Sand, Sea and Sewage

Sand, Sea and Sewage

The history of our campaign to address the health threats imposed by marine sewage pollution, and the nature of the response by government in the light of the European Bathing Water Directive, 76/160/EEC.
Author: Patrick Gowen


Patrick Gowen


The author of this article, Patrick (Pat) Gowen died in August 2017 (1932-2017). He was a founder member of Marinet and its first Chairman at the time of Marinet’s establishment in 2002. In 2017, when his health was declining, he asked me to act as an editor for him and to complete this article based on the written text he had finalised for the first half and his notes for the second half.

This I have now done, and this article is the outcome. It is an extraordinary record. It is extraordinary not just because it records clearly the deviousness of government in seeking to evade its responsibilities, in this instance with respect to the safety of sea bathing waters and the scourge of sewage pollution, but also because it is a testament to an exceptional person who, with colleagues, selflessly gave himself to years of environmental campaigning — effectively his lifetime — and to serving the public good and doing so entirely voluntarily and for no personal benefit.

Professionally, Pat Gowen was a man of many abilities. Primarily a scientist, Pat joined the Biophysics Department at the University of East Anglia shortly after it was established, and it was here that he became a Chief Technician and earned his living until he retired. Pat was also a person of strong conviction, and he said “I decided that as a scientist, I could do more as an activist. At some point you have to stand up and be counted and speak for the environment.” The account he relates in this article is exemplary evidence of this belief.

His abilities and activities were not restricted to environmental work alone. He was also a highly qualified and accomplished amateur radio operator, and he became a Director of AMSAT (the Radio-amateur Satellite Corporation) based in Washington DC, USA. This involved him in the design, building and launching of free access satellites for the radio amateur for their own use in communications, education and research, with these satellites managing to secure a “free-ride” on NASA’s own weather and earth resources satellites.

In 1978 the USSR version of AMSAT — known as DOSAAF — put a pair of amateur satellites into orbit with a COSMOS launch, and it was for his original work through and with these spacecraft which led to the award to Pat of a COSMOS Diploma and Gold Medal.

However it was not until around 2000 that the paths of Pat and myself crossed, the issue of sewage pollution of our bathing beaches being the meeting point. In subsequent years I came to know Pat as an environmental campaigner of immense conviction and ability. Not only did he give unstintingly of his time and pioneering campaigning mind to sewage pollution, but also to another scourge that affects the coast of East Anglia — commercial offshore aggregate dredging for sand and gravel from the seabed, and the profound consequences this has and still does have on the quality of beaches, coastal sea defences, sea fisheries and marine life in general.

Almost single-handedly Pat developed the campaign and expertise that first challenged these UK-wide offshore aggregate dredging practices — now supplying around 20% of sand and gravel throughout the UK, and more than 80% in London. Whilst chairman of Marinet he established the marine aggregate campaign as one of the principal components of Marinet’s work and this still remains the case today.

Pat and I were founder members of Marinet — he as chairman and I as its co-ordinator, and throughout the years that I worked alongside him I could be certain that he would always remind me of the basic principles involved in our campaigns, and I could be certain that he would chide me and others if we had overlooked something fundamental. He set standards for a focus on truth and accuracy that were unwavering and he had little time for those who would dissemble from such a commitment.

I believe you will find this clearly evident in the facts related here in his article.

It is neither exaggeration nor unwarranted praise to say that knowing Pat and working with him has been one of the privileges of my lifetime. His like are not easily found, nor replaced, and the mark he has left through his life and its endeavours are a benchmark by which any young person seeking to defend the environment today could well measure themselves. There is no doubt, we are in urgent need of more of his calibre.

I would not want to seem to be putting Pat on a pedestal. He was too modest a man to permit anyone to do so and he had a sharp wit and eye for debunking all those would seek to govern and administer in this way.

In 2008 he sent me an item tilted “one NOT for the website”. I reproduce it here:

Science Reveals Heaviest Element Ever Discovered

Research has led to the discovery of the heaviest element yet known to science. The new element, Governmentium (Gv), has one neutron, 25 assistant neutrons, 88 deputy neutrons, and 198 assistant deputy neutrons, giving it an atomic mass of 312.

These 312 particles are held together by forces called morons, which are surrounded by vast quantities of lepton-like particles called peons. Since Governmentium has no electrons, it is inert; however, it can be detected, because it impedes every reaction with which it comes into contact. A tiny amount of Governmentium can cause a reaction, which normally takes less than a second, to take from four days to four years to complete.

Governmentium has a normal half-life of 2-6 years. It does not decay, but undergoes a reorganisation in which a portion of the assistant neutrons and 20 deputy neutrons exchange places. In fact, Governmentium’s mass will actually increase over time, since each reorganisation will cause more morons to become neutrons, forming isodopes, not to mention multiple oxymorons.

This characteristic of moron promotion leads some scientists to believe that Governmentium is formed whenever morons reach a critical concentration. That hypothetical quantity might normally be called “critical mass” but, in this unique case it is known as “critical mess”.

When catalysed with money, Governmentium becomes Administratium (Am), another just-discovered element that radiates just as much energy as Governmentium since it has half as many peons but twice as many morons.


Whether Pat wrote this himself, I do not know. However I feel it almost appropriate to attribute it to him. He had the measure of his opponents and, if he had more resources, he would certainly have been classed as “dangerous”.

Pat was, in my experience, very much a democrat. He was a strong believer in the rights of the ordinary person and the protection of those rights, especially when challenged by government or the bureaucratic system. However he was sharp enough to know how to use government and larger organisations to advantage, as the narrative relating to the Bathing Water Directive will demonstrate, whist being equally conscious of how government and organisations can and do suppress progress and good sense.

Thus, after a period of intense frustration and growing disillusionment which led to Marinet to decide in 2015 to part ways with its parent organisation, Friends of the Earth, he was a strong supporter, indeed advocate, of that decision.

He believed in progress, always challenging those who refuse to accept the necessity of progress; and, although he was not able to take an active part in the independent Marinet in his final years, he believed in the vision and sense of commitment to secure real change for our seas and ocean which Marinet’s independence has heralded.

He was a person of very great commitment and vision. This is his legacy. It embraces us now and, I trust, we will in the future continue to embrace him equally strongly and so sustain his legacy to us.

Stephen Eades.
Director, Marinet Limited.


Marinet owes Pat its future and present direction. He was a Chairman with integrity and vision and he led by example which Stephen and I have always tried to emulate. His enthusiasm was infectious, he always hoped the environmental lobby would pull together but never lived to see it. We will miss his guidance as our first Life President.
David Levy, Current Chairman


Photo: Marinet Steering Group, 2003: Seated (anti-clockwise) Pat Gowen ( right and front of photo, Chair, Norfolk FOE), Stephen Eades (Co-ordinator, North Wiltshire FOE), Nicole Barton (national FOE), Clare Wilton (national FOE), Gina Carrinegton (Secretary, Manhood Penisula FOE), Alan Pegg, (Treasurer, Brighton FOE).


Sand, Sea and Sewage — by Patrick Gowen

The long-view of the history of sewage pollution

Mankind has known for over three thousand years that contact with the faecal output of others is the greatest single danger known to health. The Chinese dynasties knew this, the Ancient Egyptians knew it, as did the oldest Minoan, Greek, Aztec and Roman civilizations. In those times they didn’t know about bacteria and viruses, but from bitter experience they understood that to have faecal matter in the water that they drank, bathed in and washed their clothes in was courting disaster.

History tells of whole communities having been wiped out in the past by the diseases visited upon people through contact with sewage polluted water with the result that we are now well aware of the need for hygienic disposal. Today every mother carefully teaches her offspring to wash their hands after visiting the toilet. So if we know, parents know and every little child knows this, why is it that consecutive British governments over the past fifty years do not?

The earlier authorities were very aware of the essential need to stop the epidemics of typhoid, cholera and poliomyelitis that raged in the bigger towns and cities, but the practice of discharging sewage to rivers in towns and cities was widespread and the sea in coastal regions served as the disposal route.

Where the authorities did undertake treatment the sludge was removed by primary treatment (settlement, which separates solids from liquids), and was then digested by bacteria (secondary treatment) or otherwise sterilised, and used as ‘basic sludge’ on the fields as a fertilizer and soil conditioner and for its moisture holding properties. The sludge-free liquid was given secondary treatment by trickling it over stone banks exposed to light and air, so destroying most of the pathogens.

However this destruction of the pathogens was not so with the sewage going to the sea because it was mistakenly assumed that the combination of dilution, salinity, dispersion and oxygen present in the sea water, along with daytime exposure to sun light (ultra-violet), would kill off the dangerous organisms.

In the highly saline, warmer and well sunlit seas such as the Mediterranean, this was partially true. The ‘T-90 rule’ comes into play (T= time). This rule dictates that for every four hours of immersion in sea water the coliforms (gut-related bacteria) decay by 90 per cent. Thus after four hours we would see 10% of the original coliforms remaining, after eight hours we would see just 1%, after twelve hours 0.1% and so on. But whilst this T-90 decay is operative in some seas, it is not the case in the cold, murky, poorly lit waters of the UK where the decay period (T-90) can be far longer, well over a day in some cases. In the case of viruses, the T-90 principle can cover several days because viruses die at a far slower rate in saline conditions.

Tests for the T-90 coliform decay rate under different holding conditions were conducted by the author (Patrick Gowen) as evidence for the House of Commons Environment Committee Fourth Report, Session 1989-90, ‘Pollution of Beaches’, Volume III, Appendices, pages 477-482, ISBN 0 10 297890 5. These tests showed that the actual decay rate could vary by a factor of 10 depending upon the temperature, presence of sludge, the dissolved oxygen content and light penetration.

The same factors come into play in the ‘holding time and conditions’ of samples of sea water before placing to culture in the laboratory. If delayed before culture, the coliforms remaining in the sample can die and consequently be down to less than 10% of the level that were present at the point and time of sampling, thus giving a very misleading record of the real content originally present in the sea.

Sewage has long been disposed of to sea at most seaside resorts. When the population consisted of only a tiny community of fishermen and their families the faecal input to the sea was small. It could even be said that such disposal was beneficial to the environment, as small amounts aided the eco-system’s floral habitat by the provision of the phosphate and nitrate to be found in the effluent.

However since the early 1900’s the popularity of both coastal residence and marine recreation have increased many hundred fold, and coastal populations have grown enormously. As these seaside populations increased so did the amount of sewage being discharged to sea and grave health problems began to arise.

Nowadays the population of any coastal resort in the peak summer holiday season can increase by over eight times the normal resident levels, so the amount of excrement in the sea rises proportionally. On the same basis and at the same time, the number of people bathing in the polluted sea and using the beaches rises similarly, so producing a potentially dangerous situation.

There are many highly contagious and dangerous bacteria and viruses in untreated sewage that can give rise to a large number of what are known as faecal-oral infections. Pathogens in faecal matter excreted by any resident or holidaymaker which are not treated at a sewage works and are discharged to sea via an outfall (pipeline) can be picked up by anyone swallowing seawater. Eye, ear and skin infections can result from simple contact. Sunburn sores and beach abrasions can become similarly infected. Some faecal-oral infections from ingested pathogens such as a few of the salmonella bacteria cerotypes (e.g. salmonella hadar) require a large number of organisms to cause infection and so may cause only a few days of mild diarrhoea and vomiting – yet enough to spoil an otherwise pleasant holiday. Whereas others can cause a lasting serious infirmity, (e.g. typhoid — salmonella typhi). They need only one or two organisms to infect and can even kill, especially the very young and the old.

A listing of those pathogens that we now know may be found to be present in water containing untreated sewage, and the diseases that they can cause, is listed below and is also available with additional information on the subject on Marinet’s website, see


Pathogens occurring in Sewage contaminated bathing waters

Source: Swimming in Sewage, author Mark Dorfman MSPH, published by Natural Resources Defence Council ( and Environmental Integrity Project ( , 2004.


Pathogenic Agent

Acute, Chronic or Ultimate Effects †

Origin of Waste ♦



Campylobacter jejuni

Gastroenteritis/death from Guillain-Barre syndrome

Human/animal faeces

E coli (pathogenic or enterovirulent strains)

Gastroenteritis/E coli 0157:H7, adults: death from thrombocytopenia; children: death from kidney failure

Domestic sewage



Animal urine

Salmonella typhi

Typhoid fever/reactive arthritis from certain strains

Domestic sewage

Other salmonella species

Various enteric fevers (often called paratyphoid), gastroenteritis, septicemia (generalised infections
in which organisms multiply in the bloodstream)

Domestic sewage, animal wastes, food, compost

Shigella dysenteriae and other species

Bacillary dysentery

Human faeces, domestic sewage

Vibrio cholera


Domestic sewage, shellfish, saltwater

Yersinia spp.

Acute gastroenteritis (including diarrhoea, abdominal pain)/reactive arthritis

Water, milk, mammalian alimentary canal




Respiratory and gastrointestinal infections

Domestic sewage



Domestic sewage



Domestic sewage

Coxsackievirus (some strains)

Various, including severe respiratory diseases, fevers, rashes, paralysis, aseptic meningitis, myocarditis

Domestic sewage


Various, similar to Coxsackievirus (evidence is not definitive, except in experimental animals)

Domestic sewage

Hepatitis A

Infectious hepatitis (liver malfunction); also may affect kidneys and spleen

Domestic sewage

Norwalk and Norwalk-like viruses


Domestic sewage



Domestic sewage


Respiratory infections, gastroenteritis

Domestic sewage



Domestic sewage



Balantidium coli

Dysentery, intestinal ulcers

Human/animal faeces (esp. swine)

Cryptosporidium parvum

Gastroenteritis/death in immuno-compromised host

Human/animal faeces

Cyclospora cayetanensis


Human faeces

Dientamoeba fragilis

Mild diarrhoea

Human faeces

Entamoeba histolytica

Amoebic dysentery, infections of other organs

Human/animal faeces, (sewage)

Giardia lambia

Giardiasis, diarrhoea, abdominal cramps/failure to thrive, severe hypothyroidism, lactose intolerance, chronic joint pain

Human faeces

Isospora belli and Isospora hominus

Intestinal parasites, gastrointestinal infection


Toxoplasma gondii

Newborn syndrome, hearing and visual loss, mental retardation, diarrhea/dementia and/or seizures

Cat faeces

Pathogenic Agent.

Acute, Chronic or Ultimate Effects †

Origin of Waste ♦

Helminths (worms):

Digenetic trematodes (flukes):


Schistosoma haematobium


Human faeces

Schistosoma japanicum


Human faeces

Schistosoma mansoni


Human faeces

Echinostoma spp.


Animal faeces

Fexciola hepatica

Liver necrosis and cirrhosis

Animal faeces

Paragonimus westermani


Animal faeces and crustaceans

Clonorchis sinensis

Bile duct erosion

Human faeces, raw fish

Heterophyes heterophyes

Diaharroea and myocarditis

Human faeces. raw fish

Cestodes (tapeworms):


Diphyllobothrium latum

Diaharroea and anaemia

Human faeces, raw fish

Taeniarhynchus saginatus

Dizzines, nausea, pain, inappetence

Human faeces, raw fish

Taenia solium

Dizziness, nausea, pain, inappetence, cysticercosis

Human faeces, raw fish

Echinococcus granulosus


Dog, other animal faeces

Hymenolepsis nana

Dizziness, nausea, pain and inappetence

Human faeces

Nematodes (roundworms):


Trichuris trichiura

Asymptomatic to chronic haemorrage

Human faeces

Strongyloides stercoralis


Human faeces

Necator americanus

Iron-deficiency anaemia and protein deficiency

Human faeces

Ancylostoma duodenale

Iron-deficiency anaemia and protein deficiency

Human faeces

Ascaris lumbricoides


Human, pig and other animal faeces


† Source: Centres for Disease Control and Prevention, Emerging Infectious Diseases, vol 3, no. 4, Oct-Dec. 1997, as presented in J. B. Rose, et al, Microbial Pollutants in Our Nation’s Waters :Environmental and Public Health Issues, American Society for Microbiology, Washington D. C. , 1999, p.8.

♦ Source: Katonak, R, and J. B. Rose, Public Health Risks Associated with Wastewater Blending, Michigan State University, East Lansing, November 17, 2003, pp30,39.


A more recent history of sewage pollution

In the late 1940’s, a polio and typhoid outbreak (poliomyelitis : inflammation of the spinal cord leading to paralysis / typhoid : intestinal fever and gastric ulceration) claimed the lives of many people in Britain, and crippled many more. Both of these are faecal-oral diseases, i.e. brought about by mouth contact with excreta. It was shown that many of the victims succumbed after having been swimming in sewage polluted water. One such victim was Caroline, the young daughter of Tony Wakefield. As a result, Tony Wakefield founded the Coastal Anti-Pollution League to fight the problem of sewage pollution of sea bathing waters. His was the very first organisation to campaign on this issue.

Due to the growing pressure and concern from victims and relatives, a Royal Commission was set up which reported in 1959 with the conclusion:

“On the proviso that the bathing water is not so polluted as to be aesthetically revolting there should be no danger to public health.”

This was promptly interpreted by the sewage disposal companies to imply that if you can’t see it, you are safe. Strangely enough, this statement was in part true as any potential sea bather would readily have seen in the sea the turds, condoms and sanitary towels emanating from untreated sewage outfalls, but would not do so if such were not obvious. Thus superficially and erroneously it could be concluded that the apparently clean bathing water was safe to swim in.

Very regrettably, this report was consequently used as an excuse by the disposal authorities to continue to pump untreated sewage to the sea. For example, Anglia Water’s criteria for marine sewage disposal was stated as:

“Where effluent is discharged to the sea, the impact on the receiving water cannot be assessed in a manner used for works on inland waters. The criteria for the performance is then related to the visible effect of the discharge on the coastal water or the foreshore. A sea outfall is judged to be satisfactory if under normal operation it does not cause solid matter to be deposited on the shore, etc…”

In other words, a further rendition of: ‘if you can’t see it, you’re safe’.

The result of this mis-translation was the ‘Long Sea Outfall’, where the sewage was chopped up and passed through a 6mm (¼”) mesh in order to trap all the solid items such as contraceptives, tampons, sanitary towels and panty liners which would betray the presence of untreated sewage. This “treated” or disguised sewage was then discharged into the sea via a pipeline (‘long sea outfall’). These pipelines discharged at any point between the high-tide water mark and the low-tide water mark or beyond, depending on the location.

The solid items trapped by the 6mm mesh were disposed of at a landfill site.

However the faecal content, no longer recognisable due to being chopped up, was still present in the sewage effluent (liquid) and remained completely untreated.

In fact the health hazard is actually magnified in these circumstances. Due the organic matter present in the effluent (macerated/chopped up sewage) the oxygen content of the receiving water — which would normally aid the killing of the pathogens — is reduced by the effluent’s biological oxygen demand (BOD) which consumes the naturally occurring dissolved oxygen present in the sea water.

Furthermore the turbidity created by the dispersed sludge (macerated sewage) in the liquid effluent renders the receiving sea water murky so that sunlight cannot penetrate — the sun’s ultra-violet light also being a requirement to kill off the pathogens. (See evidence for the House of Commons Environment Committee Fourth Report, Session 1989-90, ‘Pollution of Beaches’, Volume III, Appendices, pages 477- 482, ISBN 0 10 297890 5).

But worst of all was the fact that the unwitting holiday visitor would inspect the water’s edge, see no visible signs of sewage pollution and then conclude that it was safe to swim in. Nothing could be further from the truth!

To save treatment and manpower costs, many sewage treatment plants were actually closed down in order to aid and abet the profits required by the water companies, newly privatised in 1991. For example, the Caister-on-Sea Sewage Treatment works on the Norfolk coast, which prior-treated most of the sewage from the wider Great Yarmouth area, was closed down in favour of a long sea outfall (pipeline) extending out 900 metres from the shoreline. It helped create for Anglian Water a profit of £187 million in the following year.

This particular plan went ahead despite howls of protest, a record packed public meeting opposing the venture, press campaigns, widespread leaflet distribution and a large petition. Sadly, believing the hype of “improved treatment” presented by the water company, Great Yarmouth Borough Council gave the scheme its blessing only to later find, just as forecast, that all of its resort’s bathing waters had become even more polluted.

Similar long sea outfalls were installed at Scarborough, Margate and many other resorts around the UK for the same reasons, none of which resulted in their sea bathing waters passing the imperative Mandatory Standard of the European Bathing Water Directive, 76/160/EEC.

Thus despite the failure of sea bathing waters to meet these legal European health safety standards, this plan to install long sea outfalls (pipelines reaching out from the shore and discharging largely untreated sewage) continued. In Norfolk for example, long sea outfalls were planned at West Runton to take the untreated sewage from the Sheringham and Cromer area directly to the sea.


Proving the Health Links

Since the Royal Commission’s 1959 report, many medical, scientific and epidemiological studies have taken place evidencing the health problems due to the presence of sewage in bathing waters.

One of the first of these was the work of Professor Victor Cabelli and his colleagues performing studies for the United States Environmental Protection Agency. He and his team studied the short-term resultant health effects on 30,000 beach users enjoying the eastern coasts off the USA.

This study measured the number of faecal coliforms present in the water in which people were swimming, and related the resultant illness levels to the concentration of faecal coliforms discovered.

Faecal coliforms [for example, Escherichia coli] are a thermo-tolerant coliform, found present in large numbers in human excreta. Unless a mutant form — such as E-Coli-0157 — they are benign, and offer no threat unless they enter the bloodstream as in cases of peritonitis, etc. They are in fact symbiotic, performing the essential major role in the digestion and conversion of our food. We all have many billions of such in our lower intestine, and would be in a poor way without them.

However they are a major indicator of the presence of sewage, being proportional to the faecal content in any body water where sewage has been introduced. Yet although the coliforms themselves are benign, untreated sewage contains many other pathogens which are highly dangerous to health. Again, for details see above and

Prof. Cabelli discovered that at levels of 10 faecal coliforms per 100ml of bathing water, an excess disease rate was visited upon 8 out of every thousand bathers.

At a level of 100 F/Coli per 100ml he found the rate of infection rose to 30 per thousand (3%) and at 1,000 F/Coli per 100ml it rose to 50 per thousand (5%).

He did not go above this concentration because, in his own mind, such a level of sewage pollution was unthinkable. But then he had not come to Britain, where levels of up to 500,000 F/Coli per 100ml were being found.

Neither did he look for the long term infections with far longer incubation periods, such as hepatitis, the symptoms of which appear after more than ten days.

As a result of this research, the World Health Organisation (WHO) pointed to the invalidity of the ‘research’ of the outdated 1959 Royal Commission Report, and did its own evaluation based upon the meaningful evidence now available. In its 1986 paper entitled ‘Correlation between Coastal Water Quality and Health Effects’ the WHO concluded “Swimming activities in coastal areas where faecal pollution is present carry a real public health risk”.

In February 1987 the British Medical Association withdrew their support for the outdated Royal Commission Report.

Before, during and since that time many more studies have been conducted, all further evidencing the threat. The UK government commissioned a study at Langland Bay, in the Gower area of South Wales, which further demonstrated the problem. Lancashire County Council also demonstrated that even higher levels of infection resulted in younger children due to their lower immunity.

At Blackpool a team of local doctors found that sudden epidemics resulted in the local population following south-westerly gales. This study revealed that the airborne viruses responsible for the epidemics were being carried well inland in the spray from the sewage polluted sea, thus showing that one need not enter the sea to get an infection as it readily came to you.


The Protest Commences

It was in August 1986 that the North Sea Action Group (founded by the author and colleagues) teamed up with local doctors to carry out its own epidemiological survey at Great Yarmouth.

The survey showed that whilst only 2.2% of the people who stayed on the beach complained of faecally ascribed infection symptoms, in the case of those that went swimming the level was 19.6%.

Of those who knowingly swallowed sea water whilst swimming, 29% showed a variety of short term sewage related contact symptoms. These varied from ear and eye infections to skin rashes, infected wounds from shingle cuts, sand scuff abrasions and sunburn sores, diarrhoea and vomiting, biliousness and nausea, stomach pains and general malaise, with a far higher incidence in younger children.

The North Sea Action Group, a forerunner of MARINET, issued the findings of that survey to the media and followed up with numerous other actions, much to the anger of Great Yarmouth Borough Council which, concerned with the impact to the holiday trade, promptly threatened to sue.

However the Council called off the action when their legal advisers pointed out that the North Sea Action Group’s (NSAG) findings were factual, and that far greater damage to the tourist income would result from wider publicity of the situation.

NSAG’s campaign included the hoisting of Jolly Roger flags to supplant the ‘Blue Flags’ flying at the beaches (a ‘Blue Flag’ indicated safe bathing) and the distribution of a series of leaflet hand-outs to holidaymakers at the worst polluted beaches in order to warn them of the perils of swimming there. Further leaflets and descriptive four page pamphlets were popped through letterboxes and distributed to the local hotels, guest houses and B&Bs.

A thousand fluorescent eye-catching stickers like that below were placed in car windows.



Samples of leaflets and four page pamphlets descriptive of the true condition of the polluted East Anglian beaches were handed out to holidaymakers along the beaches to warn them of the risks they were taking.


Samples of some of those distributed publications:

The concerned local doctors white-painted the untreated sewage outfall points and wrote onto them signs drawing attention to the outfalls such as ‘Danger – untreated sewage!’. These were rapidly painted over in black by the Council, which gave an even better background for the re-painting of further white warning signs! Then when the Council painted these over in white, the warnings were re-introduced with black lettering! This redecoration went on until finally the Council’s officials eventually apprehended the artists and slapped a prohibition order on them which of course resulted in even more publicity of the prevailing situation.


Photo of white-painted sewage outfall pipe

A demonstration and leafleting of councillors, guests and the media invited to the grand opening of the new sewage ‘treatment’ works followed. The police were called in and asked to stop this by evicting the protestors, but it was soon pointed out that they were well within their rights to hold such a peaceful protest. So we, the protestors, did just that.

A march comprised of several hundred members of the public, the North Sea Action Group, Friends of the Earth, Trade Unionists, supportive councillors and Greenpeace (the very first combined action uniting Friends of the Earth with Greenpeace) went on from the Caister sewage works to hold a well attended meeting on the beach. This was well publicised on TV, on the radio and in the press, so further raising public awareness.

A packed meeting opposing the venture was organised to take place at Great Yarmouth Town Hall. It turned out to be the largest public meeting ever held in Great Yarmouth. It was backed by press campaigns, further leafleting and a large petition.

Some NSAG members even purchased single Anglian Water shares so as to gain entry to their Annual General Meeting. There they vociferously raised concern with the shareholders and the press, whilst those declining to buy such shares mounted a leafleting and consultation with those attending. This protest resulted in a further good exposition, eclipsing the press content that the company would have liked to have seen.

Programmes about the issue resulted on ITV’s ‘First Tuesday’ and a half page article by Pat Gowen was printed in The Guardian newspaper, with much more publicity from the East Anglian, national and even international TV, radio and press which brought about national, indeed international awareness of what was happening.


The EEC Steps In

Following our complaints, and thus conscious of the situation and the threat to public health and the environment and its amenity value, the European Economic Community (EEC) — now the European Union (EU) — brought in the Bathing Water Directive 76/160/EEC in December 1975.

The Directive first asked all EEC member countries to designate their bathing waters. France and Italy both came up with over 3,000 resorts. Even lovely little land locked Luxembourg with no sea beaches whatsoever came up with 47, all being inland waters, lakes, etc. Britain, with the second longest coastline in Europe, produced just 27. Incredibly the UK government had decided that there was not a single beach where people went bathing in the entirety of Norfolk and Suffolk. Even Blackpool, the biggest and most crowded beach in all of Europe, was not a bathing beach in their eyes!

Their methodology for arriving at this amazing discovery was soon revealed. It transpired that the UK Department of the Environment had sent the Water Authorities out on a cold, wet Saturday in early July to count the number of bathers in the sea, probably fully aware that this day was well before the main holiday season began and, Saturday being a day when people generally either finish or begin their holiday, very few people would be using the beach on that particular day.

When the findings arrived back at the DoE, the Department then decided what would constitute a ‘bathing beach’. It decided that there had to be 1,500 people per mile on the beach and 500 bathers in the sea at any one time!

Since then, thanks to the reaction that resulted, sanity has eventually prevailed, and the European Commission ruled that a bathing beach was anywhere “where bathing is traditionally practiced by a large number of bathers” and, as a result, the original 27 bathing beaches have gradually increased to 587 of our 3,000+ seaside resorts that should be designated.

However still to this day, less than 1% of our well used inland lakes, broads and rivers are designated.


Microbiological Limit Levels

The members of the EEC decided on limits to the number of coliforms that could be permitted to be present in the bathing water to enable it to pass an imperative (mandatory) level of quality which had to be met within ten years from the time of the implementation of the December 1975 Bathing Waters Directive.

Thus, after January 1986 there must be no more than 10,000 total coliforms and/or 2,000 faecal coliforms present in 100 ml of the bathing water in 19 (95%) of the twenty samplings that were to be taken in a year.

The ‘year’ was considered by the UK to be a ‘bathing season’ which commenced in May and ceased in September each year. This definition of ‘year’ completely failed to recognise the use of the sea by the many surfers, kite surfers, windsurfers and even brave bathers who use our bathing beaches in the months of Autumn, Winter and early Spring, and so declined to classify these users of the sea as ‘bathers’.

The coliform concentrations permitted by the Directive — known as its Mandatory Value — were of a very high level when related to Cabelli’s findings, permitting well over 5% infection thus making it a quality standard which is easily achievable. However the EEC is, after all, an economic community and not a health service.

In addition, the 76/160/EEC Bathing Water Directive dictated that there must be a complete absence of both enteroviruses and salmonella in a bathing water throughout the year for it to meet the Mandatory Value.

The EEC also decided upon a recommended Guideline Value which member states “must strive to meet”. This was a far more sensible value – indeed, one which if exceeded results in the closure of bathing resorts to the public in North America because of the threat to public health. Only this Guideline Value is unlike the mandatory levels in that it is not imperative (legally enforceable). It was simply given as “a level that authorities should strive to meet”. Additionally, it did not specifically demand the absence of enteroviruses and salmonella as it was assumed that if the bathing water had passed the Mandatory Standard it would prove unnecessary to further include these parameters.

The EEC Guideline Value calls for no more than 500 total coliforms, and/or 100 faecal coliforms or 100 faecal streptococci per 100 ml of bathing water in order to comply with its Guideline Standard, and that at least 80% of the samplings must meet this level.

There were many other Guideline parameters to be met also, such as no oil, no tar, no heavy metals, no phenols and other unpleasant contents. However it is mainly the microbiological components that are significant to health. The 76/160/EEC Bathing Water Directive can be read by going to


National Non-Conformity

After the ten years allowed to produce compliance, e.g. by January 1986, Britain’s beach resorts were more polluted than ever.

The government’s main excuse for selling off the nationally owned water companies to private ownership was to provide the capital needed to bring our ailing sewage services up to the standards required to meet the legal levels. But they stayed far from it!

On 17th November 1994 Robert Atkins, Minister of State for the Environment, announced that 82% of the (then) 457 Bathing Waters passed the Mandatory Standard of the Bathing Waters Directive, claiming this to be “a continuing improvement”.

Recognising the highly dubious truth of this claim the NSAG, working with Friends of the Earth, decided to obtain the actual findings of the tests performed in order to discover the realistic mandatory pass rate, as is a right under the 76/160/EC Bathing Water Directive.

Letters requesting the results of the analyses were sent to all the water companies of Britain. This resulted in some refusing the information, some referring us to the (then) Department of the Environment, and some demanding a charge of 10p per result for the data. As there were so many parameters, 457 resorts and twenty tests per year, the cost of the exercise would have been prohibitive.

However having a right to have sight of them, as detailed in the Directive itself, your author travelled to those who failed to reveal the information in order to inspect the Water Register of each and every water company [a Water Register contains all the official records and is free to view]. By reading the results from off the computer screen and speaking them into a portable tape recorder, all were eventually gathered without excessive cost to us.

On calculating the conformity of the findings to the mandatory demands of the 76/160/EC Bathing Water Directive, the discrepancies in the highly optimistic claim made by Minister of State for the Environment became obvious. They were published on the NSAG website for all to see, and consolidated into booklets printed and distributed by the North Sea Action Group and Norfolk Friends of the Earth (NFoE).

In order to make the public aware of the facts and also to raise money for the NSAG/NFoE campaign, in 1995 Pat Gowen wrote a 78 page booklet entitled ‘The North Sea Action Group’s Good Beach Guide’ covering all the Norfolk and Suffolk resorts.

Copies were distributed to every bookseller along the entire East Anglian coast. The publication gave a short history of the saga, the complete microbiological analyses and findings of every resort in Norfolk and Suffolk, a description of the beach and general area itself, with recommendations as to where it was or was not safe to swim.

It was a sell out, and produced a marked migration of holidaymakers from the polluted popular resorts to those recommended beaches of far better quality.

The following year a further more comprehensive 114 page edition followed including (by popular request) also the results and findings of Lincolnshire and Essex.

‘Good Beach Guides’ published by NSAG/NFoE

The Good Beach Guides drew attention to the fact that of the 34 East Anglian resorts tested in 1999, 17 were proven to pass the full Mandatory Standard whilst an equal number failed. (The government claimed 23 passes and 11 failures that year!). The 2000 testing (for the 2001 status) showed 18 resorts to pass and 15 to fail, with only one being of unproven compliance. The 2001 testing, for the 2002 status, proved 20 resorts to pass, 13 to fail and one of unknown compliance.

Beaches around the country were showing serious levels of sewage pollution, so the local protest groups banded together to combat it.

A meeting of Manhood Peninsula FoE, Sussex, and the NSAG came about at Selsey, Sussex, in 2002. Later in 2002 at the Friends of the Earth Local Groups Conference MARINET was formed in order to act as a FoE Local Group national network, as FoE did not cover marine issues.

Nationally failures to comply with the Mandatory levels of the Directive were similarly recorded, with beaches in North West England being some of the worst. Blackpool, the most used and most popular beach in Europe, was one of the most polluted. Thus a formal complaint was made to DG-XI, the administrative and legal wing of the EEC’s Commission which dealt with environmental legislation.

Legal proceedings against the UK were taken under Reference IP/00/1541 in respect of the Blackpool beaches (only). A successful hearing came about in the European Court, later resulting in the imposition of a huge 106,800 Euros (£87,000) per day fine placed by the European Court on 13th November 2002 in respect of the UK’s failure to meet the Mandatory Standard as required by Directive. This European Court judgment was based upon just three of the Blackpool area bathing waters.

A sudden and amazing change came about the following year.

The mind of our government must have been focused to the fact that the only way to stop the daily fine was to claim that the failing resorts met the coliform standards. Indeed, by some miracle, it was claimed that they all so did. A remarkable reduction of coliform concentration (upon which the fine was based) came about — although it is to be noted that all the resorts failed the Mandatory Standard’s requirement of a zero level of enteroviruses. Enteroviruses were discovered present at every resort in the North West Region.

The 2003 test results, giving the compliance for 2004, showed that 16 of the region’s 34 resorts were tested for salmonella, and that all passed. 16 resorts were tested for enteroviruses, of which 12 passed. With all coliform tests claimed to pass, this gave 11 passes, 5 failures and 18 resorts not fully tested (these therefore being of unknown compliance).

As the original judgment of the European Court based it’s finding on coliform non-compliance, it is very doubtful that the European Commission could now go back to re-imposing the fine on a different vector, i.e. enteroviruses. This would almost certainly have required a new legal case, and this would require many years to bring about just as the original legal case had done.

Since then, the results of the tests made by the Environment Agency (EA) have been used from which to calculate the factual compliance of each of our UK designated bathing waters. The factual compliance (or otherwise) so revealed is very different from that claimed and put out as Press Releases by the Department for the Environment (Defra) and hence the EA, who have closed their eyes and ears to those resorts failing to meet the compliance for both enteroviruses and salmonella mandatory levels.*


* Editor’s Note: The Bathing Water Directive 76/160/EEC has now been replaced by a new Directive 2006/7/EC – see section on this new Directive later on. Suffice to say here that the microbiological parameters used for assessing Mandatory and Guideline compliance have been reformed (changed), and this new Directive has been legally operative since 2015. The national results under the new Directive 2006/7/EC are now published annually for England by the Department for the Environment (Defra), see and by the devolved administrations for Scotland, Wales and Northern Ireland. The detailed results throughout the season for each bathing resort in England are provided by the Environment Agency and can be seen at with similar profiles provided by the Agencies for Scotland, Wales and Northern Ireland.


The Blue Flag Issue

Blue Flags are supposed to be issued to those resorts that meet stipulated criteria, including the Directive’s Guideline Standard for coliform and faecal streptococci levels. In practice they are given completely ignoring the more essential imperative Mandatory Standard which demands a total absence of both enteroviruses and salmonella.

When the first Blue Flags were produced in 1989 for Britain’s least foul bathing waters, they were issued to 22 resorts.

Inspection and analysis of these showed that only one of these (Exmouth) had been tested for enteroviruses and salmonella, and that this had failed. Not a single one of the Blue Flag awarded resorts had been proven to pass the Mandatory Standard.

But at least the amenity values demanded for a Blue Flag are honestly met. For full details of the Blue Flag hype, please visit “Blue Flags, Blue Flag look-alikes and Jolly Rogers” by going to the article to be found on this website at

Note: A supplementary report on this issue is a report dated August 2010 written by Surfers Against Sewage; apply to Surfers Against Sewage in order to see this.


Bathing Water Directive 2006/7/EC

Editorial note: Pat Gowen was unable to complete this article due to declining health and, as explained in the Preface, he asked me to arrange and complete the article for him. Therefore from this point forward the text is based on his notes for this article and earlier written contributions by him for Marinet.

The new Directive, 2006/7/EC, has sought to take account of improving knowledge since the original Directive came into force ( December 1975) concerning the microbiological and related health impacts from sewage discharged into bathing waters, and thus has sought to devise a monitoring regime more suited to the present time whilst also taking into account other legislative changes, e.g. the introduction of related Directives affecting sewage treatment, such as the Urban Waste Water Treatment Directive, 91/271/EEC, and the Water Framework Directive, 200/60/EC. The text of the new Bathing Water Directive, 2006/7/EC, can be seen at

At the time of the new Directive’s formulation Marinet raised a number of concerns with the UK authorities (DEFRA) as to the priorities and possible shortcomings of the new legislation. These are recorded on our website, see To summarise the main points:


● The new Directive should embrace a definition of a “bathing season” which covers not just the summer but all months of the year. This ensures that those who use the sea outside of the summer e.g. surfers and sailing clubs, are fully protected.

This is also related to the issue of combined sewer overflows (CSOs). All sewage works have a finite, limited capacity and it is important, if the sewage works is to operate 100% effectively, that it is not overloaded.

Overloading can be brought about by a sudden influx of population e.g. coastal resorts often have a population several times greater in summer months relative to winter months. However a more common reason is the widespread practice of combining surface water collection systems (e.g. from hard surfaces such as roads and paved areas) with foul water systems which collect sewage. Good practice requires that these two systems should be distinct and separate. However financial economies in the provision of water collection systems have often led to the surface and foul water systems being combined into one collection system (sewer) which then connects with the sewage works.

The problem posed by combined sewers generally arises when it rains. If the surface water collection system is separate from the foul water system, the surface water (which is relatively clean, i.e. low microbiological contamination) can be discharged to a river or the sea relatively safely. However if the two collection systems have been combined then the combined flows all go to the sewage works, thus obviously creating an increased load on the sewage works. Most sewage works have spare capacity, along with additional storage tanks in some cases, but when the rain is very heavy the volume of water arriving at the sewage works may exceed the work’s capacity. In these circumstances the sewage works has to discharge the excess (foul and surface water) via a pipeline overflow into a river or the sea untreated.

These combined sewer overflows (CSOs) are highly polluting in microbiological terms because they involve the discharge of raw sewage. They are at their most frequent during exceptional events (thunderstorms) and during wet periods of the year (winter). The existence of CSOs is therefore a hazard to sea bathing in the summer following a ‘break-up’ in good weather and during any period of extended rainfall at other times of the year.

CSO events are most frequent outside the ‘official summer bathing season’, and it is for this reason that Marinet and others sought for the new Directive to be applied all year round, thus protecting users of the sea outside of summer months. It is also to be noted that in the case of the less well performing bathing waters, CSOs are often the cause of poor bathing water quality. In these circumstances the sewage works is limited in capacity and so even in summer months low rainfall can trigger the use of the combined sewer overflow.


● Whilst the new Directive focused on improved microbiological standards, see the comparison below of the Mandatory Standard for the old Directive relative to the New Directive, the new Directive’s microbiological parameters nevertheless had shortcomings.


Old Directive, 76/160/EEC


Mandatory Standard

Total coliforms per 100ml


Faecal coliforms per 100ml


Faecal streptococci per 100ml

– *

Salmonella per 1 litre


Enteroviruses PFU/10 litres


* The Faecal streptococci sampling only applied to the Guideline Standard.


New Directive, 2006/7/EC


Excellent Standard

Intestinal enterococci per 100ml


Eschererichia coli per 100ml



As has been explained earlier, the most significant pathogens are not actually sampled by either of the Bathing Water Directives’ monitoring regimes (76/160/EEC or 2006/7/EC), and the Mandatory/Excellent Standard of these Directives, as well as Guideline/Good Standard, use substitutes which are broad indicators of the presence of sewage e.g. faecal coliforms, intestinal enterococci.

In the case of the old Directive, 76/160/EEC, the Mandatory Standard did actually take a step in the right direction regarding the detection of the potential presence of these more significant pathogens by requiring the monitoring for Salmonella and Enteroviruses under this Standard. However this component of the Mandatory Standard was never enforced, and monitoring for these parameters (salmonella and enteroviruses) rarely took place. It is also worth noting from a public health perspective that a great many of these more significant pathogens, particularly viruses, are capable of surviving for a longer time than bacteria in a saline environment.

This failure to monitor for salmonella and enteroviruses during the life of the old Directive was taken up with the UK government by Marinet and others. The reply received stated that monitoring for these parameters would only take place once a bathing water had failed the Mandatory Standard under the prescribed coliform monitoring procedure. Apart from the illegality in this interpretation of the monitoring procedure and the fact that this interpretation was not allowed for in the text of the Directive, it also had the important consequence that whilst a bathing water which might legally pass the Directive’s requirements under coliform criteria but not in terms of salmonella or enteroviruses (i.e. the most dangerous pathogens), it meant that the bathing waters failure under the Directive was never actually identified.

Further, even in the case of bathing waters which did legally fail under the coliform criteria, the actual monitoring for salmonella and enteroviruses was very spasmodic (i.e. just once a year) and, in all too many cases, wholly absent.

This failure by the UK government to apply the full rigour of the Mandatory Standard was taken up with DG XI of the European Commission, but the Commission acquiesced in this weak interpretation of the Mandatory Standard and took no enforcement action.

Consequently during the lifetime of the old Directive (from 1976-2014), this means that the full nature and the true extent of the sewage pollution, along with the attendant health risks associated with bathing waters polluted in this way, has never been properly assessed and remains unrevealed.

Accordingly Marinet and others wanted the new Directive, 2006/7/EC, operative from 2015 and ostensibly implementing a higher yardstick of monitoring quality, to include regular monitoring for salmonella and enteroviruses.

Alas, these specific parameters were excluded from the new Directive and so the true nature and extent of sewage related pollution of our bathing waters continues to remain unassessed and unrevealed. In his notes Pat Gowen also observes: “We asked that the presence of any new and dangerous pathogens (such as E-Coli-0157 likely to be present when abattoir waste is discharged to an outfall) should additionally be investigated. Further, with the newly mutated ‘SARS’ coronavirus linked to sewage proving so contagious, tests for the presence of this dangerous pathogen also needed to be instituted, as well as any new mutant infective transmissible pathogens discovered in the future.” Neither the UK nor the EU governments have been receptive.


● A further dimension is the method and storage of the samples taken to test for compliance. The need for a clearly defined methodology in the new Directive was represented to the UK government by Marinet. In his notes for this section, Pat Gowen observes:

“It all goes back to when the excuse, given by the newly privatised water companies [1989] for closing coastal sewage treatment plants and piping the mashed but untreated sewage direct to the sea, was the well claimed ‘T-90’ test.

“This dictates that coliforms decay by 90% for every four hours of their immersion in sea water. (This is in the main true for the highly saline, warmer, sunlit clear waters of the Mediterranean, but certainly not for the cold, grey and murky North Sea). I did some empirical research on this, and on the coliform life-span for stored samples of sewage polluted sea water.

“From my enquiries with the water companies on their method of sample analysis, I found delays of sometimes well over a day before the samples for coliform analysis were taken out of the sea water. This would mean that a bathing water sample with, for example, 100,000 faecal coliforms per 100 ml would show a reading of just 10,000 coliforms after four hours of storage and, correspondingly 1,000 coliforms after eight hours, 100 after twelve hours, 10 coliforms after sixteen hours and only one coliform after 20 hours if the sample of sea water were kept shaken in transport at car temperature, were oxygenated by an air gap in the container and was in light. However this rate of coliform decay becomes far less in cooled, full, sealed containers kept in darkness without turbulence.

“Nevertheless, even under ideal sample storage conditions, I found that 75% of the coliforms had decayed over 24 hours. In the case of 24 hours of waiting in room temperature, I would guesstimate that the coliform decay was at least 90%, possibly more than 99%, so bringing a non-compliant sampling from say 3,000 coliforms/100ml down to a count of between 300 to 30/100ml, e.g. a Mandatory failure had been transformed into a Guideline pass.

“For my evidence to the House of Commons Session 1989-90 Environment Committee Enquiry into the Pollution of Beaches — given following Bob Earll’s who was then with the Marine Conservation Society — see Volume II, Minutes of Evidence, page 293-323, HMSO ISBN 0 10 297790 9. For the specific data on the coliform decay rate of stored samples under different conditions see page 482-498 of Volume III Appendices, ISBN 0 10 297890 5. Your local library should be able to get this for you.

“If the European Commission, as I implored, had demanded proper sampling and storage incorporated into the new Directive, then the results of analysis may have become realistic. However I think you will find that lobbying by the water companies and our government will have seen that off, otherwise the truth of our ailing bathing waters would be revealed. Further, to have rid the salmonella and enterovirus samplings from the new Directive would mean that a false glossy picture will still go on being painted.

“I would be very surprised if the UK government (DEFRA) has not built in some loopholes and means of escape. It is not in the financial interests of the water companies and the government to have the facts known. Profits are seen as paramount relative to public health, as you will have noted from the BSE/CJD scandal, the mobile telephones hazard, GM food concerns, and much, much more.

“It is very disappointing and sad to me that the Marine Conservation Society offers no opposition to this scam despite my imploring them to take up the cudgels on the misinformation and fiddling which still goes on, year after year. Their tacit acceptance of the official line still amazes me, and I fail to comprehend the reason for this.”


● A provision in the new Directive 2006/7 EC, not present in the old Directive, is that the sampling authority — the Environment Agency, advised by the water company — can discount and eliminate any sample which breaches the new Directive’s performance standards if it can be argued that “short-term pollution” circumstances prevailed at the time (defined as an event not generally lasting longer than 72 hours) and “distorted” the sample reading. For example, an exceptional storm or breakdown in the sewage works. The new Directive also stipulates that a replacement sample must be taken when these short term pollution circumstances have passed, and this procedure of discounting can be conducted to a limit of 15% of the overall samples taken in a bathing season. [Editorial Note: A further provision in the Directive allows for a suspension of monitoring if an “abnormal situation” arises, defined as circumstances not repeated with a frequency greater than once in four years (ref. Article 2, sections 8 and 9). So far it appears that the UK has only sought to implement ‘short-term pollution’ events in its monitoring regime and ‘abnormal situations’ have not occurred (not been used in monitoring). However it has to be observed that by defining a ‘short-term pollution’ event as not being an abnormal situation does effectively render it as normal, i.e. something that can be accepted with a degree of regularity. Are we therefore expected to accept under the new Directive that repeated sewage pollution events, classed as short term pollution, are normal rather than abnormal? If so, this greatly debases the integrity and value of the Directive whose purpose is to protect the public from the health risks of sewage pollution.].

The “short-term pollution” event was a new provision and practice in the sampling regime of the new Directive which greatly concerned Pat Gowen because he believed it might easily lead to a distortion of the true compliance record. His notes observe:

“We note that the new Directive will allow for the discounting of up to 15% of samples. We cannot see other than that this may be used as a further means of escaping condemnation for failing waters, as repeated samplings could be instituted until one that passes the requirements results, so further producing false compliance.”

Is there any truth in his concern? To explore this question, the editor of this article has examined the detailed monitoring results under the new Directive for 3 of the principal bathing waters on the West Lancashire coast during the summers of 2016 and 2017 (with which he is familiar having campaigned for improvements to these bathing areas in the 1980s under the old Directive) — Ainsdale (site of the Pontin’s Southport Holiday Park) and the two beaches of the coast’s main seaside towns, Southport (Southport pier) and Blackpool (Blackpool Central).

Reproduced below are summary results for these beaches in 2016 and 2017, taken from the Environment Agency website which gives the full detailed readings during the whole bathing season . At each beach 20 samples were taken during the bathing season, 3 of which were eligible as retakes of the original sample should it be considered to be necessary to “discount” (eliminate) the sample due to “short term pollution” resulting in an exceedance reading.
Note: 15% of 20 samples = 3 samples.




Original samples

Discounted samples

Total samples, excluding discounted samples

Overall Standard








































There are four Standards of Quality under the new Directive: Excellent, Good, Sufficient, or Poor. For details of the Quality Standards under the new Directive, see

The Excellent and Good Standards require 95% of valid samples (i.e. non-discounted) to meet the required standard, and the Sufficient Standard requires 90% to meet the required standard (i.e. 1 failure in 20 valid samples against the appropriate bacteriological ceiling level is permissible under the Excellent and Good Standards, and 2 failures in 20 valid samples against the appropriate bacteriological ceiling level is permissible under the Sufficient Standard)

Each of these Standards has a higher/lower hurdle (ceiling level) for the actual microbiological level in connection with compliance (pass/fail) against that Standard. Where the samples throughout the season fail to meet the Sufficient Standard, then the beach is classified as Poor Standard. Under such circumstances, public information is required to be issued to potential bathers about the microbiological condition of that beach, and 5 years of repeated Poor Standard means disqualification of that beach as a bathing beach.

What is evident from the 2016 and 2017 performance at Ainsdale, Southport and Blackpool and the quality of their bathing water is as follows:

● None of these beaches were able to meet the Excellent Standard, even when 3 or less samples had been discounted.

● In all of the beaches between 1 and 3 samples were being discounted in order to enable the beach to comply with the Good Standard.

● At each beach “discounting” was employed in 2016 and 2017 :
Ainsdale 2016 :      1 discount      Ainsdale 2017 : 3 discounts.
Southport 2016 :   3 discounts    Southport 2017 : 3 discounts.
Blackpool 2016 :    3 discounts    Blackpool 2017 : 3 discounts.

Thus it is clear that the “discounting system” (not available under the old Directive) has been used repeatedly by the authorities to assist in their performance rating under the new Directive.

One therefore wonders to what degree the true reality at bathing beaches throughout the UK is being concealed by the use of the “discount system”, especially when taking into account the fact that the actual microbiological counts in samples can be manipulated if the sample is not counted immediately (ref. Pat Gowen’s comments on the ‘T-90’ issue)?

In these matters certainty is always going to be elusive given the nature of the sampling system that the new Directive has allowed for. Alas, Pat Gowen’s reservations about the new Directive do appear to have evidence to sustain them. This is worrying. Even more worrying is the clear fact that sewage pollution of our bathing waters still remains widespread, even if the actual degree is less certain.


● Where certainty would seem stronger is in the matter of the repeat nature of the use of the “discounting system”. As can be seen in the case of three of the main West Lancashire bathing beaches, this use has been consistent and almost fully utilised. Is this “legal”? Article 2, section 9, of Directive 2007/7/EC states: “ ‘abnormal situation’ means an event or combination of events impacting on bathing water quality at the location concerned and not expected to occur on average more than once every four years.”

Certainly repeated discounting using the ‘short term pollution’ provision is legal, but is it really a sustainable argument to assert that these short term pollution events which occur regularly each year and which are being discounted so as to disguise true performance (hoodwink the public) is normal and not abnormal? The normalisation of sewage pollution appears to be an acceptable approach, as well as the manipulation of the quality rating.

It would seem that this is a matter which requires examination by the UK Government and DGXI of the European Commission to see whether not just the spirit but also the letter of the law is being complied with, and one wonders how far this practice is also being repeated elsewhere at bathing beaches in the UK? This is a subject awaiting detailed analysis.

This potential “manipulation” also lends credence to Pat Gowen’s concerns.

Note: In the case of the bathing beach at Blackpool North (North Pier, which is adjacent to the main bathing beach — Blackpool Central) the Quality Standard achieved for 2016 was Sufficient. This beach had three discountable samples in 2016, and therefore it is very likely that if “discounts” had not been employed this beach would only have achieved the Poor Standard, and so effectively failed the quality requirements of the new Directive. These are sensitive questions because it would be very bad publicity for one of Blackpool’s beaches to “fail”, scoring only the Poor Quality Standard.

To conclude this section on the new EU Directive 2006/7/EC which has been operational since 2015, we provide some summary tables of performance for English beaches prepared by DEFRA, with UK summary results also available: ref.


Classification of beaches in England, 2016:











69.5% of total beaches in England





Those beaches only able to attain the Poor Standard were: Scarborough South Bay, Clacton (Groyne 41), Walpole Bay (Margate, Kent), Instow (North Devon), Ilfracombe Wildersmouth, Burnham Jetty North (Somerset).


Classification of beaches in England, 2017:











65.4% of total beaches in England





Those beaches only able to attain the Poor Standard were: Scarborough South Bay, Clacton (Groyne 41), Instow (North Devon), Ilracombe Wildersmouth, Combe Martin (North Devon), Burnham Jetty North (Somerset), Weston-super-Mare Uphill Slipway.

How does the performance of the United Kingdom’s beaches (England, Wales, Scotland and Northern Ireland) compare to other EU countries?

The comparative results are published in full on the European Commission website, and detailed results published by the European Environment Agency for each European country can be seen at

The summary performance results for 2016 against the Excellent Standard of Directive 2006/7/EC are as follows:


% of beaches at Excellent Standard


% of beaches at Excellent Standard















































United Kingdom






Czech Republic









The reason why the United Kingdom performs so badly, not just relatively but also absolutely, will be evident to the reader from the foregoing narrative of this article. Namely, the UK still discharges substantial amounts of treated or poorly treated sewage into bathing waters.

This reality is further compounded by the “tricks of the trade” which the UK authorities appear to be employing in order to massage the performance figures and thus understate the true position.

Apart from any moral or aesthetic evaluation of what the public is expected to tolerate is the fact that the public has to experience serious health risks attached to sewage pollution and bathing at beaches where this pollution occurs. Quite simply, unless the beach attains the Excellent Standard then the public is being exposed to a distinct, and sometimes serious, sewage-related health risk — and this occurs at around 35% of UK beaches at the present time.

It is now 42 years since the first EU Directive was introduced. Marinet takes the view that sewage pollution — inadequate sewage treatment — is not only wholly unacceptable but that it is also due to a clear dereliction of duty by the UK Government. Pat Gowen was greatly upset by what he found when he started researching and campaigning on this issue in the 1970s.

Regrettably, he would remain so today.

And the remedy? Pat Gowen would almost certainly say : more of the direct, interventionist protest action that he and colleagues pioneered in the 1970s.

Marinet is here to support all those prepared to act. Pat Gowen did make a difference by his work — a profound difference because the UK government was forced to incorporate into UK law an EU Bathing Water Directive (76/160/EEC) which it wanted to disown, and that Directive’s incorporation into UK law has meant sewage works have had to be built and upgraded.

The legacy left to us all by Pat Gowen is considerable. It is time for us to take his legacy forward in order to improve the future too. That is a message Pat would understand. If you heed it, please contact us:

January 2018



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