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Sanitary Survey - classification zone

Lympstone – 2020

Document No. – J0591/20/11/18

Carcinus Ltd, Wessex House, Upper Market Street, Eastleigh, Hampshire, SO50 9FD. Tel. 023 8129 0095 https://www.carcinus.co.uk/ Cover image: Waterfront at Village, © Andrew Tyron CC-BY-SA.

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Carcinus Ltd – Document Control Sheet

Client Food Standards Agency (FSA)

Project Title New zone classification – sanitary survey

Document Title Sanitary Survey - Lympstone

Document Number J0591/20/11/18

Revision v2.0

Date 16 December 2020 Revisions

Revision No. Date Comment 1.0 24 November 2020 Draft issued for FSA review. 2.0 09 December 2020 Final document for LA consultation

Document QA and Approval

Name Role Date

Author Joshua Baker Freshwater and Marine 09 December 2020 Ecologist;

Checked Despina Crabb Administrator & Quality 24 November 2020 Assurance

Approved Matthew Crabb Director & Principal Consultant 09 December 2020

This report was produced by Carcinus Ltd (Carcinus) on behalf of the Food Standards Agency (FSA) for the purposes of providing a sanitary survey for the specific Bivalve Mollusc classification zone (BMCZ) application as detailed in this report. Every effort has been made to ensure the information contained within is as complete and valid as possible at the time of writing. It should be noted that additional information may have existed at the time of publication of this report that was not available, not identified or has subsequently been published after the date of this report. Carcinus accepts no liability for any costs, losses or liabilities arising from the reliance upon or use of the contents of this report other than by its client.

Dissemination Food Standards Agency, West and Taunton Council. The report is publicly available via the Carcinus Ltd. website.

Recommended Bibliographic Citation: Carcinus Ltd., 2020. Sanitary survey of Lympstone. Carcinus report on behalf of the Food Standards Agency, to demonstrate compliance with the requirements for classification of bivalve mollusc production areas in and Wales under EC Regulation 2019/627.

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Contents

1 Introduction ...... 1 1.1 Legislative Requirement ...... 1 1.2 Scope of assessments ...... 1 2 Application and Fishery ...... 2 3 Sources of Faecal Contamination ...... 3 3.1 Freshwater inputs ...... 5 3.2 Sewage Discharges ...... 5 3.2.1 Continuous Discharges ...... 5 3.2.2 Intermittent Discharges ...... 10 3.2.3 Private Discharges ...... 21 3.3 Boats and Marinas ...... 21 3.4 Agricultural Sources ...... 22 3.5 Wildlife ...... 22 3.6 Other Sources of Contamination ...... 23 4 Existing Classifications and Monitoring History ...... 23 5 Hydrodynamics/Water Circulation ...... 28 6 Other Considerations ...... 28 7 Recommendations for a RMP and Classification Zone ...... 28 7.1 Provisional Classification Zone ...... 28 7.2 Representative Monitoring Point (RMP) ...... 28 7.3 Classification Species ...... 29 7.3.1 Criteria for Sampling ...... 29 8 Recommendations for a Shoreline Survey ...... 31 9 References ...... 31 About Carcinus Ltd ...... 33 Contact Us ...... 33 Environmental Consultancy ...... 33 Ecological and Geophysical Surveys...... 33 Our Vision ...... 33

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List of figures

Figure 2.1 Application zone boundary ...... 3 Figure 3.1: Potential sources of faecal and chemical contamination to the application zone...... 4 Figure 4.1 Monitoring history for Beacon Point (M. sp) – B26AT. Horizontal lines indicate classification thresholds (<230 CFU/100 ml = A, <4600 CFU/100 ml = B & <46000 CFU / 100 ml = C).25 Figure 4.2 Monitoring history for Cockwood Harbour (M. sp) – B26BH. Horizontal lines indicate classification thresholds (<230 CFU/100 ml = A, <4600 CFU/100 ml = B & <46000 CFU / 100 ml = C).26 Figure 4.3 Monitoring history for River Kenn (M. sp) – B26BC. Horizontal lines indicate classification thresholds (<230 CFU/100 ml = A, <4600 CFU/100 ml = B & <46000 CFU / 100 ml = C)...... 27 Figure 7.1: Location of RMP within application zone...... 30

List of tables

Table 2.1 Coordinates delineating the Application Zone...... 2 Table 3.1: Details of Continuous Discharges within the application zone...... 5 Table 3.2: Details of intermittent discharges within the application zone...... 11 Table 7.1: Provisional Sampling Plan ...... 30

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1 Introduction This report was produced by Carcinus Ltd (Carcinus) on behalf of the Food Standards Agency (FSA) for the purposes of providing a sanitary survey of classification zone, desktop assessment and recommendation on the need to conduct a shoreline assessment and/or bacteriological survey for the proposed Production Area within Lympstone, Devon, for the harvesting of farmed Pacific (Crassostrea gigas) and native (Ostrea edulis) oysters. 1.1 Legislative Requirement Bivalve molluscs, such as mussels, clams and oysters, are filter feeding organisms that filter the water in which they live to feed on microorganisms. This feeding behaviour increases their ability to accumulate and retain microorganisms, including those that are pathogenic to humans, and other chemical contaminants in the water column. The safety of bivalves harvested for human consumption is therefore strongly influenced by the quality of water in which they have grown. Sources of microbiological contamination from a variety of sources, including human and/or animal origin, can affect Bivalve Mollusc Production Areas (BMPAs), the suitability of shellfish harvested from such areas for human consumption and the post-harvesting processes necessary to make Live Bivalve Molluscs (LBMs) safe.

EC Regulation 2019/627 sets out specific requirements for the classification of new Bivalve Mollusc Classification Zones (BMCZs), including the requirements for a sanitary survey to be conducted. The primary element of a sanitary survey for new areas is a desktop assessment, which will determine a sampling plan to be initiated at a new specific LBM bed with a view to classification. The proposed sampling programme and the sampling locations arising from the desktop assessment are based on the examination of publicly available information on the geographical and hydrological characteristics of the area and potential sources of pollution, as well as any existing sanitary surveys and/or E. coli data relating to the area (if available) from Official Control monitoring, or any neighbouring classified production areas (where relevant). Sample numbers, sampling points and sampling frequency ensure the results of the analysis are as representative as possible for the area considered. Thus, the sanitary survey determines a Representative Monitoring Point (RMP) to inform a provisional sampling plan to facilitate the classification of a new production area/bed (Note, the RMP must represent the worst-case scenario of contamination within the production area to be classified); it, also, confirms the provisional boundary of the area/bed requested to be classified. Although the boundary of the production area or bed is suggested in the harvester’s application, it is necessary to define the boundary co-ordinates of the water body based on the available evidence to ensure any identified sources of pollution are considered. The sanitary survey also considers whether there is a need for a shoreline and/or bacteriological survey to be conducted before the sampling plan is finalised.

In England and Wales the Central Competent Authority (CCA) under Regulation (EC) 2019/627 is the FSA. Carcinus is contracted to undertake sanitary surveys for new BMCZs in England and Wales on behalf of the FSA. These assessments are to demonstrate compliance with the requirements stated in Article 56 of EC Regulation 2019/627. 1.2 Scope of assessments A desktop assessment is the first stage in the sanitary survey process relating to (EC) 2019/627, and is used to provide a basic assessment of contamination risks to the shellfishery as well as a

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provisional sampling plan that identifies a Representative Monitoring Point (RMP), sampling frequency, sampling depth, tolerance, species to be sampled and the provisional production area boundaries. The desktop survey focusses on bacterial contamination sources (primarily from faecal origins) and the associated loads of the faecal indicator organism E. coli and does not assess chemical contamination, or the risks associated with biotoxins. The assessment also determines whether the area requires a shoreline and/or a bacteriological survey before the sanitary survey can be finalised. The procedure followed is not appropriate to consideration of applications within marinas and docks.

2 Application and Fishery An application for the classification area in the waters off Lympstone, Devon was received from the District Council – Local Authority (LA). The application was validated by the FSA and passed to Carcinus for the purposes of undertaking a sanitary survey desktop assessment. The requested application zone is bounded by the coordinates in Table 2.1. The location of the application zone off Lympstone can be seen in Figure 2.1. The application zone is relatively small, approximately 130 m by 140 m.

Table 2.1 Coordinates delineating the Application Zone.

Point NGR (OSGB 1936, WGS 1984, EPSG:4326 WGS 1984, EPSG:4326 reference EPSG:27000) Latitude Longitude A SX 98801 83253 50.640150° -3.4325167° B SX 98797 83110 50.638867° -3.4325333° C SX 98932 83254 50.640183° -3.4306667° D SX 98928 83109 50.638883° -3.4306833°

There are three further Classification Zones (CZs) in the Exe BMPA; to and Exe Approaches which are classified for mussel harvesting. Dawlish to Starcross is also classified for Pacific oyster harvesting, and Sandy Bay on the outside of the estuary is classified for harvesting of Spisula solida. All three CZs are classified using samples from a single RMP within their boundaries:

• Beacon Point (B26AT) for Exe Approaches; • Cockwood Harbour (B26BH) for Dawlish to Starcoss; and • Exe West (B26BJ) for Sandy Bay.

Harvesting in an additional CZ, Starcross to Powderham, is currently prohibited for all species, although sampling at the old RMP, River Kenn (B36BC), recommenced in August 2020 with a view to reclassification.

The application specifies harvesting of farmed native and Pacific oysters that will be grown on longlines suspended 500 mm – 700 mm off the seafloor. The shellfish will be harvested by vessel at half-tide. The initial stock will comprise of part-grown oysters that will be grown to marketable size to allow classification sampling (between 60-80 mm). If shellfish flesh results indicate good water quality the production will be upscaled and spat will be laid. The estimated production, provided

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water quality results are suitable, is 5 – 10 tonnes in the first year. Output will be limited by the size of the application zone.

Figure 2.1 Application zone boundary 3 Sources of Faecal Contamination A sanitary survey desktop assessment has been conducted to identify potential sources of faecal contamination to the application area. Figure 3.1 presents the location of potentially significant sources of contamination identified as part of this study.

Active consented discharges have been identified through the interrogation of the Environment Agency (EA) permit database1 (accessed October 2020).

In addition, the sanitary survey (Cefas, 2013) and recent review of said sanitary survey (Carcinus, 2020 (in prep)) reports have been reviewed and relevant information gathered as part of those studies is used herein to support this assessment. Those reports do not specifically assess the application zone but do characterise the wider region within which the application zone is situated.

1 EA permit data have not been validated and as such the accuracy of such information cannot be guaranteed.

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Figure 3.1: Potential sources of faecal and chemical contamination to the application zone.

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3.1 Freshwater inputs Freshwater inputs require consideration as part of the assessment, as they act to carry contamination resulting from runoff, urban diffuse and point source pollution and other rural diffuse sources. During the winter, increased rainfall is likely to result in increased levels of runoff and a subsequent increase in bacterial loading carried into coastal waters. Bacterial loading is typically highest during periods of heavy rain occurring following a dry period.

The application zone is situated inside the , which has a large catchment of 1,500 km2. Much of this catchment drains into the Rivers Clyst and Exe (and their tributaries), meaning that a significant proportion of the land runoff (and therefore pollution from agricultural (Section 3.4) and wildlife (Section 3.5)) enters the estuary upstream and will be carried over the application zone on an ebbing tide. Additionally, the mouth of the River Kenn is situated about 1.3 km away from the application zone, on the opposite bank of the estuary. The position of the RMP should be located to capture this influence, as freshwater sources serve to carry up-estuary contamination into coastal waters. 3.2 Sewage Discharges 3.2.1 Continuous Discharges There are 82 continuous discharges contained within the catchment of the Exe estuary, in which the application zone is located. Details of all discharges are presented in Table 3.1 and the locations of those discharges near to the application zone are presented in Figure 3.1.

Table 3.1: Details of Continuous Discharges within the application zone.

Dry NGR (OSGB Weather Name Treatment Type 1936, EPSG Receiving Environment Flow 27000) (m3/day) ALLER GROVE BIOLOGICAL 9 SY0529096950 TRIB OF (S) STW FILTRATION ASHILL STW Unspecified Unspecified ST0860011900 ASHILL STREAM AYLESBEARE BIOLOGICAL 103 SY0358091860 (S) AYLESBEARE BROOK STW FILTRATION BAMPTON BIOLOGICAL 230 SS9541021790 RIVER BATHERM WWTW FILTRATION BICKLEIGH STW Unspecified Unspecified SS9385007300 TRIB OF BRAMPFORD BIOLOGICAL 104.54 SX9314097070 RIVER EXE SPEKE STW FILTRATION BRIDGETOWN BIOLOGICAL Unspecified SS9230033230 (S) RIVER EXE WWTW PS FILTRATION BROMPTON Unspecified Unspecified SS9553031200 PULHAM RIVER REGIS STW BRUSHFORD BIOLOGICAL 124 SS9267025860 WWTW FILTRATION

BUCKLAND BIOLOGICAL ENGLISH CHANNEL 21818 SX9606071430 WASTEWATER FILTRATION (COASTAL)

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Dry NGR (OSGB Weather Name Treatment Type 1936, EPSG Receiving Environment Flow 27000) (m3/day) TREATMENT WORKS

BURLESCOMBE BIOLOGICAL 155 ST0653016970 FENACRE WATER WWTW FILTRATION Unspecified Unspecified SS9740007750 BURN RIVER STW CADBURY Unspecified Unspecified SS9065005050 THORVERTON STREAM CROSS STW CADELEIGH Unspecified Unspecified SS9153008120 UNNAMED TRIB THE BURN STW CHERITON BIOLOGICAL 144 SX7757093550 (S) FORD BROOK BISHOP STW FILTRATION CHERITON BIOLOGICAL TRIBUTARY OF HOLLY FITZPAINE 115 SS8576006130 FILTRATION WATER WWTW BIOLOGICAL 7.13 ST0367001620 RIVER CLYST(S) STW FILTRATION COWLEY Unspecified Unspecified SX9064095420 TRIB OF RIVER EXE BRIDGE STW BIOLOGICAL 2955 ST0216006080 WWTW FILTRATION CULMSTOCK SEWAGE BIOLOGICAL 118 ST0992013680 (S) RIVER CULM TREATMENT FILTRATION WORKS DAWLISH SEWAGE UV 4856 SX9742076470 LYME BAY (C) TREATMENT DISINFECTION WORKS DULFORD STW Unspecified Unspecified ST0685005950 TRIB OF RIVER WEAVER DULVERTON (RECREATION) Unspecified SEPTIC TANK SS9133027640 RIVER BARLE SEPTIC TANK DULVERTON BIOLOGICAL 468 SS9172027190 RIVER BARLE WWTW FILTRATION BIOLOGICAL DUNKESWELL 314 FILTRATION / ST1519008580 RIVER MADFORD (S) STW REED BED UV (COUNTESS 40486 SX9497089050 RIVER EXE ESTUARY(E) DISINFECTION WEAR) STW BIOLOGICAL EXFORD STW 120 SS8567038160 (S) RIVER EXE FILTRATION

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Dry NGR (OSGB Weather Name Treatment Type 1936, EPSG Receiving Environment Flow 27000) (m3/day) SEWAGE UV 11825 SY0379079190 LYME BAY (C) TREATMENT DISINFECTION WORKS FORETOWN BIOLOGICAL TRIBUTARY OF RIVER 4.8 ST0315000010 STW FILTRATION CLYST(S) HALBERTON BIOLOGICAL (S) TRIB OF HALBERTON 208 ST0113012320 STW FILTRATION STREAM HELE (WHITEWAYS) Unspecified Unspecified SS9955002050 RIVER CULM STW HELE VILLAGE Unspecified Unspecified SS9935002350 RIVER CULM HEMYOCK WASTEWATER ACTIVATED 446 ST1339013880 RIVER CULM TREATMENT SLUDGE WORKS SEWAGE BIOLOGICAL TRIBUTARY OF RIVER Unspecified ST0290020270 TREATMENT FILTRATION LOWMAN(S) WORKS HOLCOMBE BIOLOGICAL 119 ST0639017980 TRIB OF RIVER LYNER ROGUS WWTW FILTRATION Unspecified Unspecified ST0045020350 RIVER LOWMAN STW KENN & BIOLOGICAL KENNFORD 262 SX9276085270 RIVER KENN (S) FILTRATION STW KENTON AND UV STARCROSS 1750 SX9748283180 EXE ESTUARY (E) DISINFECTION STW BIOLOGICAL KERSWELL STW Unspecified ST0782006330 RIVER WEAVER FILTRATION UNNAMED TRIB RIVER KNOWLE STW Unspecified Unspecified SS7831001590 TRONEY LORDS CHEMICAL - MEADOW 4100 PHOSPHATE SX8572099120 RIVER YEO/ WWTW STRIPPING MAMHEAD TRIBUTARY OF THE RIVER Unspecified Unspecified SX9340080350 STW EXE MARSH GREEN WASTEWATER 28 REEDBED SY0419093810 FORD STREAM (S) TRTMNT WORKS

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Dry NGR (OSGB Weather Name Treatment Type 1936, EPSG Receiving Environment Flow 27000) (m3/day) UNNAMED TRIB RIVER Unspecified Unspecified SS9535024770 STW BATHERM NEWBUILDINGS (S) UNNAMED TRIB RIVER Unspecified Unspecified SS7950003500 STW YEO NEWTON ST ACTIVATED 300 SX8885098140 (S) RIVER CREEDY CYRES STW SLUDGE Unspecified Unspecified SX7452093750 STW

OAKFORD STW Unspecified Unspecified SS9113021420 TRIB OF IRON MILL STREAM

OAKLEIGH BIOLOGICAL GROUNDWATER VIA INFILT Unspecified ST1209008480 WWTW FILTRATION SYSTEM OLDWAY END UNNAMED TRIB BROCKNEY Unspecified Unspecified SS8690024950 STW BROOK SEWAGE UV 1643 SY0923084090 LYME BAY (C) TREATMENT DISINFECTION WORKS PENNYMOOR SEWAGE BIOLOGICAL A TRIBUTARY OF 34 SS8646011670 TREATMENT FILTRATION BINNEFORD WATER WORKS BIOLOGICAL PLYMTREE STW 96.8 ST0406003960 (S) RIVER WEAVER FILTRATION PORT ROAD BIOLOGICAL TRIB OF SHUTTERTON 3.6 SX9486079650 WWTW FILTRATION BROOK PACKAGE POUGHILL STW Unspecified TREATMENT SS8653008290 HOLY WATER PLANT PUDDINGTON Unspecified Unspecified SS8360010730 RIVER CREEDY STW REWE WASTEWATER BIOLOGICAL 429 SX9455098840 RIVER CULM TREATMENT FILTRATION WORKS SAMPFORD BIOLOGICAL PEVERELL 296 ST0387013360 SPRATFORD STREAM FILTRATION WWTW SANDFORD WASTEWATER BIOLOGICAL TRIBUTARY OF RIVER 118 SS8339002240 TREATMENT FILTRATION CREEDY WORKS

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Dry NGR (OSGB Weather Name Treatment Type 1936, EPSG Receiving Environment Flow 27000) (m3/day) SHILLINGFORD Unspecified Unspecified SX9135088650 TIDAL RIVER EXE ABBOT STW SHILLINGFORD ST GEORGE Unspecified Unspecified SX9075088050 TRIB OF MATFORD BROOK WWTW CSO SHILLINGFORD Unspecified Unspecified SS9794023780 RIVER BARTHERM STW BIOLOGICAL SHUTE WWTW 12.3 SS8954000080 TRIB OF RIVER CREEDY FILTRATION PACKAGE SIDELING CLOSE 13.5 TREATMENT SX8823087870 RIVER KENN STW PLANT SILVERTON ACTIVATED 563.64 SS9712001420 HEAL-EYE STREAM WWTW SLUDGE BIOLOGICAL SPREYTON STW 34 SX6987097530 COOMBE STREAM(S) FILTRATION STOODLEIGH Unspecified Unspecified SS9250019000 STOODLEIGH STREAM STW TEDBURN ST BIOLOGICAL 383 SX8248093950 LILLY BROOK(S) MARY STW FILTRATION THORVERTON BIOLOGICAL 309 SS9359001680 (S) RIVER EXE WWTW FILTRATION BIOLOGICAL FILTRATION / TIVERTON STW 6900 CHEMICAL - SS9530010300 RIVER EXE PHOSPHATE STRIPPING UFFCULME BIOLOGICAL 564 ST0622011860 RIVER CULM WWTW FILTRATION UPLOWMAN BIOLOGICAL 42 ST0132015270 UPLOWMAN STREAM STW FILTRATION WASHFIELD TRIB OF WASHFEILD Unspecified Unspecified SS9360015300 STW STREAM WHIDDON BIOLOGICAL 41 SX6929092440 FINGLE BROOK(S) DOWN STW FILTRATION WASTEWATER BIOLOGICAL 613 ST0420010160 TRIB OF RIVER CULM TREATMENT FILTRATION WORKS WIMBLEBALL GROUNDWATER VIA INFILT RESERVOIR 6.3 SEPTIC TANK SS9640031000 SYSTEM WWTW WINSFORD BIOLOGICAL 84 SS9110034630 RIVER EXE(S) STW FILTRATION

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Dry NGR (OSGB Weather Name Treatment Type 1936, EPSG Receiving Environment Flow 27000) (m3/day) WOODBURY BIOLOGICAL 408 SX9979086780 WOODBURY BROOK WWTW FILTRATION WWTW AT PRIMARY 404 ST0057003310 RIVER CULM SETTLEMENT WASTEWATER BIOLOGICAL 493 SX7894098740 RIVER YEO TREATMENT FILTRATION WORKS OLD WOODBURY BIOLOGICAL TRIB OF GRINDLE BROOK 201 SY0128089340 SALTERTON FILTRATION VIA SWS STW CSO

Most continuous discharges within the catchment are in the upper reaches of the catchment and discharge to small watercourses that ultimately drain into the Rivers Exe and Clyst at the head of the estuary. The most significant discharges in terms of the levels of bacteriological contamination to the application zone are the Countess Wear STW and the Kenton and Starcross STW. Both employ UV disinfection and, therefore, pose a reduced risk in terms of E. coli contamination of shellfish. However, both still represent a significant risk due to either the volume of discharge (40,486 m3/day from the Countess Wear STW) or proximity to the application zone (1,300 m between the Kenton & Starcross STW and the application zone). The location of the RMP should be such that the contamination from these sources is considered in determining its location. 3.2.2 Intermittent Discharges Intermittent discharges, comprising Combined Storm Overflows (CSOs), storm tank overflows and pumping station emergency overflows have the potential to significantly affect local water quality and subsequently the management of shellfish hygiene within BMCZs. Spill events either occur during periods of wet weather, when the sewers are inundated with surface water and infiltration of groundwater, or in the event of an emergency failure of a plant/equipment. Monthly classification sampling cannot normally reliably characterise the impacts from these spills as they occur sporadically and/or infrequently. Whilst some discharges are screened to remove sewage debris prior to discharge, such screening is unlikely to significantly reduce faecal bacterial loading. These discharges therefore often spill raw/untreated effluent with high faecal coliform concentrations (7.2 x106 CFU/100 ml, Kay et al., 2008).

There is a total of 253 intermittent discharges contained within the Exe estuary catchment. Details of these discharges, including any treatment in place, are presented in Table 3.2 and the positions of those discharges closest to the application zone are presented in Figure 3.1.

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Table 3.2: Details of intermittent discharges within the application zone.

Name Receiving NGR (OSGB 1936, Treatment (if Environment EPSG 27000) applicable)

121A ST. KATHERINES MINCINGLAKE SX9419093870 SCREENING ROAD CSO STREAM 14 CLIFTON ROAD CSO RIVER EXE VIA SWS SX9223091880 NONE 15 HAMLIN LANE CSO NORTH BROOK SX9417093410 NONE 19 HEAVITREE ROAD RIVER EXE VIA SWS SX9223091880 NONE CSO 2 DRYDEN ROAD CSO NORTH BROOK VIA SX9430091240 NONE SWS 21 LOWER TOWN CSO TRIBUTARY OF ST0328014230 NONE SPRATFORD STREAM 21 WONFORD STREET NORTHBROOK VIA SX9429091240 NONE CSO SWS 23 KING EDWARD RIVER EXE VIA SWS SX9109093800 NONE STREET CSO 28 CLIFTON ROAD CSO RIVER EXE VIA SWS SX9224091880 NONE 34 CLIFTON ROAD CSO RIVER EXE VIA SWS SX9224091890 NONE 49 EXETER ROAD CSO ENGLISH CHANNEL SX9679077050 SCREENING VIA SWS 50 CASTLE PARK CSO STREAM (S) ST1361413585 NONE ARGYLL ROAD PUMPING TRIBUTARY OF SX9212094980 FLOTATION STATION DURYARD STREAM ASH GROVE CSO A TRIBUTARY OF THE SY0003083070 NONE EXE ESTUARY AYLESBEARE STW AYLESBEARE BROOK SY0358091860 SCREENING BAMPTON STREET CSO RIVER EXE SS9535012800 NONE BAMPTON WWTW RIVER BATHERM SS9541021790 SCREENING BARNHILL PUMPING GROUNDWATER VIA SX9273098460 NONE STATION INFILT SYSTEM BARRINGTON STREET RIVER LOWMAN SS9577012580 SCREENING CSO BARTON DAWLISH WATER (S) SX9591076670 SCREENING HILL/BRUNSWICK CSO BATHILL PSEO STREAM (S) ST0361107084 NONE BELLE PARADE CSO STREAM (S) SS8448600412 NONE BESSOM BRIDGE WIMBLEBALL LAKE SS9740031871 NO TREATMENT PUMPING STATION REQUIRED - GOOD ENGINEERING DESIGN

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Name Receiving NGR (OSGB 1936, Treatment (if Environment EPSG 27000) applicable)

BICKLEIGH STW TRIB OF RIVER EXE SS9401007000 NONE

BLUE BALL PUMPING TRIB OF RIVER CLYST SX9686090930 NO TREATMENT STATION REQUIRED - GOOD ENGINEERING DESIGN BONHAY PARK CSO RIVER EXE SX9140092310 SCREENING BONHAY ROAD CSO TIDAL RIVER EXE(E) SX9783081900 SCREENING BOOBERY ROAD TRIB OF SPRATFORD ST0303014370 NONE COMBINED SEWER STREAM OVERFLO BRAMPFORD SPEKE STREAM (S) SX9275097812 NONE LAKE BRIDGE PSEO BRIDGE HOUSE CSO RIVER EXE SS9532012540 NONE BRIDGETOWN WWTW RIVER EXE SS9233033200 UNSPECIFIED PS BRITTON STREET PSEO RIVER BATHERN SS9593022131 UNSPECIFIED (SIDE) RIVER CLYST VALLEY SX9851097400 NO TREATMENT PUMPING STATION VIA SWS REQUIRED - GOOD ENGINEERING DESIGN BROMPTON REGIS STW PULHAM RIVER(S) SS9553031200 UNSPECIFIED

BROOK COTTAGE NADDER BROOK SX8911093440 SCREENING PUMPING STATION BROOK HOUSE SSO DAWLISH WATER (S) SX9544076790 SCREENING

BRUSHFORD WWTW RIVER BARLE SS9264025890 SCREENING BUCKLAND ENGLISH CHANNEL SX9606071430 SCREENING WASTEWATER (COASTAL) TREATMENT WORKS BUDDLE LANE CSO RIVER EXE VIA SWS SX9300090670 NONE

BULLEN STREET TRIB OF THE RIVER SS9259002110 NONE COMBINED SEWER OF EXE VIA SWS

BULLER ROAD CSO STREAM (S) SS8448600412 NONE WWTW FENACRE WATER ST0653016980 SCREENING BURNTHOUSE LANE CSO NORTHBROOK VIA SX9429091240 SCREENING SWS CADELEIGH STW UNNAMED SS9153008120 UNSPECIFIED WATERCOURSE(S)

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Name Receiving NGR (OSGB 1936, Treatment (if Environment EPSG 27000) applicable)

CENTRAL STATION YARD HIGHER LEAT VIA SWS SX9147092500 SCREENING CSO CHERITON BISHOP FORD BROOK (S) SX7730093000 NONE PSCSO/EO CHERITON BISHOP STW FORD BROOK(S) SX7757093550 SCREENING CHERITON FITZPAINE TRIBUTARY OF HOLLY SS8580006150 SCREENING WWTW WATER CHURCH LANE TRIB OF RIVER CREEDY SS8448000410 NONE COMBINED SEWER VIA SWS OVERFLOW CHURCH ROAD CSO ALPHIN BROOK SX9176090270 SCREENING CHURCH ROAD CSO COFTON STREAM(S) SX9718280629 SCREENING CHURCH ROAD CSO CRANNY BROOK SY0416097130 SCREENING CHURCH ROAD JCT OF RIVER EXE VIA SWS SX9299090670 NONE CECIL ROAD CSO CHURCH STREET TRIB OF RIVER CREEDY SS8448000410 NONE COMBINED SEWER (SWS) OVERFL CHUTE STREET CSO RIVER EXE VIA SWS SX9223091890 NONE

CLIFTON ROAD/JCT RIVER EXE VIA SWS SX9223091880 NONE ALBERT ROAD CSO CLYST RIVER CLYST SX9865093690 SCREENING PUMPING STATION COACH ROAD CSO STREAM (S) SS9586402917 NONE COCKWOOD PSEO COFTON STREAM(S) SX9756680731 SCREENING COFTON PSCSO/EO COFTON STREAM(S) SX9711880605 SCREENING COLLETON GROVE CSO RIVER EXE VIA SWS SX9223091890 NONE CORNER LANE PUMPING TRIBUTARY OF ST0074012820 SCREENING STATION SPRATFORD STREAM COUNCIL YARD TRIB RIVER CREEDY (S) SS8447000390 NONE PSCSO/EO COWLEYMOOR ESTATE TRIB OF RIVER SS9610012990 NONE CSO LOWMAN VIA SWS CULMSTOCK SEWAGE RIVER CULM ST0992013680 SCREENING TREATMENT WORKS DAWLISH (ROYAL DAWLISH WATER(C) SX9636076620 NONE HOTEL) PS DAWLISH BREAKWATER LYME BAY (C) SX9648076510 SCREENING SSO DAWLISH SSO (BROOK DAWLISH WATER(S) SX9567076740 SCREENING STREET)

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Name Receiving NGR (OSGB 1936, Treatment (if Environment EPSG 27000) applicable)

DAWLISH WARREN SHUTTERTON SX9760478924 SCREENING ROAD PS BROOK(S) SHUTTERTON SX9760678925 SCREENING ROAD PS BROOK(S) DIX'S FIELD CSO RIVER EXE VIA SW SX9224091880 NONE SEWER DUKE STREET PUMPING CULLOMPTON MILL ST0238006730 SCREENING STATION LEAT DULFORD PSCSO/EO WEAVER (S) ST0697005960 NONE DULVERTON WWTW RIVER BARLE SS9158027280 SCREENING DUNKESWELL PS DUNKESWELL ST1426007700 SCREENING STREAM(S) DUNKESWELL STW RIVER MADFORD (S) ST1519008580 SCREENING DUNSFORD ROAD CSO RIVER EXE VIA SWS SX9299090670 NONE EBFORD PUMPING RIVER CLYST SX9758087940 SCREENING STATION (ESTUARINE) ELM GROVE CSO LYME BAY (C) SX9679077050 SCREENING EXE BRIDGE PS RIVER EXE(S) SS9296024420 NONE EXE STREET CSO HIGHER LEAT SX9146092510 SCREENING EXELEIGH PSEO RIVER EXE (E) SX9756082430 NONE EXETER (COUNTESS RIVER EXE ESTUARY(E) SX9479089240 SCREENING WEAR) STW EXETER (COUNTESS RIVER EXE ESTUARY(E) SX9497089050 SCREENING WEAR) STW EXETER BOWLING CLUB RIVER EXE VIA SWS SX9223091890 NONE CSO EXETER COLLEGE CSO HIGHER LEAT VIA SW SX9147092500 SCREENING SEWER EXETER ROAD CSO - WITHYCOMBE BROOK SX9997082010 SCREENING EXMOUTH EXETER ROAD PUMPING COTTEY BROOK SS9492011640 NO TREATMENT STATION REQUIRED - GOOD ENGINEERING DESIGN EXFORD STW RIVER EXE SS8567038160 EXFORD STW PSEO RIVER EXE (S) SS8567038160 NONE EXMOUTH SEWAGE LYME BAY(C) SY0379079190 SCREENING TREATMENT WORKS EXTON NORTH PS RIVER CLYST SX9769086890 SCREENING (ESTUARINE)

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Name Receiving NGR (OSGB 1936, Treatment (if Environment EPSG 27000) applicable)

EXTON SOUTH WOODBURY BROOK SX9809086240 SCREENING PUMPING STATION (ESTUARINE)

FERRY ROAD PUMPING RIVER EXE SX9623088140 NO TREATMENT STATION REQUIRED - GOOD ENGINEERING DESIGN FIRST AVENUE SERVICE NORTH BROOK VIA SX9480092300 NONE LANE CSO SWS FOLLET ROAD CSO RIVER EXE (E) SX9622088140 SCREENING FORD BARTON PSEO STREAM (S) SS9132318219 NONE FORE STREET CSO KNOWLE STREAM SY0649081880 NONE FORGE WAY CAR PARK MILL STREAM (S) ST0227907436 NONE CSO GENERALS LANE S/WATER SYSTEM TO SX9766081850 SCREENING PUMPING STATION EXE ESTUARY GOLD STREET CSO RIVER LOWMAN SS9576012560 NONE GRANARY LANE KERSBROOK CHANNEL SY0711082740 SCREENING (NORTH) CSO GRANARY LANE CSO TRIB OF RIVER OTTER SY0718082270 NONE (S) HAM LANE CSO WOODBURY BROOK SY0074086930 SCREENING HAREWOOD PSEO SURFACE (S) SS9680030120 NONE HARTOPP ROAD CSO EXE ESTUARY SX9996081460 SCREENING HAWKINGS WAY TRIB OF RIVER CREEDY SS8448000410 NONE CREDITION CSO VIA SWS HEATH CROSS PUMPING TRIB OF RIVER CLYST SX9882096880 NO TREATMENT STATION REQUIRED - GOOD ENGINEERING DESIGN HEAVITREE PLEASURE NORTH BROOK VIA SX9479092290 NONE GROUND CSO SWS HEMYOCK PSCSO/EO RIVER CULM (S) ST1384013930 NONE HEMYOCK STW PSEO RIVER CULM (S) ST1384013940 NONE HEMYOCK RIVER CULM ST1339013880 SCREENING WASTEWATER TREATMENT WORKS HESCANE PARK CSO YEO(S) SX7742493169 NONE HIGH MARSH PSEO RIVER CREEDY(S) SX8967097460 SCREENING (HALF MOON VILLAGE) HOLCOMBE PUMPING SHELL COVE, LYME SX9608075340 SCREENING STATION BAY(C)

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Name Receiving NGR (OSGB 1936, Treatment (if Environment EPSG 27000) applicable)

HOLCOMBE ROGUS TRIB OF RIVER LYNER ST0580018240 PRIMARY SETTLEMENT WWTW HOLLOWAY STREET RIVER EXE VIA SWS SX9223091880 NONE HOWELL ROAD CSO HIGHER LEAT VIA SWS SX9146092500 SCREENING HUNTSHAM STW TRIBUTARY OF RIVER ST0052020230 UNSPECIFIED LOWMAN(S) IMPERIAL ROAD TANK EXE ESTUARY SX9986081110 SCREENING CSO IN FIELD R/0 11 MILL BROOK (S) ST0653212323 NONE GRANTLANDS JEWSONS YARD CSO RIVER YEO (S) SX8474699207 NONE JOCKEY HILL CSO TRIBUTARY OF IVER SS8448000410 NONE CREEDY KENN AND KENNFORD RIVER KENN SX9275085270 SCREENING PUMPING STATION LANGATON LANE CSO PIN BROOK SX9731094130 NONE LARKBEARE HOUSE CSO RIVER EXE VIA SWS SX9223091890 NONE LIME KILN PSEO KERSBROOK CHANNEL SY0722082100 SCREENING LIME KILN TANK CSO ENGLISH CHANNEL SY0794081920 SCREENING LITTLE KNOWLE CSO KNOWLE STREAM SY0535082260 NONE LITTLE SILVER PUMPING RIVER LOWMAN SS9534011980 SCREENING STATION LITTLE SILVER PUMPING RIVER LOWMAN SS9544012080 SCREENING STATION LORDS MEADOW RIVER YEO/RIVER SS8488000620 SCREENING WWTW CREEDY LORDS MEADOW RIVER YEO SX8475099210 WWTW LOWER AVENUE CSO NORTH BROOK VIA SX9479092290 NONE SWS LOWER MILL COMBINED RIVER BARLE SS9125027720 NONE SEWER OVERFLOW LOWER NORTH STREET HIGHER LEAT VIA SW SX9147092500 SCREENING CSO SEWER LYMPSTONE OUTFALL RIVER EXE ESTUARY SX9874083860 SCREENING PUMPING STATION MAER PUMPING ENGLISH CHANNEL SY0111079660 SCREENING STATION & TANK CSO MAER ROAD CSO BROOK SY0107080060 SCREENING EXMOUTH MAGDALEN ROAD CSO RIVER EXE VIA SWS SX9223091880 NONE

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Name Receiving NGR (OSGB 1936, Treatment (if Environment EPSG 27000) applicable)

MAGELAKE PS RIVER CULM(S) ST0703812505 NONE MAIN ROAD CSO BERRY BROOK SX9456087320 NONE MARINA PSEO DAWLISH (C) SX9712277366 NONE MARINE PARADE CSO KNOWLE STREAM SY0664081860 SCREENING MARSH GREEN FORD STREAM (S) SY0419093810 SCREENING WASTEWATER TRTMNT WORKS MEADOW ROAD TANK KNOWLE STREAM SY0597082060 SCREENING CSO MIDDLE MILL LANE CSO MILL LEAT ST0228007350 SCREENING MILBURY LANE TRIB OF THE BERRY SX9483087970 SCREENING PUMPING STATION BROOK MILBURY LANE TRIB OF THE BERRY SX9500088340 SCREENING PUMPING STATION BROOK MILL RACE COMBINED MILL RACE, RIVER EXE SX9341090620 NONE SEWER OVERFLOW MILL ROAD PUMPING RIVER EXE SX9397090120 NO TREATMENT STATION (ESTUARINE) REQUIRED - GOOD ENGINEERING DESIGN MILL STREET COMBINED TRIB RIVER CREEDY (S) SS8418900304 NONE SEWER OVERFLOW MILL STREET COMBINED TRIB OF RIVER CREEDY SS8419000300 NONE SEWER OVERFLOW VIA SWS MILLMOOR CSO RIVER CULM(S) ST1007513766 NONE MONKERTON PUMPING PIN BROOK SX9671093970 NO TREATMENT STATION REQUIRED - GOOD ENGINEERING DESIGN MOOR LANE PSCSO/EO STREAM (S) SX9645097062 NONE MOREBATH STW SHUTTERN BROOK (S) SS9535024770 UNSPECIFIED NEWPORT PARK TRIB OF RIVER EXE SX9541088990 NO TREATMENT PUMPING STATION (ESTUARINE) REQUIRED - GOOD ENGINEERING DESIGN STW (S) RIVER CREEDY SX8885098140 SCREENING NORTH LAWN COURT NORTH BROOK VIA SX9479092300 NONE CSO SWS NORTH STREET CAR TRIB OF RIVER CREEDY SS8448600412 NONE PARK CSO VIA SWS NORTHBROOK GOLF NORTHBROOK SX9382090390 SCREENING COURSE LOWER CSO NORTHBROOK PARK NORTHBROOK SX9383090400 SCREENING GOLF CRSE UPPER CSO

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Name Receiving NGR (OSGB 1936, Treatment (if Environment EPSG 27000) applicable)

O/S 25 OAK CRESCENT TRIB OF CULM (S) ST0310010480 NONE PSEO O/S HONITON INN RIVER EXE (S) SX9254792833 NONE OAKFORD STW TRIB OF IRON MILL SS9115021420 UNSPECIFIED STREAM (S) OAKLANDS PSEO COASTAL (C) SX9610475854 NONE ROAD RIVER EXE VIA SWS SX9299090670 NONE CSO OLD TIVERTON ROAD STREAM(S) SS8448600412 NONE CSO OLD WOODBURY TRIB OF GRINDLE SY0128089340 SCREENING SALTERTON STW CSO BROOK VIA SWS PARKLAND DRIVE NORTHBROOK VIA SX9430091240 NONE PUMPING STATION SWS PATHFINDER TERMINAL LILLY BROOK(S) SX8248093950 SCREENING PS PENCEPOOL FARM TRIBUTARY OF RIVER ST0522003090 SCREENING PUMPING STATION CLYST (S) PENNSYLVANIA ROAD HIGHER LEAST VIA SW SX9147092500 SCREENING CSO SEWER PENNYMOOR SEWAGE A TRIBUTARY OF SS8645011630 SCREENING TREATMENT WORKS BINNEFORD WATER PHEAR PARK PSEO/CSO EXE ESTUARY SX9996081460 SCREENING PLYMTREE STW RIVER WEAVER ST0406003960 PRIMARY SETTLEMENT PLYMTREE STW AN UNNAMED TRIB- ST0491002790 SCREENING RIVER CLYST POUNDSHILL PSCO/EO STREAM ST0606418853 NONE PUDDINGTON STW RIVER CREEDY SS8360010730 NONE QUAY HILL COMBINED HIGHER LEAT SX9192092170 NONE SEWER OVERFLOW QUAY HILL CSO HIGHER LEAT VIA SW SX9194092150 SCREENING SEWER R/O 13 WEST STREET RIVER BATHERN (S) SS9546622016 NONE CSO R/O IMPERIAL HOTEL TADDIFORDE BROOK SX9141093490 NONE CSO RAGSFIELD PSEO TRIB OF R. CREEDY SS8442300595 NONE REWE WASTEWATER RIVER CULM SX9455098840 SCREENING TREATMENT WORKS ROSE COTTAGE CSO LILLY BROOK (S) SX8228894125 NONE

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Name Receiving NGR (OSGB 1936, Treatment (if Environment EPSG 27000) applicable)

SAMPFORD PEVERELL SPRATFORD STREAM ST0387013360 SCREENING WWTW SANDFORD PUMPING THE SANDFORD SS8309502203 NONE STATION STREAM (S) SANDFORD ROSE & THE SANDFORD SS8275102304 SCREENING CROWN CSO STREAM (S) SANDFORD TRIBUTARY OF RIVER SS8339002240 SCREENING WASTEWATER CREEDY TREATMENT WORKS SANDY BAY HOLIDAY STRAIGHT POINT (C) SY0398079190 NONE PARK PSEO SANDY LANE PUMPING LYME BAY (COASTAL) SX9736076490 SCREENING STATION SANDY LANE PUMPING LYME BAY (C) SX9742076470 SCREENING STATION SEA LAWNS OUTFALL LYME BAY(C) SX9679077050 NONE CSO, DAWLISH SEA LAWNS PUMPING LYME BAY SX9679077050 NO TREATMENT STATION REQUIRED - GOOD ENGINEERING DESIGN SEARLE STREET CSO STREAM (S) SS8448600412 NONE SHILLINGFORD ST ALPHIN BROOK SX9073087980 GEORGE WWTW CSO SHIP INN CSO COFTON STREAM(S) SX9752580690 SCREENING PS SHOBROOKE LAKE SS8712001320 SCREENING SHUTE WWTW TRIB OF RIVER CREEDY SS8954000080 SCREENING SHUTTERTON BRIDGE PS SHUTTERTON SX9658078540 SCREENING BROOK(S) SILVERTON PUMPING SILVERTON STREAM SS9527003010 SCREENING STATION VIA SWS SILVERTON WWTW HEAL-EYE STREAM SS9712001420 SCREENING SLITTERCOMBE LANE RIVER KENN(S) SX9613083470 SCREENING PSCSO/EO SMUGGLERS LANE PSEO BABBACOMBE BAY(C) SX9568074640 SCREENING SOWDEN LANE TRIBUTARY OF EXE SX9912083670 SCREENING PUMPING STATION ESTUARY (S) SPREYTON STW COOMBE STREAM(S) SX6985097520 SCREENING ST MARTINS LANE CSO STREAM (S) SS8448500412 NONE ST NICHOLAS CHURCH BROCKERY RIVER (S) SS9189725652 NONE PSEO

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Name Receiving NGR (OSGB 1936, Treatment (if Environment EPSG 27000) applicable)

ST SIDWELLS SCHOOL HIGHER LEAT VIA SW SX9147092500 SCREENING CSO SEWER

STATION ROAD SPRATFORD STREAM ST0332111417 PSCSO/EO WILLAND STATION ROAD PSEO RIVER CREEDY(S) SX8810098560 SCREENING STOKE CANON PSEO R CULM (S) SX9371097598 SCREENING STOKE MEADOW CLOSE MINCINGLAKE SX9330094620 NO TREATMENT PUMPING STATION STREAM VIA SWS REQUIRED - GOOD ENGINEERING DESIGN STONEYFORD PSCSO/EO RIVER CULM (S) ST0287607453 SCREENING

STOODLEIGH STW STOODLEIGH STREAM SS9243018980 SWEETBRIER LANE CSO NORTHBROOK SX9481092600 SCREENING SWEETHAM SEWAGE RIVER CREEDY(S) SX8813098580 SCREENING PUMPING STATION TALATON PSCSO/EO STREAM (S) SY0685699822 NONE TAN LANE PUMPING TRIB OF THE ALPHIN SX9204091350 NO TREATMENT STATION BROOK REQUIRED - GOOD ENGINEERING DESIGN STW LILLY BROOK(S) SX8248093950 SCREENING TEDBURN ST MARY STW LILLY BROOK(S) SX8250093940 SCREENING TEMPLE ROAD CSO RIVER EXE VIA SWS SX9223091880 NONE THE COLLEGE IDE CSO FORDLAND BROOK SX9001090600 SCREENING THE GREEN TANK CSO KNOWLE STREAM SY0617081990 SCREENING THE WALRONDS CSO RIVER EXE SS9526011910 NONE THORNTON HILL CSO HIGHER LEAT VIA SWS SX9147092500 NONE THORVERTON WWTW (S) RIVER EXE SS9359001680 SCREENING TIVERTON STW RIVER EXE SS9530010300 SCREENING TOPSHAM ROAD JCT RIVER EXE VIA SWS SX9223091890 NONE ROBERS ROAD CSO

TURLAKE SPS TRIB OF R EXE SX9049296109 UFFCULME PUMPING RIVER CULM ST0632011960 SCREENING STATION UFFCULME WWTW RIVER CULM ST0622011860 SCREENING UPLOWMAN STW UPLOWMAN STREAM ST0132015270 SCREENING VIADUCT HIGH LEVEL DAWLISH WATER(C) SX9630076660 SCREENING STORM TANK CSO WAR MEMORIAL CSO RIVER CULM (S) ST0973713696 NONE WASHFIELD STW TRIBUTARY OF RIVER SS9353015050 UNSPECIFIED EXE(S) WEAVER CRESCENT CSO RIVER EXE SS9481013410 SCREENING

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Name Receiving NGR (OSGB 1936, Treatment (if Environment EPSG 27000) applicable)

WELL STREET CSO HIGHER LEAT VIA SW SX9147092500 SCREENING SEWER WEST CLIFF COMBINED DAWLISH WATER (S) SX9569076710 SCREENING SEWER OVERFLOW WESTEXE PUMPING RIVER EXE SS9532012010 SCREENING STATION WESTWOOD PSEO TRIB RIVER YEO (S) SS8225800129 NONE WHIDDON DOWN STW FINGLE BROOK(S) SX6929092440 SCREENING WILLAND WASTEWATER TRIB OF RIVER CULM ST0419010600 SCREENING TREATMENT WORKS WILLAND WASTEWATER TRIB OF RIVER CULM ST0420010160 SCREENING TREATMENT WORKS WINSFORD PSCSO/EO RIVER EXE(S) SS9072034830 SCREENING WITHYBRIDGE RIVER CLYST SX9747095730 NO TREATMENT PUMPING STATION REQUIRED - GOOD ENGINEERING DESIGN WOODBURY WWTW WOODBURY BROOK SX9979086780 SCREENING WOODLAND AVE CSO STREAM DIS TO LYME SX9509074280 SCREENING BAY (S) WWTW AT BRADNINCH RIVER CULM ST0057003310 SCREENING YEOFORD WASTEWATER RIVER YEO SX7894098740 SCREENING TREATMENT WORKS

There are several discharges that spill out in close proximity to the application zone on both sides of the estuary. The closest discharges are Lympstone Outfall PS, Sowden Lane PS, Ash Grove CSO, Exeter Road CSO – Exmouth, Bonhay Road CSO, Generals Lane PS and Exeleigh PSEO. These discharges employ either primary screening or employ no treatment at all. Beyond these discharges, tidal circulation will disperse contamination from other discharges over a wider area. The RMP should take into account these sources of contamination. 3.2.3 Private Discharges In addition to the continuous and intermittent discharges, there are a number of private discharges within the catchment. The closest of these drains approximately 1 km from the application zone. These discharges will contribute to the wider level of background contamination originating from up- estuary sources and, as such, do not require additional consideration in terms of RMP location.

3.3 Boats and Marinas

The 2013 sanitary survey reported that 1,800 moorings were present (Cefas, 2013) and analysis of recent satellite imagery indicates the current number is similar. These moorings are mostly concentrated at the mouth of the estuary, although some are located off Lymptone, ~800 m north of the application zone. There are no commercial shipping ports within the Exe estuary, however, 20 vessels under 10 m and one vessel over 10 m lists Exmouth as its home port. Exmouth marina, 2.6 km south of the application zone at the mouth of the estuary has 200 berths (Exmouth Marina,

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2020) for recreational vessels of a variety of sizes. No pump-out facilities are available at this marina; the closest facilities are located in Harbour, 50 km west of the estuary (The Green Blue, 2020).

Merchant shipping vessels are prohibited from making overboard discharges within three nautical miles of land2, meaning that no impact on the application zone is expected from vessels transiting past the Exe estuary. Recreational vessels of sufficient size to contain on-board toilets are liable to make overboard discharges from time to time, particularly when moored overnight or when navigating through an area. Contamination from recreational vessels represents significant source of contamination at certain times of the year (May to September). Therefore, inputs from boats may contribute to the overall faecal loading within the area and contribute to faecal loadings to the Application Area, however, this contribution is considered to be minimal and also cannot be reliably captured by an RMP. 3.4 Agricultural Sources The main route through which diffuse sources of agricultural faecal contamination enters waterways (and subsequently BMCZs) is runoff during periods of wet weather. Faecal loading through this source is typically highest during winter months when rainfall and river flows are at their highest levels. However, high loadings are possible at any time of year during significant rainfall events, particularly following a period of prolonged dry weather.

The 2016 livestock census, the most recent for which data is available, identified 1,334,772 animals living within local authority districts contained within or partially within the Exe catchment. This population has been adjusted for the proportion of each district that falls within the catchment, assumes that livestock are distributed uniformly across the district and, therefore, some inaccuracies may be present. Land run-off from agricultural sources therefore represents a potentially significant source of contamination to the application zone, particularly as some pasture is located at the estuary edges. Land runoff from the application of animal slurry to fields within the catchment will also contribute to faecal contaminant loads in the bay after rainfall. Peak contamination levels will likely occur following high rainfall events in summer months, especially when these events follow periods of extended dry weather. Land run-off from areas of pasture during high rainfall events will likely drain into watercourses in the area, most of which ultimately drain into the Rivers Exe or Clyst. This represents a potential significant source of contamination and the RMP should take these sources into account. The RMP should be placed so as to capture this potentially significant source of contamination. 3.5 Wildlife The Exe estuary consists of several important estuarine habitats; mudflats, saltmarsh, eelgrasses, reedbeds and mussel beds. These habitats are home to significant populations of birds and other wildlife and accordingly areas of the estuary are afforded protection from a variety of statutory and non-statutory designated areas.

The average five-year count to 2018/2019, the most recent for which data are available, was 23,020 overwintering birds (Frost et al., 2020). Several avian species of both national and international importance are still supported by the Exe estuary. These include Avocet, Black-tailed Godwit, Brent Goose, Ringed Plover and Widgeon (Natural England, 2020). Geese and duck species within the

2 The Merchant Shipping (Prevention of Pollution by Sewage and Garbage from Ships) Regulations 2008.

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estuary are more likely to forage grasslands and saltmarsh that ring the estuary, where their faeces will be carried into coastal waters through runoff or tidal inundation. The locations of wading birds are related to the distributions of their prey in the intertidal areas and, as such, will vary from year to year. Therefore, the spatial distribution of any faecal contamination will be variable, but it is likely to be temporally constrained to winter months when populations are highest. Without specific information as to the locations, timings and extents of contamination it is difficult to define an RMP that will effectively capture this source of contamination.

No major grey seal colony is present in the Exe estuary, though sightings are common across the south coast (NBN, 2020). These animals show a wide foraging range and whilst they may well enter the estuary, do not represent a significant source of contamination to the shellfishery and, therefore, does not need to be taken into account when determining RMP locations. 3.6 Other Sources of Contamination Urban fabric within the catchment is concentrated around the banks of the Exe estuary. There are some minor towns and villages located throughout the catchment, such as , Cullompton and Tiverton. Settlements near to waterbodies represent a potential source of diffuse pollution via utility misconnections and dog fouling. Some dog walking may well take place around the coastline, although railway lines follow the coast on both sides of the estuary; the ‘Riviera Line’ on the west and the ‘’ on the eastern side (Travel Devon, 2020). There are some footpaths that run near to the coast and dog fouling may represent a potential diffuse source of pollution to the near- shore coastal zone. The highest risk will be around urban settlements on the coastline, such as the town of Lympstone which is located immediately north of the application zone.

4 Existing Classifications and Monitoring History The application zone is in the vicinity of the following existing CZs:

• Exe Approaches classified for Mussel (Mytilus edulis) (Class B-LT). Currently classified using samples from Beacon Point (B26AT) RMP (Figure 4.1). This RMP has been sampled since 2003 and since 2014 fewer than 20% of samples have exceeded the threshold of 4,600 E. coli/100 g required for class B, although nearly 60% of samples have exceeded the lower threshold of 230 E. coli/100 g required for Class A. A long-term classification is awarded when a CZ shows stable compliance for a period of five years or more. • Dawlish to Starcross classified for Mussel and Pacific Oyster (Crassostrea gigas) (both B-LT). Currently classified for both species based on samples from Cockwood Harbour (B26BH) RMP (Figure 4.2). This RMP has been sampled since April 2014 and, since then, fewer than 20% of samples have exceeded the threshold of 4,600 E. coli/100 g required for class B, although more than 60% of samples have exceeded the lower threshold of 230 E. coli/100 g required for Class A. A long-term classification is awarded when a CZ shows stable compliance for a period of five years or more.

In addition to the active CZs described above, harvesting from the Starcross to Powderham CZ is currently prohibited. Sampling recommenced at the original RMP (River Kenn (B36BC) in August 2020 following a five-year hiatus (Figure 4.3). E. coli levels in samples rapidly increased to levels that warranted a prohibited from first sampling in April 2014, although recent results have all fallen above the lower threshold of 230 E. coli/100 g required for class A, but below the threshold of 4,600 E. coli/100 g required for Class B. Currently only 6 samples have been collected, which is not

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sufficient to state whether water quality has improved significantly in the prohibited CZ, and as such it is not possible to comment on whether the application area would be subject to the same influences.

A further CZ, Sandy Bay, is classified for surf clams. This CZ is situated outside the estuary and as such monitoring history is not relevant to this application.

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Figure 4.1 Monitoring history for Beacon Point (M. sp) – B26AT. Horizontal lines indicate classification thresholds (<230 CFU/100 ml = A, <4600 CFU/100 ml = B & <46000 CFU / 100 ml = C).

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Figure 4.2 Monitoring history for Cockwood Harbour (M. sp) – B26BH. Horizontal lines indicate classification thresholds (<230 CFU/100 ml = A, <4600 CFU/100 ml = B & <46000 CFU / 100 ml = C).

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Figure 4.3 Monitoring history for River Kenn (M. sp) – B26BC. Horizontal lines indicate classification thresholds (<230 CFU/100 ml = A, <4600 CFU/100 ml = B & <46000 CFU / 100 ml = C).

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The status of EC bathing waters near the application zone are also of relevance to this assessment. There are three EC Bathing Water Quality Monitoring Points in the vicinity of the application zone (Figure 3.1). All have been consistently classified as excellent, with low levels of faecal coliforms (including E. coli) recorded in samples collected for classification purposes under EC Bathing Waters Directive (2006/7/EC). It should be noted that all three points are located outside the main estuary and that bathing water sampling only occurs during the summer period (May to September inclusive) and, therefore, may not represent the potential for increased faecal loading during periods of increased rainfall during winter months. However, bathing water results do provide an indication of water quality in the area during the bathing water season.

5 Hydrodynamics/Water Circulation The application zone is located on the eastern side of the Exe estuary, approximately 2.8 km from the mouth. Tidal streams are likely the dominating force of water circulation under most conditions. Tidal streams within the vicinity of the application zone are best characterised by the following data:

• The most relevant tidal prediction location for the application zone is located at Exmouth (Approaches) (50° 36’ N, 3° 23’ W, UKHO Total Tide (0026B – Exmouth (Approaches)). Tidal ranges for this location are as follows (all referenced to Chart Datum): o Mean Spring Range, 4.1 m; and o Mean Neap Range, 1.7 m.

Tidal currents in the estuary run on an approximate north-south axis. Contamination from up- estuary sources will be carried southward on an ebbing tide through the application zone.

6 Other Considerations The application zone is not located within a current Shellfish Disease Control Area and as such no further consideration of this matter is required (UK Government, 2020).

7 Recommendations for a RMP and Classification Zone 7.1 Provisional Classification Zone The application zone to be used as a production area for native and Pacific oysters is delineated by coordinates as outlined in Table 2.1. These coordinates define an area on the eastern side of the Exe estuary in Devon (see Figure 2.1 and Figure 3.1). It is recommended that the boundary of the classification zone remains the same as defined within the application. 7.2 Representative Monitoring Point (RMP) The location of the RMP has been informed based on the identified contamination sources described within this assessment, likely connectivity with the provisional classification zone outlined above, seasonality of inputs and faecal contamination loadings.

Direct contamination of the application zone will arise from three main sources: land runoff and intermittent discharges from urban fabric and areas of pasture on the eastern shore of the estuary, particularly around the town of Lympstone; diffuse sources of pollution carried down the estuary on ebbing tides from the main urban centres at the head of the estuary and sewage works located around the River Kenn on the opposite bank of the estuary. The Starcross to Powderham CZ is

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located adjacent to the River Kenn, and was classified as prohibited in 2015 following high Official Control monitoring results. It is not clear what caused this reduction in water quality, or whether the same source is currently active, as no monitoring took place from December 2015 – August 2020. Not enough samples have been collected to comment on whether the pollution source that led to the Prohibited status is inactive, and as such it is not possible to state whether the application area would experience the same contamination. Longitudinal sampling for at least 8-10 months at both the Prohibited CZ and proposed RMP would illustrate whether these pollution sources are still active. Contamination from the wider catchment will also originate from the north of the application zone via the Rivers Exe and Clyst at the head of the estuary.

Given the small size of the application zone, the choices for RMP location are limited. It is our recommendation however that the RMP be located near the western boundary of the application zone on one of the drainage channels that pass through the zone. This will best capture contamination from the various sources. It is not possible to determine from a desktop assessment or single shoreline survey whether the results from any new RMP would be significantly different to those collected nearer to point sources of contamination such as sewage treatment works, as this would only be possible following longitudinal sampling for at least 8-10 months. However, the worst- case scenario (i.e., highest E. coli results) for the application zone under consideration is likely to originate from sampling at the western boundary. 7.3 Classification Species A report commissioned by the FSA (Cefas, 2014), to examine the suitability of other shellfish species as indicator species, has been reviewed to determine the suitability of indicators for classification purposes. The recommendations for indicator species in relation to E. coli accumulation are generally limited by data availability and recommendations can only be made where sufficient data are available to compare E. coli accumulation and clearance in two or more species.

The application is for the harvesting of native (Ostrea edulis) and Pacific (Crassostrea gigas) oysters and the acquisition of either species is not anticipated to be problematic as the RMP location is situate within the boundary of the classification zone. The Cefas (2014) report indicated that monitoring of either species would be appropriate. We recommend that at samples from the dominant species in the shellfishery should be taken, to prevent unnecessary extra costs to the LA. 7.3.1 Criteria for Sampling The following criteria should be applied to sampling at the designated RMP:

• Each sample should comprise only individuals of harvestable / marketable size; and • Sample collection of the dominant species be undertaken by vessel at half tide within a tolerance of 25 m from the RMP.

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Figure 7.1: Location of RMP within application zone.

The RMP, sampling plan and provisional Classification Zone boundary are presented in Table 7.1.

Note - All coordinates in WGS1984, EPSG: 4326 are in dd.dddddd° format and those presented in OSGB 1936, EPSG:27700: are presented as Eastings and Northings (m).

Table 7.1: Provisional Sampling Plan

Production area Exe Provisional Classification Zone Lympstone Oysters RMP name(s) Lympstone Oysters (O. ed) or Lympstone Oysters (C. gi) – note, species suffix should be whichever species is used for compliance monitoring RMP Latitude / Longitude (WGS 1984, EPSG:4326): [50.639155°N, -3.4324119°E] Ordnance Survey National Grid (OSGB 1936, EPSG:27000) [298806 E, 083142 N] Classification species Ostrea edulis Crassostrea gigas Sampling species Ostrea edulis or Crassostrea gigas – whichever is the majority species Sampling depth Samples should be taken from the oyster long lines Collection method Via vessel at half-tide Sampling tolerance Samples are to be collected within a tolerance of 25 m of the RMP Sampling frequency Monthly – year round Provisional Classification Zone Delineated by lines between these points (WGS 1984, EPSG Boundaries 4326):

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[50.640150° N, -3.4325167° E] [50.640183° N, -3.4306667° E] [50.638867° N, -3.4325333° E] [50.638883° N, -3.4306833° E]

Delineated by lines between these points (OSGB 1936 EPSG:27000):

[298801 E, 083253 N] [298932 E, 083254 N] [298797 E, 083110 N] [298928 E, 083109 N] Notes The sampling species should be whichever is the more dominant within the shellfishery 8 Recommendations for a Shoreline Survey The proposed classification zone is of a relatively small size (130 m by 140 m), which limits the placement of the RMP. The application zone is located a significant distance downstream of the likely significant sources of contamination at the head of the estuary, which will diffuse out before reaching the zone. The application zone is also located near to a currently Prohibited CZ, on the opposite bank of the estuary.

It is, therefore, our recommendation that, in this case, further physical assessment of the zone to confirm existing sources of contamination or identify any unknown sources, in the form of a shoreline survey, is not considered of significant value. Physical assessment would provide limited additional information as no significant changes in bathymetry, land use or population via urban development were identified in the review of the entire Exe estuary relative to the 2013 sanitary survey. The assessment has identified sufficient information to enable the placement of the RMP in a location representative of faecal contamination sources within the area. The placement of the RMP is also limited due to the very small size of the classification zone within which the RMP can be located. A shoreline survey would not provide information as to connectivity between potential pollution sources impacting the prohibited CZ and the current CZ, as this would only be possible through longitudinal sampling at the application zone.

9 References Carcinus, 2020. Review of the Exe Estuary 2013 Sanitary Survey. Carcinus report on behalf of the Food Standards Agency, to demonstrate compliance with the requirements for classification of bivalve mollusc production areas in England and Wales under EC Regulation 2019/627.

Cefas, 2014. A critical review of the current evidence for the potential use of indicator species to classify UK shellfish production areas. FS512006. Centre for Environment Fisheries & Aquaculture Science. Weymouth UK.

Cefas, 2013. Sanitary Survey of the Exe Estuary. Cefas report on behalf of the Food Standards Agency, to demonstrate compliance with the requirements for classification of bivalve mollusc production areas in England and Wales under EC regulation No. 854/2004.

Exmouth Marina, 2020. The Harbour. Available [online] at https://www.exmouthmarina.co.uk/. Accessed November 2020.

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Frost, T.M., Calbrade, N.A., Birtles, G.A., Mellan, H.J., Hall, C., Robinson, A.E., Wotton, S.R., Balmer, D.E. and Austin, G.E., 2020. Waterbirds in the UK 2018/19: The Wetland Bird Survey. BTO/RSPB/JNCC. Thetford.

Natural England, 2020. Designated Sites View: Exe Estuary SSSI. Available [online] at: https://designatedsites.naturalengland.org.uk/SiteDetail.aspx?SiteCode=S1002089. Accessed July 2020.

NBN, 2020. National Biodiversity Network (NBN) Atlas: Halicoerus grypus. Available [online] at: https://species.nbnatlas.org/species/NBNSYS0000005137#tab_recordsView. Accessed July 2020.

The Green Blue, 2020. Coastal Pump-Out Locations. Available [online] at: UK Coastal Pump Out Location List (thegreenblue.org.uk). Accessed November 2020.

Travel Devon, 2020. Devon rail network map. Available [online] at: https://www.traveldevon.info/train/devon-rail-network/. Accessed July 2020.

UK Government, 2020. Controls of Fish and Shellfish Diseases in England and Wales. Available [online] at: Controls of fish and shellfish diseases in England and Wales - GOV.UK (www.gov.uk). Accessed November 2020.

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About Carcinus Ltd Environmental Consultancy

Carcinus Ltd is a leading provider of aquatic Carcinus provides environmental consultancy services for environmental consultancy and survey services in the UK. both freshwater and marine environments. Our freshwater and marine environmental consultants Carcinus was established in 2016 by its directors after provide services that include scoping studies, over 30 years combined experience of working within the Environmental Impact Assessment (EIA) for ecological marine and freshwater environment sector. From our and human receptors, Habitats Regulations Appraisal base in Southampton, we provide environmental (HRA), Water Framework Directive (WFD) assessments, consultancy advice and support as well as ecological, project management, licensing and consent support, pre- topographic and hydrographic survey services to clients dredge sediment assessments and options appraisal, throughout the UK and overseas. stakeholder and regulator engagement, survey design Our clients operate in a range of industry sectors and management and site selection and feasibility including civil engineering and construction, ports and studies. harbours, new and existing nuclear power, renewable energy (including offshore wind, tidal energy and wave Ecological and Geophysical energy), public sector, government, NGOs, transport and water. Surveys

Our aim is to offer professional, high quality and robust Carcinus delivers ecology surveys in both marine and solutions to our clients, using the latest techniques, freshwater environments. Our staff are experienced in innovation and recognised best practice. the design and implementation of ecological surveys, including marine subtidal and intertidal fish ecology and Contact Us benthic ecology, freshwater fisheries, macro invertebrate sampling, macrophytes, marine mammals, birds, habitat Carcinus Ltd mapping, River Habitat Surveys (RHS), phase 1 habitat surveys, catchment studies, water quality and sediment Wessex House sampling and analysis, ichthyoplankton, zooplankton and Upper Market Street phytoplankton. Eastleigh In addition, we provide aerial, topographic, bathymetric and laser scan surveys for nearshore, coastal and riverine Hampshire environments. SO50 9FD Tel. 023 8129 0095 Our Vision Email. [email protected] Web. https://www.carcinus.co.uk “To be a dependable partner to our clients, providing robust and reliable environmental

advice, services and support, enabling them to achieve project aims whilst taking due care of the sensitivity of the environment”

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