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Fiddling Fylde's Figures

Fiddling Fylde's FiguresIt's the bathing waters again.

But before we start on that story, we've got a conundrum for our readers.

We want you to think back to your school days, and answer the following question....

Q: How can you fail an exam - but pass it at the same time?

Ans:  When your examining body discounts the questions that had the wrong answers.

Now, if that had actually happened in our education system, the regulatory body would (rightly) be severely censured.

People would lose trust in what the regulator was telling them.

Yet that is exactly what the Environment Agency is doing.

They're fiddling the figures for Fylde to make the results look better.

And, as you read this article Dear Reader, - remember  that it is the same Environment Agency that is supposed to be regulating what the would-be fracking industry may do to our environment.

So what's going on with the bathing waters?

Well, we've been banging on for years that Fylde's bathing waters were going to fail to meet the required standard next year, and we predicted we would see signs going up advising people not to swim or paddle in the sea.

That was, and is, true.

But it's not now going to happen in St Annes.

It won't happen because the Environment Agency has fiddled the figures for Fylde.

They have asked (and apparently received) permission from the Government not to count the samples they took for two of the four years that they have been required to take samples under the Revised Bathing Water Directive.

Instead of counting the 80 samples they have taken over the four years (the results of which would have shown the bathing waters failing as we predicted) they're only going to count 40 samples, and these 40 will probably show that the bathing waters have passed, because it is the samples they are choosing to ignore would have made the beaches fail.

Both Fylde and Blackpool councils have issued triumphal press statements on the back of this, to make us think that everything is fine and dandy.

Councillors were also busy congratulating themselves at last Thursday's Community Focus Scrutiny Committee.

Fylde's press release said "But extra good news was given last night to councillors on the Community Focus Scrutiny Committee: both beaches (St Annes and St Annes North) look set to pass the far tougher Revised Bathing Water Directive (RBWD) tests when they are introduced in 2015.

The Environment Agency now predicts that the St Annes beaches will pass the new tougher standard with a “good” rating.

Councillor Sue Fazackerley, Fylde Council interim leader, said: “This is excellent news from the perspective of both residents and tourists.

“Bathing quality is clearly higher than ever and that is great for our reputation with visitors. We look forward to another excellent summer in which visitors and residents can enjoy Fylde’s clean sea and beaches.”

St Annes North beach achieved a higher level pass while St Annes beach achieved a pass - putting them on a par with some of the best coastlines in the country.

The results are based on weekly samples taken by the Environment Agency between May and September each year.

Councillor Tommy Threlfall, Fylde Council cabinet member for Environment and Partnerships, said: “We are delighted that both our beaches have passed both the UK’s tests and the EU’s new Revised Bathing Water Directive.

“Good quality bathing water is important to residents and vital for our tourism industry and tourism-related jobs.

“For a long time now, bathing waters in Fylde have been improving strongly and these latest statistics show it."

Blackpool's press statement said:

"The Environment Agency’s official statistics have today revealed that all eight bathing waters passed this year’s Bathing Water Directive in the peninsula’s best results since 2005"


"From next year, under what’s called the revised Bathing Water Directive (rBWD), the results will be based on bathing water samples taken over the previous four years, with new classifications awarded. These are Excellent, Good, Sufficient and Poor. These revised classifications will be displayed on the existing bathing water information signs from 2016.

In a new move, EU regulations will also require those bathing waters which are classified as ‘Poor’ to display a sign advising against bathing.

Four of the Fylde’s bathing waters – Bispham, Blackpool South, St Annes North and St Annes - are now predicted to pass the revised directive next year."

"Cllr Fred Jackson, Blackpool Council’s cabinet member with responsibility for sea water quality, said: “Today’s announcement is excellent news and I’m delighted that every bathing water in Blackpool has passed this year’s sampling. We are beginning to see the results of some large improvements undertaken by the partners of the water management group that are having a direct impact on the quality off the water off the Fylde coast."

As our readers might gather from reading between the lines of these press statements, Councils are still using the deceptive doublespeak and spin that has become the hallmark of local government since it started to employ spin doctors to improve its image.

They will happily concentrate on the good news, but what they are not keen to tell us is that whilst all 8 beaches passed this year's version of the tests, the tests are not just for one year, they are taken over a rolling four year period.

So one year's worth or results count for nothing except a quarter of what is being measured.

And, furthermore, from next year the tests will become at least twice as hard to pass, so


  • Blackpool, 

  • Blackpool North, 

  • Cleveleys and

  • Fleetwood.

But it's likely that St Annes, St Annes North and Blackpool South will now pass, and Bispham will be borderline either way.

So what's really going on?

How can (as in St Annes) some results be 'ignored' and passes awarded to them?

Well, at the bottom of this story is United Utilities, the commercial business whose job it is to comply with the legislation and to provide the infrastructure to do so. They carry ultimate responsibility for water quality.

They are monitored and regulated in this endeavour by the Environment Agency (which is itself ultimately responsible to the relevant Secretary of State). The EA is not part of the Government, but neither are they wholly separate from it.

The essence of the story is that, in the whole of the UK - excepting for the North West - the various water companies in their respective areas had done enough work to ensure that almost all the beaches met the revised bathing water standards. In fact, beaches up and down the coast away from the North West are all getting excellent results.

But in the North West, our water company - United Utilities - had not done enough to meet the same standards that were applied to other areas of the UK.

The North West has by far the greatest number of failing bathing waters.

There are no doubt reasons for this: the water company started too late in making the improvements; or they have not done enough in the time they had; or there was a bigger problem here than elsewhere because of the industrial revolution and mass housing in industrial East Lancashire; or because we're one of the wettest areas of the UK.

No doubt issues of this sort have contributed to the reason for failure, but nevertheless - and despite the huge sums that United Utilities have undoubtedly spent on making improvements - our beaches in the North West have not met the tests that everyone else had to meet, and they were destined to fail.

Bad news all round.

We think there must have been some serious discussions between United Utilities and the Environment Agency about how this would look for both of them (and, indeed, for the Government in an election year),

We think this because, as they are the 'policing' authority, the Environment Agency should normally have published a 'fail' prediction for all the Fylde Coast beaches on 6th November this year

In fact, up to 17th June this year, that's exactly what they were predicting for all Fylde Coast Bathing Waters except Bispham, as we showed in our article 'Bathing Waters Set to Fail'

But instead of publishing an embarrassing 'Fail' result, they instead asked the Government to let them, and United Utilities, off the hook, and have published predictions for some fails and some passes.

Those Bathing Waters closest to the River Ribble, (for which 50% of samples are being discounted), are now predicted to pass, and for the remainder there will be fails, (except that no one is sure whether Bispham will comply or not).

The discounting comes about because 'Regulation 10' of the Bathing Water Regulations 2013 requires

10 (1) At the end of every bathing season, for every bathing water, the appropriate agency must—

  • (a) prepare a set of bathing water quality data for that season; and
  • (b) carry out a bathing water quality assessment using the set of bathing water quality data compiled in relation to that season and the relevant assessment period.

10 (2) In this regulation, the “relevant assessment period” is -

  • (a) the immediately preceding three bathing seasons;
  • (b) the immediately preceding two bathing seasons, if the appropriate agency so determines in accordance with paragraph (3); or
  • (c) the number of immediately preceding bathing seasons, being less than three, that the appropriate agency determines in accordance with paragraph (10 - 4).

10 (3) The appropriate agency may make a determination under paragraph 10 (2) (b)  where -

  • (a) it has consulted the appropriate Minister; and
  • (b) it is at least five years since the last change in the relevant assessment period.

10 (4) The appropriate agency may make a determination under paragraph (10 - 2)(c), if -

  • (a) it has consulted the appropriate Minister;
  • (b) the set of bathing water quality data used is based on at least 16 samples; and
  • (c) it considers that any factors identified in the bathing water profile as likely to affect the classification of the bathing water under regulation 11 have changed, and the set of bathing water quality data used is based only on samples taken since those factors have changed."

And this is what they have done.

They have asked and (it appears ) received, permission from the Government to re-set the date at which they start counting the test results.

The Environment Agency has argued is should be allowed to do this because the work United Utilities did in Preston to improve seven combined sewer outfalls and other works, has changed the River Ribble 'catchment area' to such an extent that it has fixed the problem for St Annes and Blackpool South.

We suspect they will also have argued or at least implied that the better test results during 2014 are further evidence of this.

We don't agree.

The reason the 2014 bathing season results are good is that - as everyone knows - it has been an exceptionally good year for weather, with hardly any periods of heavy rain and no storms to speak of in the bathing season. That means there have been less instances of combined sewers being overwhelmed by heavy rainfall, and that means less need to discharge raw sewage onto the beaches.

To (mis)paraphrase Bill Clinton "It's the weather, stupid"

Furthermore as we have said from day one, (and despite the denials from the Environment Agency), we remain solidly convinced that the problem for St Annes and, to a lesser extent St Annes North, is the Fairhaven Sewage Treatment works just north of Fairhaven Lake. It's not sewers in Preston.

More specifically it's the 'Mushroom' just off the Fairhaven sea wall (which is connected to the treatment works).

Whenever there is heavy rainfall and the treatment works can't cope, the valves open, and raw, untreated, sewage flows out of the mushroom and into the sea - because there is not sufficient storage capacity in the system - and the pumping station would otherwise be overwhelmed with sewage.

Ergo, sewage on the beach at St Annes.

We also don't agree because of what the Environment Agency said on this matter previously.

As we reported in 'Testing the Water'  part of the application for permission to site a sea-bed testing rig off Harrowside in Blackpool earlier this year, saw United Utilities say "the Environment Agency has identified four Unsatisfactory Intermittent Discharges (UIDs) in the Poulton area leading to predictions that by 2015 the majority of the Fylde bathing waters will be classified as ‘poor’.

So at that time, they didn't think the bathing waters would pass, and specifically, they obviously didn't think the work at Preston was going to fix the problem at that time, (because they thought  the problem was at Poulton).

So we think the Environment Agency's road to Damascus runs via Expediency rather than Accuracy.

In another, separate and different move about the bathing waters, the Environment Agency has also been working with Fylde Council to identify instances of what it calls short term pollution risk, and Fylde has been putting up signs when a pollution incident has occurred.

These signs are located at the deckchair stand near the Pier, and at the disused public lavatories on North Promenade Car Park, and at North Beach Car Park.

These pollution instances are where the pollution event lasts for up to three days - which doesn't sound a lot, but Readers might like to bear in mind how much sewage can actually be pumped out in three days....

Figures we obtained from United Utilities via the Environment Agency showed that on 11 December 2011 at 11:20  (that was the most recent figure available at the time) a discharge of 35.5 hours took place from Fairhaven Wastewater Pumping Station.

And during that time, an unbelievable 1,355,000 cubic m was discharged.

That's almost 300 million gallons of raw sewage discharged into the sea.

We queried the figure with the Environment Agency (because we simply couldn't believe it). At first they said it must be wrong and referred us to United Utilities who told us they had a record of one event on 7th December which was a 15.1 hour discharge of storm sewage resulting in a volume of 12,500 cubic metres. That's 2,749,615  - which is a much less, but even 2 million gallons is still a lot of sewage.

But then the person who had recorded the data on the Environment Agency system was consulted about the discrepancy, and he said the figures they had provided to us on a spreadsheet were exactly the figures that had been supplied to the Environment Agency by United Utilities, and he stood by them.

Either way, a 72 hour pollution event from Fairhaven IS likely to make a mess of the beaches in St Annes, isn't it?

Fylde's Officers' report to its Community Focus Scrutiny Committee on Thursday night said:

"Where pollution risk forecasts have coincided with statutory bathing water sampling and if all conditions are met there is a potential for discounting samples at the end of the 2014 season. No more than 3 samples can be discounted in a bathing season. The Environment Agency is expected to announce where samples have been discounted in accordance with Article 3(6) of the bathing water directive on the 6th November 2014."

So as well as discounting two years worth of test results, the Environment Agency may also be discounting the very samples that would mean the water should fail.

It was the late Alan Clarke MP who famously coined the phrase 'Economical with the actualité'  wasn't it?

The Government clearly didn't expect to have to agree to fiddling the figures.

In its (now archived) note, called Bathing waters and the Bathing Water Directive' the Government said "We will keep a watching brief on developments and costs in predictive tools to assess whether a system may be possible in the future, but in the medium term we will be unable to fund the Agency or external proposals for development of such a system. It is therefore very unlikely that the first classifications in 2015 will include discounting of samples."

But it looks as though the Government and the Environment Agency has had to change their mind. because they ARE going to discount half the samples, and may discount another three per year.

We should probably make clear at this point that it's not Fylde Council who are fiddling the figures here, it's higher up the chain.

That said, we've no doubt Fylde's officers have been party to much of what has gone on, and they won't have been too unhappy that their skins were being saved by the numerical massaging that the EA was proposing.

The presentation Fylde's officer's made to the Community Focus Scrutiny Committee last Thursday was very much a report of what they saw as good news.

We agree that it is good that we will probably not have to put signs up advising people not to go in the sea in St Annes next year.

But it's not good that the reason this is happening is because the test results are being massaged to avoid what was inevitably going to be bad news and signs going up

Not is it good news that our seawater hasn't been cleaned up as it has been in other areas around the UK.

But what the figurative manipulation will do, is to buy United Utilities and the Environment Agency more time to put things right that should have been done way before now.

United Utilities capital spending programme - called AMP6 - is already funding the extension to the Harrowside sewage outfall. This will take the sewage so far out to sea that it won't get back to shore (they hope).

We can't see that it can ever be right to discharge sewage into the sea, but there we are. The testing rig off Harrowside (pictured below in the summer) has done its survey work and moved on.

Testing rig off Harrowside

The AMP6 programme will also fund a huge storage tank at Anchorsholme to give some relief to Bispham and Cleveleys.

But Fylde's Scrutiny Committee Chairman Kiran Mulholland wanted some of the AMP6 action for Fylde.

We've been impressed with his grasp of the bathing water issue, and we believe he knows a lot more about what's actually going on than he lets out.

He said during the meeting "....I'm sorry but I still don't want poo in the bathing water. I don't bathe, I'm not going to bathe in the sea here. My dog doesn't play in it. But I still find it distasteful. I find it quite barbaric that we're pumping out human excreta, I'm not too bothered about the donkeys and seagulls, but I find it barbaric. There's got to be a better way of doing it."

As the debate on the Bathing waters at Fylde drew to a close he sought and received the support of the committee to add a rider recommendation to that of Fylde's officers, to the effect that Fylde should ask for the Fairhaven Wastewater Sewage Treatment Works, and the Park View Playing Fields Pumping Station to have real-time monitoring of sewage discharges installed as part of the capital works in AMP6, so that actual discharge dates times and volumes could be better known.

We think he knows - just as we do - from our own histories and experience, and from anecdotal evidence, that Fairhaven is where the problem lies for St Annes beaches, and he's on-track to have something done.

He, above all others, has grasped this issue and has ensured Fylde's concerns and needs on this matter have been publicised.

Cllr Tony Ford asked for some more stringent relationship to be established between drainage issues and Fylde's emerging local plan, but his ideas didn't get taken forward.

We thought that was a shame, because when you ask yourself why it is that we are having such problems, the bottom line answer is that there appears to be no properly quantified relationship between additional housing development and the provision of additional drainage infrastructure.

This is a fundamental flaw in the planning processes. Neither United Utilities nor the Environment Agency has the power to prevent development because the sewer and drainage network is at, or over, capacity. They are specifically prevented from doing so by law.

That is a nonsense.

Belatedly, something is being done about the rate at which surface water drainage exits new developments, but that's also in a complete mess at the present time, with no-one performing checks on what rates of flow are actually taking place. And it's going to get even worse shortly, as we'll be discussing in a future article on flooding.

But the issue of flow restriction has so far only been applied to surface water drainage.

We are not aware that there is yet any move to restrict the flow of sewage to a more manageable rate. So more houses = more sewage in the system, and this inevitably means more problems.

But even Cllr Ford's point didn't hit the great drainage omission in Fylde's planning system - and that is a complete policy failure to prioritise Brownfield land over Greenfield land, as set out in the joint action plan 'Improving Our Bathing Waters' to which Fylde has signed up.

The Scrutiny Committee was told how well the Action Plan's 10 points to improve bathing waters across the Fylde Peninsula had been met.

It was said that 8 of these 10 points had achieved a 'Good' classification showing satisfactory progress.

We'd take issue with most of this assertion as far as Fylde is concerned, but there's not time to go into them here.

The two that were especially not good were: Point 7 - Creating 50 Ha of retro-fitted Sustainable Drainage, and Point 8 - prioritising development on Brownfield land.

These involved (chiefly) Council owned land having existing drainage systems changed to Sustainable Drainage (which slows the rate of surface water discharge and thus eases pressure on the older combined sewers). Fylde could report no contribution to this aim.

But more importantly, the target that Wyre had formally adopted - to deliver 60% of its development on Brownfield (previously developed) land - has been all but abandoned as far as Fylde is concerned.

The Environment Agency and the Water Company wanted this to happen because - as they said "Brownfield land should be prioritised for new development over Greenfield land. Development of existing Brownfield land presents an opportunity to reduce surface water runoff more than could be achieved through development of Greenfield land. It will also help to limit the discharge of wastewater to pre-development rates. This will lead to less surface water entering the sewer system and limit the wastewater generated."

Fylde's current policy is the complete opposite of this. It seeks to prevent redundant industrial land being used for housing. So although Fylde is a partner in this scheme, they don't seem to plan to change their policy anytime soon.

Reporting the lack of progress on this, Fylde's officer pointed to some development that *was* taking place on Brownfield sites (Pontins, and the former GEC Marconi site being prominent examples) and mumbled something about 'unrealistic targets' while completely omitting to address the policy issue on which Fylde is failing even to set a target, let alone achieve it.

So there we are. The targets are in a document that now appears to have been removed from view on the Internet, but we have a copy of the document if anyone wants it.

As far as the bathing waters are concerned, it's almost certain that, as a result of the test dates being  fiddled with - so as to exclude half of the sampling that should have counted - St Annes and St Annes North beaches will pass next year.

Sadly, Blackpool, Blackpool, Blackpool North, Cleveleys and Fleetwood beaches still look set to fail.

If any of our readers wants to see the raw details of this, they can be seen on the Environment Agency website for

The raw data for the other beaches is available from the 'Bathing Water Data Explorer' then enter the name of the beach you're looking for (or use the clickable map). This will open the dumbed-down 'Idiots Guide' to bathing waters, but if you look carefully under the heading 'Bathing water quality results' the text says  'Recent results from water quality assessments under the Bathing Water Directive appear below, or view more details of assessment results'

That  'or view more details of assessment results' is actually a link to the underlying data, but it's well hidden and you have to mouseover it to know it's a link.

We also have  our own version of the EA sampling data for St Annes sample by sample and that's available here for

So - for our holiday resort in the future, we think a lot will depend on the weather. Two bad years have been knocked off, and the clock has been re-set to start from 2012 rather than 2010. And it may be that the three worst samples in each year have been discounted as well.

So it's now all going to be down to what happens after the fiddled figures come on stream.

Unless arrangements at Fairhaven are substantially changed, and assuming the weather is as unkind to us as it has been in previous bathing seasons, we suspect the results will once again move into failure, as future years are taken into the accounting for St Annes.

Dated:  10 November 2014


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