A quick note from Save Windermere

Our blogs are deliberately detailed to provide you with comprehensive insights into the complexities of our freshwater crisis, in the hope that you can form your own interpretations, make informed decisions/opinions about the issues affecting our lake and then become an advocate for change. We appreciate this makes them quite long, but we aim to present all available information as we receive it and without filters, as opposed to the relative opacity of the Environment Agency and the water industry. We have provided a summary of the key takeaways below in the Executive Summary, but we highly recommend reading the entire analysis to gain the fullest insights. If you enjoy our blogs, you can sign up to our newsletter here.

Executive Summary

Far Sawrey Wastewater Treatment Works (WwTW) has been a focal point for Save Windermere for over 2 years, driven by three key factors:

Visual Impact on Wilfin Beck: Very early on in the campaign, we observed that the site was having an adverse impact on the freshwater ecology of Wilfin Beck.
Our second ever EIR Request: Far Sawrey is where we first initiated the investigative arm of the campaign, using the Environmental Information Regulation to obtain data and information to help us understand the impact United Utilities is having on Windermere. In this instance, we obtained the site's permit, which was the beginning of this investigation into Far Sawrey.
State of Disrepair: Initially, despite our early naivety regarding the proper functioning of sewage treatment works, the site appeared decrepit, primitive and inadequately maintained, prompting us to ramp up our investigation to understand more about what was going on.

The following report outlines the findings of our extensive investigation into Far Sawrey WwTW. Save Windermere asserts that the site is fundamentally not fit for purpose due to the limited sewage treatment technology and the impact it is having on Wilfin Beck.

We have quantified the substantial, chronic adverse impact that the site is having on the freshwater ecology of Wilfin Beck, with our annual invertebrate data in 2023 reflecting an average 75% reduction in species abundance from above to below the sewage works. In October of 2023, above United Utilities sewage input, we identified 27 different invertebrate species with 228 individual insects collected. Below the sewage works, there was just one species and two individuals, representing a 99% reduction in species abundance and a 96% reduction in species diversity in that survey.

This, we believe, demonstrates that the site is not necessarily compliant with its descriptive permit as the permit states that “as far as reasonably practicable, the works shall be operated so as to prevent: i) Any matter being present in the effluent which will cause the receiving water to be poisonous or injurious to fish or to their spawn, or spawning grounds or food, or otherwise cause damage to the ecology of the receiving water; and ii) the treated effluent from having any other adverse environmental impact.” Not only is the permit from 1989, but we believe due to the sites remote and rural nature, it hasn’t been able operate at a standard that would protect the freshwater ecology. The interventions that United Utilities (UU) has implemented at the site are not reflective of best practices. As a key example of this, instead of installing telemetry alarms to make quick and effective operational interventions, they have instead installed CCTV cameras that are directed at the equipment and outfall which provide limited insights into what the site is doing.

We also believe that the Environment Agency's monitoring of the site is wholly inadequate. There was a gap of nearly a decade where the Agency did not visit the site, their monitoring is insufficient to conclusively determine the impact on the freshwater ecology of Wilfin Beck, and the permit for the site is over 30 years out of date. Once again the EA has failed here.

The treatment process appears to have remained in a near state of stagnation, seemingly unchanged for 40 years. We have evidenced this by a report written in 1978 which describes the treatment process as being exactly the same as it is today. We also expose operational inefficiencies attributable to the site's age, along with inadequate maintenance and neglect.

We hope you will be able to take away 2 key points from this report:

1) Due to the campaigns vocal and persistent pressure, United utilities has implemented operational and structural interventions at the site, albeit incomplete and patchy, that will have actively reduced the environmental impact of the site on Wilfin Beck. It’s important to note that since we began heavily scrutinising the site, the examples of operational issues have become less frequent as UU has been visiting the site more often, however we have not seen any investment that would stop these issues reoccurring if we were to stop campaigning.

2) This site epitomises our long-standing call for complete removal. These rural sites are difficult to maintain, challenging to operate, require unsustainable costs, and continue to contribute to the environmental issues Windermere faces. However, consolidating these sites into larger treatment works with better technology, located away from Windermere, will secure Windermere’s ecology for the nation, now and forever.

This report is the culmination of years of work, including our own desktop investigation, active on-the-ground sampling, and regular site visits to document operational and maintenance shortcomings. Please enjoy it.

Far Sawrey Wastewater Treatment Works

Far Sawrey WwTW is a small rural treatment works, positioned along the western shoreline of Windermere. This unassuming plant handles the wastewater of the local community in Far Sawrey and visitors to the area, discharging into the tributary, Wilfin Beck, which flows for an additional half a mile before entering the South basin of Windermere. This area holds significant national cultural importance, as Hardwicke Rawnsley, one of the three founders of the National Trust, was once vicar at St Margaret’s Church, which is located in the area served by this site. It is also the parish where Beatrix Potter lived and wrote her beloved children’s stories.

*Location of Far Sawrey WwTW in the Windermere catchment*

Far Sawrey WwTW is the least sophisticated treatment plant owned and operated by United Utilities in the Windermere catchment. Far Sawrey is a ‘treat all flows’ system. It’s very basic. Firstly, there is a twin primary settlement tank with each tank being separated into two by a baffle. The next stage of treatment comes via a self-perpetuating rotation arm which disperses the effluent, following settlement in the primary tanks, over a percolating filter bed. Finally, effluent makes its way to a humus tank, essentially a final settlement tank, before discharging directly into Wilfin Beck.

That’s sewage treatment at Far Sawrey. The site has no electricity, no flow monitoring or inlet works; it essentially runs itself, but requires regular operator maintenance and intervention to ensure that the site remains functional.

Treatment at Far Sawrey WwTW is primitive; however, so is the environmental permit for the site which, as we are about to demonstrate, we deem to be wholly inadequate.

The site’s permit is descriptive (rather than numerical), which means there are no set discharge limits for the water company to comply with. This also means that discharge concentrations and volumes go unmonitored and do not have to be reported to the Environment Agency (EA). A descriptive permit is supposed to “limit the impact of the discharge on the receiving water,” whatever that means. If that’s not concerning enough, the Far Sawrey WwTW environmental permit was granted right at the start of privatisation in 1989 and has remained unchanged since. The Agency has been aware of the age of the permit for at least a decade, yet remains adamant that the permit is appropriate as “it includes conditions which are similar to those that are found in more recent permits”, despite Windermere’s national significance.

*Far Sawrey WwTW Environmental Permit dated 1989 and made out to The North West Water Authority*

Despite the absence of regular updates to the Agency regarding activities at the site, the EA did not visit the site to complete a compliance assessment for almost a decade between 2014 and 2022. The Compliance Assessment Reporting (CAR) process is typically employed to “notify operators of all permit condition breaches, their Compliance Classification Scheme (CCS) score, what actions are [being] considered, and any observations made during site inspections.” In essence, it serves as a measure of how effectively the site is operating and being maintained.

We challenge the beliefs of the Agency and are adamant that both the permit and the site itself are inadequate to safeguard Wilfin Beck. This, once again, reflects enormous regulatory oversight by the Agency and reaffirms our assertion that the EA has failed and continues to fail to protect Windermere.

Site Operations, Infrastructure and Maintenance

Treatment processes unchanged since 1978?

One of the fascinating aspects of Windermere and its surrounding rivers is the wealth of historic data available, stemming from its status as "one of the most studied lakes on the planet." This historical information occasionally unveils insights into what has or hasn't changed in the Windermere catchment area over time. Data retrieved from the paper "Spatial variation in epilithic algae in a stony stream (Wilfin Beck) with particular reference to Cocconeis placentula" [Source] not only sheds light on effluent quality from the site four decades ago (more on that later), but also indicates that sewage treatment at Far Sawrey in 1978 was conducted using the exact same process employed today. In the report, Far Sawrey is described as “consisted[ing] of primary settling tanks, a trickling filter and a final settling tank. The effluent discharged directly into Wilfin Beck”. The site still treats sewage in the same way despite the significant increase in visitor numbers to the area over the past 40 years, significant improvements in sewage treatment technology and the added strain of a rapidly changing climate. One would hope that the infrastructure has undergone some improvements in the intervening years, but unfortunately, this remains uncertain.

Structural integrity of the site appears poor

In more recent times, a 2013 Windermere catchment study conducted by United Utilities revealed that the trickling filter bed, when assessed for its structural integrity, was only in average condition.

*2013 Windermere catchment study showing trickling filter bed in average condition*

Despite this assessment, no further investment was made to address the issue at the site. When the site was next assessed by the EA, almost a decade later during their September 2022 compliance assessment report (CAR), they then determined that the site's infrastructure was in sound condition. The discrepancy between these assessments raises doubts about the EA's evaluation not only at Far Sawrey, but also elsewhere, particularly considering the absence of structural improvements made to the site from 2014 to 2022. While the site may have appeared visually sound, the absence of scrutiny from an engineering perspective calls into question its true structural integrity.

In the summer of 2023 (just 11 months after the EA completed it’s CAR), an ITV news segment featured evidence provided by Save Windermere which revealed sewage visibly seeping through the cement of Far Sawrey Wastewater Treatment Works' primary settlement tank. Following this revelation, United Utilities applied a cement render to the tank and filter bed, indicating, what we are interpreting as a real concern over potential structural issues. This suggests a likelihood that sewage had escaped through cracks in the primary settlement tank and filter bed due to the site's poor structural condition and again, calls into question the EA’s assessment. Save Windermere contends that the site is in need of substantial investment and should be connected to a larger site.

Insufficient site maintenance / site inadequacies

Not only is the site's current infrastructure inadequate, but we also believe it is not being maintained sufficiently. Below, we present several observed examples. It's important to note that issues at the site will not solely result from insufficient maintenance; rather, it could be that the site requires significantly more intervention to ensure effective functioning. However, if this is the case, such a system would be unsustainable and likely costly. Consolidating several sites would reduce the need for intervention, especially if the site were newer.

Our concerns with the site stemmed from numerous instances in which we documented poorly treated sewage and clumps of sewage fungus coming directly from this outfall pipe. Issues within the treatment process likely stem from several points, but typically begin with the primary settlement tank (PST). The PST may be ineffective due to the exclusion of screening, high volumes running through the site, or inadequate maintenance by desludging to prevent carryover. This often results in a high level of solids passing through the PST, leading to complications in subsequent steps and ultimately less effective treatment, along with high suspended solids in the final effluent, as we have observed.

Evidence of operational and maintenance issues at Far Sawrey WwTW

During wet weather, the site seems to experience significant pressure due to infiltration in the network or a combined sewer system, both of which are symptomatic of a lack of investment in the wider network. Rainfall rapidly increases the flow at the site, and since it operates as a 'treat all flows' operation, the 'storm overflow' element that would normally relieve this pressure is instead forced through the system. As observed, this surge in volume often pushes solids through from the PST, overwhelming the flywheel/filter bed and reducing its functionality. This results in uneven distribution of effluent, potentially accelerating sewage passage through the filter bed and increasing the volumes reaching Wilfin. Within the filter bed lies the biological treatment of the site, where less time translates to fewer opportunities for nutrient absorption by bacteria, or conversely, high flow washes out this biological treatment.

Further issues arising within the treatment process can be demonstrated in the following examples seen in the above video. We have been advised on the significance of these issues by those within the industry:

Blockage on the way to the filter arm due to inadequate screening/hydraulic capacity issues
Filter bed medium covered by sludge carry-over from the PST and subsequent 'ponding', leading to uneven treatment standards – likely due to excessive flows hindering settlement of suspended solids
Even in low flow, issues persist, such as the seized flywheel, which disrupts effluent dispersion across the filter bed, resulting in high biochemical oxygen demand and ammonia in the final effluent. While the cause of the flywheel seizing remains unknown, implementing remote monitoring could enhance site maintenance effectiveness.

This final point raises the next issue that Save Windermere has with the site, and that is the lack of monitoring.

Withholding of Data and Lack of Monitoring

Withholding of Data

The absence of monitoring and transparency regarding United Utilities’ operations presents one of the most significant hurdles in fully uncovering the extent of the harm inflicted upon Windermere and its surrounding rivers. Accessing maintenance records hinges on UU’s compliance with EIR legislation.

Determining the scope of work conducted at Far Sawrey and the frequency of site maintenance proves challenging, as data is continuously withheld. In a 2013 report, UU disclosed that the settlement tanks at the site are emptied every six weeks. However, in August 2022 when a request was submitted for all maintenance documents pertaining to Far Sawrey over the past decade, along with future maintenance plans for the next five years, UU declined to provide the information. They cited that maintenance records do not constitute "environmental information" under Regulation 2(1) of the EIR legislation.

EIR legislation explicitly encompasses measures affecting the environment, including administrative actions and activities aimed at protecting environmental elements. Thus, withholding maintenance data seemed unjustifiable, especially since the environmental permit for Far Sawrey specifies the site's maintenance requirements. This includes the frequency of sludge removal, which directly impacts the amount of suspended solids released into the environment, highlighting the environmental relevance of maintenance practices.

Following a year of work by Save Windermere, during which we challenged UU’s lack of transparency—culminating in the Information Commissioner (ICO) imposing a special enforcement measure on them—we have finally obtained data on tanker operations from the site. The data shows that, prior to our scrutiny of the Far Sawrey operation and raising the issue on the national stage, UU was emptying the tanks as little as seven times in 2020, 11 times in 2021, and eight times in 2022. However, in 2023, following our pressure, this increased to at least 25. A significant increase, don’t you think? We’re still trying to figure out what prompted that change…

Although we've observed inadequate maintenance at the site, questions remain regarding the promptness of issue resolution. Upon the escalation of pollution incidents from the site, UU responded by installing three CCTV cameras. One camera is directed at the humus tank, one is pointing at the filter bed and the other is directed at the outfall. These cameras offer limited insight into the substances entering the environment or operational issue.

Lack of Monitoring

Not only is the withholding of data a significant concern, but the failure to collect comprehensive data at the Far Sawrey site is equally troubling. The responsibility for this oversight primarily rests with the EA, tasked with regulating discharge permits for UU assets, which determines the requisite data collection by the water company.

*Far Sawrey Flow & Performance Data from 2013 Windermere Catchment Study*

Remarkably, historical data from 1978 sheds more light on effluent discharge from the site than present-day records. Samples from the outfall of the sewage works in 1978 indicated effluent concentrations, revealing an average of "1 mg/l soluble reactive phosphorus, 1.2 mg/l NH4-N (ammonia), and 8 mg/l N03-N (nitrate)." [Source] In comparison, data from the 2013 Windermere report, albeit from a limited dataset, suggests that modern average concentrations of phosphorus and ammonia from the site are double those of 1978 under what seems to be the exact same treatment process. The recorded peak of 11.3 mg/l of ammonia at the site is most concerning, with significant implications for the ecological health of Wilfin Beck. Our analysis of Near Sawrey Wastewater Treatment Works illustrates the detrimental effects of elevated ammonia levels on freshwater ecosystems. We believe that these heightened readings may coincide with periods of increased tourist activity, typically during the summer months, amplifying ecological strain on the receiving watercourse.

Further to this, a spot sample taken by the Agency on September 14, 2022 indicates nearly six times the ammonia levels and twice the phosphate levels recorded on average in 1978.

“A sample was taken of the final effluent which returned results of BOD 6.4 mg/l, suspended solids 15 mg/l, COD 41 mg/l, Ammonia 6.5 mg/l, soluble reactive phosphate 2.2 mg/l.”

It’s important to note that this 2022 spot sample is just one sample, which was also not taken during peak summer loading, so it is safe say that this may not reflect treatment levels year round and that concentrations could be much higher in the summer months and likely much lower when flow through the site increases with rainfall.

Documentation over the past decade reveals mounting pressure on the site. In 2012-2013, UU reported that the site was treating 65 individuals during peak summer tourism loading. This surged to 177 in 2020 and 159 in 2023. This illustrates that the site is now coping with double the visitor loading in the summer, a decade after the average recorded concentrations were collected from the site by UU.

While the permit ostensibly represents treatment for a population equivalent (PE) of 250, the transient nature of tourism establishments like restaurants and pubs in the area casts doubt on the appropriateness and accuracy of this figure especially with the lack of regular monitoring of biochemical oxygen demand (BOD). Moreover, scepticism arises regarding the determination of treatment capacity for 2023, resulting from a broader lack of transparency within the water industry. Whilst we can only rely on the information we have been provided, if we were operating a water company, we wouldn’t be rushing to say that our site was treating more people than was stipulated in the permit, as this would results in a breach of permit, a fine and most likely require us to replace the asset, but this is just speculation…

Turning to Windrush Against Sewage Pollution (WASP), our esteemed partners specialising in regulatory scrutiny, a pointed inquiry to the EA unveiled troubling revelations. The EA confirmed that the site operates under a 'Descriptive Consent,' devoid of numeric limits, with the sole stipulation that the works must operate without causing adverse environmental impacts. Despite this assurance, evidence indicates that the site is indeed negatively impacting the freshwater ecology of Wilfin Beck.

WASP EIR Request: “Assuming the permit from 1989, now 34 years old and presumably not well-suited to current conditions at the site, is, in the opinion of the EA, the one that the operator should be following, could you confirm that there are no hydraulic limits such as DWF or emission limits such as BOD, S/S, Am, or P that the works is subject to, and the only operational numerical condition within the permit is that the works operate serving a PE of under 250?”
EA Response: “This is correct; it is known as a ‘Descriptive Consent.’ A descriptive consent does not have any numeric limits. In summary, it requires that the works should be operated and maintained properly, and that there should be no adverse environmental impact on the receiving water.”

Severe, Adverse Ecological Impact & Insufficient Regulation

After numerous observations of sewage fungus accumulation and inadequately treated effluent discharge from the outfall, Save Windermere partnered with WildFish to undertake an in-depth survey of invertebrate species. The objective was to quantify the detrimental impact of Far Sawrey WwTW on the freshwater ecology of Wilfin Beck. This monitoring is still ongoing, with data sets being updated year on year.

The initial survey, conducted on August 1, 2022, revealed alarming findings: a 61% decrease in riverfly species diversity and an 88% decline in riverfly abundance from above to below the sewage pipe on Wilfin Beck. Attempting to corroborate these results, Save Windermere sought data from the Environment Agency's (EA) catchment explorer platform, which is intended to host and disseminate EA data to the public. Surprisingly, there was no data available for Wilfin Beck on the platform, suggesting that our invertebrate survey may be the first publicly accessible study assessing the impact of Far Sawrey WwTW on the river ever completed.

Upon presenting this independent survey to the EA, alongside documented pollution incidents reported on social media and filed with the Agency, the EA conducted their inaugural invertebrate survey at Far Sawrey WwTW in February 2023. Subsequently, we submitted a formal request under the Environmental Information Regulations for the invertebrate data collected as part of the Far Sawrey STW Compliance Assessment Report (CAR) S/0749224. The EA provided us with the requested spreadsheet, which is attached here for reference.

Upon analysing the provided data, we argue that the EA’s study and dataset is not sufficient to truly determine the impact of the sewage works on the health of the river. This insufficiency stems from the focus being at a coarser taxonomic resolution, i.e., family/genus as opposed to species level, which does not enable comprehensive assessment of river health and biodiversity. For instance, the EA identified one group of mayfly down to the family level (Baetidae). But within this family, the large dark olive (Baetis rhodani) is a species more tolerant of organic pollution than the iron blue (Baetis muticus), two of the species found in the Wilfin Beck SmartRivers survey. Therefore, when analysing their data, the EA cannot determine what any changes to this families' abundance means at a species level and thus gives less information as to the pollution pressure. Therefore, the EA data is missing key information on the impact of the sewage works on invertebrate communities, rendering the analysis insufficient to assess the true impact of Far Sawrey WwWT on Wilfin Beck. Another concern with this data is how it was analysed — ‘live sorted’ on the riverbank, making it more challenging to assess species present due to on-site work with live animals. In contrast, the data collected as part of the SmartRivers project was taken away and analysed in a laboratory under microscopes by an independent expert.

Having identified flaws in how the EA conducted their sampling on Wilfin, we undertook two additional river samplings and compiled an annual report on the impact of Far Sawrey WwTW on Wilfin Beck. The annual average abundance reduction from above to below the site reflects a 75% decrease in invertebrates. However, the most recent results are the most startling. In the Autumn of 2023, above United Utilities sewage input, 27 different invertebrate species were identified, with an abundance of 228 individual insects. Below the sewage works, there was just one species and two individuals, representing a 99% reduction in species abundance and a 96% reduction in species diversity. The Environment Agency refuses to put into writing if it has any concerns with our results despite us asking on several occasions.

*Save Windermere and WildFish SmartRivers Data for Wilfin Beck showing significant reductions in abundance and diversity of invertebrates below the WwTW*

One potential explanation for the most recent results could be the incredibly wet summer we saw in 2023. The most pressure on infrastructure occurs during the school summer holidays. As stated above, increased pressure and rainfall could have led to what we observed in the data due to increased flow combined with a higher concentration of effluent. However, we do need more data to be sure.

So, what does this sampling confirm for us? First, the EA monitoring at this site to assess the impact of United Utilities on the river is inadequate. Second, the United Utilities sewage works is indeed having a severe, adverse impact on the freshwater ecology of the river.

The permit for the site specifically states, “as far as reasonably practicable, the works shall be operated so as to prevent: i) Any matter being present in the effluent which will cause the receiving water to be poisonous or injurious to fish or to their spawn, or spawning grounds or food, or otherwise cause damage to the ecology of the receiving water; and ii) the treated effluent from having any other adverse environmental impact.”

As such, we contend that this site might be breaching its environmental permit due to the chronic, adverse impact it is having on Wilfin Beck, along with clear evidence of insufficient operational maintenance. Even if Far Sawrey’s permit were brought up to modern descriptive permit conditions, the treatment at the site is evidently not adequate to protect Wilfin Beck and the fish that reside within it.

Environment Agency’s Motivation

The campaign has now extensively documented both the visual and ecological impact of Far Sawrey WwTW on Wilfin Beck. On multiple occasions, we've captured evidence of the site's effects, including the presence of globular masses of sewage fungus in the river, and shared these directly with the EA and through videos on social media. The Environment Agency took notice of one of these videos after it garnered over 400,000 views on X (Twitter). However, their visit to the site, prompted by our evidence, wasn't primarily motivated by ecological concerns or evidence of damage to the environment. Instead, it appears their main concern was the potential reputational damage to the Agency. It's concerning that this took precedence over addressing the ecological issues at hand.

*Compliance assessment report undertaken by the EA following social media post. Reason for visit as noted as ‘Reputational Issues’ as opposed to a concern over environmental impact.*

The BBC Panorama documentary "The Water Pollution Cover-Up" shed light on the troubling practices within the regulatory framework. The documentary revealed that the EA allows water companies like United Utilities to self-report pollution incidents, which are often being misreported and subsequently categorised as not causing ecological harm. Many incidents, which we see as serious, are being reported as category 4 events (i.e. no environmental impact). The number of these incidents is then reported to OFWAT, which assesses whether the water company meets its target. If they do hit these targets, they receive a 'bonus.'

Even when members of the public report pollution incidents, they are asked if they've informed the water company and if they consent to the EA notifying UU on their behalf. This means that in almost all cases, the water company is informed before EA staff arrive at the scene of the incident, and, in most cases, the EA does not even attend pollution incidents, creating a significant loophole that could be exploited.

At Far Sawrey, we have concerns about the frequency of such occurrences and the potential underreporting or non-reporting of pollution incidents resulting from inadequate maintenance practices.

Evidence of pollution on Wilfin Beck from Far Sawrey WwTW

Conclusion – is this site fit for purpose?

In conclusion, Save Windermere firmly asserts that Far Sawrey WwTW is not only unfit for purpose, but that the permit governing its operations is also inadequate. In light of the extensive evidence presented, we call upon the Environment Agency to take decisive action. This should include requesting comprehensive maintenance scheduling for the site, including tanker operations, conducting an immediate review of the permit and requesting UU to assess how they could consolidate this site with a larger, more technologically advanced one. It's crucial to reiterate our earlier point: while the issues we've highlighted are appearing less frequently at the site, there has been no investment to ensure they don't recur if we cease campaigning.

We advocate for the complete overhaul of the regulatory framework governing wastewater treatment in Windermere. Descriptive permits should be replaced with clear numerical standards that must be adhered to, with effluent quality monitored regularly and in real-time. Currently, over 150 privately-owned septic tanks in the catchment adhere to such numerical standards, serving much smaller populations. We believe the same rigorous standards should be applied to Far Sawrey WwTW. Until this is implemented, there is no obligation for United Utilities to actively monitor the site's outputs, leaving us in the dark about its true impact on Windermere. Real-time monitors with publicly available data should be installed to track key parameters such as phosphorus, turbidity, flow and ammonia.

The evidence overwhelmingly indicates that the site is potentially breaching its permit, particularly concerning its impact on the freshwater ecology of Wilfin Beck. To reiterate, the permit explicitly mandates that the works should be operated to prevent any adverse environmental impact, yet the evidence suggests otherwise. The site's treatment capacity appears inadequate to cope with increased rainfall, growing transient populations and the heightened risk of droughts.

Ultimately, it falls upon the regulator to fulfil its duty and enforce the necessary measures to safeguard the environment and they are failing to do so. The time for action is now. The future for Windermere could follow one of two paths: repeating history or going above and beyond to protect it. Once again, we seek inspiration from the achievements at Lake Annecy. The progress made in Annecy, France, demonstrates what is possible for the long-term protection of oligotrophic lakes. The justification for implementing a complete solution for Windermere is best summarised by Dr Paul Louis Servettaz, the founder of the Lake Annecy campaign, who first raised the alarm about Annecy's decline:

“Either we could proceed, as the Department of Bridges and Roads had already suggested, with the total purification of all wastewater before discharge into the lake. A difficult solution, at the very least very incomplete, uncertain, costly and of dubious effectiveness. As the numerous wastewater treatment plants to be set up could only be small, precarious and difficult to monitor and maintain and we would miss the opportunity of a complete solution and the future of the water would remain uncertain. Or we could collect all the wastewater in a sewer encircling the 2 shores of the lake and take it downstream to be treated in one large wastewater treatment plant before being discharged into the river Fier. The cost of construction for both projects was similar, but the security provided by this second project (fewer bigger, stronger, pieces of equipment) meant that it could be operated more cheaply.”

Far Sawrey WwTW Site Review and Ecological Damage on Wilfin Beck