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Bathing Waters Update

Bathing Waters UpdateWe did a very detailed article on the looming Bathing Waters disaster in 'All Going Swimmingly?'

That article is fine for technical detail, (including an easy to follow table that shows the comparative standards). But we thought it was time for a simply-worded review and update of the situation - so here goes....

The EU has introduced more stringent requirements to improve the quality of bathing waters. This is commonly known as the rBWD (revised Bathing Water Directive) and this has been incorporated in UK law by regulations.

There were three main changes as a result of new legislation.

  1. The type of bacteria being measured has been changed. Rather than measuring total coliforms and faecal coliforms, the test became more specific and now measures a specific bacteria called Escherichia coli and also intestinal enterococci (the latter being faecal bacteria of the genus Streptococci).
  2. The rules for the sampling process changed
  3. There is a new classification system to replace the current one

From the start of the 2012 bathing season the Environment Agency has collected and analysed water samples using the new (specific) E Coli and intestinal enterococci markers that they are required to use by the revised Directive

BUT, (most confusingly), until 2015 they are aggregating the new sample results under something akin to the former "Guideline", "Mandatory", and "Fail" system which (even more confusingly) the EA now calls "Higher Quality", "Minimum Quality", and "Fail".

As if that wasn't confusing enough, there will be another change of nomenclature from 2015.

After that date, the results will have to be published (as well as collected) under the specific requirements of the revised Bating Water Directive, and there will be four (new and different) classification categories.

These new classifications will use a four-year rolling data-set to produce results for each subsequent year.

It sounds complicated, but it's not really.

Four years on from the 2012 season, ie from 25 March 2015, the first of the results using the new classifications will have to be published.

These new (EU Specified) category classifications will be:

  • 'Excellent' (approximately twice as stringent as the current 'Guideline' standard);
  • 'Good' (similar to the current 'Guideline' standard);
  • 'Sufficient' (approximately twice as stringent as the current 'Mandatory' standard), and
  • 'Poor' for waters which do not comply with the Directive's standards.

When the first results using the new four-year rolling classification are published (ie from March 2015), if a bathing water has been classified as "Poor", it means a sign must be displayed at the bathing water which advises against bathing. It is the equivalent of the present "Fail"

Going forward, if five consecutive "Poor" classifications arise from the rolling dataset at any time, (ie potentially at any point from the start of the 2020 bathing season onward), then permanent advice against bathing must be displayed at the bathing water.

As if the Environment Agency's own changes were not already confusing enough, and although they are undoubtedly well intentioned in this matter, it is unfortunate that the Marine Conservation Society is currently using a different system and confusing things further.

It says on its website "The Good Beach Guide uses water sampling data collected by the UK environment agencies and local authorities during the previous summer (i.e. Good Beach Guide classifications for 2014 are based on results of samples taken during summer 2013) to assess water quality at beaches against the following standards, from best to worst water quality:"

But first of all, they have also added their own (higher) category above all the others.

After that, they have used the pre-2014 definitions of "Guideline", "Mandatory", and "Fail" (presumably because they're referring to the samples taken in 2013 when those were the way it was measured).

So the bathing water classification shown on the Marine Conservation Society website is:

  • MCS Recommended - excellent water quality
  • Guideline - higher water quality
  • Mandatory - minimum water quality
  • Fail - did not meet the minimum water quality standard

They also have a 'disclaimer' which says: "Our standards are based on the European Bathing Water Directive (76/160/EEC), but our results are not the same as those published by the UK Government and devolved administrations. We award some beaches our MCS Recommended standard for excellent water quality and we include any UK beach sampled for water quality, even those not legally required to comply with the Directive's standards."

Clear as mud.

So, if we try to make sense of the smoke and mirrors that are being set out all around us - and we use the results for the 2013 bathing season which were published in March, at the start of the start of the 2014 season, we find

The Environment Agency says
'St Annes' and 'Fleetwood' beaches were designated as "Fail"
St Annes North, Blackpool South, Central and North, Bispham and Cleveleys were designated as "Minimum Standard"

The Marine Conservation Society says
=========== ====================
St Annes and Fleetwood were designated 'Fail'
St Annes North, Blackpool South, Central, North, Bispham, and Cleveleys were designated 'Mandatory'

However, (despite trying to confuse us with different terms) these folk are ALL using the pre-2015 nomenclature and classification systems.

If the new (2015 and onward) classification and nomenclature had been applied to them, it would have been roughly twice as hard for 'St Annes' and 'Fleetwood' to pass muster than it has been up to now.

There is, in our opinion, no prospect at all of St Annes Bathing Water (and probably Fleetwood as well) having anything but a 'Poor' classification from 2015, and that means a notice which advises against bathing in the sea next year.

After four years of such results, if no further improvements are made (and it's difficult to see how the water quality here can be improved by double or more), then permanent advice against bathing will have to be displayed at these bathing waters probably from spring 2019 or 2020.

The other local waters in this part of the world (St Annes North, Blackpool South, Central, North, Bispham, and Cleveleys) are currently designated as 'Mandatory' (if you're the MCS) or 'Minimum' (if you're the EA), and that classification gets them off the hook at the moment

But during this year they will have to improve by a factor of roughly two times just to stay where they are now, and keep out of the "Poor' category that will be applied from 2015 onward.

We can't see that the volume of storage tanks that are being currently built will do enough to prevent these waters dropping into the 'Poor' category, so we're very pessimistic about the future.

By the start of the 2015 bathing season we think some of the beaches that are presently designated as bathing waters along the Fylde coast will either be de-designated for bathing, or they will have signs put up advising people not to bathe.

De-designation in the North West has already begun. The process involves producing evidence to justify the removal of status as a bathing beach. The most recent is 'Askam in Furness' under Barrow Council.

There, it was shown that "the warning signage at the beach, together with the absence of facilities and of any references to Askam in Furness as a bathing beach, confirms that the local authority does not promote it for bathing. Dedesignation would support the council’s work to discourage the public from bathing at the beach. Askam in Furness will be removed from the list of bathing waters with effect from the 2014 bathing season on the grounds of concerns about public safety and low usage for bathing."

We think most of Fylde's beaches would be difficult to justify for de-designation, so by 2019 or 2020 it is quite possible there could be permanent signs warning people against bathing here.

But there's another trick being tried as a workaround. It is to reduce the length of the 'Bathing Season' in the UK (if you shorten it at either end you get further from the sort of weather that causes combined sewers to overflow and sewage to discharge).

The Government recently consulted on reducing the season,  offering the following as options for comment:

  • Retain the existing season length;
  • Allow flexibility where individual sites could set their own dates, based on usage;
  • Regional seasons, based on Environment Agency regions;
  • A longer season (e.g. 15 April – 31 October);
  • A shorter season (e.g. 1 June – 31 August).

The results were (probably) not what they had hoped for.

Only 2.5% of respondents opted for a shorter season.

4.7% opted for 'no change', and the 'regional season' was supported by just 7.6% whilst a 'flexible season' was supported by 12.8%.

But dwarfing all of these was a massive 72.4% opting for a LONGER bathing season.

This preference is three times all the other preferences combined, and almost certainly not what Government wanted to hear.

Thankfully, (unlike some of the surveys Fylde BC has done), Government didn't simply ignore it and go ahead anyway, they are doing an 'Impact Assessment'  and we'll no doubt hear more when that is completed.

There's also another little workaround that's being prepared. We understand that permanent advice against bathing can be introduced earlier than the statutory timetable if it is thought that the achievement of the ‘Sufficient’ categorisation would not be feasible, or if it would be disproportionately expensive.

Those last two words could yet become quite significant.

Finally, there's another last ditch attempt to hide, rather than fix, the problem.

As well as wanting to clean up the water quality, the EU Bathing Water Directive also makes sure the public is well informed about the results.


But now we hear that some of the North West beaches might use a scheme called "Short Term Pollution", or STP, to help manage the bathing water in 2014.

This means if there is heavy rain, and water quality is predicted to be poor for up to 72 hours, FBC will be notified, and will put a sign up at the beach letting visitors know, and advising people against bathing and paddling during that time."

We don't have the wording for this sign, but we hope it isn't something like...

"Sorry you came to the beach today because we're likely to discharge untreated sewage into the water on account of the recent heavy rain, so it's not safe for you or the little ones to paddle or swim in the water. Hope you can come back to our lovely beach when the weather's better or when we've fixed the sewage problem properly."

Dear God what on earth are these people thinking about.

They need to solve the problem, not avoid it!

We think the problem is really going to be quite bad - and you don't have to take our word for it.

Each year the Environment Agency assesses what the classifications would have been, if the new standards had already been in force, using data from the previous four years. To be fair, these results do not take into account the actions being taken between now and 2015 to improve water quality, but you can follow this link to download the most recent (November 2013 pdf) report. You'll have to scroll through to the end to see the plethora of red 'Poors" that are the North West.

And we don't for one minute believe those attempting to play the 'get out of jail' card that says it's all down to sheep and cows (and even seagulls for heaven's sake) - don't these creatures also exist around other estuaries and beaches in the south of England where results are much better? Doesn't farmland in the south and east drain into rivers there? Are not the saltmarshes in the south managed as they are here, with sheep grazing? Does cow and sheep poo not get washed off the saltmarsh in the south?

Of course they do, yet most beaches in the rest of the country are MUCH higher quality than the North West.

Nor are we taken in by the smoke and mirrors of the 'Love your Beach' clean-up sessions - whose purpose is chiefly to divert attention from the fact that insufficient resources have been put into solving the water quality problem. 

No amount of well intentioned litter pickers can pick E coli out of the water - however good they are!

And it's bacteria that are the sole measure of water quality.

'Love Your Beach' is undoubtedly a good thing, but it is simply a deliberately devised distraction technique to make it appear that things are being done to solve the water quality problem when they are not.

The failure to meet the requirements of the rBWD will have potentially catastrophic consequences for the local tourism industry, not so much because of the advice against (or even the prohibition of) bathing (because not that many people actually come here to swim), but because of the PERCEPTION that will attach itself to this area for being an unclean and unhygienic part of the country to visit.

And that has ramifications far wider that holidaymakers.

A perception of the Fylde as an unclean and unhygienic area will impact on all manner of other industries - food and milk and cheese production and so on.

We've been banging on about this problem for years, and in our view, because the scale of what needs to be done would eat heavily  (and we imagine they think, unacceptably). into the profits and shareholder payments of United Utilities, not enough has been done to fix it.

We remain convinced the real cause of the problem is a lack of sewage transport and treatment infrastructure to cope with storm water volumes in combined foul and rainwater sewers.

The short term workaround for this problem is to build massive temporary storage tanks, and UU *is* building them - but not enough of them are being built to hold the predictable storm water we get.

Ergo, combined sewers will continue to discharge - as they do now just offshore of Fairhaven Lake - and bathing waters along this coast will continue to fail the EU requirements as raw sewage from combined sewer overflows discharges into rivers and directly the sea.

United Utilities should at least have built more storage tanks.

The Environment Agency should have pushed them into doing so.

And local Councils should have applied FAR more pressure than they have to ensure the EA did its job.

Although this issue has been to Fylde's Scrutiny Committee and they have at least tried - probably better than anyone else on the Fylde coast - to get some action moving, they have not managed to convince those responsible to take a strong enough stand.

We also believe Fylde has been badly let down by the officers responsible for these matters who do not seem to have wanted to grasp the nettle and warn the elected members of the seriousness of the situation.

Like Nero fiddling whilst Rome burned, the officers trot out an "It'll be alright on the night' message.

But it's not going to be alright.

Those responsible for such matters at Fylde are the Cabinet Portfolio holders for:

Environment and Partnerships - that's Councillor Tommy Threlfall, and

Leisure and Culture - Councillor Susan Fazackerley

Instead of standing up for the tourism industry, Fylde has been complicit in a scheme that lets each level of responsibility hide behind a QUANGO or some form of joint committee so that individually they can put hands on hearts and say "not me guv! - it was them!" and no one will be able to hold them accountable.

Dated:  13 May 2014


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