Summary of responses and government response
Updated 12 April 2022
Executive summary
Defra held a consultation on a proposal to designate an area of the River Thames in Oxford as a bathing water under the Bathing Water Regulations 2013 (S.I. 2013/1675) (the ‘Regulations). The consultation ran from 9 February 2022 to 2 March 2022.
The objective of designating a beach or inland bathing area as a bathing water is to protect bathers’ health against faecal pollution. Water quality is monitored by the Environment Agency (EA) during the bathing season, which in England runs from 15 May to 30 September, and bathing waters are classified annually as excellent, good, sufficient or poor. If water quality does not meet the legally required standards, the EA will investigate the sources of pollution and recommend remedial measures to make improvements.
The consultation asked respondents whether they supported the proposal to designate a stretch of the River Thames in Oxford as a bathing water and invited them to provide evidence if they wished to do so.
This was a national consultation, following a local consultation that was held by the Oxford Rivers Project as part of the evidence gathering process for the application. This document summarises the responses to the national consultation.
Number of responses
In total 1,267 responses to the consultation were received.
1,051 private individuals and 216 individuals representing 140 organisations responded to the consultation. A number of organisations sent several separate responses from different individuals. All respondents have been included in the total number. There was a wide range of organisations who responded, including local civic organisations, environmental Non-Governmental Organisations and conservation organisations and national bodies. A list of organisations who submitted a response is included in Annex A. The key arguments raised in organisational responses are included alongside individual responses below.
Responses
The consultation asked respondents “What is your view on the proposal to designate Wolvercote Mill Stream as a Bathing Water?” Respondents were invited to provide evidence to support their answer if they wished to do so.
Of the 1,267 responses received, 1,260 supported the proposed designation as a bathing water and 7 were opposed.
There was a widespread view among respondents that this area of the River Thames is an asset to Oxford, with many commenting on its popularity for swimming and paddling with local residents and visitors to the area. Around 209 respondents commented that they or their family swim in the river.
In addition, there was widespread concern about pollution in the river. Around 362 respondents commented on sewage discharges and their potential impact on bathers’ health and the environment. These respondents felt that a bathing water designation would decrease the amount of untreated sewage discharged into the Thames near the site, as a result improving the water quality. A number of people stated that although they had swum at the site in the past, in recent years the level of sewage pollution had prevented them from swimming.
Two of the respondents who opposed designation acknowledged the concerns over the amount of untreated sewage but did not feel a bathing water designation for the site would be suitable. One felt that a bathing water designation would be pointless as the river quality will continually be classified as poor. If designated, the EA will draw up action plans and will work with local partners, such as Thames Water, in order to improve water quality issues at the site.
Another respondent who opposed designation stated that pressure groups are using bathing water status as a lever to improve river quality, therefore a bathing water designation wouldn’t be appropriate.
Two respondents opposing designation wrote that the area should not be designated as a bathing water due to concerns regarding angling. One stated a designation will have a detrimental impact on fish stocks and negative impact on their ability to breed. Currently, the site provides very important cover from predators in the breeding season and having people swimming in the stream will ‘destroy’ the shelter these fish need to seek sanctuary in. However, as shown in the consultation document, the site already has very high user numbers.
Another response opposing designation had strong concerns that designation as a bathing water would cause safety issues between large boats and swimmers. They stated that they regularly boat around this stretch. However, Oxford City Council has confirmed that the site for the proposed designation is off the navigational channel, and although small rowing boats start from this point, and slowly move to the navigational channel, they do not see this as an issue.
Many responses that supported designation included comments about the possible positive effect of increasing visitor numbers to Oxford and stated that designation would be good for the environment.
Some respondents stated that the consultation was not simply a local issue, but part of a wider interest in improving water quality in all rivers, both for the benefit of the environment and so that more people can enjoy the health and recreational benefits of open water swimming. For example, Surfers Against Sewage referred to the increase in the popularity of sports such as stand-up paddle boarding and kayaking, although recreational users such as water sports participants are not included in the survey numbers as the Regulations focus on bathers and the monitoring may not be directly relevant to them as they tend to use a wider area in the water than bathers. A few responses stated that some other European countries have large numbers of bathing waters on rivers.
The National Farmers Union opposed designation on behalf of its members due to being unable to seek view in the small consultation window. Livestock farming is an important activity in the local area and their response emphasised the importance of using evidence on the sources of pollution in the river if the site is designated. Farmers in the area will have already taken action to reduce pollution in the river over recent decades, which is likely to have included a reduction in bacterial pollution, and if shown that local farms are contributing significantly to bacteria levels in the water, more activity should be encouraged in proportion to other sources.
Government response
Wolvercote Mill Stream, on the River Thames at Oxford, will be added to the list of designated bathing waters and monitored with effect from the 2022 bathing season.
The photograph shows the location of the new bathing water site, highlighted in red.
The EA will prepare a bathing water profile and identify a sampling point based on where the greatest number of bathers go into the water. Monitoring will commence in May 2022.
During the bathing season, Oxford City Council will be responsible for providing public information about water quality and potential pollution sources at the bathing water and for taking management measures, usually in the form of providing warning signage as advised by the EA, during pollution incidents. Defra will provide funding towards the cost of information signage. The Regulations do not impose any further requirements on local authorities for the management of bathing waters.
Annex A – List of responding organisations
This list of responding organisations is not exhaustive. Rather, it is based on those that declared their organisation. This may include responses from individuals who are members of specific organisations and therefore does not necessarily reflect that organisation’s views. This list also does not include those that asked their response to be kept confidential or those that did not include the name of the organisation.
Abingdon and Vale Triathlon Club
Abingdon Carbon Cutters
Abingdon Green Gym
Abingdon School
Acer Trust
All Souls College, University of Oxford
Amazon Ltd
BBC
Berks, Bucks and Oxon Wildlife Trust
Berkshire Tri Squad
Bothy Vineyard
British Canoeing
Brrrrrr! Local Outdoor Swimmers Group
Cardiff University
Cattleford Press
Centre for Alternative Technology
Chiltern Rangers
Church of England Continuing
Cicada Online
City Councillor, Carfax and Jericho
Cllr Summertown Ward Oxford City Council
CORT (clean our river Thames)
Cotswold Flyfishers
Cotswold National Landscape
Cotswolds Rivers Trust
CPRE Oxfordshire
Crisis
Cutteslowe Community Association
DBA - The Barge Association
Define Media
DRARA Divinity Road Residents
Earthwatch
#endsewagepollution mid-Thames
ESOWSC
Exscentia
Eynsham Nature Recovery Network
Faculty of Oriental Studies, University of Oxford
Falcon Boat Club
Falcon Rowing and Canoeing Club
Flowersfromthefarm
FWAG SW
Global Reach
Grr-owl
Gsk
Guardian News and Media
Gurdens Gardens
Harwell Campus
Hedgerley Wood Trust
Henley Mermaids
Hereford and South Herefordshire
Humankind
ISIS Canoe Club
Janssen
Jessop and Cook Architects
Kennington River Swimmers
Kingfisher Kayak Club
Labour City Councillor for Hinksey Park Ward
LMC International
Magdalen College
Magdalen College School
Magic Moments with Birds
Medley Sailing Club, Oxford
Middlebury-CMRS
Mile Oak Medical Centre
My Life My Choice
NABO
National Farmers Union
Nature Recovery Network
Nature-based Solutions Initiative
Neighbourhood Forum
NHS
ODB
ORIC - Oxford Rivers Improvement Group
Osney, St Thomas and New Botley Allotments Association + Osney Island Residents Association
OUP Piscatorial Society
Outdoor Swimming Society
Outdoor Swimming Society Thames Group
OX2psychotherapy
Oxford Brookes University
Oxford Canoe & Kayak Club (OCKC)
Oxford City Council
Oxford Consulting Partners
Oxford Flood and Environment Group
Oxford Montessori Schools
Oxford Piscatorial Society
Oxford Rivers Improvement Campaign
Oxford Sailing Club
Oxford Triathlon Club
Oxford University Hospitals
Oxford University Museum of Natural history
Oxfordshire Bluetits
Oxfordshire County Council
Oxfordshire Green Party
P G Kane and Son
Pens of the Earth
Port Meadow Ranger
Primark
Reading Bluetits
Reading University
Real Farming Trust
Rose Hill and Iffley Low Carbon
Scale
Seoxha
South Oxfordshire and Vale of White Horse District Council
St Johns College, Oxford
Summertown Clinic
Surfers Against Sewage
Swim England
Taiko Oxford
Thames 21
The Centre for Sustainable Healthcare
The Partnering Initiative
The Whole Tree Company
University of Cambridge
University of Luxembourg
University of Oxford
University of Warwick
Vanbrugh Press
WASP
Waterways Protection
Watlington Climate Action Group
West Oxford Community Association Trustee and Local Resident
West Oxford Wild Swimmers
Windrush AEC Ltd
Wolvercote Wombles
Wolvervote Commoners’ Committee
Worshipful Company of Water Conservators