Îʶ¦ÓéÀÖ

The Îʶ¦ÓéÀÖheld a consultation on proposals to designate Lisvane and Llanishen Reservoirs and Swing Bridge, as bathing waters under the Bathing Water Regulations 2013. The consultation ran from 7 January to 17 February 2025.

The consultation asked respondents whether they supported the proposals to designate Lisvane and Llanishen Reservoirs, and Swing Bridge, as designated bathing waters for 2025 and provide reasons/evidence to support their views.

This document provides a summary of responses to the consultation and shows how the Îʶ¦ÓéÀÖis responding to them. It does not offer an opinion on individual comments. 

The objective of designating a site as a bathing water is to protect bathers’ health against Escherichia coli (E. coli) and Enterococci pollution and provide information to the public to enable bathers to make informed decisions about where and when they bathe.

This document is for information only.

Large print, Braille and alternative language versions of this document are available on request.

Water Branch
Îʶ¦ÓéÀÖ Government
Cathays Park
Cardiff
CF10 3NQ

Email: water@gov.wales

This summary of responses and copies of all the consultation documentation are published in electronic form only and can be accessed on the Îʶ¦ÓéÀÖ Government’s website.

Link to the consultation documentation: /bathing-water-review-wales-2025 

This document provides a summary of the responses received during the Îʶ¦ÓéÀÖ Government’s consultation on the proposed designation of Lisvane and Llanishen Reservoirs and Swing Bridge, and public perspectives on defining a threshold for a ‘large’ number of bathers. It also outlines the Îʶ¦ÓéÀÖ Government’s response and the next steps following the consultation.

The consultation sought public and stakeholder views on whether these locations should be designated as bathing waters for the 2025 bathing season (between 15 May – 30 September).

Respondents were asked whether they agreed, disagreed, or had no opinion with the proposed designations and were encouraged to provide reasoning for their views. Additionally the consultation invited feedback on what constitutes a ‘large’ number of bathers at site across Wales.

The consultation received 152 responses. Of these, 148 were received via the online portal and a further 4 responses were received directly via email. Participants could respond about a single site or both sites. They were not required to answer every question and could select those most relevant to their site, ensuring their input remained focused and meaningful to the consultation.

*A full list of responding organisations is included at Annex A 

A thematic analysis of the responses was undertaken. This categorised the opinions, comments, statements and issues raised by respondents into overarching themes, which included:

• Support for the benefits of promoting bathing and maintaining high water quality standards.
• Emphasis on the health benefits of swimming and spending time in nature.
• Importance of providing safe and accessible areas for swimming.
• Recognition of the mental health benefits of open swimming.
• Acknowledgement that water quality monitoring would give bathers data to make informed choices on when to enter the water.

Lisvane and Llanishen Reservoirs   

The consultation received 26 responses. 23 supported the proposal to designate Lisvane and Llanishen Reservoirs as bathing waters, 1 disagreed, and 2 had no opinion. Supporters highlighted promotional efforts such as social media, website, and local advertising, along with in-person interactions to encourage bathing. Many also appreciated the health benefits of outdoor swimming and the importance of maintaining water quality standards at a popular site. Some emphasised the need for safety measures, such as lifeguards, and protection for local wildlife. 

The Lisvane Community Council supported the proposal with a call for Îʶ¦ÓéÀÖ Water to ensure appropriate safety measures.

One organisation objected, expressing concerns that the proposal commercialises the site and requires payment to use.  

A stakeholder group supported the proposal, stressing the importance of inland bathing waters to provide access for urban communities.

Swing Bridge

The consultation received 139 responses. 123 supported the proposal to designate Swing Bridge as a bathing water, 14 disagreed, and 2 had no opinion. Supporters emphasised the benefits of regular water quality checks, increased safety for bathers, and the reassurance of cleaner water. Many highlighted the health benefits of outdoor swimming and the site’s importance as a community amenity, especially in the absence of alternative swimming facilities. Social media and word of mouth were noted as key promotional factors. 

Respondents raised several concerns opposing the designation. Some challenged the accuracy of the usage figures surveyed, arguing that the number of bathers in the application was exaggerated. Others questioned whether any river in the region is suitable for bathing, citing safety and environmental risks such as flooding, whirlpools, pollution from sewage and animal waste, and the absence of permanent supervision. Additional objections included antisocial behaviour like littering and drug use, the fast-flowing nature of the river, and insufficient nearby facilities.

Environmental concerns focused on the potential decline in fish stocks and agricultural runoff. Concerns were also raised about potential injuries, trespassing on private land on which the site sits, and associated damage to crops and livestock.

View on the impact on Îʶ¦ÓéÀÖ Language

Responses on the potential effects of the proposals on the Îʶ¦ÓéÀÖ language were mixed. Some respondents felt there would be no significant impact, while others suggested that increased use of sites with Îʶ¦ÓéÀÖ language signage could raise awareness and provide more opportunities for Îʶ¦ÓéÀÖ speakers. A few respondents highlighted that promoting bilingual signage and communications would ensure the Îʶ¦ÓéÀÖ language is treated equally to English, fostering social engagement in Îʶ¦ÓéÀÖ-speaking communities.

Other related issues

Additional feedback primarily focused on the Llandeilo site, highlighting concerns about the health of the Tywi River. Respondents raised issues related to climate change, the strain on water treatment facilities, and water quality, suggesting the implementation of regular checks and public signage. Some expressed interest in participating in citizen-based water sampling projects to reduce costs. Environmental concerns included pollution from silage and fertiliser runoff, a decline in fish stocks, and the river's suitability for swimming. While some feared that promoting the area for wild swimming could lead to further harm, others felt these concerns were exaggerated. Several advocated for bilingual signage and safety measures. 

Concerns were expressed about the validity of the consultation at Swing Bridge, noting the potential influence of multiple duplicate submissions as a result of campaigns by stakeholder groups. They highlighted the use of model answers and their potential to impact the diversity of individual responses.

Concerns were also raised about water quality testing at Lisvane and Llanishen Reservoirs, questioning its appropriateness given the site's industrial use. 

A stakeholder group supports the designation of official bathing waters to enhance water quality and public awareness but recommended improvements to the testing regime for the need for year-round water quality monitoring to reflect diverse water users and suggested revising short-term pollution provisions for greater transparency.

Public views on bather numbers

The consultation sought views on defining a threshold for a ‘large’ number of bathers. The responses to questions regarding what constitutes a ‘large’ number of bathers for coastal and inland sites of the course of a peak day showed significant variation. For coastal sites opinions ranged from 0 to as many as 10,000 bathers, with over half of all 150 responses lacking a specific number, and no clear range identified. Similarly, when considering the suitable average number of bathers per day across the entire bathing season at coastal sites, responses ranged from 1 to 100,000, with almost half of the answers not identifying a specific number.
When asked to consider whether people consider a ‘large’ number of bathers to be the same for both coastal and inland sites, the majority answered that they do not expect this number to be the same.  

When considering a ’large’ number of bathers for inland sites responses ranged from 1 to 2,000 bathers. The most popular answer was fewer than 100 bathers for inland sites, although over one third of responses did not specify a number. Similarly, for average number of bathers per day at inland sites, values ranged from 0 to 5,000, with fewer than 100 being the most popular answer and more than a third unable to specify a number.

Whilst responders were asked to specify a number only, some responses contained further detail that suggest that factors beyond just the number of bathers are considered for bathing water designation, including location, access, environmental considerations and the site’s condition. These remain outside the remit of the existing regulations.

When determining the designation of a Bathing Water, the primary consideration under the Bathing Water Regulations 2013 is the expectation of a large number of bathers. We assess evidence of significant current usage, provided by the survey data as part of the application, including swimmers and people paddling. This is validated through public consultation. We also take into account historical trends, available infrastructure or facilities, and any measures taken to promote bathing, as outlined in the Regulations, to assess the likelihood of the expectation of a large number of bathers being maintained or increased in future seasons.

We recognise that some respondents expressed concerns related to issues outside the scope of the Bathing Water Programme and grounds for decision as set out in the Bathing Water Regulations 2013, reflecting broader community concerns about pollutants affecting river health, environmental protection and physical safety management. While these concerns are important, they fall outside the remit of the Bathing Water Regulations and are already addressed through other legislated for mechanisms, which the regulations do not explicitly cover.
The purpose of these Regulations is to ensure water quality safety for bathers, based on the expectation of a ‘large’ number of bathers using the site, irrespective of the ownership or operational model of the site. 

The Bathing Water Regulations 2013 establish the legal duties of Natural Resources Wales, Îʶ¦ÓéÀÖ Government, and local authorities, and focus specifically on water quality and public health in bathing waters. They do not address broader issues.

Lisvane and Llanishen Reservoirs 

Following full consideration of all responses received and information and evidence provided, the Îʶ¦ÓéÀÖ Ministers are satisfied that Lisvane and Llanishen Reservoirs has met the criteria as set out in the Bathing Water Regulations 2013. Therefore the Îʶ¦ÓéÀÖ Ministers have taken the decision to identify Lisvane and Llanishen Reservoirs, Cardiff as a bathing water for the 2025 bathing season.

Swing Bridge

While there is strong support for the designation due to the benefits of water quality monitoring and outdoor swimming, the purpose of these Regulations is to ensure water quality safety for bathers, based on the expectation of a ‘large’ number of bathers using the site. This is the sole criterion for designation under the existing regulations.

Concerns were raised by stakeholders and the public about whether the application accurately reflected the number of bathers using the site. As the core criterion for Îʶ¦ÓéÀÖ Ministers to consider in the regulations is whether there is an expectation of a large number of bathers. Taking into account the evidence submitted by the applicant, in conjunction with the consultation responses, Îʶ¦ÓéÀÖcannot conclude that the regulatory rest has been met. We therefore intend to place this application under review until 31 October, allowing time for further evidence to be provided by the applicant and relevant stakeholders 

Bather numbers 

The consultation revealed a wide range of opinions on what constitutes a 'large' number of bathers, with no single figure emerging as a reliable benchmark. Over half of the respondents were unable to identify a specific number, and suggested thresholds varied significantly. However, there was a clear consensus that inland bathing waters should be expected to have lower numbers of bathers than coastal sites.

The Îʶ¦ÓéÀÖ government will further consider what constitutes a ‘large’ number for future bathing water designations in Wales for inland and coastal sites, and will issue revised guidance in due course.

Next Steps 

Îʶ¦ÓéÀÖ Minister will advise NRW of the decision to identify Lisvane and Llanishen Reservoirs as a designated bathing water from the start of the 2025 bathing season and ask them to prepare a bathing water profile and to keep the profile under review. 

NRW is responsible for monitoring bathing water quality at designated sites in Wales. When a surface water is designated as a bathing water, NRW must produce a detailed bathing water profile and monitoring programme, as it does for all identified sites. Monitoring will begin in May 2025.

Bathing water profiles include a description of the site and surrounding area, any rivers and streams feeding into it, and measures to manage pollution. They also outline compliance with bathing water quality standards and NRW’s collaborative efforts with partners—including water companies, the agricultural sector, and local authorities—to identify and address water quality issues.

During the bathing season local authorities whose jurisdiction the site resides, must ensure that detailed information about the bathing water is available in an easily accessible place in the near vicinity of the bathing water during the bathing season. 

The designation of a bathing water will not amend, alter, or supersede any existing legal protections, obligations, or regulatory requirements. This includes, but is not limited to, all relevant environmental, conservation, and land-use legislation, thereby ensuring that current legal standards, duties, and obligations remain fully in effect. Additionally, any existing responsibilities of private and public individuals, entities, and corporate bodies, as established under applicable law, shall remain unchanged and unaffected by the designation.

Îʶ¦ÓéÀÖwill contact the applicant for Swing Bridge, Llandeilo to discuss the concerns raised around bather numbers.

This list of responding organisations is not exhaustive and 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. Five organisations wished to keep their responses anonymous.

• Waters of Wales Dyfroedd Cymru
• Lisvane Community Council
• Curium Pharma UK Ltd
• Carmarthen Triathlon Club
• Surfers Against Sewage
• Natural Resources Wales
• Dwr Cymru Îʶ¦ÓéÀÖ Water
• National Farmers Union Cymru
• A number of individual responses