The Local Authority Waters Programme have organsied a series of…
Third Cycle Draft River Basin Management Plan 2022-2027 – Consultation Report
The Third Cycle Draft River Basin Management Plan 2022-2027 Consultation Report has been published. This report presents a summary of the issues raised in the submissions reviewed from the public consultation on the draft River Basin Management Plan for Ireland 2022-2027.
The 3rd cycle of River Basin Management Plan (RBMP) for the period of 2022-2027 is currently being prepared by Department of Housing, Local Government and Heritage (DHLGH) in line with the EU Water Framework Directive (WFD) (2000/60/EC).
A 6-month long public consultation was undertaken in this regard from September 27 2021 to March 31 2022. A total of 1401 submissions were received by the DHLGH through a combination of the Department’s online survey and direct email.
These submissions were initially categorised as submissions based on:
- Consultation Response Questionnaire issued by the DHLGH (161);
- Template response (original emanating from the Sustainable Water Network (SWAN), a network of environmental NGOs) (1172); and
- Individual ‘free style’ responses from a cross section of stakeholders (68).
Of these 259 were identified as unique content. RPS were appointed by the DHLGH to review these submissions. The questionnaire submissions included responses to 26 questions set by the DHLGH, with responses submitted either through their online survey or by completing a template response document and sending it to the DHLGH. Each questionnaire was reviewed individually to provide a summary per question (noting not all questions were answered by all respondents) and an overall summary was then prepared for each question once all 161 submissions had been reviewed. In addition, key themes raised were noted for each submission.
The main template submission was initially reviewed for content and any variations of the template were also reviewed to identify additional issues. Key themes raised were recorded.
For the final category of “free style” each submission was further categorised as:
- Government Department/Agency/Body;
- Local Authority;
- Non Governmental Organisations (NGOs);
- Community Groups;
- Public; and
Each submission was then reviewed and summarised and key themes raised were recorded. Thirty-eight themes were identified across the 259 submissions reviewed.
Key issues raised within the ten most prominent themes are summarised below.
Water Quality / Pollution – Key issues raised included the need for clear water governance and adequate investment; lack of specific measures to improve water quality in the plan; inefficient liaison with water stakeholders; transparency from authorities working in the water sector; large number of water bodies being subjected to wastewater pollution and extensive arterial drainage; lack of prosecution for defaulters and impact of water quality on public health.
Agricultural Practices – Key issues raised included the lack of recognition of the conflict between agriculture and WFD targets; urgency related to nutrient pollution; need for better incentives for farmers to promote good practices; stronger enforcement; need for WFD specific farm assessments; and the heavy reliance on Agricultural Sustainability Support and Advisory Programme (ASSAP).
Public Engagement and Awareness – Key issues raised included the inadequate public participation measures in the plan; need for a comprehensive, transparent, and participative public engagement programme; role for citizen science programmes and community involvement with provision of appropriate funding for same; and the need for simple and effective complaints channel for the public to report any pollution event. The importance of education in relation to water quality, agricultural practices, and invasive species was also raised in submissions.
Local Authority – A lot of issues were highlighted in relation to the Local Authorities including lack of funding; lack of adequate resourcing; availability of training to deliver necessary measures; role of Local Authorities to sustain, drive, fund, and coordinate community involvement; development and implementation of the proposed catchment management plans.
Level of ambition – The key issues raised on this issue in the submissions was that the level of ambitions in the plan is considered inadequate. It was noted that there is a need for measures to be more targeted, measurable, timebound and based on more Key Performance Indicators (KPIs). More focussed targeted climate change measures dealing with flooding, sea level rise and storage/reservoirs along with coastal specific measures were also recommended.
Sewage Pollution – Key issues raised included the onerous and strict nature of the grant application process for domestic waste water treatment system (DWWTS); more investment and inspectors for proper inspection of all the malfunctioning DWWT setups; the need for the Irish Water Investment Plan to end sewage pollution from all the waste water treatment plants identified as the main pollution source; and the urgent need for upgrade or replacement of specific WWTP was noted.
Department / Agency – Key issues included the need for every department/agency to carry out an internal review in respect of its role under the RBMP; the RBMP must ensure that a joined-up approach is taken to the preservation of water quality and waste water management; a single lead agency must be identified and resourced adequately to monitor and uphold key performance metrics for successful implementation of the plan.
Co-ordination – Key issues were the need for greater coordination among the implementation bodies in particular Local Authorities and the Department of Agriculture, Food and the Marine (DAFM); the imperative of policy coherence between water, climate and biodiversity plans and measures; clarity on the responsibilities of different stakeholders towards the improvement of water quality; requirement for a strong collaborative approach; and the need to work positively with the farming sector to deliver improvements in water quality.
Funding – References were related to the significant need for appropriate funding and resourcing to deliver necessary measures.
Forestry – Key issues included the requirement for WFD specific assessment and site-specific conditions for all planting and felling licences in the forestry sector.
Peat – Requirement for a list of all waterbodies that have been impacted by peat extraction to be included in the plan, need for peat-specific targets, prohibition of wetland drainage, need for a National Wetland Restoration Plan; and incentives and grants to support such measures.
Shellfish waters / aquaculture – Better integration for shellfish waters / aquaculture in the plan; need for all potential pressures from aquaculture to be included in the plan and need for effective monitoring to be put in place.
Other – Requirement of restoration programme including re-meandering, re-establishment of natural riparian zones etc.; urgency to halt the release of hazardous substances into waterbodies; constant need for compliance assurance and need for proper monitoring to track the progress of plan implementation etc.
Following review of the submissions, the DHLGH will commence a review and where necessary update the draft RBMP with a view to finalisation and publication in Q3/Q4 of 2022. The SEA and AA processes will continue in parallel until finalisation and will be completed prior to adoption of the 3rd cycle plan.
You can download the full consultation report here: https://www.gov.ie/en/publication/56b71-third-cycle-draft-river-basin-management-plan-2022-2027-consultation-report/