Ilkley Clean River Group WQR0084 Written evidence from Ilkley Clean River Group Prof Becky Malby, RSA Fellow lives in Ilkley and works at London South Bank University as a Professor of Health Innovation. She is a co-founder of the Ilkley Clean River Group, which was set up out of the frustration of some Ilkley residents with the lack of response to continued reporting of sewage discharges into the river Wharfe at Ilkley. What we found sparked national interest and 2.5 years later we achieved the first river to be awarded Designated Bathing Status, a citizen science protocol for testing river water quality, and have been promised action to clean up the river. We have shown that sewage discharges are normal and regular practice; that despite the agencies’ assertions that everyone knows it’s happening; the public are actually outraged about it; and that these sewage discharges are a threat to people’s health and to the ecology of the river. The Ilkley campaign has attracted national media attention capturing the nation’s mood in terms of protecting our environment, securing best value for our communities and seeking accountability from agencies. From January 2020 – March 2021 our campaign has been covered by BBC news and Countryfile, Channel 4 News, The One Show, the World at One, Women’s Hour; has featured in The Guardian multiple times, in The Times, the Financial Times, as well as regional and local newspapers. Restoring the river in Ilkley and beyond We are seeking sewage facilities for Ilkley that only discharge raw sewage compliant with the European Urban Waste Water Treatment Directive, (extreme weather); which do not discharge sewage solids into the river or onto the riverbank; basic ongoing maintenance of the sewage infrastructure. The Campaign We have worked to: 1. Understand what’s really going on – (a) data – through our citizen science on microbiological water quality, (b) FOI and requests to secure storm overflow frequency, (c) collaboration with Yorkshire Water to investigate infiltration and pollution sources. 2. Hold the agencies to account for the real situation we are facing through Town Meetings and the media. 3. Secure Bathing Status as a means to catalyse regular water quality testing for feacal bacteria and a clean-up. Ilkley Clean River Group WQR0084 National Media 2019 Bathing Status Timeline application Collaborate on understanding More Testing sources of 2018 and meet with pollution Hold agencies national EA to to account in show the data Town Meetings Citizen Science Local Testing at Ilkley with media present Media Reporting Get the media Incidents interested 1. Context: The River at Ilkley On hot sunny days over 1000 people use the river at Ilkley for recreation. Figure 1: the river at Ilkley in the Designated Bathing Status Application showing the distinct stretches of usage. 2. Understanding What is Really Going on (a) The extent of storm overflow discharges at Ilkley The sewage works at Ilkley continues to discharge raw sewage into the river at Ilkley when it rains. YW reported 123 days of sewage discharges in 2018, 201 discharges over 114 days in 2019. For 2020 we are verifying the data from Yorkshire Water but it looks like 120 days with discharges, only 10 of which were in heavy rainfall (with thanks to Peter Hammond). Our data shows 8mm of rain can trigger a storm overflow discharge of raw sewage into the river. Ilkley Clean River Group WQR0084 According to the SOAF (Storm Overflow Assessment Framework) 40 ‘spills’ a year over 3 years or >60 spills a year should trigger the SOAF requirements for investigation and solution finding (a 15-year process). The EA did not know the extent of the ‘spills’ (raw sewage discharges) at Ilkley because their water monitoring was not triggering investigation of the spill frequency. Yorkshire Water knew about the frequency (they provided us with the data) but was not required to report it. All reported incidents were legal under the Consent Limit for the treatment plant at Ilkley set 18 years ago. The Wharfe was apparently under the radar until our campaign. (b) Water quality The EA claimed the water is in good condition, (as set out under the Water Framework Directive) at our first Town Meeting (February 2019), then subsequently confirmed it is Moderate. Our own review of the data shows it is Moderate. (a) The EA monitors for nutrients. (b) No-one monitors the faecal bacteria concentration in sewage effluents, either treated or untreated. We pressured the EA into monitoring water quality at Ilkley which they instigated monthly in 2019 for a 12-month period upstream and downstream of the sewage treatment works, but they did not include faecal bacteria monitoring. Prof Rick Battarbee from the ICRG developed the UK’s first Citizen Science river testing protocol for faecal bacteria and put it into action. This demonstrated the severity of the pollution coming both from treated and untreated sewage effluent discharges The EU Bathing Water Directive 2006/7/EC provides the following 90 percentile values for faecal bacteria in water of sufficient quality for bathing Parameter Excellent Sufficient2 quality1 Intestinal enterococci (cfu/100 ml) 200 330 Escherichia coli (cfu/100 ml) 500 900 As you can see from our testing when the river is in low flow the river quality far exceeds this minimum standard downstream of the sewage works (i.e. treated sewage outflow). In low flow conditions, high concentrations are caused by faecal bacteria from the treated effluent. Ilkley Clean River Group WQR0084 Ilkley Wharfe: E. coli (cfu/100 ml) during low flow (10th July 2019) 350 2 35,500 450 3 1 1 2 10,800 100 4 0 1 = storm overflow 2 = treated outfall In high flow the whole of the river is a public health hazard Ilkley Wharfe: E. coli (cfu/100 ml) during high flow and a spill (13th June 2019) 32,500 2 43,500 3 11,600 1 1 2 9,500 4 0 11,800 1 = storm overflow 2 = treated outfall Upstream tributaries, especially those in Addingham, also contain high concentrations of faecal bacteria (and nutrients) from livestock and septic tanks (yellow) causing poor water quality in the becks in turn contributing to the pollution load on the main river through Ilkley. We found that upstream sewage sources (from the village of Addingham) were more important than agricultural sources, although agriculture caused high concentrations in tributary streams. Ilkley Clean River Group WQR0084 Bolton Bridge to Ilkley: E. coli (cfu/100 ml) during medium flow (no spills) on 10th December 2019 Inflows Sampling Main River Town Beck (Church Field) sites Bolton Bridge Dean Beck Suspension Bridge 300 Main river Mill Stream Low Mill Weir Inflows Lumb Beck Below Dean Beck Ramsgill Old Bridge Black Beck Above Iron Bridge 800 200 Spicey Beck Below storm overflow New Brook St Beanlands island 3 1,100 Pumping Station Denton Bridge 400 2,300 800 1,100 1,300 39,000 300 300 1 2 0 300 4,600 18,000 500 1 = storm overflow (Ashlands) 2 = treated outfall (Ashlands) 3 = storm overflow (Addingham) Our whole Wharfe testing demonstrates the impact of CSOs Ilkley Kettlewell Burnsall 32 popular bathing beaches, were included in the sampling Wetherby Bolton programme. Abbey On the day in question most had concentrations of faecal bacteria above the limit considered safe for swimming Ilkley Clean River Group WQR0084 Burnsall Ilkley Kettlewell Bolton Abbey Wetherby (c) The consent limit The consent limit was set in 2002 (effective from May 2021). However, climate change, population growth, and changes to the sewage infrastructure mean the consent limit is not fit for purpose. It should be set so that the sewage works complies with the Urban Waste Water Treatment Directive (UWWTD), spilling only in exceptional circumstances. The current consent is in effect a license to pollute. Ilkley Town Council (ITC) wrote to the Environment Agency asking for a change in the consent limit to realign the storm water discharge levels. ITC were told that a permit alteration would only be made by the National Permitting Service in response to evidence of adverse environmental impact which was not currently (in the eyes of EA) established. The Environment Agency apparently did not wish to change the consent as they didn’t think the level of discharges were unacceptable. (d) Legislation Raw Sewage Discharge should only happen under extreme, unusual and unpredictable conditions to be compliant with the UWWTD (1991). 3. Bathing Status Application for Bathing Status required: • Evidence of owner support (for us that was Bradford Council) • The survey of usage (counting people paddling, playing, swimming and using the riverbank over the whole bathing season and submitting the highest 20 days covering a mix of weekends, holiday days and weekdays) • A list of facilities (for us that included toilets, parking, refreshments, lifebelts) Ilkley Clean River Group WQR0084 • A local consultation (for us that was a Town Meeting – circa 100 ppl; an online survey >500 people; Local council meetings and letters of support from stakeholders (business, community groups) Defra then also undertook a consultation • 1046 private individuals and 27 organisations responded, 998 supported designation and 75 opposed. This is the highest response Defra has ever had to a public consultation Bathing status secures Ilkley Weekly testing by the EA to assess water quality Signage about Water Quality and any risks to bathing for the Bathing Season (May to Sept) A Management Plan for the River And we anticipate investment to solve the pollution problem. The EA has told us Ilkley will be designated as poor water quality (Town Meeting March 2021). 4. Regulation, Governance and Accountability We have found that the agencies (EA and YW) were not in tune with public opinion.