Have your say on the Bathing Water Rules Consultation: Our guide to submitting a response

Questions 9 and 10: To what extent do you agree or disagree with the proposed removal of automatic de-designation from the Bathing Water Regulations 2013 for England and Wales?

Agree

• Removing automatic de-designation is a positive step forward. Automatic de-designation pulls the plug prematurely on efforts to improve bathing water quality.

• Improving water quality takes time, often longer than 5 years, as pollution from sewage, farm run-of and road run-off require long-term, ambitious actions to resolve.

• De-designation based on an assessment of how “feasible and proportionate” it is to get a struggling bathing water site to sufficient water quality raises significant red flags. There is a serious risk that making the necessary improvements to bathing water quality will be seen as too expensive or too much hard work, leading to de-designation. This would waste years of hard work and deprive water users of vital information.

• Bathing sites on our most polluted rivers and waterways will be in urban areas that are most in need of access to swimming/exercise opportunities and nature connection. We cannot give up on these sites.

Questions 11 and 12: To what extent do you agree or disagree that water quality, the feasibility to improve water quality to ‘sufficient’ standard, physical safety and environmental protections be considered before deciding whether to designate a site as a bathing water under the Bathing Water Regulations 2013 for England and Wales?

Strongly disagree

• Increasing requirements for designation will put greater strain on communities preparing applications and will mean fewer sites get designation, leaving water users without vital information and preventing action to address pollution in these areas.

• Introducing an assessment of how “feasible and proportionate” it is to get a struggling bathing water site to sufficient water quality sets off major alarm bells. There is a serious risk that making the necessary improvements to bathing water quality will be seen as too expensive or too much hard work, preventing designation at many new sites.

• This assessment would disproportionately affect river sites, as they often face systemic, hard-to-tackle pollution. Yet it is often bathing sites on highly polluted rivers, in urban areas that are in need of access to swimming/exercise venues and nature, that would benefit most from designation.

Questions 14 and 15: To what extent do you agree or disagree with the proposed increase in flexibility of Bathing Season dates prescribed in the Bathing Water Regulations 2013 for England and Wales?

Agree

• Outdoor swimming and water sports do not just take place between May and September; the health and wellbeing benefits of cold water are causing many of us to use our bathing sites for most, if not all, of the year.

• The bathing season should be extended so that monitoring takes place for as long as people are using the water, giving them the information they need about health risks and ensuring pollution is prevented.

Questions 27, 28 and 29: To what extent do you agree or disagree that government should pursue wider reform of the Bathing Water Regulations 2013 for England and Wales to include widening the definition of ‘bathers’?

Agree

• It is important that all recreational uses of bathing waters are recognised through designation, as this better protects public health and encourages more people to get engaged in and care about our bathing waters and the many benefits they offer.

• It is not just swimmers that are exposed to the health risks of pollution; paddlers, rowers, fishers, kayakers and more, all deserve to know about the quality of the water they are coming into contact with.

Questions 30 and 31: To what extent do you agree or disagree that the government should pursue wider reform of the Bathing Water Regulations 2013 for England and Wales to include the use of multiple monitoring points at bathing water sites?

Strongly agree

• Monitoring a river bathing site at a single point can be very unhelpful, as it give very limited information for bathing water users. Using multiple monitoring points builds a fuller, picture of water quality across the whole bathing water site.

• There are opportunities to use collaborative and community monitoring methods, like citizen science, to make multi-point monitoring more cost-effective.

Question 32 – Please provide links to any relevant evidence that you have used to inform your views for this consultation. If there’s anything else you’d like us to know or consider please add it here.

• More types of pollution should be monitored for, to protect public health better and target actions at these sources. For example, chemical pollution stems from farm and road run-off and should be monitored as it can impact human health.

• When counting numbers of users for prospective bathing water sites, long-standing organised events, like galas, competitions, family days, should be included, as they are an integral part of how local communities use and enjoy the site.

For more information:

Read our entire response to the consultation

Read our background information & summary of the proposed changes to the Bathing Water Rules blog