CCPR response to DEFRA consultation on the implementation of the revised
Bathing Water Directive
CCPR is the representative body for 270 national sport and recreation organisations,
including the governing bodies of sport. CCPR supports its members to gain
sustainable and safe opportunities to enjoy their recreational activity. Our members
include the Amateur Rowing Association, British Canoe Union, the Royal Yachting
Association and many others that rely on the water to enjoy their pursuits.
CCPR acts to promote, protect and develop the interests of sport and physical
recreation at all levels. We provide support and services to those who participate in
and administrate sport and recreation.
CCPR welcomes the opportunity to comment on this consultation.
Question 1: Bearing in mind the cost and benefit implications, do you think that
England and Wales should aim to do more than the minimum that the rBWD
requires (scenario 2 (note: includes proposals in scenario 1A/B)) by 2015?
Yes. England and Wales should aim to do more. The cost implications are very
minor when considered using the net benefit calculations. Scenario 2 has a
stated net benefit of £4,305m, but scenario 1B (which, the figures suggest, offers
the greatest net benefit) has a net benefit of “only” £7m more, which represents
less than 0.25% difference from the total net benefit figure of scenario B. This
difference is so small as to be insignificant and is certainly much smaller than the
margin of error for the overall net benefit figures, given the inherent uncertainty in
measuring and quantifying many of the elements that make up the NPV.
The Government should look to extending the rBWD to recreational waters, not
just waters used for bathing. Those involved in immersion sports such as dinghy
sailing, windsurfing, kite surfing etc are at risk of ingesting or inhaling water while
undertaking the water-based activity and deserve similar protection to bathers.
Poor quality water can also pose risks to sea anglers.
Question 2: If England and Wales are to go beyond the minimum requirements
of the rBWD should the focus mainly be on increasing/maintaining the number of
‘excellent’ bathing waters with the potential for achieving a Blue Flag (scenario
2)? If not, which types of bathing waters should be targeted?
CCPR supports Article 5(1) of the rBWD which requires member states to classify
all bathing waters (as ‘poor’, ‘sufficient’, ‘good’ or ‘excellent’) by the end of 2015.
Article 5(3) requires member states to ensure that all bathing waters should be
classified as ‘sufficient’ by this time, with limited exceptions. However CCPR
would welcome a more ambitious timescale.
We support all efforts to improve the quality of England and Wales’s inland and
coastal waterways. This should not be limited only to those already classified as
excellent. Resources should instead be targeted on areas which receive the
greatest use of all water sports users, such as canoeists, boaters, surfers and
anglers as well as bathers.
This test of “utility” for water sports users in the round, rather than blindly building
on current successes, should be used as the basis of targeting resources.
The Blue Flag is an important brand and which should receive continued support
and engagement.
The emphasis should be on achieving ‘good’ water status for both bathing and
recreational waters.
Question 3: Should the Government and the Environment Agency continue the
development of the prediction and discounting system with a view to using it at a
limited number of bathing waters to help achieve the minimum standards required
by the rBWD (scenario 1B) by 2015?
The development of the prediction and discounting system helps to provide an
accurate picture of the long term quality of bathing water. The points made in
1.56 are very important. “Discounting should not…be seen as a way of avoiding
taking measures to improve bathing water quality., but instead as an option
where measures have been taken and continue to be takes….” This should be
monitored on an ongoing basis.
Where there is a continued need for the discounting system to be applied in
particular areas, and the trend of its application is either constant or upward, this
should provide strong evidence for the need to invest in improving measure to
reduce water pollution, both direct and diffuse.
Question 4: If the prediction and discounting system can be used to help meet
the minimum requirements of the rBWD, who should help meet these costs?
(please list those who should be expected to help fund the system)
Adequately funded local authorities should be responsible for meeting some of
the costs, but the majority should be met by those responsible for creating the
pollution, such as water companies or industry. Those who benefit from the
cleaner waters such as marina owners, or tourist-related businesses might also
make a contribution proportionate to the size of their business, to the cost. The
level of such a fee should not be exclusive, nor act as a deterrent to current and
aspirant recreational users.
Question 5: If the prediction and discounting system can be used to enable a
bathing water to obtain a higher than ‘sufficient’ classification, for example, to
achieve the classification needed for a Blue Flag award, who should help meet
these costs? (please list those who should be expected to help fund the system)
As above.
Question 6: Do you agree that by 2012 the vast majority of beach operators will
have included the bathing water quality information on their beach signage, for
example, during routine sign replacement and updating, at minimal cost? If not,
why not? (Beach operators - could you please list the bathing waters you control
and indicate whether your bathing waters currently have beach signage).
Yes. Due consideration must be given providing information online as well as in
situ. Proper maintenance must be in place to ensure that telephone numbers/web
sites are up to date, signs remain legible and the effects of vandalism are
mitigated.
Question 7: Do you support our proposals to develop the information on signs to
provide bathers with advice to help them avoid bathing during ‘poor’ water
quality? If not, why not?
Yes, but it is very important that a ‘poor’ water quality classification is not used as
a reason to close beaches and waterways to other water users such as
canoeists, sailors etc. Except under rare and extreme conditions, individuals,
furnished with accurate, up to the date and readily available information on water
quality should be free to decide on whether to participate in water sports.
Recreational users should be fully represented on any DEFRA group or fora that
plans or manages such signage.
Question 8: Are you content with the Government’s proposal not to consult again
on amendments which will need to be made to the Regulations post March 2010,
which will require local authorities and private controllers to use the signs or
symbols proposed by the Commission and adopted by the EU through the
Directive’s committee procedure? If not, why not?
Yes CCPR is content that there would not be consultation on this issue and
welcomes consistency with signage across England and Wales.
Question 9: The Government’s proposals assume that the rBWD will apply to the
existing list of bathing waters. Do you think that any waters need to be added to,
or removed from the current list of bathing waters? If yes, please give reasons.
CCPR believes that all recreational water and not just bathing waters should be
covered by the rBWD.
Recreational use of waters provides enormous benefits to the economy and
national health. Improvements in water quality will serve to enhance these
benefits.