reported 1,924 sickness cases in 2024 from water users affected by sewage pollution. [](https://www.sas.org.uk/water-quality/water-quality-facts-and-figures/)
– **Contact Details**:
– Email: info@sas.org.uk
– Phone: 01736 555950
– Address: Surfers Against Sewage, Unit 2, Wheal Kitty Workshops, St Agnes, Cornwall, TR5 0RD, UK
– Website: www.sas.org.uk
– **How to Reach**:
– Submit a query via their website contact form or email info@sas.org.uk, requesting collaboration to identify affected water users through their sickness report database.
– Reference their Safer Seas & Rivers Service app, which tracks real-time sewage alerts, and ask to connect with affected individuals (anonymized, respecting GDPR).
– Attend their events or campaigns (e.g., paddle-outs) to network with affected communities. Check their website for upcoming events.
– Note: SAS encourages water users to submit sickness reports at www.sas.org.uk, which could help identify victims, though direct personal data access may require formal legal processes.
2. **Marine Conservation Society (MCS)**
– **Description**: A UK charity focused on protecting oceans from sewage pollution and other threats. They advocate for stronger regulations and are pursuing a judicial review against DEFRA’s Storm Overflows Discharge Reduction Plan, which aligns with your concerns about regulatory failings. MCS engages with coastal communities, swimmers, and environmentalists. [](https://www.mcsuk.org/ocean-emergency/ocean-pollution/water-quality-and-sewage/sewage-pollution/)
– **Contact Details**:
– Email: info@mcsuk.org
– Phone: 01989 566017
– Address: Marine Conservation Society, Overross House, Ross Park, Ross-on-Wye, Herefordshire, HR9 7US, UK
– Website: www.mcsuk.org
– **How to Reach**:
– Email info@mcsuk.org to express interest in their legal action against DEFRA and inquire about connecting with affected coastal stakeholders.
– Request anonymized data or testimonials from their supporters who reported sewage-related impacts (e.g., health issues, economic losses).
– Join their membership or donate to gain access to their network of supporters, which may include affected individuals. Details are on their website.
– Follow their social media (e.g., Twitter/X @mcsuk) for campaign updates and opportunities to engage with affected communities.
3. **The Rivers Trust**
– **Description**: An umbrella organization for river trusts across the UK and Ireland, addressing sewage pollution in rivers and coastal waters. They maintain a sewage map (2019-2022 data) and work with citizen scientists to report pollution incidents, making them a valuable resource for identifying victims. [](https://theriverstrust.org/key-issues/how-to-report-sewage-pollution)
– **Contact Details**:
– Email: info@theriverstrust.org
– Phone: 01579 372140
– Address: The Rivers Trust, Rain-Charm House, Kyl Cober Parc, Stoke Climsland, Callington, Cornwall, PL17 8PH, UK
– Website: www.theriverstrust.org
– **How to Reach**:
– Contact info@theriverstrust.org to discuss their sewage map and request assistance in identifying affected individuals or communities in coastal areas.
– Ask about their Outfall Safari program, which involves volunteers mapping sewage outflows, and seek introductions to local river trusts (e.g., Aire Rivers Trust) with relevant data. [](https://www.bbc.com/future/article/20240704-the-wetlands-cleaning-up-the-uks-sewage-pollution)
– Write to your local MP, as suggested by The Rivers Trust, to amplify your request and gain traction with their network. Use their website’s advocacy tools to find MP contact details.
– Monitor their sewage map updates (available on their website) to identify specific coastal regions with high discharge incidents.
4. **WildFish**
– **Description**: A conservation charity challenging DEFRA’s sewage discharge policies through judicial review, particularly criticizing the Storm Overflows Discharge Reduction Plan for allowing discharges until 2050. They represent anglers, swimmers, and environmentalists affected by water pollution. [](https://amp.theguardian.com/environment/2022/aug/31/uk-sewage-discharge-plan-judicial-review)
– **Contact Details**:
– Email: info@wildfish.org
– Phone: 020 7359 4590
– Address: WildFish, PO Box 66669, London, N19 5AH, UK
– Website: www.wildfish.org
– **How to Reach**:
– Email info@wildfish.org to align your case with their judicial review efforts and request anonymized data on affected anglers or swimmers.
– Request a meeting with their CEO, Nick Measham, to discuss collaboration and access to their supporter network.
– Engage with their campaigns via social media (e.g., Twitter/X @WildFishOrg) to connect with affected individuals.
– Note: Their legal action may provide a framework for identifying victims, but direct contact details will likely require a formal data-sharing agreement.
5. **Royal Yachting Association (RYA)**
– **Description**: Represents recreational boaters, who are affected by sewage discharges due to health risks and environmental impacts. Their Green Blue initiative provides resources on waste management and pump-out facilities, connecting with boaters in coastal areas. [](https://www.rya.org.uk/knowledge/environment/waste-management)
– **Contact Details**:
– Email: environment@rya.org.uk (for Green Blue inquiries)
– Phone: 023 8060 4100
– Address: RYA House, Ensign Way, Hamble, Southampton, SO31 4YA, UK
– Website: www.rya.org.uk
– **How to Reach**:
– Email environment@rya.org.uk to inquire about boaters affected by sewage pollution in coastal waters, referencing their Green Blue maps.
– Request access to their regional pump-out facility directories to identify coastal areas with high boater activity and potential victims.
– Attend RYA events or webinars (check their website) to network with recreational boaters who may have experienced sewage-related issues.
6. **Local Coastal Community Groups**
– **Description**: Grassroots groups, such as those listed on coastal.cocoo.uk (e.g., Save Our Seas, Coastal Action Network), represent residents, businesses, and activists in specific coastal areas. These groups are often informal but can connect you to affected individuals.
– **Contact Details**:
– Vary by group; coastal.cocoo.uk lists some contacts (e.g., info@saveourseas.uk for a hypothetical group).
– Search local council websites or social media (e.g., Twitter/X, Facebook) for groups like “Save [Beach Name]” or “Clean Coast [Town].”
– **How to Reach**:
– Visit coastal.cocoo.uk to identify listed groups and contact them via email or social media.
– Search Twitter/X for hashtags like #EndSewagePollution or #CleanCoasts to find local campaigns and their organizers.
– Contact local councils’ environmental health departments (via www.gov.uk/find-local-council) to ask for introductions to community groups reporting sewage issues. [](https://www.gov.uk/report-environmental-problem)
### Strategies to Reach Prospective Class Members
To build your class action case, consider these approaches to connect with victims via the above associations:
– **Collaborate on Data Collection**: Request anonymized data or testimonials from SAS, MCS, or The Rivers Trust, citing their existing sickness reports or pollution maps. Ensure compliance with GDPR by working through formal data-sharing agreements.
– **Engage in Campaigns**: Join public campaigns or events by SAS, MCS, or WildFish (e.g., beach clean-ups, protests) to meet affected individuals directly.
– **Leverage FOIA Data**: Use the FOIA response (when received) to identify specific coastal areas with high discharge incidents, then target local groups or businesses in those regions via social media or council referrals.
– **Public Appeals**: Place calls for affected individuals on coastal.cocoo.uk or through association newsletters, ensuring anonymity options to encourage responses.
– **Legal Partnerships**: Partner with WildFish or MCS on their judicial review efforts, as their legal actions may uncover victim data or connect you with affected communities.
### Limitations and Notes
– **Privacy Constraints**: Direct names and contact details of victims are protected under UK GDPR and unlikely to be disclosed without consent. Associations may provide anonymized data or facilitate introductions.
– **FOIA Relevance**: Your ongoing FOIA request (18 July 2025) may yield data on specific discharge incidents, which can help narrow down affected regions and communities. Follow up with the EA if no response is received by 15 August 2025 (20 working days).
– **Future Victims**: Identifying future victims is speculative but can include anyone in coastal areas with ongoing discharge issues. Use SAS’s real-time sewage alerts or The Rivers Trust’s sewage map to predict high-risk areas.
– **Web Search Results**: Information from sources like SAS, MCS, and The Rivers Trust confirms widespread impact (e.g., 464,056 discharges in 2023, 3.6 million hours of sewage spillage), supporting the need to connect with affected groups. [](https://www.theguardian.com/environment/2024/mar/27/water-companies-in-england-face-outrage-over-record-sewage-discharges)[](https://www.sas.org.uk/water-quality/water-quality-facts-and-figures/)
If you need assistance drafting outreach emails to these associations or refining your FOIA follow-up, let me know!
USP
To secure our initial engagement, we will deploy the below-threshold direct award tactic. Our USP will make the case that COCOO is the only logical choice for an initial, highly specialised scoping study, thereby justifying a direct award. Our argument will be that our proprietary methodologies and the deep situational knowledge gained from our months-long investigation constitute a unique intellectual property. We will state that no other supplier possesses this insight and that a competitive process would therefore be a false economy. We will propose a tightly scoped “Systemic Liability Scoping Study” for a fixed price just below the £12,000 threshold. This presents a low-risk first step for the government and secures our position as the incumbent expert.
Our Unsolicited Proposal will be structured as a professional Statement of Work. It will clearly define the problem as the government’s exposure to massive, unfunded liabilities from regulatory failure. Our proposed solution will be the implementation of our proprietary framework for assessing and managing these risks. The deliverables will include a detailed report mapping their specific liabilities and a high-level implementation plan for a full redress and future assurance program. We will outline a clear timeline, detail our project team’s expertise, and offer a fixed price for the initial study. The proposal will conclude by stating our readiness to engage with their commercial department to formalise the scope of work within the appropriate government service contract, seamlessly transitioning our campaign pressure into a commercial procurement process.
Our media campaign will begin with a phase of “Factual Framing and Validation.” The first step is to publish a comprehensive White Paper on the cocoo.uk website, presenting an undeniable, evidence-based case. This document will consolidate the official Findings of Infringement from Ofwat and the Environment Agency, detail the legal implications of the Supreme Court’s rulings, and present our initial analysis of the scale of the environmental and economic damage. We will then manually curate a list of key journalists and offer them an exclusive embargoed briefing, ensuring high-quality, in-depth launch coverage rather than relying on generic press release distribution.
The second phase, “Narrative Saturation,” focuses on making the case personal and inescapable. We will produce a series of short, powerful video testimonials from the class members we identify—the shellfish farmer, the guesthouse owner, the local resident—for relentless dissemination across Meta platforms and X. This humanises the abstract data from phase one. Concurrently, we will initiate a “Digital Picket Line,” a daily campaign on X where we tag the corporate and investor perpetrators and their executives with specific, dated evidence of their failures, ensuring they cannot ignore the public conversation.
The final phase is the “Pivot to Solution.” Here, we transition from defining the problem to owning the solution. We will draft concise policy briefings based on our White Paper for members of relevant parliamentary select committees. Critically, we will create and send a formal “ESG Risk Alert” to the foreign pension funds and sovereign wealth funds that own the utility companies, outlining the severe financial and reputational risks their investments now carry. This phase culminates in the public launch of our Unsolicited Proposal, positioning COCOO as the only entity with a credible, integrated plan for resolution.
To power this campaign on a limited budget, we will use a stack of free and freemium tools. For identifying contacts, a free alternative to Sales Navigator is Apollo.io, which offers a generous number of free credits per month to find the email addresses of specific executives, regulators, and potential partners at target firms. We will use this in combination with manual LinkedIn searches to build our target lists. To manage these thousands of contacts—claimants, defendants, journalists, and partners—we will use a free CRM like HubSpot’s Free CRM, which allows for unlimited contacts and provides a central dashboard to track all communications. For mass claimant outreach, targeted Meta ad campaigns can reach thousands of affected residents in specific coastal postcodes for a very small budget. For broader announcements, we will use free press release distribution services like PRLog and openPR. This integrated, low-cost toolkit provides us with the sophisticated capabilities required to execute a national campaign and contact every relevant party effectively.
Our media campaign will be architected around a central, powerful narrative: “The Great British Rip-Off,” a story of how essential public services were handed to private monopolies that have extracted immense profits while failing in their fundamental duties, leaving communities to bear the cost. This strategy, modelled on successful campaigns, moves beyond simple reporting of failures and instead frames the issue as a systemic betrayal of public trust that demands a systemic solution.
Our campaign will have three distinct phases. Phase one is “Evidence and Exposure.” In this phase, our primary goal is to relentlessly publicise the official Findings of Infringement from Ofwat, the Environment Agency, and the courts. We will translate these complex regulatory and legal judgments into simple, powerful media assets. For example, we will create infographics showing the exact amount of illegal sewage discharged by specific water companies alongside the dividends paid to their foreign owners. For the rail failures, we will map chronic cancellations on coastal lines against fare increases and public subsidies. This phase is not about making allegations; it is about amplifying the adjudicated facts to establish an undeniable record of failure.
Phase two is “Humanisation and Coalition Building.” Here, we will shift the focus to the victims. We will work with local media in affected coastal towns to feature the stories of the people we have identified: the shellfish farmer whose business was ruined, the hotel owner whose bookings have plummeted, the family whose local beach is a no-go zone. We will create a series of short, high-impact video testimonials for social media. Simultaneously, we will formally invite allied organisations—from environmental charities like Surfers Against Sewage to business groups like the National Federation of Fishermen’s Organisations—to join our public coalition, demonstrating a united front of opposition.
Phase three is “Accountability and Solution.” In this final phase, the narrative will pivot towards our proposed resolution. We will publicly launch our Unsolicited Proposal, framing it as a credible, expert-led plan to fix the broken system. We will target financial news outlets like the Financial Times and The Economist with opinion pieces explaining how our proposed redress scheme and new compliance frameworks can resolve the government’s contingent liability crisis. The call to action in this phase will be directed at Parliament and the regulators, demanding they engage with our solution as the most efficient way to end the crisis.
To gather the class members for our collective tort claim, our digital campaign will be targeted and platform-specific. On Meta platforms like Facebook, we will use geo-targeting to run video ads in the specific coastal communities most affected by pollution and rail failures. The call to action will be direct and empathetic: “Has your community been harmed by sewage pollution or failing train services? You may be entitled to compensation. Join the collective claim.” This will lead to a dedicated, secure page on the cocoo.uk website where they can register their interest. On X, our campaign will be more aggressive, tagging the specific water and rail companies, as well as regulators and politicians, in posts that highlight their failures and our campaign’s progress, using targeted hashtags to galvanise public anger and direct new claimants to our registration portal. On LinkedIn, our approach will be professional, targeting employees of affected industries like tourism and fishing, as well as legal and environmental professionals, inviting them to join the claim or support the campaign by sharing our detailed reports and analyses. The consistent goal across all platforms is to channel widespread public anger into a structured, powerful legal action.