Bathing water designation for local swim spots? 

Why is there a push to do this? The focus on swimmers is partly political – a number of environmental groups are turning to swimmers now to try to get their message across. Not because swimmers are particularly at risk – compared to plants, wildlife or other water users like canoeists and SUPers – but because swimmers may unlock funding for them to achieve their aims, and because swimming is currently popular so they can lever that popularity to encourage people to care about their environmental priorities.

Swimmers care about their environment – they are often immersed in it, after all – and get involved in all sorts of campaigns. Should they be leaping into action to campaign for local swim spots to be designated as bathing water places?

PROS

More designated places could increase pressure to improve bathing water quality, ideally leading to:

• more monitoring of discharges from sewage works, and reducing or stopping untreated outflows
• more funding and support for Environment Agency and equivalent agencies in other UK nations
• water companies prioritising investment in improving infrastructure over profit and shareholder dividends
• the water regulator to push for this rather than reducing water rates
• more actions to deal with wider problems which are overpowering our antiquated infrastructure, and more awareness of individual actions that can help
• Good campaigns in which everyone works together – swimmers and other river users, conservationists, authorities, water companies and those monitoring the water, landowners and farmers, local politicians and the local community – could lead to understanding each other better and achieving our common aims.
• Campaigns could lead to more people getting involved in valuing and caring for their rivers and environment, and a focus on swimmers could put them centre stage in access to rivers.
• Bathing Water Quality status would help guide swimmers with good relevant information in the summer months on the cleanliness of water in designated spots.

CONS

Campaigns to designate bathing spots could

• buy in to the narrative as seen in media articles with often misleading and questionable claims that ‘No River Is Fit to Swim In’
• give the impression that the river in question, and rivers generally, are always unsafe to swim, whether or not there is evidence or that evidence applies to all conditions
• make swimmers lose confidence to swim in many places when often they’re okay
• drive swimmers out of the river, making a bid less likely to be successful and risking losing access at that spot if it is less used
• strengthen the actions of any authorities or landowners or others wanting to stop people swimming at that spot
• lead to a backlash against swimmers, with concerns about increased numbers, crowding, impact on wildlife and the local community
• potentially make opposition by environmentalists and nature conservation organisations more likely, particularly during the growth and nesting seasons
• could lead to or magnify conflict and tension between different users of an area of river, if designation and surrounding publicity or actions increases the numbers or balance of users
• make negotiation with the landowner more difficult – they might be put off if a place needs to go through bathing water designation procedures, when they might have been quite happy to agree to low-key swimming access
• lead to unrealistic expectations of swimmers, who might think they can only swim if the water quality is ‘excellent’, when they could make their own decision to swim when it was ‘sufficient’ or even ‘poor’
• mean losing the pragmatic approach, and making people less likely to take responsibility to judge for themselves, and instead wait for approval from the authorities to tell them that the water at a particular place is clean.

Some potential cons once bathing water is designated:

• swimmers could think the water is guaranteed good quality in designated places (and not good quality in non-designated places)
• swimmers could make assumptions about the place being safe because it is designated, rather than making assessments of any risks
• unrealistic expectations about the speed of improvements in bathing water quality
• unintended consequences arising from the financial issues, including either a rise in sewerage bills, or if these bills are not allowed to rise investment could be prioritised to bathing waters in preference to non-designated waters.

PRACTICAL CONSIDERATIONS FOR GROUPS CONSIDERING APPLYING FOR STATUS

• Consider whether there is a problem and whether it is necessary or the best way
• Have you got the necessary number of users – 100 a day, or the facilities – toilets within 500 m?
• Consider strategy and aims, and how a campaign would benefit swimmers
• Focus on swimming (and other splashing about), rather than more broadly on the environment
• Have a clear focus and a plan for a long-term campaign
• Consider timing. It is likely that a campaign would be at least a year of work, focusing particularly on the summer bathing water season, starting 15 May, when numbers need to be counted to include in an application. Applications are submitted in October.
• Consider whether the place is suitable, and whether there is local support
• Be aware of the work involved in campaigning for bathing water status, including surveys of swimmers and others across the summer, having numerous discussions, and drawing up documents
• Some campaigns, generally led by local councils, have paid for this work to be done, costing tens of thousands of pounds, only for their bid to be turned down (2022-3)
• Consider whether such a campaign is worth the time and effort that needs to be invested, or whether the aims could be met a different way
• Ensure campaign members have or can gain skills, and that they have the time and can make a long-term commitment, and have the resilience for what can be a testing process
• Check whether it’s possible to provide the necessary range of evidence, including on the number of swimmers in the summer, on facilities and other infrastructure
• Ensure your publicity and campaign messages are balanced, clearly explaining the issue to get support while avoiding exaggerations that can drive people out of the river and sometimes unnecessarily put people off swimming
• It is essential to get the support of the landowner, the local authority, local people, other water users and others who might be affected
• Make sure river swimmers are involved, and consult local swim groups
• Involve parents and young people, teenagers and summer dippers
• Involve wildlife/environment campaigners, but be clear about aims and understand the different measures, standards and actions to improve river water quality
• Work with other river users, anglers, paddlers, boaters (though be aware that only swimmers and people paddling with their feet can be counted)
• Get the support of local MPs, other politicians and other key members of the community
• Work with Environment Agency or equivalents in other UK nations, water companies and other authorities, avoid attacking them by concentrating on resources and funding issues and the legislative framework. Note that a number of water companies are working with local campaign groups towards designation bids.
• Find out who might be hostile to such a bid and consider how to engage them or deal with that
• Be prepared for a backlash and hostility to outdoor swimming generally, to improved access, increase numbers, misunderstandings about safety and liability. See further resources for essential reading on access issues.
• Campaign groups are liaising across the country, via the Rivers Trust and the policy section of Surfers against Sewage.

Please note: The Outdoor Swimming Society cannot support specific applications for bathing water designation. This is because we are an official consultee at the stage when an application goes out for public consultation, so it would not be appropriate for us to do so.

ROUND UP OF THE SITUATION NOW (DEcember 2024)

A consultation on some details of the procedure for designation closed 231224, and you can download the OSS response (Word.docx 17 pages). We expressed concerns about the potential implications for access.

In February 2024 the annual bathing water designation consultation included a total of 27 locations, 22 inland (including six estuaries). OSS is a formal consultee and responded in relation to the 22 inland locations (link downloads Word.docx 2 pages) (and the five coastal locations).

In May 2024 it was announced that all 27 were agreed, so there are now an additional 12 inland rivers, 6 tidal rivers, and 4 lakes. At the same time it was announced that there would be no further applications taken until at least spring 2025, and meanwhile a consultation would take place on some changes to the procedure.

Only three rivers in the UK are currently designated under the bathing water directive (at May 2023), unlike hundreds of coastal spots and about a score of lakes. This legislation has done a lot to clean up beaches. If a place is designated it must be regularly monitored over the summer, with reports and warnings if the water contains levels of bacteria so high as to make bathing unsafe. On 22 December 2020 part of the river Wharfe at Ilkley became the first designated bathing site river in the UK, with water quality monitoring beginning May 2021. A second river spot was designated in April 2022, an area on the Mill Stream at Port Meadow, Wolvercote, Oxford. (Read the OSS response to the consultation (link downloads Word.docx 2 pages). Another river has been designated from May 2023, the Deben estuary at Waldringfield; read the OSS response to the consultation (downloads word.docx 4 pages), (and see the consultation and government response).

In May 2023 nine other river applications were turned down, and requests for explanations have been rejected. Indications are that they were deemed not to have high enough number of users or sufficient facilities. Questions were asked, including in the Swim England consultation response (link downloads word.docx 2 pages), and there is a review of the process and its context by DEFRA, with OSS included in the stakeholder group.

Also announced in April 2023 were two further successful applications for designation for Rutland Water reservoir sites, one of which is a private supervised venue open two hours a week, at a cost of about £8 a swim and only open to swimmers able and wishing to do 250m loops, and the other for an existing lifeguarded beach, which is not open for swimming outside the supervised times in the summer season. Read the OSS responses to the beach application and to the supervised venue application (each link downloads word.docx 4 pages), which though welcoming the applications point out that the water is already clean and there are several other questionable aspects. Although announced as an expansion of places to swim outdoors, there doesn’t appear to be any intention to widen access to the reservoir beyond these places and times, and that is not enough for the growing popularity and demand for places to swim. We argue that reservoirs are very suitable for outdoor swimming and that this generally does not need to be supervised.

Then in July 2023, midway through the season during which groups wanting to apply for designation had already started their counting and consulting, the procedure was changed without warning or consultation. The revised procedure includes requirements for there to be toilets within 500 m and at least 100 people on two separate days (but not at organised events) must be counted and photographed. (Previously numbers had to be counted on 20 days, but there was no stated number requirement. People doing other activities such as paddle sports have never been counted, and the revised procedure has made this clear.) Information needs to be given about parking, public transport, and easy access to the water (including disabled access), and about other facilities. Water testing is not needed for an application. The local consultation process can include local swim groups.

FURTHER INFORMATION

The OSS has two social media platforms where social swim groups and those looking into status for their areas may meet others to discuss, and has information for swimmers.

• The ‘Inland Access Group – Outdoor Swimming Society’ is a private group on Facebook for people looking at setting up free inland beaches in their area or at protecting existing access.
• The ‘Network for Admins of Outdoor Swim Groups – Outdoor Swimming Society’ is a private group on Facebook,  a place where those who moderate social swim groups can share advice and experiences

The OSS Guide to Inland Bathing Waters provides essential legal and practical information on establishing free swimming in the UK

‘Is it Clean?’, in our Survive section, along with 10 Ways to Stay Well Swimming, are all most swimmers need to know before deciding whether to get in.

Post questioning the ‘no rivers are fit to swim in’ narrative on swimming access campaigner’s website

Surfers against Sewage toolkit helps explain the application process

Surfers against Sewage are running a series of webinars to supplement their toolkit, and you can see all the recordings on their Bathing water designation toolkit – YouTube, and get in touch with them to join in future sessions.

Designated Bathing Waters explained on this website – what they are and why they matter

Designation application procedures:

• England
• Scotland
• Northern Ireland
• Wales

The trade association for water companies is Water UK.

February 2020, latest update October 2023