Ciarán Cuffe TD GREEN PARTY Dún Laoghaire
|
Ciarán Cuffe TD GREEN PARTY Dún Laoghaire
|
|
|
Policy: Water Cherishing Ireland's Living Waters Green Party Water Policy 2004 Adopted by National Council April 2004
1.0 Introduction: ‘Some for all, forever’ 1.1 Water: Emerging Issues for Ireland and the World Ireland is fortunate to have access to vast amounts of freshwater with our famous salmon rivers and lakes spanning the length and breadth of the island. Our rivers, springs and lakes are a vital source of our individual daily intake of about four litres of freshwater and for industry. Ireland’s waterways also run deep in the popular imagination, informing our culture, identity, history and ritual. There is an echo of the conservation ethic at the heart of the Green Party’s water policy in the local proverb:Ni chronaitear an t-uisce go dtriomaitear an tobar(You don’t miss the water until the well runs dry)The bountiful nature of our water sources, together with our modern tendency to reduce our appreciation of this living substance to a mere chemical formula (H2O), has contributed to a culture of complacency at all levels of administration and among many of the stakeholders who rely on water for domestic or industrial uses. Water has come to be viewed as little more than another disposable ‘commodity’ in our vast circuits of consumption and production; a deeply under-valued commodity at that.Here in Ireland, and throughout the world, water resources and their regenerative capacities have become stressed, due to unsustainable patterns of exploitation, agricultural and industrial pollution, and poor delivery and wastewater treatment infrastructure. Abroad, competition for water resources, in the Middle East for example, lies behind an increasing number of border disputes; and these may be exacerbated by the impact of climate change. Our water policy addresses all the key social, economic, environmental and governance issues.Locally and globally, water issues are demanding urgent attention:Wasted Lives, Wasted Resources– 1.1 billion people have no access to safe drinking water; 2.4 billion people live without adequate sanitation facilities;– In Ireland leakage from water supply systems accounts for as much as 45% of the water in distribution systems in some urban areas. Children’s Health and Water Pollution– Every hour, 450 children below 5 years die due to waterborne diseases in the developing world;– Children are more sensitive and more vulnerable to environmental health hazards than are adults. On a body-weight basis, Irish infants and young children drink more water than adults. Where drinking water is heavily polluted by nitrates infants can be exposed to disease . In an Irish village today, a number of school children cannot drink from the water supply to their school because of lead contamination from water pipes.Water and Conflict– A number of the world’s regional conflicts have a water dimension, arising from contested ownership of resources. The inhabitants of Israel and the Palestinian Territories share their main sources for drinking water, including the Jordan River. Some observers believe that without a sustainable solution for the water conflict, Israel and the Palestinians are heading for a disastrous water crisis in the first quarter of this century . – The North-South Ministerial Council, one of the mechanisms set up under the auspices of the Good Friday Agreement, has overseen cross-border cooperation in the implementation of the European Water Framework Directive. For the purposes of the Directive, Ireland is being treated as a single eco-region. Water basins such as the Shannon and the Foyle will be managed by stakeholders coming together from both sides of the border. Eutrophication: The Dead Zones– Eutrophication arises from industrialised agricultural practices and the use of phosphates in household detergents. The toxic impact of the process and the resulting algal blooms are apparent throughout the world. Agricultural run-off in the United States and carried down to the Gulf of Mexico has led to a massive die-off in ocean species.– Ireland’s Arctic Char, one of the most beautiful members of the salmon and trout family, are very susceptible to water pollution. Eutrophication is upsetting the ecological balance of Ireland's rivers and lakes and many Char populations have now become extinct in areas such as Lough Conn. Famous trout loughs such as Ennell, Inchiquin, and Owel, that once held this ice age relic, are now devoid of Char.Sustainable water policy and joined-up government– At the World Summit on Sustainable Development in South Africa delegates were given a practical example of the importance of joined-up thinking and sustainable development policies have real implications for young girls in the developing world. They were told how the rights of girl-children to education can be undermined by the requirement in many of their communities that they spend many hours each day transporting potable water from distant wells.– In Ireland, investment costs for water infrastructure are climbing, few stakeholders know the true cost of delivering water supplies, and there is little or no encouragement to conserve. The economics of water infrastructure in Ireland are so perverse that one proposal to invest in re-circulation of ‘grey water’ in an education establishment was turned down where correct prices might have shown the investment to be worthwhile. Water conservation and the delivery of quality drinking water will require a new approach across government, supported by clear economic signals that demonstrate the need to conserve and protect our living waters.Wetlands – integration with water management strategy– Wetlands (bogs, swamps, fens, estuaries and tidal flats) form an essential part of the hydrological cycle, storing and purifying fresh water by filtering out or diluting pollutants. In most European countries wetland management is still regarded primarily as a ‘nature conservation’ issue. This leads to missed opportunities for fully exploiting their positive role in water management.– In Ireland the role of wetlands in the water cycle and the functioning of aquatic systems is not recognised in current water management strategies. Nor is there an overall plan or strategy specifically aimed at the conservation of wetlands. Climate change– Climate change is expected to impact on numerous sectors including water. The greatest impacts globally will fall on the poor and those living in remote regions. Indeed climate variability and weather extremes are expected to set back the achievement of the United Nations Millennium Development Goals.– In Ireland, climate change is expected to dramatically alter agricultural production and water availability by the middle of the century. Heaths and peatlands, marine habitats ecosystems and forestry will be affected. The Green Party will deliver a sustainable water policy based on a commitment to restoring and maintaining water quality and the associated ecosystems, notably wetlands. Sustainable water management will be fully integrated into all the relevant policy areas, including spatial and economic development, planning, environmental protection and health. Departments with the responsibility for economic sectors such as agriculture and tourism will take on new responsibilities to ensure that no economic development opportunities are compromised by a failure to protect our natural environmental resources.There will be a step change in policy, with the adoption of a demand management-led approach twinned with support and incentives to encourage conservation and reuse.We shall use the European Water Framework Directive and the local river basin districts as a template for a new participatory approach to decision-making on activities that may impact on water quality and water resources. There will be a new emphasis on capacity building to ensure effective participation by all stakeholders, including environmental NGOs.New resources will also go to the Environmental Protection Agency and the newly formed Office of Environmental Enforcement to ensure that Ireland has access to the latest research on ‘best practice’; and to improve monitoring and enforcement activities throughout the country.The Party will step up Ireland’s commitment to supporting overseas development, including water-related assistance, by honouring our commitment to the UN ODA spending target of 0.7% of GNP. 2.1 Green Party principles The starting point for our approach to freshwater is the Green Party’s set of core principles, which seek to reconcile human development needs with those of the environment and the imperatives of social justice, local decision-making and co-operation: – The impact of society on the environment should not be ecologically disruptive. – Conservation of resources is vital to a sustainable society. – All political, social and economic decisions should be taken at the lowest effective level. – Society should be guided by self-reliance and co-operation at all levels. – As caretakers of the Earth, we have the responsibility to pass it on in a fit and healthy state. – The need for world peace overrides national and commercial interests.– The poverty of two-thirds of the world's family demands a redistribution of the world's resources. 2.2 Access to water is a human right The Green Party upholds the inherent right of all people to water in quantities and of a quality necessary to meet their basic needs. This right should be protected by law. Further, the Party asserts the right to water is satisfied when every person has the physical and economic access to a basic water requirement at all times. Therefore, there can be no circumstances where water-pricing mechanisms lead to the deprivation of a citizen’s right to access to water. The Green Party views privatisation of water services as incompatible with the fundamental right of all citizens to access water to meet their needs. 2.3 Core principles for a sustainable water policy The following core principles inform the Green Party’s approach to the development of a sustainable water policy. 2.3.1 Access to water is a human right The Green Party upholds the inherent right of all people to water in quantities and of a quality necessary to meet their basic needs. This right should be protected by law. 2.3.2 Sustainable Use Sustainable use of water through measures to protect water resources so as to ensure their indefinite availability for human use and environmental services.2.3.3 Equity of Access (locally and globally)Equity of access to: (1) Water services; and (ii) The benefits of water use. Failure to extend the fundamental benefits of hygiene, sanitation and water to all peoples in the world remains a hurdle to sustainable development. 2.3.4 Optimal use of water Optimal use of water to foster wise and efficient use of water by, inter alia, conservation and demand-management measures and incentives, and transparent costs to ensure efficient pricing signals to industry and other stakeholders. 3.0 Policy Frameworks Any recovery in the quality of Irish waters in recent years can be attributed primarily to the impact of European environmental legislation. European legislation has provided citizens’ groups with leverage to bring about limited improvements in some cases. While this is to be welcomed, the Green Party views the need for external legal pressure ultimately as an indictment of our Government and administration. The adoption of European legislation will always be insufficient to guarantee a quality environment in Ireland, in the absence of: (i) political will to enforce legislation and provide adequate capacity building; and (ii) an inherent appreciation within the Government of the need for effective environmental legislation. 3.1 Europe Irish environmental law is derived for the most part from EC Directives . EC water legislation comprises a series of water quality Directives, a Directive controlling industrial emissions (supplemented by a series of daughter Directives dealing with emissions of specific substances), and a new Water Framework Directive that will gradually replace existing measures.A characteristic of Irish implementing legislation is that it implements substantive requirements, but does not mention the objectives of the Directive, so that the latter are not given legal effect. The European Commission initiated proceedings at the European Court of Justice (ECJ) alleging non-compliance by Ireland with regard to a number of Directives on water quality standards e.g. rural water schemes. The Green Party supports: The full and timely implementation and enforcement of European Environmental Directives, with adequate resources provided for capacity-building for Government and local authority officials, the EPA and Office of Environmental Enforcement, and all stakeholders including environmental NGOs. The immediate, full and proper implementation of the Habitats Directive. 3.2 The Water Framework Directive Directive 2000/60/EC is the new Water Framework Directive that will replace many existing Directives over the coming years. The Directive was agreed in September 2000 and came into force on 22 December 2000. The Directive rationalises and updates existing water legislation and provides for water management on the basis of River Basin Districts (RBDs)The core environmental objectives of the WFD are:- Good status of inland surface waters, transitional waters, coastal waters and groundwater by 2015; and- To end the emission of hazardous substances within 20 years.These objectives are underpinned by the following environmental principles (Article 1 WFD):- No deterioration;- Protection and enhancement;- Sustainable water use;- Progressive reduction of pollution.The objectives are to be achieved through a combination of River Basin Management Plans for identified River Basin districts; a transparent approach involving active public participation; and the application of the ‘polluter pays’ principle.Between now and 2009, Seven River Basin Management Plans will be written for Ireland. And by 2015 Ireland is expected to achieve the WFD objective of “good water status”.The main activities for the implementation of the WFD will take place in the context of River Basin Management Projects let by local authorities. The objectives of the WFD are:o To protect and enhance the status of aquatic ecosystems (and terrestrial ecosystems and wetlands directly dependent on aquatic ecosystems);o To promote sustainable water use based on long-term protection of available water resources;o To provide for sufficient supply of good quality surface water and groundwater as need for sustainable, balanced and equitable water use;o To provide for enhanced protection and improvement of the aquatic environment by reducing/phasing out of discharges, emissions and losses of priority substances;o To contribute to mitigating the effects of floods and droughts; o To protect territorial and marine waters; and To establish a register of ‘protected areas’ e.g. areas designated for protection of habitats or species. 3.2.1 Summary of the WFD requirements The WFD sets quality levels for different types of water, and existing water quality must be maintained (particularly where quality is already high), then improved to “good” quality (i.e. only slightly modified from its natural state) by 2015. Member States are required to prevent or limit the input of pollutants to groundwater, ensure that the standstill provision is respected, and protect, enhance and restore all surface and groundwater. There are limited exceptions to deadlines and States must classify waters as polluted in advance to avail themselves of the exceptions. (Doyle 2003)The core obligations of Article 4 are expected to form a body of substantive rules which active citizens can rely on as against the state and against the competent authorities, and which the competent authorities must take into account in the exercise of their functions.The Directive stipulates that there must be proportionate, effective and dissuasive penalties for breach of national implementing regulations. 3.2.2 Cross-border implementation For the purposes of the implementation of the WFD the island of Ireland is to be treated as a single eco-region. The Green Party welcomes proposals that the arrangements for implementation of the WFD in relation to cross-border waters, will be overseen by the North South Ministerial Council, which will ensure that co-ordination on a bilateral basis is pursued at Ministerial level in the North and South. Ministers will be assisted in their task of implementation by a North/South Water Framework Directive Co-ordination Group. The Green Party welcomes plans for the cross-border river basins, and other small adjacent river basins, to be arranged in groups to form three International River Basin Districts. 3.2.3 Problems with the Water Framework Directive There is no legally binding obligation on Member States to improve the current state of their water resources. Points 31 and 32 of the Preamble effectively serve as an opt-out clause if a member State chooses to do so. Point 31 states:In cases where….it may be unfeasible or unreasonably expensive to achieve good status, less stringent environmental objectives may be set on the basis of appropriate, evident and transparent criteria.Key Policy Points: Implementing the WFDThe WFD provides a new and innovative template for a participatory approach to the protection of our water resources and related ecosystems. Significant investment will be required to support effective participation by stakeholders, notably our environmental NGOs. The EPA will also require new resources to effectively monitor and oversee implementation for biological/ecological monitoring; the Central Fisheries Board is also expected to require additional resources. On-going negotiations regarding the interpretation of concepts such as ‘ecological quality’ under the terms of the new Water Framework Directive will potentially support or undermine efforts to maintain standards in Ireland. There is concern that a downward pressure on standards could result from the outcome of the European negotiations, in particular, if negotiations are unsuccessful at the Inter-calibration Committee (where some national negotiators are unwilling to disclose their current national discharge standards). If negotiators are forced to resort to the Article 21 Committee where a more pragmatic approach to the upholding of standards can be expected to dominate deliberations. We expect the Government to instruct our negotiators to resist such downward pressure in negotiations. ooOooThe Green Party supports: The WFD as a template for the development of an integrated and sustainable approach to the use and management of Ireland’s waters and wetlands; A strong commitment to national enforcement and monitoring of implementation of the WFD; Increased resources for River Basin Management Plans and monitoring, and continuous review of the same; The empowerment of River Basin District Committees and other key agencies, together with the provision of adequate resources to enable such agencies to play a full and effective role in the implementation of the WFD; An integrated approach to sustainable management at the River Basin level; Responsibility for ultimate delivery of River Basin Management Plans and ensuring co-ordination between agencies and the setting of targets and time frames for action to lie with River Basin District Committees; The preparation of WFD Plans and Programmes to be conducted with maximum and meaningful public participation, especially with input from interested NGOs; Core funding for NGOs engaging in capacity building work on WFD implementation;NGO representation at national, regional and local fora overseeing WFD implementation and related capacity building and public awareness activities; The integration of the benefits of wetlands into the plans and programmes for WFD delivery; The integration into the WFD’s implementation of clean production initiatives and protection for ecosystems and vulnerable species e.g. Irish Char, through appropriate designations under the Habitats Directive. 3.3 Industrial Emissions & European Directives The Dangerous Substances Directive (76/464) is the principal Directive dealing with industrial pollution of water. It applies to fresh water and to sea waters within the national jurisdiction. Under the Framework Directive, it will continue in force with some amendments until 22 December 2013. Directive 76/464 is implemented to some an extent by the EPA Act.A series of Regulations establishes implementing rules for the various EC Directives. The implementing regulations tend to share one common flaw : whereas the Directives lay down a minimum quality standard which must not be breached, and a target standard of which there can be no new breach, and with which existing polluted areas must endeavour to comply as soon as possible, the Irish regulations lay down only the minimum standard. There is therefore nothing to prevent Irish waters deteriorating to such a state that they breach the target standard, contrary to the provisions of the Directives. 3.4 Phosphorous Regulations Under European environmental law, the implementation of European legislation can not be used to allow any deterioration in environmental quality standards. It has been claimed that Ireland’s Phosphorous Regulations of 1998 are seriously undermining the integrity and purpose of the European directive (1987/659). The authorities are in breach of the spirit and intent of Article 8 of the Directive by applying worsening standards, which allow increased Biological Oxygen Demand (BOD) and Suspended Solid Discharges. The implementation into Irish law of the original Directive by Statutory Instrument 293 of 1998 has been the subject of a complaint as it appears to allow increases in pollution rather than what is required under Article 8: no deterioration permitted. 3.5 Irish Environmental Legislative Reform – The Water Services Bill The Water Services legislation deals with the provision of drinking water and the collection and treatment of waste water, and paved the way in 2004 for the transfer of water services responsibilities of town sanitary authorities to county level as set out in the Local Government Act 2001.The legislation deals only with actual provision of water services and does not seek directly to take on board wider environmental issues surrounding water resources, including pollution, water quality, river basin management etc. Instead the legislation relates to the management of “water in the pipe” from the time, following abstraction, that it fist enters a supply pipe to the point of subsequent discharge to the environment to be treated as waste water. One of the stated objectives of the legislation is to “develop a modern and progressive approach in relation to the sustainable management of water services” , a strengthening of administrative arrangements for planning the delivery of water services at local and national level, and the introduction of a new licensing system and regulatory framework for group water services schemes, to assist their development and address water quality problems. The Minister will have powers to prescribe performance standards and to direct water services authorities to provide specific services. 3.5.1 Overdue Clearly, the Water Services Bill provides the administrative infrastructure to introduce perhaps for the first time strategic decision-making at local and national level in pursuit of sustainable water management. This is a long overdue reform, aimed at creating water service authorities with the necessary powers to tackle water management around the country. 3.5.2 Flaws There are two overall flaws in the bill:1. One of the central aims of the bill is to develop a modern, progressive and sustainable management for water services. However, it specifically excludes taking on board wider environmental issues such as pollution control, water quality. 2. Demand side solutions, targets and mandates for the water services authorities are entirely missing. This unnecessarily wastes hundreds of millions of taxpayers money (see green water policy document). It follows the out-moded engineer-driven approach of focusing exclusively on the supply of fresh water and its treatment.The Bill’s “explanatory and financial memorandum” contains a remarkable admission that “it is not possible at this stage to estimate the overall cost of implementing this bill “. The legislation could become a blank cheque for bureaucrats to set up new administrative structures and pay engineers ever increasing amounts of money to supply and clean ever larger amounts of water, whilst ignoring the impact on river basins, the environment, and national finances. 3.6 National Development Plan 2000-2006 The Government has allocated several billion Euro in capital investment under the National Development Plan 2000-2006 for water services. This spending will go largely towards infrastructure, engineering and ‘technological fixes’.Among the priority infrastructure spending will be significant sums to be spent on wastewater treatment plans. The Government is adopting conventional ‘end-of-pipe’ technology based on the minimum protection afforded under the Urban Wastewater Treatment Directive.This form of treatment can act as a disincentive for elimination of pollution at source and the introduction of clean technologies. Conventional technologies also provide a means for industry to transfer its liability for pollution to local authority run plants. Stringent species conservation measures required by related European legislation are also undermined by low-tech approaches to the wastewater treatment. 3.7 National Water Study The Government commissioned WS Atkins (in association with J. Tobin and McCarthy & Partners) to conduct a National Water Study at a cost of €600,000 in 1998. The scope of the study covered all public water supply schemes outside the Dublin area serving over 5000 consumers (a separate study having been completed for the Dublin area). Responding to the Study, the then Environment Minister, Noel Dempsey, conceded that water conservation measures already in place had delivered results: “These have conclusively proved that water conservation, in addition to the environmental benefits, is a practical, realistic and economic way of meeting much of the extra demand for water. There is no reason why such benefits cannot be enjoyed by communities throughout the country.” The Green Party supports: Comprehensive implementation and adequate funding for the implementation of the recommendations and conclusions in the National Water Study (NWS); Periodic review of the implementation of the NWS recommendations and conclusions, focusing on the impact of implementation; An independent review of the NWS recommendations and conclusions with a view to enhancing the sustainability of solutions e.g. a greater focus on conservation and protecting raw water quality as opposed to inefficient investment in end-of-pipe technologies; Investment in capacity building, training and public awareness. 4.0 Potable Water Green Party policies based on a new conservation ethic can save the Government and tax payers millions of Euros by placing a new onus on efficiency. We are also putting forward proposals to reduce pollution at source, in the home and in industry, because it is more efficient and cheaper in the long run to pre-empt and prevent pollution. Water quality also demands a new and urgent approach to policy, given the potentially serious implications for the health of consumers. 4.1 Water supply – Time to manage demand The Irish Government pursues an out-dated and unsustainable approach to providing water to householders and industry. Too often policies are exclusively focused on increasing water availability only and not on managing and limiting the existing demand. The image of bountiful supplies of water available to the country continues to inform policy thinking, despite talk of drought in Donegal and other areas of the country. What the Government’s approach overlooks is the waste of financial resources that results from a supply-led approach, when demand management and pollution prevention could save the tax payer millions of Euros every year. Essentially there are only 4 ways in which we can meet demand for water. These are;1. Invest in the infrastructure to extract water from the natural environment, to store it, and distribute.2. Use of transfer schemes to extract water from one region to a second region where demand is growing significantly.3. Use or reuse water more effectively.4. Meet the same needs with less water.Irish policy, such as it is, follows the first 2 options above. Planning for water supply and wastewater throughout the country is epitomised in the “Greater Dublin Water Supply Strategic Study”. This focuses on the conventional engineering path of gearing up additional capital resources to meet increasing demand by spending in excess of €571 million Euros of taxpayers money (not including significant additional hidden costs to the environment). The same is true to a lesser extent of the rest of the country.The Green Party is advocating a radical new and cost-effective approach to the supply of potable water based on: i. the effective use and reuse of water; and ii. Doing more with less i.e. meeting existing demand by making more efficient use of existing supplies of water.ooOooThe Green Party supports: Strategies for the reduction of water consumption by managing water demand and improving water use efficiency, instead of simply increasing water availability to meet increasing water needs. Improved enforcement of legislation. Enhanced consumer awareness of the environmental damage caused by water wastage, by teaching simple and effective practices that can reduce water consumption and the provision to water users of financial support and advice to choose and install water-saving systems.- The removal of hidden subsidies on water use.Key Policy Point: Cost effective solutionsThe Green Party can show how demand for water can be met more cost effectively by introducing environmentally-friendly strategies (use and re-use of water; using less water to meet perform established tasks) and adopting modern best-practice environmentally friendly approaches currently working in other countries. 4.1.1 Our strategy to reduce water consumptionHere is a summary of our proposals for simple and cost effective ways to reduce water consumption in Ireland:The water closet: As can be seen from the figures above, the water closet at 35% is the main user of domestic water. Standard w/c technology used in Australia, Sweden, Norway, Denmark and Germany would allow very significant reductions in the order of 66% in the amount of water required for flushing compared with the installed norm in Ireland.The waterless urinal: Commercial companies, public buildings of all kinds and individuals alike can avail of this new technology, completely eliminating the use of water in urinals.Water efficient washing machines: It is therefore feasible to save an average of between one quarter and half of the water consumed by washing machines or up to 6% of overall household consumption by regulating type of washing machine used in Ireland. Recently introduced regulations prohibit the sale of appliances rated less that “C”.The shower: Additionally were existing households to be equipped with low-volume shower heads, the NRA believes that 10% or 3.5 litres per household per day can be saved at a unit cost of 10 pounds per shower. In figures fully later in this study, it can be seen that the Irish Government could avoid capital costs of €5.8 and annual water system costs of >€10 per annum per shower.The Dishwasher: Regulations in the Irish market could ensure that only dish washers meeting the efficiency rating “C” and above are sold, reducing national water consumption by up to 2.5 litres per capita per day.Other Potential Water Savings: Similar approaches are possible with washbasins, kitchen sinks and baths. Nevertheless the 5 areas above demonstrate that substantial water savings can be met with little or no investment, especially in a “new build” situation.Many other simple cost effective approaches are possible. Examples include “Hippo Bags” which cost 13p each and can be inserted into existing WC cisterns. These reduce unnecessary excessive water consumption in older WC’s at a low cost. The Wessex and Thames Water Authorities in the UK estimate that they save 19.4 litres per property per day.The water savings are summarised in this pie chart:
4.1.2 Leaking Water – Losing Cash (National Water Conservation Programme (NWS)) In May 2003, the Government announced the allocation of over €276 million for the first round of a new nation-wide water conservation programme. The programme is designed to identify and substantially reduce the levels of unaccounted for water in Ireland's water supply network.The N.W.S. reckoned that up to 47% of all water produced by the treatment plants in the study is unaccounted for and that in some areas of the country this level of unaccounted for water is much higher. Not all of this water is lost – a good proportion is just not being properly metered and recorded. However, the results of the NWS and the Greater Dublin Water Supply Strategy Study leave little room for doubt that a very significant amount of water is lost into the ground every day. The The Green Party believes that this represents an unsustainable and unacceptable drain on the resources of local authorities and the State and on the environment itself.The earlier schemes offer very strong evidence that water conservation, in addition to the environmental benefits, is a practical, realistic and economic way of meeting much of the extra demand for water. Results from the first 15 schemes show that Unaccounted For Water rates have reduced significantly. For example, in Dublin they reduced from 42.5% to 28.7%; in Donegal from 59% to 39%; in Meath from 47% to 34%; and in Kilkenny from 45% to 29%. Similar reductions in UFW rates will be expected in respect of the local authorities now approved.The Green Party supports the further initiatives announced to address concerns raised by the study: · The development and national application of a Complete Information System for water services. This integrated management information system (being developed on behalf of the Department by Kerry County Council and the Local Government Computer Services Board) will collect comprehensive data across the full range of water services operations. · The commissioning of a national audit/study of Waste Water infrastructure. · Training to FAS standard for 2000 local authority operatives. · Major legislative revisions in the Water Services Bill. 4.1.3 Using Building Control regulations to promote sustainable water measuresThe Building Control Act 1990 includes measures to promote energy efficiency. It is time to introduce building regulations to encourage water conservation, which also leads to reduced energy use and less pollution.Advances in building design and equipment could contribute to a significant reduction in the demand for freshwater resources. The simple step of introducing separate delivery systems for drinking water and water used for other household applications is an essential requirement if we are to halt the current unsustainable practice of squandering freshwater supplies for everything from cleaning to flushing toilets. The use of separation techniques such as dual piping systems ensures that pure water is used for drinking and washing, and reclaimed water is used for lawn watering and similar purposes.The Green Party favours the introduction of new building regulations to facilitate water conservation in domestic and commercial properties, including measures to encourage the adoption of new technologies (e.g. toilets, showers, sinks, automated-building leak detection technology etc). Efficiency technologies already commercially available can in combination double or triple water efficiency, with no loss of service or convenience, even without a change in the source of water, and in the absence of wastewater recovery . 4.1.4 Water Supply Separation The Green Party advocates the use of separation techniques such as dual piping systems in new buildings where pure water is used for drinking and washing. This would help to encourage the use of grey water for uses other than human consumption.4.1.5 Recovering rainwater and greywaterNaturally distilled rainwater falls on buildings, flows off roof surfaces, and is guided into gutters that quickly send the water into sewers to be combined with human and industrial wastes, to be ‘disposed off’ at great expense.Harvesting rainwater remains a standard practice in other countries, such as Hawaii and Bermuda; and in many regions of Australia, rainwater collection systems are mandatory. Regulations could also be used to encourage the capture of “grey water” from showers, sinks, dishwashers, baths, and washing machines. The Californian Plumbing Code now defines how grey water should be controlled to protect public health, keeping it underground and off food crops. Typical recovery and reuse rates average about 50 gallons per house per day, cutting total water use in half, and achieving even greater savings in multifamily and commercial buildings where grey water is used to flush toilets. Many buildings in Salt Lake City deliver brackish water in a separate plumbing system specifically for flushing toilets. There is potential for public amenities e.g. swimming pools, and other high volume users of water to investigate grey water recovery and recycling outlets. The City of Boulder, Colorado, for example, recycles swimming pool water for irrigation. 4.2 Water Quality & Health It took a ruling against the Government by the European Court of Justice (November 2002) to bring about the launch of the Rural Water Programme (€100 million) to address water quality problems in rural areas.Only a step change in existing remedial policy to address water quality standards will succeed in reversing current trends, with their potential consequences for human health. As the ‘Friends of the Irish Environment’ have pointed out, Irish measures to improve water quality are ‘fundamentally misguided’. Successive Governments have allocated massive funding for ‘end of pipe’ solutions based on high cost engineering and damaging chemicals, while the Nitrates Directive remains unenforced and dispersed rural septic tanks continue to proliferate. Pathogens carried by livestock must be prevented from entering streams, lakes, and springs; and buffer areas around sources of drinking water must be created to create a safe distance from livestock. The presence of chemicals in water sources is a concern across Europe. Table 1: Distribution of drinking water in 2001 Group water schemes (GWS) obtain their water from either a public authority supply or from a private source, with or without treatment. Though public supplies distribute greater quantities of water, group water schemes are more numerous, numbering some 5500. Table 2: PWS and GWS Compliance with standards in 2001 (2000 figures in brackets)
The Environment and Energy Management journal has reported that a compliance rate of 94.3% means that 5.7% of tests conducted failed to comply with a standard. This means that over 8000 exceedances were recorded out of a total of 146,352. of these, 4,348 occurred in public water supplies while 3,718 occurred in group water schemes. The remainder occurred in small private supplies. Parameters most frequently exceeded in 2001 were: Total coliforms (Total 3,121; PWS 1,124; GWS 1,793); Faecal coliforms (Total 1,520; PWS 422; GWS 1073); Colour (Total 1031; PWS 503; GWS 518); Odour (Total 771; PWS 588; GWS 180); Iron (Total 606; PWS 324; GWS 258);Ø Manganese (total 594; PWS 259; GWS 315); and Aluminium (Total 585; PWS 547; GWS 37). 4.2.1 Total and Faecal Coliforms – Key Indicator of drinking water quality The performance of group water schemes still lags behind public water schemes and remains unacceptable to the Green Party.On a scheme-by-scheme basis, 720 (79.6%) public water supplies and 1,051 (68.4%) group water schemes monitored were free of faecal contamination in 2001. Conversely, 184 public water supplies and 485 group water schemes exhibited some degree of faecal contamination during 2001. The majority of exceedances were ‘moderate’ in scale. However, there were 373 serious incidents of faecal coliform contamination (i.e. >20/100 ml) reported in group water schemes in 2001.However, it must be assumed that the actual number of group water schemes exhibiting faecal contamination is probably higher than 485 because only 1,536 schemes out of a total estimate of 5,500 schemes were monitored by the EPA in 2001. 4.2.2 Water & Human Health Drinking water can be a source of exposure to a number of potential carcinogens, including metals, agricultural and industrial chemicals, radioactive substances, and byproducts of chemical disinfection. Drinking water sources are vulnerable to contamination by agricultural runoff, chemicals used at home (e.g. phosphates), industrial wastes, and many other sources. Naturally occurring carcinogens, such as arsenic and radon, can contaminate groundwater. In Ireland, the major concern is agricultural run-off e.g. nitrates. Fifty thousand households in Ireland are serviced by private group schemes (group water schemes) and are potentially exposed to ‘unsatisfactory’ levels of water quality.The US group, Physicians for Social Responsibility , has noted limited evidence suggesting that potential increases in cancer risk are associated with the consumption of drinking water contaminated with nitrates and triazine herbicides. Studies have also suggested a link between long-term consumption of chlorinated water and an increased risk of certain cancers, including bladder cancer. 4.2.3 Fluoridation Ninety-eight percent of Europe’s drinking water is free of fluoridation. The Irish Government’s continuing support of fluoridation as a mass exercise in dental health treatment is no longer acceptable. There is sufficient evidence to demonstrate that fluoridation is associated with bone cancer, arthritis, osteoporosis, hip fractures, memory loss, genetic damage, depressed thyroid functioning, immune system damage and damage to infant health.Key Policy Points: Water Quality and health- The Green Party believes that the repeated breaches of drinking water standards poses a significant challenge for the implementation of the Water Services legislation. The Party will monitor the new arrangements closely and continue to draw attention to the threats to human health posed by current practices.- We shall review routine regional and local provision for routine epidemiological and toxicological studies to identify potential links between poor water quality and ‘hot spots’ of ill health.- We are committed to the repeal of the 1960 Water Fluoridation Act and a ban on fluoridation. Green Party TD, John Gormley, has already introduced a Bill in an attempt to bring this about.- The Party is supportive of the European Commission’s new policy for registration, evaluation and authorization of chemicals (REACH) that is expected to take effect in 2004. - We are disappointed at the decision of the European Parliament (January 2004) not to support the European Greens’ call for an immediate phase-out of phosphates in detergents, but welcome the European Commission’s agreement to propose legislation with a view to a ban within three years.- We welcome the decision of the European Parliament’s Environment Committee to phase out the production, trade and use of Persistent Organic Pollutants (21 January 2004) in line with the global Stockholm Convention on POPs.- We support formal documented procedures for public and group water schemes, which form part of an overall documented management and control system, as an integral part of ensuring that any exceedance is addressed.- We are calling for the commissioning of independent research by the EPA and immediate publication of water quality results where contamination above the legal limits is found. The current delays in publication, of up to one year, are unacceptable.- We are calling for continuous independent review of the suitability of river-based drinking water sources (e.g. the River Nore and its tributaries).
Nitrate pollution, leading to eutrophication, is recognised as one of the greatest pollution problems facing the State. The problem of spreading excessive amounts of fertiliser is compounded by the practice of spreading slurry from piggeries and cattle sheds, particularly if done so just before wet weather. Slurry is not regarded as waste if it is added to land. Agriculture is responsible for 60% of phosphorous pollution in our rivers, according to research conducted by the Three Rivers project. There is growing recognition of the need for a radical new programme of water monitoring and enforcement and for nutrient management planning on a river catchment basis. Legislative responses are being driven by European Directives, including the nitrates directive and the WFD.The entire State has been designated a nitrate sensitive area under the EU nitrates directive . 4.3.1 Storage and handling Farmers point to inadequate manure storage and handling facilities in some farms as a root cause of pollution. Run-off from yards is still a significant source of pollution. Generous financial assistance to farmers to improve storage facilities is a sound investment in pollution mitigation. Alternatively, they can be assisted to convert to a straw-based bedding system and to put in reed beds to take care of the yard run-off.ooOooThe Green Party supports: Financial assistance to assist farmers to comply with requirements of the Nitrates Directive; New laws to control the spread of slurry & the use of REPS funding to provide incentives for further reductions in the use of chemical fertilizers; Harsher penalties for failure to respect buffer zones between the slurry spreading and water sources (20 metres from lakes and main river channels; 10 metres from streams). Few local authorities are using nutrient management planning powers available to them under the Water Pollution Act. A few have introduced bye-laws to control agricultural activities. New measures may be required to oblige local authorities to take the threat to water supplies from agricultural pollution more seriously.ooOooKey Policy Points: Agricultural PollutionWe are calling for the phasing-in of a programme for the adoption of Nutrient Management Plans for all farms & the provision of assistance/training to farmers. The programme will commence with the introduction of an obligation for large-scale dairy farms, which are not currently covered by legislation. Farmers must be encouraged to make more efficient use of the nutrient content in slurry by using anaerobic digesters and so reduce their dependence on fertiliser, with potential financial savings and reduced environmental impacts. The Green Party will take steps to introduce and encourage the establishment of waste treatment plants, such as anaerobic digesters, by the most intensive agriculture sectors e.g. piggeries , poultry farms and dairies. Such an obligation already exists for piggeries in the Netherlands. Food waste and dairy sludge should not be injected into the soil but processed through anaerobic digesters first.The introduction of water to the slurry production process to help manage slurry contributes significantly to the dispersal of slurry and to the pollution impact. Reed beds, rather than the slurry tank, should be used to cope with the dairy washings and the run-off from the yard. Only biodegradable cleaners, like citricidal, should be used to clean out the milking equipment. Straw-based bedding should be encouraged as providing a more comfortable environment for the animal as well as a more nutrient rich product. Care must be taken to place manure heaps away from waterways and to cover them. The licensing of piggeries remains a problem for the EPA due to the practice of transferring slurry to lands not adjoining the licensed farm. There is currently no way of knowing where some slurry is being applied. In addition the follow-up to the initial land test (Morgan P Test) for phosphate content is not systematically followed-up to monitor the build up of phosphate in the soil. The licensing of piggeries remains a problem for the EPA due to the practice of transferring slurry to lands not adjoining the licensed farm. There is currently no way of knowing where some slurry is being applied. In addition the follow-up to the initial land test (Morgan P test) for phosphate content is not systematically followed-up to monitor the build up of phosphate in the soil. More monitoring capacity is required to establish the condition of soil. 4.4 Industrial PollutionCleaner Production programmes and not the licensing of chemical pollution emissions into our waterways is our preferred solution to the problem of deteriorating water quality. The UNEP International Declaration on Cleaner Production states :We recognize that achieving sustainable development is a collective responsibility. Action to protect the global environment must include the adoption of improved sustainable production and consumption practices.We believe that Cleaner Production and other preventive strategies such as Eco-efficiency, Green Productivity and Pollution Prevention are preferred options. They require the development, support and implementation of appropriate measures.We understand Cleaner Production to be the continuous application of an integrated, preventive strategy applied to processes, products and services in pursuit of economic, social, health, safety and environmental benefits.We are committed to ensuring that cleaner production principles – the most cost effective and environmentally friendly approach - become the norm throughout industry in Ireland. Cleaner production programmes are consistent with the European Commission’s determination to introduce its REACH programme and radically reduce the threats to human health from chemicals in our environment. In contrast to IBEC and the business lobby, we do not view more stringent regulation of chemicals as a threat to competition but, rather, as an opportunity to embed clean production as a cornerstone of a clean, green competitiveness strategy for Irish-based industry. The green economy is now a billion Euro sector – and growing.Cleaner production programmes promote environmentally friendly business through increased resource productivity, waste reduction, recovery and reuse of materials, improved efficiency in production and energy management. The Green Party wants to see a greater emphasis on cleaner production when regional and local water plans, river basin plans and catchment-based initiatives are being drawn up.ooOooThe Green Party supports: Cleaner production at the centre of policies on industry and water quality and environmental protection. Increased funding for Clean Production. The integration of Clean Production Demonstration Programmes into Catchment-Based Management plans and River Basin Management Systems.ooOoo4.5 Seveso Directive Irish transposition of the European Seveso II Directive on major accident hazards involving dangerous substances must be reviewed in order to ensure full and open consultation with the public. ooOooThe Green Party supports: A review of Ireland’s implementation of the Seveso Directive and a full consultation with the public on future
implementation. The most common type of water pollution in Ireland is organic pollution caused by sewage, animal manure slurries and food processing wastes. As the waste is consumed by organisms of decay, the oxygen in the water is used up and the breakdown products, including phosphorous and nitrogen compounds, are released into the waters. The main effects of organic pollution are the depletion of oxygen in the area immediately below the discharge and eutrophication i.e. enrichment further down stream.Eutrophication, which is also caused by the inappropriate and/or excessive application of organic (slurry) and inorganic (artificial) manure to agricultural and forestry lands, has become very widespread. In the period 1998-2000 it is estimated that approximately one third of the river channel length surveyed was affected to some degree. Toxic pollution is commonly caused by poisons such as sheep dip, mining wastes and industrial discharges. Physical pollution refers to siltation arising from quarrying, bog and forestry development and arterial drainage.Some wastes e.g. sewage and manure slurries, can give rise to all three types of pollution: organic, toxic and physical. 5.1 Water Quality – assessment Rivers, lakes, groundwater, estuarine and costal waters, canals and bathing waters were assessed for the EPA’s and published in 2001 in the EPA water Quality in Ireland 1998-2000 Report. The Report indicates that water quality was satisfactory (Class A) at 59% of surveyed locations, slightly polluted (Class B) at 20% of locations, and seriously polluted (Class D) at 2% of locations. The Report revealed that the length of polluted river channel in the State decreased for the first time since national surveys commenced. This reduction has been attributed to the wider range of catchment management techniques carried out under large catchment management programmes funded by the Department of the Environment and Local Government (DELG). Long-term serious pollution is still to be found in some rivers that were first surveyed in the early 1970s. Similarly, some lakes, estuaries and groundwater bodies are seriously polluted even though the overall picture is quite good by international standards. The European Commission has expressed concerns at the criteria being used by the EPA to determine water quality. Water quality defined as polluted under the EU regulations has been treated as unpolluted or ‘satisfactory’ by the Irish authorities. 5.2 Phosphates The EPA Water Quality in Ireland 1998-2000 report identifies phosphorous as a primary cause of water pollution in the State. Phosphorous sources requiring particular attention include wastewater treatment plants that do not have phosphorous removal facilities or those that are overloaded or poorly operated. Other sources are rural septic tanks and diffuse phosphorous losses from agriculture including both farmyard losses, slurry runoff from fields and phosphorous lost to water from over-fertilised agricultural soils. There is an onus on local authorities to do more to protect and improve local water quality in rivers and lakes throughout the country if targets set by the Phosphorous Regulations and, in the longer term, the Water Framework Directive, are to be met. It remains to be seen how many local authorities will find adequate budgets to prioritise water quality.Problems with the implementation of the Phosphorous Regulations have contributed to a worrying decline in the number of river stations recording the highest biological water quality. The latest information from the EPA’s Office of Environmental Enforcement suggests that one third of all river stations are not in compliance with the targets. The OEE has conceded that meeting targets set by the Regulations will be a “major challenge.” Some 38.2 per cent of river stations monitored for the latest reporting period were found to be non-compliant with the targets set out in the Phosphorous Regulations.Nationally it has been estimated that Irish farms apply a phosphorus surplus of somewhere between 11 and 15kg/ha/year on land that is farmed (Brogan et al., 2001). This means that over the 10 years leading up to 2000, Irish farmers may have applied almost half a million tonnes of phosphorus in excess of requirements.There is a voluntary arrangement with industry to supply phosphate free detergents e.g. around lakesides where septic tank contents threaten to leak into the lake. The Government has shown some resolve in relation to the detergents industry with the introduction of a phosphates phase-out programme. Similar targets can and must be set for all emissions affecting water and public health. The Green Party supports: A ban on the use of phosphates and all phosphate detergents; proper and fair pricing of safe alternatives. The Green Party also calls on consumers to play a role in the protection of our water resources by choosing to buy phosphate-free cleaning products. The Green Party also advocates a ban on the purchase of phosphate-based detergents by public sector procurement agencies and officers. Targets for the reduction and elimination of persistent toxic chemicals and heavy metals into our waterways. 5.3 Wetlands The Worldwide Fund for Nature has noted that Ireland currently has no overall plan or strategy specifically aimed at the conservation of wetlands. Some peatlands are considered for restoration in SAC/SPA management plans at individual sites. Moreover the services provided by wetlands are currently not explicitly stated and valued in national policy. Nor is the role of wetlands in the water cycle and the functioning of aquatic systems is not recognised in current water management strategies.It would appear that the Government continues to confine wetlands to the ‘nature conservation box’, failing to integrate wetlands strategy into water management. This inevitably contributes to uncoordinated action in managing wetlands and missed opportunities for fully capturing their positive role in water management, including flood management and pollution abatement.Key policy points: wetlands- Wetlands are an essential part of the ecosystem that produces and maintains our freshwater resource. Wetlands play a positive role in the achievement of good ecological and chemical status of surface and groundwater. There is a pressing need for an inventory of our wetlands and a national strategy for restoration.- Management of wetlands must be fully integrated into our water management strategies, including river basin management strategies to be pursued under the Water Framework Directive. This will require new capacity-building in the form of awareness raising and financial resources. In 2002, Green Party TD, Trevor Sargent, introduced the Planning and Development (Wetland Habitats) Amendment Bill in an attempt to enhance protection for wetlands in the planning process. 5.4 Groundwater A quarter of all water consumed is taken from groundwater, the other 3 quarters come from surface water. Public water supply may be a problem in rural areas where the density of population is low. This fact leads to regional provisions of piped supplies, which is expensive. The more isolated farmhouses are responsible for their own supply with boreholes and springs. A body of European legislation is beginning to reverse the historically poor regulatory status of groundwater in Europe. The nitrate directive (91/676/EC) converted the existing drinking water standard for nitrate into an environmental standard with significant potential consequences for agriculture. Protection of groundwater is upheld under the provisions of the groundwater Directive 80/68/EEC until 2013 when the provisions required by the WFD should be completed and the provisions of the groundwater Directive will be repealed. ooOooThe Green Party supports: Maximum protection for groundwater In line with the European Commission’s recommendations on implementation of the Nitrate Directive, the Party underlines the importance of measures to address the total groundwater resource affected rather than the protection of individual public water supply sources. Measures must reflect the complexity of groundwater systems. This may require additional resources to introduce aquifier-wide monitoring. In the context of the EC Water Framework Directive the Party advocates the use of ‘source protection zones’ (as opposed to resource protection zones). On validation of protection zones, the Party is calling for rapid introduction of validation methodologies for resource and source protection zones. There may be a need to review current provisions for hazard mapping in Ireland. 5.5 Biodiversity Many wetlands rightfully enjoy the protection of the Ramsar Convention on Wetlands, and the EU Birds and Habitats Directives. The protection of biodiversity and the ecosystems that provide environmental services go hand in hand. The fate of species such as the Arctic Char and Irish salmon , for example, can act as a critical indicator of our impact on water bodies. Measures to protect biodiversity, including relevant European directives, can serve as useful proxies for the protection and maintenance of freshwater resources. This is particularly true in the case of designations and SAC/SPC management plans. Salmon are a listed species in Annex II of the European Habitats Directive and must receive the protection afforded by the designation of Special areas of Conservation. However such designations must include the tributaries of the rivers where salmon spawn. The national biodiversity plan, including a robust consultation and regular review process with NGOs and other stakeholders, can serve an important function in extending protection to ecosystems and species and highlighting the important relationship between their fate and our reliance on clean water. Robust consultation with maximum public participation can serve a critical public education and awareness role, thus helping to fulfil the ultimate objectives of the biodiversity strategy. Designation of certain landscapes servicing our major water supplies, for example as National Parks or for special protection, can augment the protection of water sources. Such a designation would prevent harmful agricultural and forestry activities e.g. the use of polluting herbicidal and pest control practices in upland managed forestry. Large upland areas of the Mourne Mountains have been enclosed since the early 20th century, affording protection of water supplies for Belfast and its environs. 5.6 Climate Change and Water in Ireland A report by the Environmental Protection Agency, Climate Change – Scenarios and Impacts for Ireland, shows that agricultural production and water availability in Ireland will dramatically alter by the middle of the century as a result of climate change. Changes to heaths and peatlands, marine habitats, ecosystems and forestry will also occur.The major impacts of climate change in Ireland are likely to be:o An increase in winter rainfall by 10% which is expected to lead to flooding in the west;o A 40% decrease in summer rainfall will mean droughts which will require farmers to supplement grass for livestock feeding and decrease river, lake and reservoir levels;o A temperature increase in summer of up to 2° C, with typical midland temperatures of up to 24.5° C;o Drier summers will decrease potato yields but may benefit other crops such as grain maize;o A temperature increase of up to 1.5°C in winter; and o A rise in sea levels and more extreme weather events and an increase in sea temperatures, which may negatively impact on salmon farming.Threats to water supplies in the east of Ireland and an increased risk of seasonal flooding, particularly in parts of the west, are just two of the impacts predicted by the EPA report – Climate Change – Scenarios and Impacts for Ireland. Speaking at the launch, Dr Mary Kelly, Director General of the EPA said, “Decisions about what crops to grow, what landscapes to protect, where to build transport corridors in coastal zones, and perhaps most importantly of all, where to build new residential areas urgently require to be ‘climate change proofed’. There will be serious implications for water management policies, both for the supply and for the quality of water.”ooOooThe Green Party supports:- Action across all government departments to accelerate efforts to reduce GHGs, with departmental procurement personnel, estate managers and services leading by example;- All future water management policy decisions must be climate-proofed, to ensure that local change scenarios are taken into account;- Investment in research leading to GHG mitigation in the Irish agricultural sector; research on adaptation scenarios for Irish agriculture;- A greater emphasis on the integration of climate change considerations into our national biodiversity plan.
The dominant approach in wastewater treatment in Ireland remains ‘end of pipe’ technology. As these are governed by the Urban Wastewater Treatment Directive they are exempt from more stringent measures governing water quality. About 70 per cent of waste water currently receives secondary treatment, up from 29 per cent in 2001. The latest information from the EPA’s Office of Environmental Enforcement suggests that nearly two thirds of secondary waste water treatment plans failed to comply with one or more of the required standards during the most recent reporting period. We are pressing for corrective action programmes to address these failures, which can be traced back to design, construction and training lapses. Wastewater treatment plants (WWT) can act as a disincentive for industry to adopt pollution elimination and substitution strategies in pursuit of clean production. Municipal plants accept trade and domestic sewage rendering it difficult if not impossible to allocate responsibility for certain pollution streams . A Wastewater Plant can offer a liability free way route for industry to discharge through a publicly owned sewer, with the protection of a licence to do so. We have concerns about sampling regimes at wastewater treatment plants. As reported by the EPA’s OEE, while sampling regimes exist at most secondary waste water treatment plans, in the majority of cases the reference methods for monitoring, as set out in the Regulations, are not being rigidly adhered to. In particular, 24-hour flow proportional samples should be taken in order to monitor compliances with the requirements for discharged waste waters as specified in the Regulations. Phosphorous from domestic detergents is also a major concern. The Green Party supports: The separate collection and treatment of lightly polluted grey water. While improvements in water quality will result from the wastewater infrastructure to be rolled out under the National Development Plan, the Green Party has concerns about:- The level of contribution by industry to the costs of providing wastewater treatment;- The vulnerability of the local political system to political lobbying on behalf of industry, especially where industrial emissions to public wastewater treatment systems have led to overloading;For the most part only secondary treatment is available outside the capital. Contracts for design, build and operation of wastewater treatment plans have been awarded for new waste treatment plants around the country. Construction standards have sometimes left a lot to be desired as has the operation of some of the new plant due to issues such as training, sometimes giving rise to major pollution incidents. Key Policy Points: Waste Water TreatmentThere have been failures to adequately predict the required capacity of new waste water treatment plants, leading to overload e.g. under estimation of population growth trends. This has resulted, in part, from a poor integration of national and regional water management planning into spatial planning. On sampling at secondary treatment plants, 24-hour flow proportional samples should be taken in order to monitor compliances with the requirements for discharged waste waters as specified in the Regulations.Many local authorities must review their procedures in relation to the use of sewage sludge in agriculture. About 45 per cent of sludge produced in treatment plants covered by the latest EPA OEE report (2004) was reported to be reused in agriculture. We are calling on local authorities to ensure that sampling programmes for soil and sludge testing are in place, and where these are currently inadequate, they must be improved. Where sludge is reused in agriculture, the sludge from each waste water treatment plant should be analysed according to the Regulations and a detailed analysis of soils carried out according to the standards prescribed in the Regulations. Where the limit values in the Regulations pertaining to soils are exceeded the practice of reusing sludge in that area should cease.A significant design failure is the ‘storm overflow’ system. The storm overflow system bypasses the wastewater treatment plant and results in pollution, including phosphates entering the receiving water (Kells, Mullingar). Storm water ought to be retained or dealt with separately in order to avoid this pollution problem. This would require an upgrade. Due to training difficulties and poor human performance some newer waste water treatment plans have gone septic. This suggests a need for investment in capacity building.Local authorities around the country are reporting that many single house treatment systems are not installed or mainted properly. Progress will call for improved 6.1 Waste water – changes in the pipelineAs with the other services, wastewater falls into two main categories - domestic/municipal and industrial. The level of wastewater generation and treatment is given in Table 3. As can be seen, the majority of waste is generated by the industrial sector, and this sector also does most of the treatment currently carried out. Municipal service levels vary by whether an agglomeration is inland or coastal. Most inland towns are serviced by secondary wastewater treatment, while no coastal town or city is as yet (of the latter, only Dublin currently has primary treatment).The coastal regions contain most of the large urban areas, which means that currently the bulk of the population (70 to 75 per cent) is not serviced by wastewater treatment plants. Therefore, no costs exist for waste water treatment in these areas.This situation is destined to change over the coming years, as the EU Urban Wastewater Directive is implemented. This will involve a major programme of expansion of municipal wastewater treatment. Weston-FTA Ltd (1993) calculates that the current contributing population equivalent (PE) to existing sewerage and treatment facilities in the agglomerations affected by the Directive amounts to 2,715,000, while the future design PE for facilities in these agglomerations is 4,099,000. By the time of full implementation they estimate that 70 per cent of the population will be served by treatment plants. Treatment conditions for industrial wastewater are generally set out in the firms' water pollution license. Because of the lack of treatment in the main urban areas, and the importance of agri-industry (many large food-processing plants are situated in rural areas or small towns), the majority of firms currently carry out their own treatment. With the planned increase in treatment levels in the urban areas, more firms are likely to become connected to municipal treatment plants in the coming years. 6.1.1 Environmental impact The potential impact of waste water entering open bodies of water is significant, in terms of oxygen depletion, eutrophication (these two factors are mainly responsible for fish kills and reductions in fish populations), health risks from human consumption of the water, loss of amenity, smells, etc. The actual impact depends on the level of treatment the effluent receives before release, and the assimilative capacity of the receiving waters. In relation to the latter point, there is generally more concern about discharges to inland waters than to open marine waters. 6.1.2 Existing fiscal structure for waste waterUntil recently, local rates and charges made no contribution to these costs, with 100 per cent of being paid for by central government (with considerable aid from the EU). These costs will increase as all urban areas start to get secondary and tertiary treatment. More recently, industry has been asked to make capital contributions to the cost of municipal treatment plants to which they discharge.In the future the “polluter pays principle” can be expected to increase local charges for all waste water treatment around the country. However at the moment, it is a central government cost.In the 1998 ESRI report “Environmental Accounts: Time Series + Eco-taxes” (ref 1) the overall cost of waste water services was estimated as over €74 million in 1998, and the Cu.M figure derived as approximately €0.25 per Cu.M .It would be fair to say that in the course of our research, it became clear that the additional future costs of delivering increased demand for water to the final consumer were not being fully reflected by national or local government sources in their proposals. But more significantly, the future cost of waste management of the additional demand seemed to have disappeared off the official radar completely. 6.1.3 Conclusions on waste water financeTable 5 summarises the situation. This shows the present shortfall in financing the service, plus the likely increase in costs in the future - €35.5 million - to give the future shortfall in funding the system in the absence of full cost recovery i.e. €130 million per annum. This is also, by definition, the improvement in public finances by moving to full cost recovery, though increased social welfare payments of perhaps €25 million per annum would be required to help low-income households.
*Note that all figures above are based on 1994.
6.2 Urban Wastewater The World Bank has stated that European sewage-treatment practices...do not represent the zenith of scientific achievement, nor are they the product of a logical and rational process. Rather, [they]...are the product of...a history that started about 100 years ago when little was known about the fundamental physics and chemistry of the subject and when practically no applicable microbiuology had been discovered. These practices are not especially clever, not logical, nor completely effective – and it is not necessarily what would be done today if these same countries had the chance to start again.A rethink of the sewage treatment process is under way, with arguments now increasingly in favour of small-scale plants. There is a new emphasis on techniques such as switching from chemical engineering to biological techniques that already offer striking ecological and economic advantages. Ireland may be an ideal location to promote and support small-scale alternatives in rural areas where septic tanks often pose a serious threat to local environs. 6.3 New approaches to sewage treatment for domestic households The widespread use of septic tanks in Ireland is a source of water pollution due to common operational problems.Examples of problems arising from the use of septic tanks include:- Inadequate or infrequent sludge removal;- Improper and unsafe disposal of septic tank sludge onto fields;- Improper and inefficient percolation conditions in the receiving soil;- The absence of secondary treatment after collection in a septic tank, resulting in an effluent that can potentially cause fish kills if the content is allowed to leach into nearby rivers;- Failure to maintain electro-mechanical secondary treatment systems;- Incomplete or non-removal of nitrogen from waste water, resulting in potential emissions to lakes and contributing to algal blooms;- Dispersal of phosphate-based detergents due to low take up of low- or phosphate-free detergents by householders; and- The absence of final treatment for the removal of remaining harmful bacteria from the human gut.A number of water companies have begun to introduce reed bed systems to treat sewage.The principle of the treatment of sewage by Reed Beds is relatively simple. The Common Reed (Phragmites Australis) has the ability to transfer oxygen from its leaves, down through its stem, porous speta and rhizomes, and out via its root system into the rhizosphere ( root system.) As a result of this action, a very high population of micro-organisms occurs in the rhizosphere, with zones of aerobic, anoxic, and anaerobic conditions. With the waste water moving very slowly and carefully through the mass of Reed roots, this liquid can be successfully treated, in a manner somewhat similar to conventional biological filter bed systems of sewage treatment. Constructed reed beds can be used to treat domestic sewage in many situations. This involves first removing large solid material, or turning it into liquid (e.g. in a septic tank), and then passing the liquid portion of the sewage through one or more reed beds. The water is cleansed during this passage. 6.4 Sustainable Urban Drainage Systems (SUDS)The traditional approach to draining developed areas is having a damaging impact on our environment and is not sustainable. The SUDS approach offers a wide range of techniques which can be adopted for most new and redeveloped sites to give a reduced environmental impact from surface water drainage. Widespread adoption of these techniques will see a long-term improvement in the quality of our urban rivers, contributing to a more varied and attractive urban environment built on a sustainable basis.SUDS is an alternative approach to conventional drainage design and implementation, that replicates natural drainage and deals with runoff water where it occurs.Examples of SUDS techniques are set out in Appendix ll. Key policy points: SUDSSUDS provides an innovative design-led and cost effective approach to mitigating water pollution. The Green Party will support the adoption of ‘best practice’ in local communities and support the introduction of regulations to encourage SUDS techniques. We are also committed to the introduction of regulations to encourage separate run-off systems in households for grey water. This will not only enhance our ability to control pollution but encourage grey water capture and reuse.
It has been noted that with excessive water use not discouraged, Ireland is climbing up the marginal cost curve more quickly than necessary when it comes to water infrastructure. This is due to wastage by both customers and suppliers. Unaccounted for water represents almost 50% of the potable water in circulation. New investment is already being pumped into the system and further spending will be required to protect and secure supplies, given population growth, declining household size, higher standards, and, potentially, the impact of climate change.Our proposals demonstrate that there are considerable opportunities to control demand and protect water resources while reducing costs. Further steps are also required to render the costs of water more transparent to consumers to enable greater efficiency and stimulate conservation. The current lack of transparency in the financing of water services has led to perverse decisions, including a withholding of permission to an educational establishment for the introduction of a ‘grey water’ re-circulation system. This was due in part to the absence of correct information on costs.
Coomhola Salmon Trust, StreamScapes Advanced, Cork: CSTDoyle, Alan, ‘Environmental Law: Integrated Control of Pollution?: Introduction and background’, in Irish Perspectives on EC Law, Dublin: Round Hall Ltd. European Environmental Bureau, July 2001, ‘Making the Water Framework Directive Work: Ten Actions’, EEB: Brussels. European Commission, DGXl, Press Office, Brussells. Gleick, Peter H, 2000, The World’s Water 2000-2001, Washington: Island Press. McDonagh, Sean, 2003, Dying for Water, Dublin: Veritas.National Water Study, National Report, Volume 1, Ireland.North South Ministerial Council, ‘Managing our shared waters’, March 2003.Office of Environmental Enforcement: An Introduction, EPAO’Grady Walsh, Clare, ‘Green Party: A water policy for Ireland’, March 2001. Scott, Susan (ESRI), 2003, ‘Abolition of Domestic Water Charges in Ireland’, World Bank Group. Voice of Irish Concern for the Environment (VOICE), ‘The EU Water Framework Directive: Making way for cleaner Irish waters?’, leaflet.Voice of Irish Concern for the Environment (VOICE), ‘The Water Framework Directive – issues and opportunities: An NGO Agenda for Ireland’s waters’, leaflet. Worldwide Fund for Nature, ‘WWF Water and Wetlands Index – Critical issues in water policy across Europe’, Results overview for Ireland, November 2003. WWF Water and Wetland Index, ‘Critical Issues in water policy across Europe’, Executive Summary, November 2003.
| |||||||||||||||||||||||||||||
