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Don't Go In The Water

Dont Go In The WaterLast week's Gazette carried the banner headline 'Warning Signs' together with sub-heads saying 'Resort beach water set to be branded poor' and 'Signs go up warning bathers from next year' and 'Move a major blow for trade'

A second article a few days later had some very clear descriptions of the technical aspects.

counterbalance readers will know all about this of course, and it will come as no surprise to them. We've been banging on about this for almost three years.

Our coverage of this topic has been....

The Gazette's first of two articles reported the Environment Agency as saying that signs will need to be placed at Blackpool North Beach ahead of the 2016 bathing season because the water quality will fail to reach the standard and will be classified as 'Poor'

The EA also believe the same fate awaits Blackpool Central, Fleetwood and Cleveleys bathing waters.

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

This is done over a rolling four year period, so there are 20 samples a year per beach, giving a rolling 80 sample dataset of results.

The tests measure the volume of two sorts of bacteria (Intestinal enterococci and Escherichia coli)

Coliform bacteria come from colons, the endgame of food digestion. They are universally present in large numbers in the faeces of warm-blooded animals.

While coliforms are themselves not normally causes of serious illness, their presence is used to indicate that other pathogenic organisms of faecal origin may be present. Faecal pathogens include bacteria, viruses, or protozoa and parasites.

In seawater, coliform bacteria are a signal that excrement is, or has recently been, present in the water in significant quantities.

According to the Environment Agency, coliforms, faecal coliforms and faecal streptococci (the main bacteria involved) are not directly harmful but they "indicate the presence of pollution". However, we doubt that sort of advice would go down well on a novovirus-ridden cruise ship, or even a hospital ward for that matter.

To borrow (and mangle) a metaphor in order to simplify this, where there's muck there's potential for sickness. And the bacteria are the markers for muck.

From March 2015 (when the first results using the new four-year rolling classification will be published), if a bathing water has been classified as "Poor", it means a sign must be displayed at the bathing water which advises against bathing.

To avoid this happening, (as we showed in detail in 'All Going Swimmingly') 90% of the four years of test results must all have below 185 colonies of Intestinal enterococci per 100 ml of water, AND they must have contained less than 500 colonies of Escherichia coli in 95% the same samples over the same period.

But that's not the end of the story, because, going forward from here, 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.

If this happens, the Environment Agency will stop sampling, and the bathing water will no longer be designated as a bathing water.

So readers will see that, once you get to an point where you've failed, you can add as many wonderful results in after that as you like, but you've already failed for that aggregated four year period.

That's why we have been able to be so confident about forecasting future failures. Nothing could be done to change them once the tests had been taken. (Well, apart from fiddling the figures - which is what happened in St Annes)

The Gazette goes on to say that beaches at the Fylde’s other four designated bathing waters – Bispham, Blackpool South, St Annes North and St Annes - are predicted to pass the revised directive next year.

In the case of St Annes and St Annes North beaches, that's because the Environment Agency persuaded the government to let them (as the water regulator) and United Utilities (whose job it is to actually comply with the legislation) fiddle the figures for St Annes and St Annes North beaches by re-setting the date at which they start counting the test results.

Instead of 20 samples a year for four years, they're discounting two bad years.

We reported this in 'Fiddling Fylde's Figures' last November.

We suspect the Environment Agency will have argued that works to the sewage system in Preston had delivered such a benefit to St Annes Beaches that it wasn't fair to count the last four years of samples (ie the 80 samples which included samples taken before the Preston improvements were made), so they got permission to count just half of them, and have only counted the most recent 40 samples.

We gave our readers chapter and verse on this in 'Fiddling Fylde's Figures'

We don't believe the Environment Agency's story for one minute. It's a con. We believe the reason that the figures for Bispham, Blackpool South, St Annes North and St Annes were better last year is because we had exceptionally good weather with low rainfall, so the stormwater discharges (Technically Combined Sewer Overflows) were not as frequent, and that good weather has saved the bacon for Bispham and Blackpool South.

Furthermore, a combination of that same good weather and fiddling the figures has saved it for St Annes and St Annes North.

But along with some of the Gazette readers, we HAVE been experiencing 'shock horror' on this matter but for different reasons.

Firstly, we are shocked and horrified that the Industry Regulator, the Environment Agency (and perhaps OFWAT), has been instrumental in helping the industry they regulate to discount the bad test results in order to make things look better. What sort of confidence can we have in them when they actively support the figures being fiddled like this?

That's all the more important when you think that this same Environment Agency (albeit a different branch) is in charge of regulating the fracking industry that wants to establish itself in Fylde. We've already highlighted our concerns about the way they're doing (or rather not doing) that. See 'Render Unto Caesar'

But even more than that, we've been shocked and horrified how 'The Establishment' has come together to - in our view - intentionally, confuse and mislead the public as to what was really happening.

Right back in the 'Turning the Tides' conference we began to have some doubts about what was being planned, but even we didn't grasp the scale of what was going on.

We now believe this conference wasn't about turning the tides of water cleanliness at all, it was about turning the tide of public opinion to make it look as though those who were failing in their duties were not really accountable for what was happening.

It's our view that this the 'Turning Tides Group' that was announced by platform speakers at the conference (not by a vote of the conference itself) has been playing a huge and expensive PR con-trick on us. This is a group that - whilst mostly made up of publicly elected officials or their officers, is wholly undemocratic in that it published no agenda or minutes for its meetings and it holds it's meetings out of the public gaze, in secret.

It has spawned the separate 'Love My Beach' campaign, with its friendly graphics and its dumbed down messages about beach cleanliness.

We rather liked this quote to describe what we think is going on....

"Propaganda must always address itself to the broad masses of the people. (...) All propaganda must be presented in a popular form and must fix its intellectual level so as not to be above the heads of the least intellectual of those to whom it is directed. (...) The art of propaganda consists precisely in being able to awaken the imagination of the public through an appeal to their feelings, in finding the appropriate psychological form that will arrest the attention and appeal to the hearts of the national masses. The broad masses of the people are not made up of diplomats or professors of public jurisprudence nor simply of persons who are able to form reasoned judgment in given cases, but a vacillating crowd of human children who are constantly wavering between one idea and another....."

(Thanks to Wikipedia's exposition of part of Chapter 5 of Hitler's 'Mein Kampf').

Love my Beach is a very worthwhile scheme in some ways, but we are entirely convinced it's function was primarily to divert attention from the real problems and make it look as though everything possible was being done.

The beach litter picks and so on that LmB do are very worthwhile, but there's no way on earth they can influence the level of coliform bacteria being discharged into the sea.

'Love My Beach' emanated directly from the turning Tides Partnership, and we believe it was intended simply as a diversionary tactic.

As was the trumped-up claim that the coliform bacteria causing the water tests to fail were coming from donkeys, and sheep grazing the marshes, and cows polluting watercourses, and dogs on the beach and even seagulls.

Using these as diversionary ideas has enabled those who would confound us to do just that.   People think, well, you can't do anything about sheep droppings or seagulls, so its nobody's fault really.

Oh yes it is!

Just stop and think for a minute.

Do these problems not affect every other beach in the country. Do the Essex marshes not have grazing sheep or cows. Do seagulls not fly over the sea in Paignton, or Brighton, or Bognor. Do the resident of Ilfracombe not have dogs. Do other resorts not have donkey rides? Of course they do. So why is it that over half the UK's failing bathing waters are in the United Utilities area of the North West, and other water companies in the rest of the UK have hardly any beach failures?

The 'Love my Beach' campaign is still peddling this same bullshit (literally). They told the Gazette last week they were urging everyone to help improve water quality. They said their 12 point action plan ranged from asking farmers to fence off watercourses in a bid to restrict pollution from run-off, to organising regular beach cleans.

What a load of tosh. The very idea of fencing to prevent rainwater runoff reaching the rivers is self evidently stupid (even if it is aimed at keeping livestock a few metres further away from the riverbank), and the beach cleans (unless they're pouring hundreds of thousands of gallons of disinfectant into the sea) have not a hope in hell of denting the number of coliform bacteria that are discharged by the water company's stormwater overflows after heavy rain.

This is disinformation. Pure and simple.

We accept there may be some reasons that the North West United Utilities area has far and away the greatest number of failing beaches in the UK. - We've alluded to them before - United Utilities 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 East Lancashire, or because we're one of the wettest areas of the UK.

No doubt all of these sort of issues contributed to the reason for the particular failures in the North West, and we might have accepted those if they had 'come clean' (so to speak) and been given as honest reasons for the failure.

But what we cannot accept is the creation of an undemocratic, secretive body that has used spin and disinformation to mislead the public to excuse their own shortcomings. We believe that has been done on a scale and to a degree that would have impressed even Joseph Goebbels.

This is why we go on so much about councils who create 'Working Groups' or 'Steering Groups' whose agenda, reports and minutes remain publicly unavailable because - thy claim - no decision are taken in these groups, so there is no legal requirement to publicise their proceedings. Like the Turning Tides Partnership, they may not take formally recorded decisions within their groups, but we have no doubt that agreements are reached about courses of action that most people would regard as a 'decision' even if it is not formally framed and referred to as such.

Thankfully, the Scrutiny Committee at Lancashire County Council does not meet in secret - and last week, they examined Environment Agency officials on what was happening.

Readers can follow this link to see the full video webcast of that meeting - and if you're interested in the bathing waters issue , we recommend that you do look at it.

Our own impression of the meeting was that the EA - whilst now bowing to what they and OFWAT have allowed to become inevitable - are still wriggling to get off the hook wherever possible.

By way of introduction, their representative said "The starting point for me is that 2014 saw the best ever water quality for Lancashire in terms of bathing waters. And that is a result of the phenomenally huge and significant investment that's occurred in the last 20 years or so through United Utilities and efforts by all the local authorities, ourselves and others. So it's important to note that I think. Last year's quality for the bathing waters was in a really good place compared with its history. I guess it's easy to then take that and say OK, that's really good and we've got it sorted.

The truth is there is an element always of weather related impacts for bathing waters, and so, although it didn't perhaps feel like we had a glorious summer throughout last year, we did have a better summer than in previous years recently, and that did definitely play a part in the situation, because the quality of bathing waters is impacted by stormwater discharges from the sewer network, and when you have significantly wet summers, then those discharges will increase. But it's important to note that last summer saw a particularly strong performance, which is brilliant

See what we mean?

Here was the regulator admitting that the problem is really the Combined Sewer Overflows in times of heavy rain, but he was still stressing the positives and saying last year's performance was "brilliant".

No it wasn't.

United Utilities still has more than half of ALL the failing bathing waters in the UK.

That's because whatever they have spent so far it has not been enough. And the reason it has not been enough is that the Environment Agency and OFWAT has failed to enforce requirements that would have solved the problem by now. They should have insisted on either more sewage treatment works, or less expensively, more temporary underground storage capacity to hold the sewage in times of storm.

It's also because Local Councils have, for the most part, not made anything like enough fuss about pressuring the EA and OFWAT to do a proper job.

Unusually, and from what we can see, Fylde Council has more or less led the way on this.

It has done so far better than Blackpool or Wyre.

It still hasn't been enough in our book (We can imagine former Cllr Mrs Eileen Hall 'going nuclear' if she'd have been told what this chap just told the County Councillors).

Turning to the new standards he said "Members may well be aware that there is new directives in relation to bathing waters coming into force, and that is upping the game in terms of the standards that we, as a country, are required to meet for bathing waters It's going up from what it was previously, and ourselves with County, Fylde, Wyre, Blackpool, United Utilities and others have been working on trying to do the best that we can to prepare for that."

Just look at the neurolinguistic use of language here. The subliminal implication presented is that a new directive has just come into force; it's not just the North West that is in trouble; and we've all done the best we can.

The reality of the situation is that the revised directive (2006/7/EC) came into force in February 2006. As we showed in 'All Going Swimmingly?' that directive set out both the new standards and the timetable for implementing the new system - and that was way back in 2006.

So it isn't a new directive coming into force. They've actually already had had nine years to undertake the work necessary to meet the requirements - that last of which fall into place this year, - as set out in the original timetable.

Furthermore, whilst there are odd beaches elsewhere in the UK that are failing, the greatest concentration is in the North West operated by United Utilities. You don't need to take our word for that, just scroll quickly through this pdf file and look for the red colours of failing beaches predicted by the EA in 2009.

When you get to the North West (the last page) you'll see exactly what we mean. This is not a 'we're all in it together' situation, it's a specific failure of United Utilities to do enough, and of the regulator that should have made them do more.

Thirdly "We're doing the best we can" (subtext = so don't be cross with us). Utter tosh. They had done nothing like the best they could - as we have said repeatedly in previous articles.

Picking up his 'working together' theme, the EA spokesman continued "And that's [being done] through two things: There's the Fylde Water Management Group which I know Ian is involved in on behalf of the County, and some of our staff are as well. It's about trying to bring together all the different organisations that are involved with water management issues on the Fylde. that's both in relation to flood risk, and to water quality issues as well.

But also, for the region as a whole there's also something called the North West Turning Tides Partnership which is a partnership involving ourselves and local authorities across the entire region where they have designated bathing waters. So that's to try to build a network of sharing, and learning and supporting and helping each other across the entire region as well."

Like he said - this group is about helping and supporting each other.

Turning to the impending signs warning against bathing, he once again dropped into neurolingistic techniques to create an impression, saying "The new Directive has an important part in it, in that where a bathing water fails to meet the required standard by 2015, there may well be a need for notices to be put at that bathing water to give advisory information. And it's really important that I emphasize the word 'advisory'. It doesn't close beaches, it's simply a notice that describes to potentia... [ooops note the slip of the tongue there] to users of the beach who are thinking about bathing - and again I emphasize 'bathing' rather than just necessarily walking their dog on the beach or anything of that sort of thing, that the water quality at that location is not as good as it could be, and the reasons why it isn't as good as it could be, and the things that are happening to try and help with that".

Here again - we're invited to believe it's a 'new directive' (so we can't do anything about it!). Furthermore 'There may well be a need' is a very weak description. It's actually mandatory under law to erect the signs.

It's true that the sign might be 'advisory', but it typically says "Advice against bathing" and the Government's own guidance says "From 2015, if a bathing water receives a 'poor' classification it will be necessary, in the following season, to advise the public against bathing in order to prevent bathers’ exposure to pollution. This is not a ban on bathing; there will simply be advice against bathing together with information about why bathing at the site is not recommended."

He concluded that "the water quality is not as good as it could be". (This is neurolingistic programming to avoid using the words "it has failed to reach the minimum standard")

See what we mean about wriggling.... And this is supposed to be the regulator who protects our interests.

He then dropped some new bombshell information into the matter to say that not only were the figures for Lytham (we think he meant St Annes) and St Annes North bathing waters going to have the results figures fiddled to remove two years of test results, this was also being done at Blackpool South beach as well.

Specifically, and linking it to the work in Preston, he said "I think there's what we describe as a 'step change' been agreed So that means that rather than taking into account the last four years data, it will take into account just last year's data"

That seems to say that it's not even the 40 of the 80 samples that are being discounted, it's now grown to 60 of the 80 test results that will be ignored.

He did at least have the grace to say that "And that means that the performance of those beaches is assessed on last year, and as I say, last year was a particularly good year. So that means that there wouldn't be notices put out for those beaches".

The implication of this is clear. If they hadn't fiddled the figures, St Annes, St Annes North and Blackpool South beaches would all require notices advising people against going in the water.

So now we have three beaches where the figures are (quite lawfully) being fiddled, but none the less they ARE being fiddled, and we believe that's quite disgraceful.

Effectively these three beaches have been given a 'Get out of jail free card" for three years, because the clock only started ticking last year instead of 4 years ago.

The hope (no doubt) is that in the next three years, more improvements (improvements that should have already been made by now but which United Utilities have failed to make), will make enough of a change to lift the water quality out of the danger zone.

Unfortunately for him, our own Queen Elizabeth Oades is a member of the County Council's Scrutiny Committee - and she isn't a lady to be messed with.

Her first question was "Did you ask the Government to allow you to only take account of 50% ....." (she actually said more, but at this point her sound is cut on the webcast).

The reply was "Ultimately, yes, it is government that make those decisions. We provide the information to them and they make that choice about whether they feel it's right and appropriate that 'step change' is applied...."

He also went on to say that some of the samples had been discounted anyway because they had "wet weather waivers" and if you had an extreme weather event, "outside the normal range of weather events that we get", the directive allows for those samples to be disregarded "because they are that extreme. They sort of skew the results, shall we say"

Cllr Oades was quickly back: "So if you'd taken account of the 80 samples as you really should have done, would the bathing water have failed?"

Our neurolinguistic EA chap replied with "I think it would have been much more marginal. I'm not going to say for sure whether it would have been in a position to be classed as failed, but yes, I think it would have been in a different place than we anticipate it being"

Cllr Oades asked "So therefore would it be fair of me to say that the actual samples have been fudged to get the result that perhaps the EA and the Government wanted, particularly in an election year?"

Like we said - not someone to be messed with.

She and Fylde's Cllr Kiran Muholland, are almost alone amongst all the councillors in Fylde Wyre and Blackpool on this matter. Each has tried to make the EA publicly accountable for their failings in this matter, and we commend them for their tenacity. We wish Fylde had more councillors like Queen Elizabeth.

Mr Slippery wasn't going to be caught out though, and said "I would disagree with that, because I think - I can see why it might seem like that - but I think the fundamental for me is that the step change is being put in place because a very large investment has been made in terms of capital infrastructure of United Utilities, so the nature of and the volume of discharges that come from that system, and impact on those bathing waters, will be very fundamental and different from what it was before that infrastructure was put in...."

We disagree.

We say it all depends on the weather we get, and how often (as we have said many times in these articles) the Fairhaven Sewage Treatment works discharges raw untreated sewage through the 'mushroom' that's 50m off the sea wall at Fairhaven lake. That's what's causing the problems on St Annes beaches, not something five miles upstream in Preston.

It seems Cllr Oades has this view as well, she said "Is it not true though that the problem for Lytham St Annes is Fairhaven? And what works are you doing at Fairhaven because there's still an awful lot of sewage being discharged into the water at certain times" (We suspect she remembers the day when the North West Water Authority - as it then was - defended exactly this point in a Planning Meeting in Fylde, and lied through their teeth about the number of discharges from Fairhaven. They had previously been honest with Fylde's officers in private)

We wanted to cheer.

We suspect Mr Slippery must have been feeling quite uncomfortable by now. He said "Fairhaven clearly plays a part because of physically where it's at, but I think from the modelling and works that my colleagues have done, and more importantly United Utilities have done - because ultimately it's their asset, it's their responsibility - the most significant impact came from the Preston situation and issues there, and that's why that was particularly strongly prioritised."

Cllr Oades asked "So you believe that with the more stringent EU tests that you're going to have to apply, that you will be able to get passes for all the Fylde coast next year"

That was just too firm for an evasive answer. He said "Erm, I guess there's a few aspects to that. We can't deliver it in isolation, as an agency..... Do I believe it will happen? I hope it will happen. And we'll do all we reasonably can with others to ensure it does.


Cllr Oades came back with an innocuous sounding question "Why the North West? Why are our bathing waters worse than the rest of the country? Is it a lack of investment generally by United Utilities?"

The answer was "I think, for many decades, prior to the early 90s, the infrastructure in this part of the country, and some other parts to be fair, wasn't invested in to the degree it was or that it needed to be, and everything that we are now dealing with, to some degree or other is dealing with legacy of that investment decisions previously. But also, actually, the bathing waters directive itself didn't exist until relatively recently, so up until that point, there wasn't that standard that water companies and others were required to work to. So at the same time as dealing with historic investment decisions, we've also set some high standards that they needed to meet."

Something approaching the truth at last.

United Utilities has simply not done enough since 2006 to meet the standard that was published at that time.

And the Environment Agency has failed to require them to do so.

Queen Elizabeth was tight on the button when she said "Thank you Chairman, I don't want to shoot the messenger, but I'll just say I'm very sceptical about the answers I've received, and I do believe there's a great fudge going on with our bathing waters."


Couldn't have said it better ourselves.

Other County Councillors asked about misconnections to the sewer network and about who was responsible to stop them. One wanted the figures to show what the coliform test required and what the test results had been over the last five years.

Then Queen Elizabeth was back. She said "I believe the problems that we've got at Fylde are at Fairhaven where there's a short term pollution risk and in the last 12 to 18 months, we've seen at least 2 million gallons of raw sewage and possibly 300 million gallons of raw sewage pumped into the sea, and I would like to see that the Fairhaven Water Sewage Treatment Works, and the Park View pumping station have real-time monitoring of sewage discharges installed, so that actual discharge dates and times and volumes are better known. And I would ask this committee to support me in getting that in place if at all possible.

I don't want to pray for a good summer. Like everybody else, I enjoy a good summer, but if that's the only way that our beaches and our bathing water quality can pass the test, then it's not good enough. I'm not convinced that the Preston works will sort the problems of the Fylde out, and therefore I would like measures putting in place as soon as possible"

It was subsequently changed to include all the pumping stations on the Fylde coast then seconded and supported by the scrutiny committee.

This is excellent if it comes off. It follows on from the work at Fylde spearheaded by Cllr Kiran Mulholland who called for real-time monitoring of the Fairhaven Treatment Works at his Fylde Scrutiny Committee.

We find it amazing that there is not already an automated system to monitor the volume and times that raw sewage is discharged from pumping stations like Fairhaven.

But then, if it tells you something you don't want to know, then maybe there's a good reason not to do it.

So where does that leave us?

Well, the bathing water failures ARE an awful mess for this area.

As we've said before, things are probably not as important as they used to be in the 1950s and 60's because going into the sea is less 'the done thing' than it used to be, and today's holidays are about more than just beaches.

But the real damage is in the perception that it creates of the area.

Having seawater in which it is not fit to bathe (or even paddle), suggests the area is dirty and unhygienic - and that has implications not just for tourism, but for all sorts of other industries as well, especially food and food production for example.

When that's coupled with the industrialisation of the Fylde countryside that looks set to come from a fracking industry, it's probably time to do what the sensible residents of Blackpool have already done.

Pack up and move out.

Dated:  20 February 2015


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