Transcript Document

SWMI Submissions
21st 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
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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
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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
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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 Submissions
REF
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
SE_SWMI_020
Daniel Norton
SE_SWMI_021
Susan Crampton
SE_SWMI_022
Michael Brennan
SE_SWMI_023
SE_SWMI_024
SE_SWMI_025
An Taisce
Environmental SPC Member
South Eastern Network Group
Marie Power
Irish Wildlife Trust
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
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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
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
Physical Modification
– Update of legislation and planning laws are required
– A comprehensive registration and authorisation is needed to control
the impact
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.
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
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
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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