Defra have launched a 6-week consultation on their plans to reduce storm overflows in England, closing 12 May 22. It proposes a range of new duties, better monitoring and enforcement and sets new targets dates, essentially 75% compliance by 2035 and 100% by 2050 on both riverine and coastal overflow discharges, with particular reference to new and existing bathing waters.
Some of the key issues for existing bathing waters can be found on pages 11 to 13, however, we would recommend reading or at least scanning the full 24 pages to get a complete understanding of the importance of the recommendations, the cost related options and some of the potential pitfalls. The map of storm overflow investigations and improvements 2020 – 2025 on page 22 give a helpful overview of where problems are currently thought to exist.
Some environmental groups have already been critical of the proposed time scale involved. It does have some striking similarities with the starting position and timeframe coastal bathing waters faced in the early 1990s; defending the often indefensible, with only the promise of a long slow programme of capital improvements to come. Improved monitoring, indeed in many instances any monitoring at all, plus the promise of far more robust enforcement based on that monitoring could be the critical differences?
Although, it is a relief to see existing (largely therefore coastal) bathing waters retain a degree of priority, it does seem that this priority is likely to continue to focus on maintaining minimum acceptable standards in, at risk sites, rather than improving standards at whatever level, wherever possible? While improvements in river water quality, as a whole, should contribute to improvements in bathing water quality at some coastal sites, the much-needed action on many more inland sites will significantly increase the competition for finite capital investment funding, almost certainly changing the historic dynamic for the coastal improvements. That may put some existing bathing waters at a new unexpected disadvantage?
It may also beg questions about water quality at those many coastal sites that are not (or are no longer) designated and may give some bathing water controllers new food for thought on the pros and cons for further coastal designations or cause for pause for more thought on potential de designation? There is significant evidence that a number of campaign groups are now looking to use designation on English rivers as a tool to increase the degree of investment priority, by default on a river, always at or up stream of the site. An critical but easily overlooked difference between riverine and most coastal site where water often circulate rather than simply flows past.
A survey conducted by the Rivers Trust has identified 273 “popular” river bathing sites where the “public” say they want to be informed in real time of bathing quality, information only readily accessed via the mechanism of bathing designation? It is also said that at least 13 groups in England are actively preparing applications for bathing water status, to add to the existing riverine bathing water on the Wharf and that pending at Port Meadows Oxford, the decision announcement for which is immanent.
Reading between the lines, I think it increasingly unlikely that Government can’t give much, if any ground on the arguments being made by user groups for an extension of the bathing water season. Even if the public health case supported it, the financial case and carefully crafted investment framework for the yet to be set 2025 -2030 cycle and beyond probably doesn’t? Meanwhile, pressure for an extension of the season and some interesting questions being asked about the impacts of discharges made between the relatively fixed two week testing cycle, particularly but not exclusively at sites rated as excellent, seem likely to continue to gain momentum.
Greater public awareness of water quality issues and a migration from a purely coastal to an almost everywhere issue is on balance a very good things. That said, the more people who become directly or indirectly engaged with local bathing waters the more regularly difficult questions will be asked about what is by any modern standard still a fairly pedestrian, indicative system for rating bathing water quality. Hopefully the current two site, pilot of automated real time testing being conducted by Southern Water and some of their local authority partners will in time lead us to a more accurate, practical, and, if it is to be rapidly adopted, an affordable alternative solution. Let us hope so.
The 20 sample, person in a van, waders/boat and bottle, white coat, petri dish and microscope driven system, based around the past season’s results and your new rolling 4 year average, setting the coming years rating, is difficult one for a lay person to comprehend, let alone to accept as being both sensible and the obvious state of the art, best available practice. Fifteen years into a digital revolution it is surely well past time that some of the benefits of digitalisation (essentially ease of passage and manipulation of data) began to obviously rub off on beach and bathing water’s management?
I would welcome views on the consultation (available below) in general for inclusion in a potential UKBMF response and also any strong reactions or thoughts on the non-consultation issues I have indicated, like length of season, new testing methodologies and the potential to use the digital revolution to aid beach and bathing water management.
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UK Beach Management Forum 