Yesterday we published images of yet more spillages at the Merryton/sewage bridge - part of the problem we face with Nairn's sewage infrastructure and contamination that affects the water quality of the river and the beaches.
More images here.
Anyone in Gurnshire interested in these matters may wish to read the information below that has been forwarded to the Gurn by one of our regular readers. It is the text from a note prepared by Nairn Residents Concern group for the recent stakeholders' meeting and submitted/circulated to SEPA, Scottish Water and the Community Councils and local Highland Councillors. The Gurn understands that this paper has been accepted as an agreed framework for future action by the major players in the working group set up to deal with the recent bathing water quality crisis.
Keep yourself informed folks and ask questions of your local representatives - especially the Highland Council ones, you may see a bit more of them between now and the local elections in May. Now for a wee read, have that cuppa or pour that dram...
NAIRN BATHING WATER – SEPA STAKEHOLDER GROUP Notes for meeting, Wed 13 July1. This note is essentially a summary and checklist. with comments and background information as necessary. It reflects local views and concerns regarding some of the key areas which the stakeholder group might usefully address. It follows earlier meetings with officials and others. This document has no formal status. It does not claim to be comprehensive or technically-detailed. It is made available simply as an aid to planning future discussion, decisions and action
Why does the quality of bathing water matter to Nairn? (local impact)
1. Tourism. Beach-related tourism is vital to the town – indeed defines its image and reputation. Seaside recreations, including bathing, sailing and other watersports, and a high-quality natural environment are key elements in Nairn's appeal to visitors. The classification of the water quality at Nairn's Central and East beaches as “poor” (and the considerable publicity and reporting of this) has done immediate and significant damage to the town as a recreational destination. A brand image, once tarnished, takes a very long time to recover. The PR challenge is not so much to disseminate information, rather it is damage-limitation. Re-establishing credibility (especially in view of the apparent disconnect between SEPA classification, Blue Flag awards, and Trip Advisor ratings….) is an important task.
2. Local economy. It follows that tourism is one of the principal drivers of the local economy. The retail sector, the hotel & B&B operators, the caravan park, and other service and amenity providers all rely heavily on the (seasonal) flow of visitors. Any deterioration or questionmark over the quality of the natural environment – especially the beaches, riverside and the water of the Moray Firth - risks leading to a decline in visitor numbers. This directly threatens seasonal employment and potentially the viability of local enterprises (many of them small businesses) already affected by wider economic pressures.
3. Health. The implications for the health of residents and visitors alike of contaminated bathing water, especially by e.coli, i.enterococci and other sewage-related organisms, are too obvious to need spelling out.
4. Future development. The longer-term prospects for the expansion of Nairn, the delivery of more housing, and the promotion of business investment all depend on the adequacy, capacity and effectiveness of the infrastructure – drainage and sewage just as much as water supply, roads, telecommunications and other services. Limited capacity or shortcomings in the drainage and sewage networks and plant become constraints on development (as has already been signalled by the recent SW policy requirement that all the costs of future drainage/sewage provision will have to be met, upfront, by developers).
What needs to be done? (the key objectives)
1. The current debate was triggered primarily by the public reporting of the implementation of a 2006 EU Directive requiring by 2015 the classification – and posting of public warning signs about – bathing water quality…… which in the case of Nairn beaches is defined as “poor”.
2. Meetings in recent weeks/months have focused on the detail of the wording on signs and interpretation of the sampling statistics which determine the classification. This is one of the requirements stipulated in the Directive. But it does nothing to tackle the risks, or causes, of the contamination.
3. The key requirement is rapid action to mitigate, alleviate and prevent unacceptably high levels of contamination in the River Nairn, its outflow into the Firth, and the adjacent beaches.
What is currently proposed? (the draft improvement plans)
9. The draft plans (circulated for the meeting) are described as 'work in progress'. In summary, they identify four strands of SEPA/SW activity undertaken or under way:
• modelling (review of SW map of output), with more modelling as a potential future action;
• sampling (modification/variation in sampling frequency and locations);
• talking (the convening of a stakeholder group);
• signage (review of texts, design, and wording of signs).
1. Given the clearly identifiable objective noted at para 8 above, this is wholly inadequate and misses the point. None of the proposed actions represent specific practical measures on the ground to reduce pollution-risk or bacteria levels. None of the proposals in the drafts are remedial action.
2. The draft plans address the symptoms, not the cause(s). Sampling variations (and “discounting”) are simply ways to manipulate statistical data. Modelling is hypothetical and only as good as the underlying assumptions (and has already been shown to have been inadequate as a predictive tool). Signage has no effect on the levels of pollution: its principal effect – however much explanation is provided and whatever text is used – is to deter. Discussion meetings have value, but only insofar as they enable a two-way dialogue and lead to decisions and outcomes: meetings are a means to an end, not an end in themselves.
What needs to be tackled? (the issues that should be addressed)
12. The following checklist is not in any order of priority or achievability. It identifies a number of issues which an action plan or improvement plan ought sensibly to address, and which merit discussion by stakeholders on the basis of relevant information. Some call for short-term measures. Others may be long-term aspirations. Few are unique to Nairn. But all have a bearing on the task of improving local bathing water quality.
i. High Rainfall and Combined Sewer Outflows (CSOs). Much of the evidence so far confirms that high bacteria counts correlate with periods of high rainfall. It is also a fact that much of Nairn relies on CSOs. As the WHO guidance explains:
Combined sewer and stormwater overflows, which are built into most sewerage systems where the effluent “combines” with rainfall, may present the greater health risk, because water users may be exposed to diluted untreated sewage. Where the sewer does not receive surface water after rainfall, the “uncombined”raw sewage overflows present a direct health risk, contact with which should be avoided.
The best option is to have separate collection systems for sewage and rain/stormwater. Although treatment is an option for combined sewer overflows often the treatment plant cannot cope with the quantity of the sewage, or the effectiveness of the treatment is lowered due to a change in the “quality” of the sewage.
Replacing the existing system with separate systems is clearly a very ambitious, costly and long term aim. But recognition of the shortcomings of CSOs, and action to minimise overflows, has to be a part of an improvement plan.
ii. Human waste v other pollutants. Much recent discussion and official comment has pointed to agriculture and ruminant waste as a source of pollution, particularly in the upstream catchment area. This may be a factor. But SEPA's own bathing water profiles for Nairn's beaches refer to DNA testing and conclude explicitly that “mainly human sources are likely to be contributing to affect bathing water quality” . That being so, it makes no sense to prioritise resources and effort on the agricultural dimension. Given that Nairn is at the mouth of the river with an urban population of some 10,000 while the hinterland (catchment area) is sparsely populated with declining numbers of livestock, it is self-evident that action has to be concentrated on the principal (ie human) sources of faecal pollution. This means an improvement plan should prioritise action to mitigate risk in the location(s) where the greatest problems of wastewater and sewage-management arise.
iii. Condition of ageing network. The network especially in the older parts of Nairn, is old – much dating from the Victorian era. Like bridges, the pipes are no longer fit to carry the increased loads placed on them. Like bridges, they are prone to collapse. This is a nationwide problem. Large-scale replacement (with or without separation) is a long-term goal, and costly. But there is no alternative to the progressive, gradual replacement of ageing pipes, and an improvement plan should outline a strategy and indicative costs for this. Meanwhile the operational problems of silting up, blockages, cracks and collapses underline the crucial importance of regular, consistent surveillance and maintenance, and joined-up action with the local authority (eg over surface runoff, roadside drain-clearing etc) to ensure that the old network is kept as robust and capable as possible.
An improvement plan should spell out the operational maintenance obligations and targets.
iv. Capacity of the network. It has been officially recognised that the Nairn network is already under stress. This has implications for planning for future construction development and for the expansion of the town. It follows on from the age and condition problem: for example, older pipes are generally smaller, and routes and access points have been modified (or blocked up) over the years. An improvement plan ought to include proposals for the expansion of drainage/sewage network capacity with indications of cost and funding sources (eg developer-funded).
v. Effectiveness of WWTW. There seems no major concern over the plant's designated capacity. Recent issues have been technical failures/malfunctions (the 2014 'abnormal event') and the problems of odour. These have reportedly been addressed, which is encouraging. But there is a persistent concern that the WWTW is not always operating at optimum efficiency. It would be useful to see in the improvement plan some indication of the level of reliability of the plant.
vi. Direct discharges at peak times. It is recognised that in certain “emergency” (?) circumstances raw or partially treated sewage is discharged, or overflows, directly into the River Nairn. This is regulated by SEPA through consents/licences. Ideally there should be enough marginal capacity in the system for this never to occur. The frequency, and “acceptable threshold” of authorised discharges, is not widely known. An improvement plan should look at what alternatives there might be to licensed discharges; and what scope there might be to raise the threshold either temporarily (to allow bathing water recovery - a “blitz” measure?) or as a specific and measurable objective to be attained progressively over a period of time.
vii. Unmonitored/authorised discharges. Two particular aspects. The improvement plan should spell out the management and monitoring regime for septic tanks (both urban and rural), the number of which appears not to be known. The other problem, specific to the town, is the discharges of chemical toilets and associated waste from campervans, either into the river or into drains. This threatens the WWTW processes. It is seriously polluting. It is illegal. Since campervans are an inevitable part of the tourism sector and will continue to visit the town, a strategy is required (largely involving the local authority, not the utility companies) to deter the practice, and also to devise acceptable alternative disposal provision (whether public or 'commercial'). Prosecution may be a costly last resort, and it appears sensible for an improvement plan to indicate possible alternative options.
viii. Flooding – especially of Fishertown. The Highland Council is committed to delivering a flood management plan, although the timescale/priority appears to have slipped. The flood risk in certain areas of Nairn has been designated as severe. The configuration of the local CSO network means that flooding is of sewage as well as rain or grey water, so the linkage is obvious. Flood management is a national and regional priority. The debate over the implications of climate change has reinforced the case for “future-proofing”. It is noteworthy that flood alleviation works have already been delivered in Inverness (the Ness), in Forres (the Mosset) and in Elgin (the Lossie) at a cost of many millions. All have similar catchment area characteristics, All have comparable levels of risk. This raises the question – which an improvement plan should address, and stakeholders should have the opportunity to discuss – of the rationale for the absence so far of similar works in Nairn and the case for assigning such work a higher priority.
1. The problems are physical (sewage and waste overflows, bacteria in the water) and presentational (how best to advise and explain water quality within the rules and without detriment to the tourism message). Dealing with them requires sustained effort and attention and a joined-up collaborative approach, accompanied by clear, factual explanations.
2. The solutions require technical expertise (from the agencies), financial resources (from national and regional authorities), and political will. The stakeholder group can, and should, have a role in influencing the priorities for action, exerting pressure for the allocation of resources, and monitoring the process of delivering the necessary improvements.