Response from Surfers Against Sewage.

COM (2000) 860 final. Communication from the Commission to the European Parliament and the Council - Developing a new Bathing Water Policy.

Surfers Against Sewage (SAS) would firstly like to thank you for the opportunity to comment on the above document. As a pressure group campaigning on behalf of the 20 million people who utilise the UK's coastal and inland waters each year, the revision of the 1976 Bathing Water Directive is of obvious interest and of great importance both to ourselves and to those we represent.
The main aims of SAS are;
1. All sewage to be fully treated before discharge and for both the liquid and the sludge content to be regarded as a resource rather than a waste.
2. The Water Industry's capital investment programme to be aimed at the real issue of sewage disposal - the viruses, bacteria and nutrients contained therein.
3. The greatest environmental benefit per pound spent by the Water Companies.
4. Protection for all water users.

Over the past ten years SAS have given evidence to a number of House of Commons Select Committee Inquiries, acted as advisors to Environment Minister, the Rt. Hon Michael Meacher MP and given numerous talks, presentations and lectures on the issues of bathing water quality and health risks to water users. We have also lobbied both the UK and the European Parliament.

Response to communication
We have commented on each section in turn and will refer to relevant page numbers or section headings throughout the document.
Page 5 - the Bathing Water Directive and its revision.
There is no question of a need to revise the 1976 Bathing Water Directive. The Directive is over 25 years old and there have been many developments in science and research as well as changes in social behaviour since the legislation came into force. It is vital that these changes and developments are acknowledged, indeed embraced by the European Commission and European Parliament. The existing Directive has limited practical use, focussing on compliance with standards that have questionable relevance and there is much room for improvement in a number of key areas.
It is vitally important that the Commission and Parliament note that there is a great deal of public interest surrounding water quality and that this Directive is perhaps the most directly relevant piece of legislation. The obvious tie-in with the Water Framework Directive must also be acknowledged.
When considering this Directive, SAS ask that the potential benefits of a revised Directive be given as much emphasis as the potential costs (that will undoubtedly be highlighted in a large percentage of responses to the policy document). It is only too apparent that the benefits of a cleaner, safer environment are usually given short shrift, with costs taking the priority in any studies that have taken place. As far as we are aware, very little work has been done to assess the benefits both in terms of quality of life for local residents and in terms of the tourist industry. This is no reason to ignore the potential benefits, which may be harder to quantify but are none the less, very real.

It is our view that in order to produce a piece of legislation that will actually fulfil its purpose i.e. to ensure that the public at large are not exposed to sewage contaminated water, there are a number of issues that need addressing:
1. Current standards within the Directive must be re-addressed.
2. The heavy emphasis on monitoring and compliance with these standards must be rethought. There has been little effort made to 'understand' bathing waters and the various factors influencing water quality.
3. The current Directive only acknowledges 'bathers' as the word is traditionally interpreted. Bathing is most certainly not the only activity that involves direct contact with the water.
4. The water environment is utilised year round, yet the current Directive is only applicable in the 'bathing season'.
5. There is very little dissemination of information to the public. Monitoring of bathing waters is apparently done purely to determine compliance with the legislation; the public are currently unable to make a fully informed choice about where they go in the water.
6. Questions have arisen over sampling procedures, sample handling and methods of sample analysis and the differing interpretations of the Directive by each Member State.

Response to specific points raised in this section. (page 7)
1. Water quality standards are indispensable.
They have to be ambitious and legally binding. SAS agree that the Directive must feature water quality standards. We suggest that a single standard is set (as opposed to the current standards of mandatory and guideline), with the emphasis being placed on microbiological indicator organisms that are more closely linked to the harmful viruses and bacteria they are intended to represent. As has been correctly highlighted, standards act as a benchmark to gain an insight into bathing water quality, they should not however be viewed in isolation. SAS believe that the mandatory standard within the existing Directive is not adequate to protect public health. Our medical database contains over 800 records of illnesses contracted at bathing waters that have passed the mandatory standard. We must be sure that the new standard is adequate to protect health.
2. Bathing Water Quality Management is not just a matter of quality monitoring.
SAS agree that the new Directive must promote an understanding of all factors influencing water quality at each designated bathing water. It is important to recognise that it is not just the main point source inputs that can compromise water quality. Discharges upstream of a bathing water, CSO's, land runoff and small private discharges, undoubtedly affect water quality. In order to assess risk to water users, effort must be made to understand all these factors and their relevance at each bathing water. As highlighted in the draft document, this will tie in with the Water Framework Directive.
3. As a consequence of the above two principles, it is more than ever necessary to have good quality information in near real-time about the bathing area. A 1996 Department of the Environment survey entitled 'Survey of Public Attitudes to the Environment' revealed that in the UK, bathing water quality and sewage contamination of beaches was the second greatest issue of public concern. This fact alone should be enough to show that informing the public about bathing water quality is of key importance. SAS feel that provision of information will not only serve to enable the public to make an informed choice, it will also enable relevant authorities and regulators to make decisions on water quality management, based on relevant facts. At this point SAS would have to flag up the essential need for each Member State to agree on who exactly will be responsible for the provision of this information. Those that we feel would be most suited for the job would be local authorities and or the environmental regulator, but this will no doubt be a topic for much discussion. It is vital that the Commission and the Parliament do not allow the requirement for information provision to be diluted simply because Member States feel their resources will be hard pushed to cope. There is a clear duty to inform the public and with careful consideration of resources and responsibilities, we are sure that an answer to the potential problem can be found.
4. Specific issues in Bathing Water Quality Management. 4.1 Identification of bathing areas. (The term 'water users' shall be used here to represent those people coming into direct contact with the water but who are not bathing).
SAS feel that one of the fundamental flaws of the existing Bathing Water Directive is in the identification of 'bathing' areas. Not only do we dispute the assumption in the Directive that the only people needing protection from risks are 'bathers', we also question the concept of a 5 month bathing season. We know that people use the water all year round, indeed many year round water users spend far longer in the water per session than the average 'bather'. SAS believe that if the new Directive does not take these factors into account it will fail to fulfil it's potential and it will fail in its duty to protect the public at large. European citizens enjoying the water environment, often at locations that are actively promoted by local authorities and tourism associations, will remain unprotected. Numerous studies have highlighted the health risks to water users (including bathers). The risk to health is not lessened because one wears a wetsuit or is supported by a surfboard or a kayak, yet under the existing Directive the 'tools' used by water users mean that they do not get the protection they deserve.

Ironically the surfboard, the kayak, the sailboard, the dingy can mean that the water user is at greater risk of infection. It is commonly accepted that ingestion is the main route of infection - this fact has particular relevance to water users other than bathers. Water users are arguably more likely to ingest water than the average bather. Wiping out or capsizing in water can be violent and sudden - ingestion of water is an accepted consequence.
The risk to water users who come into direct contact with the water, is as great as if not more than the risk to bathers. The legislation must acknowledge this fact by acknowledging the locations water users frequent and year round water usage.
We do not believe that every stretch of water in Europe should be designated/identified, but what SAS would like to see is the identification/designation of those waters that are heavily utilised for any type of water contact sport, be it swimming, surfing, dingy sailing etc. Particular attention should be paid to those areas that are actively promoted. SAS have circulated their Discussion Document on the Bathing Water Directive to stakeholders and interested parties in the UK. Concerns have been raised as to the practicality of identifying further areas under the Directive. These concerns range from monitoring costs through to costs of sewage treatment. We are sure similar concerns will be raised in other Member States. However, SAS feel that these concerns are without substantial backing. As we only have knowledge of the situation in the UK we will use the UK as an example. Firstly, monitoring costs can be minimised with the adoption of a sensible, relevant and more streamlined monitoring methodology. The Authority with the role of taking the samples (the Environment Agency) will need to look at available resources and ensure that the most effective use is being made of them. We would doubt whether at the current time, the Agency are working as efficiently as they could be.
Secondly, it is unlikely that major investment in sewage treatment will be needed if further bathing areas are identified in the UK. Two European Directives, namely the Shellfish Waters Directive and the Urban Waste Water Treatment Directive have already driven in improvements to sewage treatment works in the UK. Presumably the same is true in all other Member States. The benefits in terms of improved water quality will not just be felt in 'bathing waters' that have already been identified. Water quality will have improved over much larger areas. Surely therefore it is in the interests of a Member State to flag up additional waters, rather than ignore their existence, especially when the work on sewage treatment facilities will have already been done under other Directives.

Take the example of the Carrick Roads in Cornwall - an intensively used water body. Windsurfing, kayaking, diving, surfing and water-skiing are frequently practised here year round. The area is renowned and promoted as a haven for water contact recreation. Under the Environmental Programme that is underway in the UK, (driven by European legislation), all water company point source sewage discharges into the Carrick Roads will be fully treated. The work has already been agreed, the cost implication should this body of water become a bathing water is zero in terms of sewage infrastructure.
SAS believe this is the case in many other areas. For example the popular surfing beaches of Abbotsham and Cornborough. Neither are designated waters, yet both are heavily utilised by surfers year round. In close proximity to both of these beaches is Westward Ho! a designated bathing water, recognised under the Directive because of its popularity with bathers. A sewage treatment scheme for the area has been agreed and once planning problems are overcome, a full treatment works will be built. This will not only have a beneficial effect on water quality at Westward Ho! It will also improve the water quality at both Cornborough and Abbotsham.

The SAS Water Alliance
Over the past few months SAS have been collecting information from water users all over the UK. Specifically for this purpose we have formed the SAS Water Alliance - an Alliance of the UK's Water Sports Governing Bodies, headed by SAS. These Governing Bodies represent thousands of UK water users, in a variety of sports; windsurfing, surfing, kayaking, canoeing, diving, dingy sailing and water-skiing. All of the organisations listed below are backing SAS's proposals for a revised Directive. They believe that if SAS's proposals are taken on board in the new Directive, their reality as water users will be greatly improved. All these Governing Bodies and their members want to be acknowledged in legislation that is designed to protect the health of the water using public.
The Governing Bodies that are part of the SAS Water Alliance are as follows:

In addition to adding vital weight to SAS' calls, the Water Alliance has also enabled us to build up a picture of where people are going in the water on a regular basis. SAS asked the Governing Bodies to give us information about popular spots within their sports, those waters that are well used and known by water users, but which are not identified under the current Bathing Water Directive. As you will see in the report attached to the back of this document, there is no shortage of waters that could be designated if the term 'bathing' was to incorporate water users other than swimmers (and this is not all of them!)
All the information SAS obtained through the Water Alliance is presented in a report at the end of this document. As well as listing those Governing bodies that have supported SAS and helped us gain the relevant information, the report also details popular un-identified waters in each sport and includes photo evidence of year round water use.

Definitions (page 8): · "Bathing for the purpose of this Directive means any direct body contact with water involving head submersion and/or risk of ingestion of water".
SAS are pleased to see a broader definition of the term 'bathing'. Under this definition it would certainly be possible to incorporate surfers and divers into the Directive as both sports demand direct body contact with water. However, we do not feel that the broadening of this definition goes far enough. As has already been stated above there are other water users, whose sports do not involve 'direct body contact with water' at all times, but for whom there is a very real risk of submersion or ingestion of water. Here we are talking about the kayakers/canoeists, the windsurfers, the dingy sailors and the water-skiers and wakeboarders.
When participating in these sports it is inevitable that submersion and or ingestion of water will occur, but direct body contact with the water is not a constant factor, it is a risk - a very high risk particularly for children who are learning the sport. According to the WHO it is children who are at the greatest risk of infection - surely efforts must be made to reduce that risk? SAS feel that the Directive will be fundamentally flawed if it does not recognise those water users that are at risk from sewage polluted water and would proposed that the above definition is altered to:
"Bathing for the purpose of this Directive means any activity where there is direct body contact and/or high degree of risk of body contact with water involving head submersion and/or risk of ingestion of water."
· "Water identified as bathing water includes all running and still surface waters, transitional water and coastal waters that: -are actively promoted - locally, regionally, nationally or internationally - for bathing (or which are likely to be so promoted in the foreseeable future) and/or are regularly used by the local and/or visitor populations for bathing"

SAS agree that if a body of water is actively promoted for 'bathing' (as in the amended definition above), it should be identified/designated under the Directive. We believe that it is irresponsible for member states to encourage the promotion of bodies of water for recreational use by the public if those bodies of water are not subject to compliance with legislation.
It is obvious that promoting bodies of water for recreational use is of economic importance and that many regions depend on income from this sector. Tourists will be encouraged to visit areas they may have otherwise passed by, spending money on watersports lessons and equipment hire/purchase and also at bars, restaurants, hotels and clubs in the area. Local schools will take pupils for classes, local water sports clubs will organise visits, and families will visit at weekends.
By promoting these areas, business will be attracted; this is a glaringly obvious reason why promotion of these locations takes place.

SAS know that at the current time there are waters around the UK, promoted by local and district councils, by Tourist Boards and by the water sports sector themselves but which are not recognised under the Directive. Citizens are being actively encouraged to visit these waters but there is no system in place to protect them. It is vital that each member state carries out a survey to identify these waters, SAS believe this will involve a minimal amount of work as the sites will already be listed in publications for either local, regional or national distribution. Many of the locations identified in the report attached to this document are actively promoted. Other areas that are known by SAS include bodies of water such as the Carrick Roads and the Fal Estuary in Cornwall and the Solent in Southern England, where a wide variety of watersports take place and where the economy of the area is highly dependent on water use.

· "Bathing zone means the defined/discrete location within a bathing water where, on average throughout the bathing season, most bathers will be found".
With the broader definition of the term 'bathing' it becomes harder to identify the bathing zone, particularly where multiple water use takes place. It is essential that at each identified water a study is made of the predominant water activity and that subsequent sampling and management actions are designed to maximise protection for this user group. This could be done in conjunction with user groups. Identification of the bathing zone is presumably necessary in order to identify the most relevant sampling locations. SAS would suggest that there will have to be more than one sampling location at some bathing waters and that the authorities responsible for monitoring should be prepared to take samples further from the shore than under the current Directive.
It is vital that a minimum limit value for numbers of water users is set, above which the use of a body of water is deemed significant. These limit values may be different for each water contact activity. For example there is a limit to the number of surfers you can 'fit' onto a peak (a surf spot), so the number of surfers in the water at one time is bound to be less than the number of swimmers at a location at any one time. SAS would suggest that if a body of water is actively promoted for a water contact activity, that this is enough to warrant identification/designation. However, if it is necessary for a threshold to be set to determine whether the body of water is used by a 'significant' number of 'bathers', we would suggest that a mean or average figure is calculated over a set period of time, for example a month. This is because, with a number of contact sports, weather conditions may prevent participation in the sport for a period of days, so the water will not be used, but when favourable conditions return water usage will be intense and user numbers will increase.

· "Bathing season means the period during which bathers can be expected, in the light of local custom, any local rules which may exist concerning bathing, and weather conditions".
This definition implies that the bathing season should extend year round. SAS feel year round water use must be acknowledged under the Directive, so we would endorse this definition. With the advent of the wetsuit, year round water use has become a reality. The bathing season from May to September as it is currently defined is not a reality to year round water users. For example the Easter Holidays which fall in April see millions of citizens heading to the coast or inland waters for short breaks that will incorporate water usage. Of course in the UK this will rarely involve bathing as the word is traditionally interpreted, citizens will participate in other water contact sports that require a wetsuit and some form of equipment. Once again SAS would refer you to the report at the end of this document where there is a selection of photographs of water users, all taken outside the traditional bathing season. Ideally SAS would like to see the Directive applied year round at all identified waters and if year round water use is a reality in the UK, it is certainly a reality in other member states where the weather may be more conducive.
As certain water contact sports require particular conditions in order for citizens to participate, user densities will vary on a daily basis. This poses the question as to whether monitoring and management of these waters only need take place when conditions are favourable. SAS believe that this will only mean more work for local authorities and would suggest that year round, blanket monitoring and management takes place.
De-identification of bathing waters.
Whilst SAS would not wish to see unscrupulous de-identification of bathing waters, we do acknowledge that changes in local customs and changes in the usage of an area can mean that certain areas may lose their function as a bathing water. Looking at this in an economic context there will be benefits to incorporating a function to de-identify. It could be argued that it is a waste to spend valuable time and money on monitoring and managing waters that are no longer used by the public. Again it is vital that if de-identification is to be incorporated into the Directive, a limit value on user numbers needs to be set for each sport, below which the water is no longer deemed 'significant' as a bathing water. Caution must be used here and any de-identification would have to be made public. It is questionable how local authorities and tourism officials will respond to this suggestion. If de-identification saves them money then it may be viewed favourably, but those relying on tourism for an income could also view it as a negative.
In SAS' view as representatives of all water users, there are waters in the UK that are used more heavily than some of those currently designated as bathing waters under the Directive. We feel that it is a priority to acknowledge all those bathing waters that are heavily utilised and actively promoted and if that means that a number of existing bathing waters are deemed insignificant, then we would support moves to de-identify them. But this can only take place after careful consideration and justification.

4.2 Compliance
SAS agree that the existing Directive has an excessive emphasis on monitoring and compliance with standards. We would fully endorse moves towards a Directive that places greater emphasis on management actions but which also has requirements for compliance with quality standards.
It is vital that the Directive details obligations for bathing water managers should management action need to be taken at bathing waters, in both the short and the long term. Without concise blanket guidelines that must be adhered to by all beach managers in all Member States, the management approach will not work. A timeframe for actions must also be given and penalties should be incurred if this timeframe is not followed.
SAS have always argued that there is not enough information available to the general public at bathing waters and that management actions (should a problem occur) are very rarely utilised. In the UK there is currently no single organisation that takes responsibility for warning the public of incidents that could result in human exposure to pollution. In some areas of the UK local authorities have taken it upon themselves to erect warning signs should a CSO discharge or a sewage treatment works break down, although these authorities are the exception rather than the rule. The environmental regulator - the Environment Agency also helps to warn the public of pollution incidents, but this tends to be through the media, after the event, rather than at the time. Something must be done to remedy this situation.
At the present time, it is possible for a bathing water to be flying a Blue Flag, indicating water of a superior quality, even if a CSO is discharging in the vicinity. Because the Blue Flag is awarded on the previous years bathing water results and the pollution incident is occurring in the present, there is no need for the public to be warned in the eyes of the authorities. SAS believe that immediate management actions should include posting of warning signs at beaches and notification on a central website, should a pollution incident occur. This is to enable the public to make an informed choice about whether or not they go in the water. It is vital that this management system is applied uniformly throughout Member States so that the 'Jaws syndrome' is removed. Whoever is given the responsibility for posting warning signs must be assured that the same action would be taken anywhere else in the EU, otherwise they will be fearful of flagging the incident up, for fear of damaging tourism.

SAS suggest that a major public awareness campaign be launched throughout the EU upon implementation of the revised Directive, in order to inform the public of potential risks at bathing waters and of the actions that will be taken to protect them. We believe this will highlight to the public the fact that pollution incidents can occur at most bathing waters at some time, this should mean that they will be less likely to avoid an area in the future if they experience a one off incident at the location. At the present time the public feel that authorities cover up pollution incidents. This leads them to think that if they experience a pollution incident at a particular bathing water, it is a persistent, chronic problem rather than a one off incident. SAS believe the current lack of information is actually more of a deterrent to visitors than if the problem was flagged up and management action was taken.
This will also encourage local authorities, water companies and regulators to resolve problems quickly to save them re-occurring.
Once a warning sign has been posted the question arises as to when the sign should then be removed. SAS suggest that following a pollution incident such as a CSO discharge or the breakdown of a sewage treatment works, beach managers should wait for the discharge to cease and water quality monitoring should continue until water samples are back to the usual background level for that bathing water. The sign can then be removed.

Once problems have been identified and flagged up to the public, it should then be a matter for beach managers to decide what long-term management measures need to be taken. For example investment in new infrastructure or land use management techniques designed to minimise the impact of agricultural pollution could be implemented.
It is important that a single body takes responsibility for erection of signs and co-ordination of management actions. This body should work in conjunction with the environmental regulator, the water company and the local authority in order to provide a solution that is realistic and feasible. This joined-up thinking is crucial. Obviously the question of funding for the 'bathing water manager' will arise, SAS would be most disappointed if funding problems were to deter the development of a Europe wide beach management system and would suggest that European funding may be an option here. Alternatively, the money could be found from Government funds.

4.3 Surveys and Monitoring
SAS agree that the current approach to monitoring and compliance does not go far towards understanding the behaviour of the bathing water/zone. Monitoring results are merely reported to determine compliance and if a sample fails to meet the standards in the Directive, no immediate short-term action will be taken. SAS view this as both short sighted and a waste of resources, surely if the time is taken to take the samples and analyse them, it would be sensible to at least use the results more constructively.
The idea of developing a beach profile is something that SAS would wholeheartedly support. Rather than simply monitoring and reporting results, efforts will be made to understand why the results are as they are, a picture will build up, rather than monitoring results being viewed in complete isolation. SAS agree that it is necessary to map and understand all the potential sources of contamination in and around the bathing area in order to fully implement management plans and in order to inform the public sufficiently. The information on potential sources of pollution should not only be utilised to aid beach managers to take action, it should also be made available to the general public in the form of display boards at bathing waters. These boards should feature a map of the bathing area with the location of outfalls, CSOs, treatment works, streams and rivers etc, all clearly marked. The bathing water sampling location/s should also be marked, along with any zones that have been identified for particular water uses. Bathing water monitoring results should also be displayed on display boards but SAS would suggest that these are not simply reported as figures/data. A simple guide, to allow easy interpretation of the figures should accompany the data. Perhaps a system using symbols could be created.
The beach profile will be a valuable tool.

SAS would suggest that in order to develop beach profiles for all bathing waters, a study of each bathing water should be carried out, with monitoring of waters taking place under a variety of environmental conditions. For example, waters should be monitored during heavy rainfall, after heavy rain that has followed a dry spell, after prolonged sunshine, etc. By carrying out this study a clear picture of the behaviour of the bathing water will be built up, the relevance of the varying inputs under different environmental conditions will become clear. In order to fully understand the relative contribution of each potential input, SAS suggest that transects are drawn from the shore out into the water body. Sampling points should be set up along each transect and then each sampling point should be monitored under a variety of environmental conditions.
It is important at the study stage to ensure that when routine sampling commences, there is a correlation between what is going on in the bathing water as a whole and what is happening at sampling locations. The profile study will be of little value if subsequent water samples, taken as part of routine monitoring, do not reflect the changes in water quality that will occur as conditions change. Again SAS would suggest that routine sampling does not just take place in one location at a bathing water, but that the most relevant sampling locations are chosen. These could be established during the survey using the transect methodology described above.
SAS acknowledge the importance of continued monitoring of water quality and would argue that this should take place year round. Monitoring of waters will ensure that discrepancies in water quality will be revealed so that management action can be taken to remedy the situation. We would agree that sampling frequencies at bathing waters could be adjusted depending on the whether the water quality is variable or consistently bad or consistently good.
A sampling frequency of fortnightly for waters that are consistently good and weekly for those waters with variable or consistently bad water quality, would appear sufficient provided that should a pollution incident occur, monitoring frequency would increase until samples show that water quality has returned to background levels.

4.4 Trends in water quality
SAS would agree that a long-term approach to bathing water quality management is necessary. In order to gain a true picture of a bathing water, it will need to be examined over a number of years - 5 years would seem realistic. However, these monitoring results will still be of little relevance if they are taken in isolation. For a 'trend' in water quality to emerge the monitoring results will need to be linked to environmental conditions.
It is our understanding that this 5 year quality record would simply be used to gain a picture of a bathing water in order to determine long term actions should a problem be revealed. It will also prevent the labelling of a bathing water that has overall 'good' water quality with a 'bad' label, because of a single pollution incident.
Whilst we can understand that when determining the overall quality of a bathing water it makes more sense to look over a 5 year period rather than over one bathing season, we seek assurance that this will not mean that pollution incidents are merely dismissed as blips in an otherwise good record. Any pollution incident should be viewed seriously and action should be taken to amend the situation. Taking this approach could avoid making unnecessary spending and if utilised correctly will help identify those areas requiring priority investment.
4.5 Standard setting and methods of analysis
In order for the Directive to protect public health it would seem appropriate for microbiological standards to be at the focus of standard setting. The scope of other European Directives means that the need to monitor the physical/chemical parameters under the Bathing Water Directive is reduced.
SAS are in no doubt that there is a correlation between faecally polluted water and public health. As representatives of water users and as the founders of the SAS medical database we are well aware of the health risks to water users and have experienced many illnesses first hand. It is important to remember that whilst the milder ear, nose and throat infections and gastro-intestinal complaints are harder to link conclusively to sewage polluted water, there is much circumstantial evidence that supports this claim. A number of studies have also arrived at the conclusion that there is a definite link between less serious illnesses and faecally polluted water.
The link between more serious illnesses such as Hepatitis A has been easier to prove and a number of studies exist to demonstrate this. This Directive is designed to protect the health of water users; therefore it is vital that the standards set in the legislation ensure that the water user is at minimum risk from faecally polluted water.
SAS would support moves to take account of the recommendations of the WHO and agree that current studies do indicate that Intestinal Enterococci and Escherichia Coli are the most relevant 'indicator organisms' available.
We also support the move to identify separate indicator organisms for fresh and marine water. We would question whether the standard set for fresh waters of 400 E.Col/100ml is low enough to ensure public health protection, but await the conclusions of the WHO recommendations.
We would also suggest that monitoring for E.coli 0157 could take place, particularly where run off from agricultural land is an issue or where abattoir waste is known to enter the sewerage system.
A single method must be used to analyse water samples in each Member State - we understand that the Robens Institute has successfully developed a standard procedure - the PAQUALAB method. Similarly methodology for the collection and handling of samples must be standardised. It is essential that a time limit for sample analysis is set, death of coliforms is a very real issue and if samples do not reach a lab until the day after sampling, only 10% of the original coliform numbers may survive.
There is a need for 'instant indicators', but we would question the suitability of salinity - we understand that Welsh Water carried out studies looking at salinity as an indicator and that it was not thought to be of great use. We would prefer the use of rapid tests and hope that the Directive will incorporate a provision that will enable the sampling methodology to be altered should science and technology allow.

4.6 Obligations to take action
Member States must be obligated to take action when water quality is bad or if it deteriorates. The timescale set for this action must be realistic but it must also be tough. Every effort should be made not only to address the problem and prevent it happening again but also to ensure that the public are informed at the time the incident occurs. There are a variety of possible management options that have been identified and it will be up to the beach managers to adopt the correct procedure after taking account of all influencing factors. It is vital therefore that the beach profile previously discussed, becomes a central part of the Directive, this is the only way that the beach management team will be able to make an informed decision about what action to take. Of prime importance is the immediate need to inform the public of the risk, there should be some form of penalty if this is not done. Informing the public should involve the display of water quality information on location at bathing waters and via a website designed specifically for the purpose of informing the public about bathing water quality.
4.7 Prediction of water quality
Predicting water quality using computer models would seem a logical progression in the future. There are a number of variables (sources of faecal pollution, current patterns, tidal regime etc) to 'plug in' to the model. These variables although changing in numerical value will all need to be considered at each bathing water, modellers should simply be able to add or remove variables where appropriate. We would support the use of models wherever possible but would also request that the simpler methods of water quality prediction be used in conjunction. SAS agree that the ability to predict water quality will vary from bathing water to bathing water, however, the beach management team should be encouraged to develop a predictive approach.
4.8 Information requirements, public participation and reporting.
Firstly, SAS feel that for any initiatives concerning the provision of information to the public to succeed, a major Europe wide publicity campaign needs to be launched. This publicity campaign should not only inform the public of the potential risks they may experience at bathing waters, it should also help them to understand that it is impossible to avoid pollution incidents altogether. By highlighting the fact to the general public that water quality information will be available to them at bathing waters and via the internet, the public are being given the chance to make an informed choice about where they are going in the water. As long as this information is conveyed in an understandable format, SAS are sure that the public will appreciate being able to make that choice. They will also be able to rest assured in the knowledge that action will be taken to remedy the situation, should a pollution incident occur or a discrepancy in bathing water quality be revealed. Launching a major public awareness campaign will also serve to help those people who are responsible for beach management. If the publicity campaign is Europe wide, beach managers will know that standards and procedures for management action are the same throughout Europe (and that the general public are also aware of this fact), this should remove some of the reservations beach managers may have about flagging up pollution incidents.
What is important here is that the fear factor is removed. If the public have a better understanding of what is the reality at our bathing waters they will also understand that incidents can occur almost anywhere and that every effort will be made to remedy the situation as soon as a problem is revealed. They will also be able to rest assured in the knowledge that should an incident occur whilst they are at a bathing water, they will know about it. The current lack of will to inform the public about pollution incidents and the numerous factors affecting water quality have lead the public to view those deemed responsible for bathing water quality with suspicion. This is unhealthy.
SAS would suggest that an organisation such as ourselves should be used to publicise the elements of the new Directive to the public. SAS are viewed with less suspicion than the authorities!
The provision to ensure that the public are able to make an informed choice before going in the water is, in SAS's view, key to the success of this Directive. Information provided, both at beaches and via the Internet, should be as current as possible. Water quality results should be regularly posted, plus the public must also have access to maps/profiles detailing the location of potential sewage inputs and water quality sampling locations. SAS believe that if remedial action is being taken at a bathing water, the public should also be able to access details of that action, particularly if whilst work is being done, the risk to water users is elevated above normal levels.
Once again in order that the public are able to get the most out of this provision of information, SAS would suggest that a publicity campaign would be the best way to highlight all the official sources of information and how to access them. SAS suggest that a completely independent website be set up in each Member State, specifically for the purpose of disseminating information on bathing waters. This site must be easy to use, navigate and understand.
4.9 Keeping the Bathing Water Directive up-to-date
It is essential that there is a provision within the Directive to allow for updates, which may be needed as a result of scientific, technical or social developments and changes. 5. Scope of the Directive
SAS like the proposal for a move to an 'effort and results' Directive. We feel that this type of approach has benefits not only for the general public but also for all those concerned with water quality and water quality management.
We acknowledge the tie in with the Water Framework Directive and hope that with the two pieces of legislation running side by side, a much better understanding of European water quality will emerge. It is crucial that between the two Directives, all issues are covered, so careful consideration must be given to what is covered by each and any omissions must be picked up.

We look forward to watching as things develop and hope that what will emerge will be a more informative, action based Directive that takes account of all water users and gives them the protection they deserve.