Key Questions for seeking bathing water designation

Key points following a very useful seminar by the Ilkley Clean River Group – the first to successfully campaign for a river bathing water designation. There is enthusiasm for others to do this, but I think there are some questions to ask first: is there actually a problem at that place and is this the best response; do enough people swim there and are there facilities; are there people to do the work; do the landowner, the local authority and the local community support this; and are there any unintended negative consequences?

Introduction

In December 2020 the first bathing water designation in a river was announced, for a stretch of the Wharfe in Ilkley. The campaigners that brought this about, the Ilkley Clean River Group, have been generous with their advice and information, and ran a seminar on 3 February for anyone interested in how they did it. Their website has links to the slides, video and their application, along with other campaign info.

The seminar was useful and interesting, the organisers were responsive to questions, and they are open to people contacting them and want to encourage others to do this. Throughout they emphasised transparency in their campaign and on their website.

This note summarises the key points I took from the seminar, together with some comments and questions that I think are raised in relation to this process.

This Outdoor Swimming Society post (originally from February 2020, updated a year later) examines the pros, cons and practicalities of campaigning for designation, https://www.outdoorswimmingsociety.com/should-swimmers-seek-bathing-water-designation-for-local-swim-spots/

Summary of key points I took from the seminar

Ilkley had a problem with their river, but if there isn’t a problem you wouldn’t undertake this. It takes a lot of time and effort over a sustained period, and involves work by a lot of people ( including swimmers, though they were not able to say how many of those involved were swimmers). The numbers of people using the bathing area is a crucial factor, together with facilities. The numbers counted at Ilkley were only just enough to achieve the status. There was some local backlash, though the majority supported the bid.

At Ilkley they needed to convince the water companies and EA and others that there was a problem, so their campaign involved water quality testing and a lot of critical media, however they also recognised the value of collaboration with them. Having achieved BWD will lead to closer working locally and to an improvement in investment in water treatment facilities.

Key points and messages I took from the seminar and associated material and discussion, with my Comments/Questions – C/Q

Is there a problem?

  • If there is a problem it is likely to be obvious, e.g. signs of raw sewage (Ilkley definitely had a problem, and getting it recognised and resolved was a problem, too)
  • There might be a less obvious problem, e.g. suggested by discharges info on the Rivers Trust map, which might need to be backed up by further questions, testing etc
  • Q: Do swimmers want or need this in most places, and what would be the benefits to them?

If there isn’t a problem, why would you embark on a campaign for bathing water designation?

  • Ilkley campaign said you wouldn’t unless you suspected or had raw sewage discharges
  • Q: Are conservation bodies pushing for designation or putting pressure on to do this, and for what purpose and with what implications?
  • Q: If there is a considered to be a problem, is it one to do with ecological river water quality? If so is this an appropriate way to achieve that end? Or is it better to work with river catchment partnerships?

Numbers need to be substantial for the size of the swimming area

  • The Ilkley beaches were extremely well used, but the numbers they counted were only just enough to achieve designation. There is no set number, as it depends on the size of the swimming spot. (To give an idea: In Ilkley they counted all summer, and submitted the top 20 daily counts, which ranged from 1,751 to 42, a daily average of 394. The river stretch was 1.75 km.)
  • The proximity of Ilkley lido, with a capacity of over 4000 and often busy or sold out on hot days, was also a factor.
  • Definitely count swimmers and paddlers, probably count people on the riverside e.g. having a picnic, anglers, people in inflatables, but it was less clear whether to include kayakers and canoeists. Subsequently made clear in Govt response on Oxford designation – they should not be included, and see this from Govt in the Oxford consultation “In considering a proposal for a site to be designated as a bathing water, we look at the number of bathers and the facilities provided by the local authority or private site owner to promote and support bathing. Adults and children swimming, and children paddling, are counted as bathers.”.

Facilities are important as well

  • The application procedure requires this information, and Ilkley said that this was the subject of questioning by DEFRA. They were able to confirm there were toilets, parking, lifebuoys and nearby shops etc, as well as the lido. This is confirmed by another campaign, Warleigh Weir, where they are having to negotiate some practical issues with the local council, including the need for toilets (along with parking/access and litter), https://fb.watch/3I-JHv8PQJ/.

Time and effort to prepare an application and associated work is considerable

  • Summer-long monitoring and counting, gathering of information, talking to authorities etc. Ilkley campaigners said that they were fully engaged on this throughout the summer and busy at other times.
  • Numbers needed to do this work. Ilkley had 50 volunteers involved from different river users and parts of the community on all the work (they had no information on how many of these were swimmers).
  • A local consultation must be done for the application, of the local community, businesses, organisations etc, which involves considerable work. Ilkley also held public meetings.
  • Citizen science water quality testing is not needed for an application, but Ilkley did it to prove there was a problem. This took a lot of work, training and expertise; many volunteers were involved.
  • Ilkley felt that doing the count and giving a leaflet to everyone and doing the consultation was useful in raising awareness of the issues and informing users.
  • Campaigners (and swimmers) need to be resilient, as there can be backlash and controversy.
  • Funding is needed too, especially for citizen science.

Timing

  • Preparation and planning
  • Summer counting, from 15 May-30 September
  • Summer/autumn consultation
  • Prepare application to submit in October
  • If citizen science survey being done, this would probably have to span a period involving different sorts of weather and water levels
  • By February decision announced
  • 15 May monitoring by EA begins

Support of the landowner is essential

Support of local authority, stakeholders, community, locals

  • The procedure requires that the local authority must support the applications.
  • There must be a local consultation (and if there were strong opposition from the community it would be unlikely to succeed). A national consultation run by Defra follows the local one, and again there would need to be support in that survey which the campaign would need to encourage.
  • Ilkley encountered some opposition from locals, on the grounds of safety concerns, the possibility of increasing numbers coming to swim, and impact on the environment.
  • Q: Could this opposition and backlash lead to losing access to a bathing place in some situations, or to conflict or bad feeling between users?

Issues of safety and management will arise, and concerns about numbers swimming

  • Concerns were raised by Yorkshire Water and some respondents about the safety of swimming in the river (mainly about currents), saying that giving the designation might give the impression it was a safe place to swim.
  • C: There is no requirement to have a safety management plan, though any landowner that knows there is swimming going on has a duty to do a risk assessment and to warn about unusual dangers. They are not generally required to warn on the obvious dangers, though if they suspect that many users are not aware of these then it would be good practice to do so (e.g. outlined by RoSPA, VSG, see this page on Landowner liability and swimmers)
  • Q: Could a bathing water campaign be a chance to educate landowners, authorities and users on safety? Or could that take place in any case, and perhaps be a better use of time and effort (in a place where water quality is not a big issue)?

The place of swimmers in a campaign

  • Swimmers were not the key focus of the Ilkley campaign.
  • C: I would suggest that any bathing water application campaign should be done only with the involvement of swimmers – initiating or prompting, involving, consulting and benefiting them. Otherwise, it could appear that it is being done using them and the popularity of outdoor swimming as a lever to meet other agendas, and there is the potential for a backlash against swimming and consequences such as loss of access.
  • C: Other prospective places for bathing water designation applications have been suggested by conservation organisations [see links below], but not prompted by swimmers or necessarily in places where swimmers are concerned about bathing water quality.

Making a distinction between bathing water quality and ecological water quality

  • C: These are both very important, however only the first has a potential direct impact on the health of swimmers while the second does not. Swimmers might be keen and interested in campaigning on both issues, but it is important to be clear about the difference if considering a campaign for bathing water designation.
  • The Ilkley citizen science was only on bathing water quality measures, and those leading that part of the campaign were very clear. The campaign was clearly focused on bathing water quality.
  • C: The idea widely reported in the media that all rivers are dirty and unsafe for swimming on the basis that none met ecological river quality standards is an inaccurate and confusing message. Not all key participants and campaigners at the seminar appeared clear about the distinction. This distinction matters because of the implications for participation in swimming and for access – swimmers might be driven out of the water when there is no need for this, based on inaccurate information. This in turn can lead to a loss of access – and indeed could make achieving bathing water status harder (or lead to loss of status).

Key links

From Ilkley Clean River Group campaign

Blog explaining the campaign approach https://sites.google.com/view/cleanwharfeilkley/the-campaign-news?authuser=0

Citizen Science section https://sites.google.com/view/cleanwharfeilkley/the-science?authuser=0

(see also on wider river testing https://sites.google.com/view/cleanwharfeilkley/the-science?authuser=0%20)

The process of applying for Bathing Status – application from here https://sites.google.com/view/cleanwharfeilkley/swimming-in-the-river?authuser=0, or this link takes you to it in Google Drive https://drive.google.com/file/d/11HhFG-bmdC0k8c_xqgv3w_tQ5r9gc-Qa/view

Ilkley Clean River Group: the slides and the link to the seminar recording here https://sites.google.com/view/cleanwharfeilkley/the-campaign-news

[I have a copy of the chat from the seminar, including questions and answers]

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GOV.UK

Procedure (England – see 2nd OSS link below for other nations), https://www.gov.uk/guidance/bathing-waters-apply-for-designation-or-de-designation

Ilkley Consultation outcome, Summary of responses and government response, Bathing waters: designation of an area of the River Wharfe, Ilkley, https://www.gov.uk/government/consultations/bathing-waters-designation-of-an-area-of-the-river-wharfe-ilkley/outcome/summary-of-responses-and-government-response

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OSS

Bathing water designation for local swim spots?

Designated Bathing Waters explained

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River bathing water sites identified by Rivers Trust survey: https://arcg.is/0T8DPP

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My pages/posts on the issues:

Page on Bathing water quality

Post, Rivers not fit to swim in?

swims and swim places, and related issues