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SCOTLAND'S BATHING WATERS: A strategy for improvement

THE STRATEGY

Sewage

9. Sewage is waste domestic water, or waste domestic water in any mixture with rainwater and/or industrial effluent. Discharges of sewage can affect the quality of bathing waters depending on the level of treatment provided. For some premises, the sewage might be discharged without treatment or from simple treatment systems such as septic tanks. Intermittent discharges of crude sewage also occur via designed overflows, in order to cope with storm conditions and emergencies, such as power failures. Continuous discharges of sewage effluent also occur from sewage treatment works. All types of sewage discharge must have permission - "consents" - from SEPA, under the terms of the Control of Pollution Act 1974 (COPA) ⁶. SEPA's policy on microbiological standards at identified bathing waters expects that the design criteria for new or modified discharges to be such that the most stringent "guideline" standards under the Bathing Water Directive are achieved.

10. Premises served by septic tanks, or with no treatment provided, are largely, though not exclusively, a rural issue due to the inability to secure a connection to a public sewerage system. Partially treated discharges of sewage direct to the water environment is clearly a source of contamination. Measures to encourage connection to the sewage network are in place to reduce this threat (see paragraph 13). In the case of septic tanks, they need to be correctly designed and operated. The ideal arrangement, where appropriate, is for the discharge to be made via a soakaway system, thereby permitting dispersion in the soil and subsoil. Reedbeds are becoming increasingly used to provide further treatment of the sewage effluent from individual houses and businesses in the countryside. However, there are still many septic tanks which discharge directly to a watercourse, which are not of adequate capacity for the property concerned or are not emptied as frequently as they should be. The best way of dealing with drainage from individual dwellings and businesses is to connect them to a collection and treatment system, when this is available cost-effectively. Scottish Water's investment programme for the years 2002 - 06 includes provision to address this. Failing such connection, however, septic tanks must be properly designed and maintained. Routine de-sludging is fundamental to ensuring that septic tanks meet SEPA's consent requirement. Maintenance is the responsibility of the owner. Pollution prevention guidance with respect to disposal of sewage where no mains drainage is available from SEPA, on its website at http://www.sepa.org.uk/guidance/index.htm.

11. Some recent sewerage systems keep rain water separate from waste water, so that the waste water pipe is separate from that for surface water. This requires the provision of separate pipes for waste water and surface water. In most of our collecting systems, however, rain water flows into the same sewers as waste water, thus greatly increasing its volume. When the system's capacity is reached designed overflows, called "Combined Sewer Overflows" (CSOs), come into operation. The resulting discharge is, of course, very dilute, and is generally screened to remove gross solids, but may nevertheless have a significant effect. SEPA issues consents for such discharges and imposes conditions on consents which are intended to protect water quality. They include, for example, legal limits on the frequency of operation, stipulations about the arrangements for screening, or about storage capacity. All are intended to minimise the impact of such discharges on the aquatic environment. The water authorities are currently undertaking work to improve CSOs which have been identified as unsatisfactory. If CSOs, cross connections or leaks are identified as causing problems at bathing waters the water authorities will be required to make their improvement a priority.

12. Similar arrangements exist for emergency overflows at sewer pumping stations and sewage treatment works. These are designed to operate either when there has been a failure at the works, for instance owing to mechanical or electrical problems, or when all storage capacity has been utilised. SEPA imposes conditions on these emergency overflows as well.

13. The most important influence of sewage is, however, at the point of discharge of effluent from the sewage treatment works to the water environment. Since the original provision of public sewerage, in Victorian times, Scotland's coastal sewage has been discharged directly through outfalls to the sea. Legislation was introduced, at European and Scottish levels, to bring about improvements. To comply with the Urban Waste Water Treatment (Scotland) Regulations 1994 ⁷ (the 1994 Regulations) the water authorities must ensure treatment before sewage is discharged from all collection systems serving settlements from large villages upwards. The water authorities are, over and above this, providing first-time sewerage and treatment at many smaller settlements, which should further reduce pollution from direct discharges and septic tanks.

14. The default standard for the 1994 regulations is secondary, or biological treatment, and all sewage from significant settlements which is discharged in the vicinity of bathing waters is to be treated to this standard by 2005. At some bathing waters further treatment is also being applied. Through the Scottish Executive's Quality & Standards process SEPA is working closely with the Water Authorities and their economic regulator, the Water Industry Commissioner. The aim is to ensure that planned capital investment programmes maximise environmental benefits efficiently and bring about compliance with Scots legislation implementing EC environmental Directives including, as a priority, the 1991 Regulations. Attention must be paid not only to coastal discharges, but also to discharges in river catchments draining to identified bathing waters. SEPA ensures that appropriate treatment of the sewage is achieved and that the arrangements for discharge are consented and controlled.

Industrial Point Source Pollution

15. Industrial processes often produce waste water, which is then discharged with or without pre-treatment to the public sewerage system, or direct to the water environment via a private outfall. While all kinds of industries may affect the quality of receiving waters, one with particular importance at bathing waters is the tourist industry. Hotels, caravan parks and marinas, especially, potentially contribute to the pathogen loading, and thus can affect compliance with the microbiological standards in the 1991 Regulations at identified bathing waters. Their managers should maintain an effective dialogue with regulators or beach managers about standards and potential problems.

16. In the case of a connection to the public sewer, a trade effluent consent under the terms of the Sewerage (Scotland) Act 1968 must be obtained from the water authority. This consent may have conditions attached by the water authority, for example, to meet the conditions imposed on it by SEPA in its turn. In the case of private arrangements for direct discharge to the water environment, a consent under the terms of COPA must be obtained from SEPA. If the industrial effluent is mixed with domestic waste water, the mixture must meet the standards of treatment laid down in the 1994 Regulations. Whether the eventual discharge is through the urban waste water system or the processor's own private outfall, SEPA's consenting policy for discharges which might affect bathing waters is to be applied.

Urban Diffuse Pollution

17. The run-off from roads, car-parks, housing, retail and industrial developments can become contaminated with pollutants such as silt, oil, metals, chemicals, nutrients etc. which are present in these environments, or can be collected in the sewer system with domestic waste water and other rainwater. For bathing waters, contamination from dog faeces or bird populations may also be a potential factor.

18. Scotland has been at the forefront of developing systems based on natural processes, which retain and treat this kind of diffuse pollution. These systems are called "Sustainable Urban Drainage Systems" (SUDS), although analogous arrangements might equally be applicable in rural areas - for example, to certain types of farm drainage. SUDS are 'soft' engineering techniques such as soakaways, porous paving, filter drains, swales, ponds and wetlands, which are replacing the use of traditional piped surface water sewers. They keep the contaminated water out of the sewer, attenuate and treat it prior to infiltration or discharge, as close to source as possible. SUDS implementation has been promoted by SEPA via the Sustainable Urban Drainage Scottish Working Party (SUDSWP) which is a partnership of organisations including SEPA, water authorities, local authorities, developers, and planning authorities. The aims of SUDSWP are to promote the use of SUDS by influencing legislation and regulation, co-ordinating research, producing policies and design guidance, and developing a framework in which SUDS can be applied. It published a SUDS Design Manual in March 2000 ⁸, containing considerable detail on technical aspects of SUDS. Drainage methods inspired by natural processes are introduced and guidance is given on selection and design of suitable systems.

19. The Scottish Executive published a Planning Advice Note ⁹ to help developers and planners apply SUDS solutions, on 27 July 2001. It is SEPA policy that SUDS are incorporated in all new urban developments. In addition, increasing attention must be paid to the 'retro-fit' of SUDS or analogous systems to existing surface waters sewers which are known to be having an impact, or to individual drainage systems, for example from hotels. Renaturalisation of watercourses, by restoring meanders and ponds, for example, can also help reduce pollution, as well as enhancing the quality of habitat and promoting biodiversity.

Agricultural Point Source Pollution

20. Agricultural point source pollution tends to occur when ordinary containment procedures fail - for example when there is a leak from a slurry store, or a spillage of fuel. The Control of Pollution (Silage, Slurry and Agricultural Fuel Oil) (Scotland) Regulations 2001 ¹⁰ are based on earlier regulations and set minimum standards used for the storage of such substances and their effluents. Since the introduction of the predecessor regulations in 1991, the frequency of pollution incidents associated with slurry stores has steadily decreased. It is hoped that the new Regulations will continue to reduce the number and severity of agricultural pollution incidents in Scotland, while at the same time working in a more flexible manner than earlier version. The adoption of source control techniques for lightly contaminated drainage at farm steadings also has the potential to reduce the inputs of faecal organisms into surface waters. The control of such discharges can be achieved by means of a COPA discharge consent issued by SEPA. Techniques analogous to SUDS might also be used to control and treat dirty water from point source farm pollution, as appropriate.

21. SEPA has deployed specialist officers in some areas so as to ensure that the statutory requirements of the Regulations are met and that pollution prevention guidance (e.g. separation of clean and dirty water) is followed. A new advisory post has been established at the Scottish Agricultural College by the Scottish Executive, WWF Scotland, the College, NFU Scotland, the Farm Wildlife Advisory Group, SEPA and Scottish Natural Heritage. Most of the funding is being provided by the Executive. The postholder will also be able to call on the support and expertise of the other partners. The intention is that this post will assist with the provision of better and more co-ordinated advice for farmers and their advisors, as called for in Action 48 of A Forward Strategy for Scottish Agriculture.

Agricultural Diffuse Pollution

22. Important sources of agricultural diffuse pollution are livestock slurries and farmyard manures, which are valuable to the farmer, but are potential sources of faecal pollution if they are not handled carefully. Similarly, pesticides and dips must be handled carefully to ensure they do not contaminate watercourses or otherwise compromise bathing water quality. Other sources are leaking middens, slurry stores and silage clamps. Agricultural diffuse pollution has been linked with failures at Ayr, Sandyhills on the Solway Coast, and Ettrick Bay on Bute. It may be contributing to failures elsewhere, but its impact has been disguised by insufficiently treated sewage.

23. The Scottish Executive, SEPA and the water authorities have sponsored a great deal of research into the causes of bathing water failure. Much of this research has been focussed on Ayrshire bathing waters owing to the poor compliance record in this area. Work by the Centre for Research on Environment & Health ¹¹ concluded that whilst improvements to the various sewage outfalls would indeed reduce the contamination loads to beaches, failures would still occur, primarily due to river-borne bacteria discharged during periods of high rainfall. The source of much of this contamination was considered to come from diffuse sources, partly from CSOs and septic tanks, but primarily of agricultural origin.

24. In 2000 the Scottish Agricultural College (SAC) undertook a survey of farms in the catchments of the River Irvine, the River Garnock and the Water of Girvan on behalf of the Scottish Executive to identify those aspects of farming practice that might give rise to risk of water pollution and downstream bathing water failure. NFU Scotland (NFUS) and SEPA were represented on the steering group and encouraged farmers to help with the survey. This was reflected in the very good response from farm businesses in the catchments. The Executive published the report as Impact of Agricultural Practices and Catchment Characteristics of Ayrshire Bathing Waters in May 2001.

25. We intend to build on this work. The thrust of efforts to reduce the potential for pollution from agricultural activity must be to encourage best practice. An advice note, based on SAC's findings, was distributed to farmers in catchments at particular risk of failing through agricultural diffuse pollution in July 2001. Again, NFUS helped with publicity. The Scottish Executive's code on the Prevention of Environmental Pollution From Agricultural Activity (the PEPFAA Code) advises farmers on good practice to minimise pollution, and the Scottish Executive committed itself, in A Forward Strategy for Scottish Agriculture, to revising it. The Strategy also committed the Executive to supporting the development of a CD-ROM providing farmers with advice on meeting environmental objectives through integrated crop management and other low-cost environmental management techniques. We are developing pro-forma risk assessments for manures and slurries and farm nutrient budgets so that farmers, particularly those with smaller operations, will no longer have to rely so heavily on paying consultants for the provision of such advice. The pesticides industry is working together with agricultural interests, government and NGOs in an initiative, overseen by a government-led steering group, to improve stewardship and advice with respect to use of pesticides.

26. Another action in A Forward Strategy for Scottish Agriculture was to establish a group made up of environmental and farming interests which would examine the impact of environmental issues on the farming and food-processing industries. It would examine the issues, take evidence, and give advice to the Scottish Ministers. The group, under the chairmanship of Professor Jeff Maxwell, formerly Director of the Macaulay Land Use Research Institute, has advised that diffuse inputs to water is the main pollution concern at national level. Particular issues are fertiliser run-off and organic wastes. The group has been examining methods of dealing with these risks, and how solutions may be applied most effectively for the benefit of all parties.

27. In the mean time SAC's work in the catchments of the Irvine, the Garnock and the Girvan suggested that the key elements of best practice for farmers and their contractors could be distilled into the four actions described below. The Agriculture and Environment Working Group chaired by Professor Maxwell has also stated that techniques such as those described below are deserving of wider application. If these actions were adopted, they could have a major impact on point source and diffuse pollution while costing farmers relatively little and, indeed, offering the potential for savings.

28. The Scottish Executive believes that moves to combat agricultural diffuse pollution must be based on the consistent deployment of the following four actions in the catchments of bathing waters. Although the Regulations referred to in paragraph 20 can enforce preparation of risk assessments for manures and slurries, we are encouraging participation in developing this four-point plan through voluntary action, for example by workshops involving farmers. The farming industry is becoming increasingly aware of these issues and many farmers have moved, or are already moving, to address them. In the same way as successful operators in other industrial sectors, they have built in environmental concerns as a key part of their overall strategy. These farmers will be able to provide invaluable input and advice. NFUS, as noted above, has taken an active interest in the research work and in publicising the sort of remedial actions which have emerged

29. It will be clear from the foregoing that this strategy does not attempt to suggest that the four actions we are describing are in their final form. They will be refined in the light of practical experience of their implementation. Researchers and practitioners will also be able to advise on improvements as more knowledge of science and best practice, particularly at local level, becomes available. The views of the Agriculture and Environment Working Group on the kind of solutions to apply, and the best means of applying them, will assist Ministers with advice on the range of policy required to protect the environment through a sustainable farming sector. For example, the group has commissioned research from the Macaulay Land Use Research Institute to examine the research basis for pollution control techniques and the general efficacy of control measures across all conditions. This kind of work by the group will be invaluable for refining the four-point plan. In the mean time the plan nevertheless provides a practical framework for the urgent task of addressing diffuse agricultural pollution in catchments where livestock farming potentially impacts upon the quality of bathing waters.

The public

29. Finally, of course, the public has a role in improving the quality of bathing waters. Individuals should think carefully before flushing inappropriate items into the waste water system. Visitors to bathing waters should ensure that they clean up behind them. Dog owners should clean up after their dogs. We should all think more carefully about what we can individually do to reduce pollution. This is particularly true at the many remoter Scottish identified bathing waters, which are not actively managed and thus do not have dedicated staff to warn those responsible for litter or pollution, or to clean up after them. It is heartening that many organisations are helping to raise public consciousness of these issues, particularly at local level. The public may also play a useful role in reporting to SEPA and to other interested bodies any incidents or conditions which have the potential to cause pollution at bathing waters.

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