Our Response to Defra Consultation on Bathing Water Regulations

The consultation is open so please do respond

This is the Ilkley response summarised in case of any use for you

Our response:

Please note the purpose of the Bathing Water designation is to provide testing to alert the public who use the water way to the water quality so they can decide if they want to use the water recreationally; and to clean up water ways that are a public health hazard to people accessing the water for recreation. The impact to be assessed should be in relation to water quality and reduction in risk to the public; not on the financial impact to any businesses – which totally misses the point of the  Bathing water process.
We are a community organisation trying to clean up our river so it is fit for people and wildlife. Every year we have children sick from paddling, playing and swimming in the river, with instances of hospitalisation. Starting this consultation with a focus on financial impact is a disgrace.

The de-designation review should remain 5 years but the site should not be de-designated if there is action being taken that will clean up the waterway. Lengthening the period will reduce the imperative to clean up waterways that have been shown (by virtue of the designation) to be used recreationally by hundreds of people. Using the Ofwat Accelerator programme it is possible to secure infrastructure to deliver safe water. In Ilkley, the new infrastructure to clean up our river will have started within the 5 years, but it wont be delivering better water quality for at least another year. If de-designation is lengthened people and wildlife will be at risk, and there will be no motivation for cleaning up the waterway. The only reason 5 years was in question was the AMP review was too long.

The purpose of Bathing Designation is to protect people where they use the waterway by providing water testing and signage to inform the public of the water quality. It reflects where the waterway is being used regularly by significant numbers of people. This should trigger a clean up of pollution and no waterway should be exempt from this. There are no reasons that a waterway cannot achieve sufficient. We can only assume the ‘feasibility’ this consultation proposes is financial feasibility. Given all waterways should be safe for people and wildlife, there should be a plan for all rivers, lakes and seas to be at sufficient.

If a site is being used by the public for recreational purposes there is no reason not to secure water quality. You have not identified what you mean by feasible, but it is definitely not feasible to pollute our water ways for profit to the detriment of the health of our rivers, lakes and seas

People use rivers lakes and seas for recreational purposes all year round. The designation should reflect actual usage.

1.Water users. The original guidance (when we applied as the first designated river) was for people paddling, playing and swimming in the water, and we had to count adults and children separately – it was not for swimmers only. The adoption of swimmers as the definition is a recent change. The original definition should be reinstated, and extended to include any water user coming in contact with the water as they need to know the pollution risk.

The definition should just be any recreational user who has contact with the water and could ingest the water. You don’t need to specify types of water user, it makes it overly complicated.

Monitoring is to inform and protect the public. Rivers are moving watercourses, and the bathing stretch may have polluting outflows  eg CSOs along the stretch, which affects water quality. In Ilkley the top of the Designated Bathing water stretch is safe for the public when it hasn’t rained, and poor quality when it has rained; but downstream below the sewage works it is unsafe in any conditions because of the pollution from treated sewage. Testing must take into consideration where the public accesses the river, and th sources of pollution, putting in a testing regime that reflects this.

Ilkley is the first designated river bathing water. We have provided evidence over the last 4 years, letters to defra, seminars and briefings. These all reflect the issues identified in this consultation. We can re-provide these if useful.
Please also take into consideration the application process. Local authorities know where people use the waterways, they provide car parking, lifesaving equipment etc. Rather than the public spending a whole summer counting people to apply for testing and signage, you should just ask LAs where there are stretches of water being used recreationally and designate those. The current application process is unnecessary bureaucracy.