Submission to EU consultation on Bathing Water Quality

The EU is reviewing the rules on Bathing Water monitoring. I have made a submission addressing

  • the ongoing failure to identify traditional and heavily used swimming locations;
  • the refusal to monitor locations used for contact water sports, even where the discharge of treated effluent means there is a potential health risk to the public;
  • the fact that monitoring is only over a short summer season, not throughout the year when people are actually swimming.

I am a Councillor for the Howth / Malahide Area on Fingal County Council and Mayor of Fingal. I am also a member of Friends of Balscadden Bay, a group concerned to protect, maintain and improve public access to Balscadden Beach in Howth.

Failure to identify traditional swimming locations

The identification of bathing waters doesn’t work properly in Ireland. Balscadden Beach, which became a popular swimming location for visitors from Dublin since the railway opened in 1847 and remains intensively visited by swimmers is not on the list of bathing waters. This is despite repeated requests to Fingal County Council over the last decade from Friends of Balscadden Bay (FOBB) and raising our concerns about the non-inclusion with the Environmental Protection Agency. I attach information about the Beach from FOBB.

Other popular and traditional swimming locations in the area such as at High Rock and Low Rock, Malahide are also not on the list of bathing waters.

I don’t know exactly what changes are required to the EU rules to ensure that the places where large numbers of people swim are identified, but it’s clear to me that changes are needed.

Waters used for water sports, in particular Broadmeadow Estuary

I understand that the definition of bathing in the Bathing Water Directive is considered by both EU and Irish authorities to exclude water used for sailing, kayaking, and other water sports unless significant numbers of people are also swimming there without being involved in the other water sports. This is the answer I received when I raised the issue of water quality testing in Broadmeadow Estuary, which is used for sailing, windsurfing and kayaking training, including as an inherent part of that training, capsize drills and deliberate immersion by the children being trained.

The situation of Broadmeadow Estuary is a particularly striking example. The Estuary receives effluent from the Swords Urban Wastewater Treatment Plant, licensed by the Environmental Protection Agency under licence D0024-01. The EPA Inspector’s report, based on which the above referenced licence was granted included the following advice for the Board of the Agency in making its decision:

“The Broadmeadow Estuary is extensively used for water sports and while it is not designated as a bathing water, the Local Authority has stated its objective of ensuring that the waters in both the inner and outer estuaries are suitable for contact water sports in terms of bacteriological quality and other relevant water quality parameters.”

Despite this commitment, Irish Water (which has taken over the licence from the Local Authority) have confirmed that neither they nor anyone else is carrying out monitoring of bacteriological quality in the Estuary which is used for contact water sports.

Fingal County Council have confirmed that it is not carrying out monitoring due to the definition of bathing as not including contact water sports even if swimming and immersion are an inherent part of those sports.

Short Bathing Season

Ireland only measures water quality during a short summer bathing season. In reality people swim all year long in all of our bathing waters. We have a major problem in Dublin with closure of beaches due to overflows from the urban sewage network. We should be ensuring the monitoring of bathing waters at all times at which sewage overflows and effluent discharges could affect the health of swimmers, bathers and contact water sport practitioners.

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