SWMI Submissions 21 st May 2008

SWMI Submissions The Water Matters booklet was published on the 22 nd June 2007 and there was a consultation period of six months until the 22 nd December A compendium of Public Submissions and Responses to the Water Matters report is being prepared. There were responses received under the nine topic areas in the Water Matters booklet. There were 10 national responses received and 15 SERBD responses received.

TopicNo of Submissions Wastewater and industrial discharges 11 Wastewater from unsewered areas 10 Agriculture 9 Physical Modifications 9 Abstractions 9 Landfills, quarries, mines and contaminated lands 8 Dangerous Substances 8 Climate change 7 Development pressure 7 Public participation 6 Forestry 5 Invasive alien species 5 High quality areas 5 Aquaculture 5 Roads 4 Marine and estuarine issues 3 Water charging 2

National Submissions

REFNameOrganisation (if any) SWMI_001Nigel RussellWaterways Ireland SWMI_002Dr. Elizabeth CullenIrish Doctors Environmental Association SWMI_003Declan MurphyFáilte Ireland SWMI_004William SymthIrish Concrete Federation SWMI_005Siobhán EganBird Watch Ireland SWMI_006Nathy GilliganOffice of Public Works SWMI_007Thomas RyanIrish Farmers’ Association SWMI_008Sinead O’BrienSWAN SWMI_009Damian AllenForest Service SWMI_010 Irish Wildlife Trust

Wastewater and industrial discharges –Lack of Local Authority resources was noted as an issue – A moratorium on development until plants upgraded was suggested –An upgrading of plants to tertiary treatment was suggested –Suggested prohibiting the spreading of sludge from sewage treatment plants Landfills, quarries, mines and contaminated lands –Suggested that timescales for remediation and better planning for mines “end of life” was necessary –Analysis of illegal landfill sites and capping of landfills is required –Suggested that there is a conflict of interest as LA license and are significant customers of quarries

Agriculture –Stated that the Nitrates Regs level is too high in sensitive areas –Suggested that the Land Drainage Act should be reviewed –Enforcement of Nitrates and bye-laws is required –There are too many enforcement bodies and there is a need for an independent enforcement body –Inspection without notice is required –Called for the Farm Improvement Scheme to be reopened –Financial incentives for e.g. rain water harvesting, bio-digestors were suggested Wastewater from unsewered areas –There is a requirement for regulations, licensing and accreditation of installation companies –Called for stricter planning controls –Financial incentives for upgrades/alternative treatments were suggested –Awareness campaigns

Forestry –The positive impacts of forestry were not highlighted –Stated that the issues with forests are not historic as suggested –Requirement for the revision of Forestry Act to remove replanting requirements –EIAs for all afforestation in or near protected areas –Clearfelling restrictions were suggested –Stated that there is an over reliance on conifers Abstractions –The issue of leakage should be addressed –Rainwater harvesting should be encouraged with incentives –Water charging was suggested Physical Modifications –Registration, authorisation and rehabilitation were suggested –Requirement for headwater and floodplain protection –EIAs should be carried out before flood prevention measures –Land Drainage Act to be reviewed

Dangerous Substances –When an IPPC license is suspended or revoked the business must cease to operate and this must be enforced through a straightforward legal process –Details of all licences for use and discharge of dangerous substances should be made easily accessible on-line –Prohibit the use of phosphates in detergents –Awareness Campaign –Synthetic pyrethroid in sheep dip should be suspended or banned –Concern about the addition of fluoride to water supplies Marine and estuarine issues –Felt limited attention was given to pressures on the coastal zone –Queried the support of departments regulating the marine environment to the implementation of the Water Framework Directive Aquaculture –Called for aquaculture to be considered as a national significant water management issue –Expressed concern over the range of impacts of aquaculture

Public participation –Report should include contacts for the Advisory Council –Definition of powers of Advisory Council required –Cooperation between Advisory Councils North and South required –Awareness Campaigns Climate change –Not dealt with adequately in the Water Matters report –Highlighted the potential effects of climate change –Proposed that the draft river basin management plan is climate change ‘proofed ’ Invasive alien species –How will a water body reach good status if an invasive species is present? –Regulation of ornamental plants and animals was suggested

High quality areas –Importance of wetlands was highlighted –Lack of Resources within NPWS was highlighted Water charging –Water Charging for all users was suggested –Inappropriate for farmers to pay for water leakage outside the farm gate Development pressure –Lack of integration of planning –Strong environmental enforcement required

SERBD Submissions

REFNameOrganisation (if any) SE_SWMI_011P.J. JackmanCashel, Golden, Tipperary Anglers Association SE_SWMI_012Christopher FinlayPortarlington Anglers Ltd. SE_SWMI_013N Eacha SE_SWMI_014Jim Hurley SE_SWMI_015Brian Rickwood SE_SWMI_016Pat Durkin SE_SWMI_017Charles Tweeney SE_SWMI_018John Fitzgerald SE_SWMI_019Eamon MooreAn Taisce SE_SWMI_020Daniel Norton SE_SWMI_021Susan Crampton SE_SWMI_022Michael BrennanEnvironmental SPC Member SE_SWMI_023 South Eastern Network Group SE_SWMI_024Marie PowerIrish Wildlife Trust SE_SWMI_025 Burrin Drainage Committee

Wastewater and industrial discharges –Requirement for further investigation into the pressure, alternative techniques –Water Pollution Trading schemes –Charges for wastewater treatment –All new developments should have mandatory sewage treatment prior to receiving planning permission Landfills, Quarries and Contaminated Lands –Should include stricter controls, enforcement and monitoring –Illegal landfills need remediation and restoration –Quarries and mines are users of large quantities of water and are a threat to surface water and aquifers

Agriculture –Requirement for training –Use of buffer zones was suggested as a measure –Enforcement of Nitrates Action Plan Wastewater from unsewered properties –Planning controls need to be tightened –Proper construction and maintenance is required –Licensing and legislation is required with enforcement –Use of alternative technology should be encouraged with guidance –Financial incentives to encourage improvement Forestry –Native Woodland Scheme should be expanded and should be encouraged in all farm schemes –Acidification, nutrient run-off and dangerous substances are the main water quality issues linked to conifer plantations –Legislation is needed to protect the freshwater pearl mussel from bad forestry practice

Physical Modification –Update of legislation and planning laws are required –A comprehensive registration and authorisation is needed to control the impact Dangerous Substances –Awareness raising campaign –Alternative methods should be used for controlling vegetation along rivers –Research is required into the impact of antibiotic consumption on water quality –Stricter regulation of chemicals in use were suggested

Invasive Species –The import and use of exotic plant and animal species should be controlled –Maps drawn up of invasive species –Control of discharging of ballasts in ports –Further survey work is required –Training of council staff on identification and basic handling guidelines should be provided Abstractions –Awareness campaigns –Need for new legislation and licensing system –Licensing/enforcement needs to be adequately resourced –Suggestions were made on: What the application process should involve, items to be considered by licensing agency and license conditions.

High Quality Areas –Completion of Habitats Directive obligations and Natural Heritage Areas designation –Register of Protected Areas to be given to AC, LAs and eNGOs Aquaculture –Aquaculture needs proper up to date scientific assessment –Stricter controls required Climate Change –Climate Change impacts on water quality should get a greater reference than what is in the Water Matters booklet Education and publicity –Need for more publicity –Higher visibility and regular updates

General Recommendations –EPA monitoring should be accessible to the public –Need for more monitoring and enforcement –Bring Merchant Shipping Act under Habitats Directive –Tourism and recreational value should be taken into account when prioritisation of water quality improvements works within the RBD Planning and development –Zoning should involve a study to be carried out to ensure that existing wastewater treatment plants are adequate to carry such development –Suggested that an overhaul of the planning process is necessary Roads –Road runoff should have proper inceptors. Maintenance and inspection should be carried out regularly –Suggested monitoring of watercourses adjacent to roads

SWMI Responses The National and Local responses are being prepared by the POMS studies for the POMS specific submissions and the RBD teams The preparation of the responses is being coordinated by the Public Participation Working Group.

Thank you