Submission to the Department of the Environment, Community & Local Government on the next round of River Basin Management Planning

WFD SWMI Consultation,
Water Quality Section,
Department of the Environment, Community & Local Government,
Newtown Road,

3rd December, 2015.


RE: Significant Water Management Issues in Ireland – Public Consultation


Dear Sir/Madam,

Thank you for the opportunity to input into the preliminary consultation for the next cycle of River Basin Management Planning in Ireland.

I have read the Significant Water Management Issues in Ireland document in full. It identifies most of the primary issues affecting water quality in Ireland. The introduction of the Integrated Catchment Management Concept is welcome. I support it strongly as the only way by which good water quality management will be achieved. The increased focus on community involvement is long overdue and also very welcome.

However, like so many of our responses to European Directives in Ireland, the document is very strong on identifying targets to be achieved, problems to be tackled and not so strong on the ways in which we in Ireland must change our modus operandi by which to achieve these targets. But we will never hit the environmental targets we set with a “business as usual” approach.


  • Agriculture

One of the aims of Food Harvest 2020 is to increase milk production by 50% now that milk quotas have been abolished. Cork County Council has also spoken positively about the potential the rich grasslands of the county offer for massively increased dairy production. Significant Water Management mentions the difficulty of achieving the Water Framework Directive targets in the context of Food Harvest 2020. It does not dwell on this issue, other than to comment on how research work currently underway will identify better how agriculture impacts on water at a catchment level.

Whilst research is always valuable, we already know how agriculture impacts on water quality, both at the individual stream level and at catchment level. The fact is that to increase the numbers of cows is to increase the volume of slurry produced. It is to increase poaching along riverbanks where cattle get direct access to flowing water. It is to increase the need to intensify grassland management. There is no getting away from this and if we are to attempt Food Harvest 2020 with any cognisance of the Water Framework Directive, Ireland will need to invest heavily in farmer education, slurry treatment and guidelines to protect watercourses from direct access by cattle. It will also be necessary to build centralised biogas plants similar to those in Denmark and Germany for improved management of agricultural slurries. These could offer tremendous potential to rural communities but have never been incentivised in Ireland.

Incentives such as planting of riparian zones and the designation of buffer zones for water source protection are only ever offered to farmers availing of agri-environmental schemes. It is necessary to introduce them across the board. Most farmers are stewards of the countryside. With education and guidance, they will be happy to work towards achieving better water quality. But it is no longer good enough that such agri-related water quality measures are conducted only on farms participating in agri-environmental schemes.


  • Urban Wastewater Treatment Discharges

Irish Water is putting investment into several of the major wastewater treatment schemes without which Ireland continues to fail the requirements of the Urban Wastewater Treatment Directive. The Cork Lower Harbour wastewater treatment plant is a stark example of a long-awaited wastewater treatment scheme which, when delivered, will end the discharge of significant volumes of raw sewerage.

However, the discussion of urban wastewater in the Sustainable Water Management Issues document does not link wastewater with land use policy. I believe this link is critical. We as a country need to carefully examine our policy of one-off house construction. In particular, we need to consider the impact on the environment of disparate house-building in rural areas. Haphazard siting of houses requires installation of a septic tank or biocycle unit. Treatment of wastewater in discrete units in this way is less effective, less efficient and more difficult to monitor than treatment of wastewater in a communal treatment plant. Planning houses in clusters rather than scattered or in a linear form along a country roadside would allow far greater control of domestic wastewater treatment and discharge.

We are also culpable at all planning levels of building on flood plains. Flood plains perform an essential riparian function. Not merely do they allow vast areas onto which a full river can spill. They also soak rainwater running towards a river, filtering sediment and other pollutants from it before it reaches the water. Yet because they have been constructed on, many floodplains in our larger towns are no longer available to perform this essential function. It is critical that the impact of building on floodplains would be acknowledged as being highly retrograde in terms of water quality.


  • Hazardous chemicals

Issue 13 discusses hazardous chemicals, particularly heavy metals and PAHs, in our watercourses. It is essential that endocrine disruptors would also be considered. These insidious chemicals strike at the heart of many of the most fundamental aspects of nature.

It is critical that we examine the source of these chemicals in our discharges to water.

One of the key contributors to hazardous chemicals in the water environment is urban wastewater. When wastewater is treated, much of the hazardous content is captured in the sludge. Irish government policy is for the beneficial use of sewage sludge (biosolids) in agriculture. Although the Code of Best Practice advises for the spreading of sludge at a rate which optimises the trapping of these hazardous compounds in soil, it is an indisputable fact that the sludge to land policy may permit levels of hazardous compounds in our agricultural environment to accumulate. The assimilative capacity of soil is limited and so, ultimately, these compounds will make their way to watercourses.

Ireland’s sludge to land policy was drawn up almost 20 years ago. It is well past time that it was revisited. In 2013, almost 24,000 tonnes of untreated sludge was landspread in Ireland. Septic tank sludges are regularly disposed of by landspreading. Research, technology and the microchemical composition of sewage sludge have all moved on. The Sustainable Water Management Issues document needs to identify this sludge policy as being in need of updating.

The Sustainable Water Management Issues document does not identify the link between industry and hazardous chemicals in our watercourses. Producer responsibility dictates that industry must take cognisance of the ingredients of cosmetics, pharmaceuticals, etc. It is time that Ireland focused on this link with a view to reducing the ongoing build-up of hazardous compounds such as these in our environment generally.


  • Road drainage

Runoff from roads is not mentioned at all in the Sustainable Water Management Issues document. Yet this is a significant source of water pollution. Rainwater running off our impervious urban surfaces contains petrol, oil, heavy metals and PAHs. Fertiliser use on golf courses and residential gardens increases the nutrient load of runoff. Runoff also raises the temperature of smaller water bodies, often with adverse effects on fish life.

Drainage in Ireland typically involves collecting as much stormwater as possible and removing it quickly to avoid flooding. But this approach not just maximises the direct introduction of these pollutants into surface water, it also causes flooding further downstream.

There are many best practice methods by which road drainage and stormwater generally can be more effectively managed. Many local level policy changes can make a real difference. These include incentives towards the installation of green roofs, the development of neighbourhood-constructed wetlands, bioretention systems and infiltration basins.

Sustainable Urban Drainage Systems need to become the norm rather than the exception in Ireland if we are to combat the unsustainable effects of our “collect and dispose” method of stormwater management.


  • Determination and the allocation of resources

The very first issue listed for consideration in the Sustainable Water Management Issues document is affordability. If the starting point towards achieving any targets is what we cannot afford, then we will never achieve those targets.

The hesitancy of the “Can we really do it?” ethos is reflected throughout the document. Thus the document lacks determination, punch and the will to succeed. It is essential that resources are dedicated to achieving compliance with the Water Framework Directive. It is essential that if additional tasks are to be undertaken by local authorities, they would be adequately staffed and financed. It is essential that all community stakeholders buy into achieving Ireland’s targets under the Water Framework Directive.

But equally and perhaps more important is that the same level of buy-in is committed to by both industry and the government. Industry is the source of much of the cyclical and difficult to treat compounds found in Ireland’s rivers and lakes. Policies and strategies of other governmental departments have the potential to significantly impact on achieving the targets of the Water Framework Directive. It is not sufficient to address achieving these targets in an integrated way merely at catchment level. A multi-sectoral, cross-departmental approach is also essential.

Yours faithfully,


Marcia D’Alton, B.E., M.Eng,Sc.,
Independent Member, Cork County Council