Ilkley Clean River Campaign
30 Nelson Rd
Ilkley LS29 8HN
Sir James Bevan
Chief Executive
Environment Agency
Seacole Block
2 Marsham Street
London SW1P 4DF
20.08.2019
Dear Sir James
We are disappointed by the response from Mr Harmar, which is not congruent with our understanding from our meeting with you. In our previous letter we state “At that meeting you expressed privately that the case was made for development work; and that you wanted to secure improvements in the river environment, and to secure a solution to the problem.”
Please note that since Mr Christmas letter in June, and prior to our meeting with you, we have undergone more citizen testing which showed the extremely high levels of ecoli in the river by the sewage outflow from both the treated and storm overflow. You letter does not address this situation.
“We reiterate that the number of sewage discharges into the river in the middle of a spa town is unacceptable for the modern day and contravenes legislation.”
Our testing shows 35,500 E Coli cfus per 100mls in dry, low spill conditions and 43,500 E coli cfus per 100mls in wet, high spill conditions. These are 40(dry weather) to 50 (wet weather) times higher than the EA bathing water quality limits.
The letter yet again does not respond to the issues raised, which we will spell out again here:
1. The solids on the riverbank where people play, swim and picnic.
2. The number of ‘spills’, which already trigger investigation in terms of the UWWTD, as per your previous letters. You have not addressed how you contest the UWWTD ruling in terms of ‘exceptional’ weather, only providing details of a process that tolerates circa 40 – 60 discharges a year, which is not compliant with the UWWTD. AS we state “In terms of triggers for spills there was one extreme weather incident in Yorkshire on the 16th March 2019 when there was flooding. This would meet the UWWTD definition of Extreme Weather.
3. You state EDM is still being commissioned, given the situation at Ilkley we do not understand the delay (now a year since we raised the issue) and your tolerance for the slow response by Yorkshire Water to installing EDM
4. You state the water quality meets the WFD, however given that people bathe
in the water there is a real risk to public health of the extremely high e coli concentrations in the water. Whilst this is not WFD, it is of concern to people in Ilkley. We are glad to hear you support the bathing water status application but given we have now proved how dangerous the water is to public health and you have that data, and it’s in the public domain we are surprised that you do not feel required to act on it. If Yorkshire Water installed UV disinfection and phosphate stripping we believe this would dramatically improve the treated sewage quality, which would reduce the danger to the public. There is a moral obligation here whilst we apply for bathing water status as the numbers bathing in the river are very high. See attached briefing for the BBC for the 6 o’clock news this week.
5. The letter provided by Mr Christmas in June set out a number of options. We asked for a plan by the end of September. The subsequent letter stated the ‘number of options’ was the plan. Given your view at the meeting with John Grogan and Prof Malby that the ‘case was made’ which of these options is going to be pursued?
6. Mr Harmar asks that we continue to monitor the illegal discharges on the footpath in Ilkley. We believe that that is the job of the EA and Yorkshire Water. We have brought the issue to your attention. Yorkshire Water should now be monitoring the situation and cleaning up the footpath after every incidence until the problem is solved. It is not for citizens to be regulating and monitoring the company. Please confirm how you will be regulating this situation. You fail to respond to our concerns about ongoing monitoring of the sewage infrastructure in Ilkley and Yorkshire Water’s obligations in this regard.
Yours sincerely
Karen Shackleton, Prof Rick Battarbee, Prof Becky Malby, Kathleen Roberts, Stephen Fairbourn
Ilkley Clean River Campaign
On behalf of Ilkley Town residents.
Supported by Climate Action Ilkley.