SWMI Submissions21st May 2008

SWMI Submissions

• The Water Matters booklet was published on the 22nd June 2007 and there was a consultation period of six months until the 22nd December 2007.

• 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.

Topic No 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

National Submissions

REF Name Organisation (if any)

SWMI_001 Nigel Russell Waterways Ireland

SWMI_002 Dr. Elizabeth Cullen Irish Doctors Environmental Association

SWMI_003 Declan Murphy Fáilte Ireland

SWMI_004 William Symth Irish Concrete Federation

SWMI_005 Siobhán Egan Bird Watch Ireland

SWMI_006 Nathy Gilligan Office of Public Works

SWMI_007 Thomas Ryan Irish Farmers’ Association

SWMI_008 Sinead O’Brien SWAN

SWMI_009 Damian Allen Forest 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

SERBD SubmissionsREF Name Organisation (if any)

SE_SWMI_011 P.J. Jackman Cashel, Golden, Tipperary Anglers Association

SE_SWMI_012 Christopher Finlay Portarlington Anglers Ltd.

SE_SWMI_013 N Eacha  

SE_SWMI_014 Jim Hurley  

SE_SWMI_015 Brian Rickwood  

SE_SWMI_016 Pat Durkin  

SE_SWMI_017 Charles Tweeney  

SE_SWMI_018 John Fitzgerald  

SE_SWMI_019 Eamon Moore An Taisce

SE_SWMI_020 Daniel Norton  

SE_SWMI_021 Susan Crampton  

SE_SWMI_022 Michael Brennan Environmental SPC Member

SE_SWMI_023   South Eastern Network Group

SE_SWMI_024 Marie Power Irish 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