Ervia's Response to the Draft National Risk Assessment 2019

Ervia’s Response to the Draft National Risk Assessment 2019

25th June 2019 Ervia 1

Introduction to Ervia

Ervia is a commercial semi-state company with responsibility for the delivery of gas and water infrastructure and services in Ireland, through Gas Networks Ireland (“GNI”) and Irish Water (“IW”). It also provides dark fibre broadband infrastructure through its business Aurora Telecom.

GNI develops, operates and maintains the natural gas transmission and distribution networks in Ireland, consisting of 14,172km of gas pipelines. GNI provides gas transportation services to all gas suppliers and shippers.

IW is the national water utility responsible for providing safe, clean and affordable water and wastewater services to 1.7 million customers in the Republic of Ireland. IW is responsible for the operation of all public water and wastewater services.

These national gas and water utilities underpin the social and economic development of Ireland and will play strategic roles in the transition of Ireland to a low carbon, climate resistant and sustainable economy by 2050.

Ervia have reviewed the draft document and provided the following high level observations. The consultation outlines a broad range of risks facing the country and Ervia is involved in initiatives that will help mitigate against some of these risks, these are included in our response.

The first section of our response relates to those risks impacting across Ervia (impacting both GNI and IW), the second section is a specific response to those risks as they relate to GNI and the third section is a specific response to risks as they relate to IW.

1. Ervia response to risks impacting across IW and GNI

In delivering the required large scale infrastructural and energy projects over the next number of years, a number of the strategic risks identified require particular focus across our businesses. We have referenced in order each section of the Draft National Risk Assessment 2019 we are responding to.

Section 2: Draft Geopolitical Risks 2.5 Terrorist Incidents and Armed Conflicts “Ireland and its citizens could be negatively affected by terrorist incidents, depending on the location of such incidents and their wider impact”. Ervia concur that Ireland could be negatively impacted by a terrorist incident. As a result, Ervia has liaised with An Garda Siochana and the PSNI on security standards associated with critical assets. GNI have recently completed a risk review of security at all of their sites and are currently commencing a phased renewal of the security infrastructure at their installations. IW are also undertaking a risk review of security on a phased basis across all their water and wastewater sites, having commenced with the most critical sites and have also commenced a phased renewal of security infrastructure across their sites.

These upgrades are expected to enhance our ability to detect and delay any attack and enable a more rapid Security response.

Section 3: Draft Economic Risks Section 3.2 – Loss of Competitiveness The content relating to inflation does not call out in sufficient detail the impact of construction inflation on our major infrastructure projects. With construction inflation running consistently in excess of the harmonised inflation consumer price index (HICP) for the past number of years (but currently not recognised by our regulator), this has the potential to result in projects that are unviable, unaffordable or require significant additional budget.

There is also considerable challenge in relation to supply chain capacity within the construction sector which has the potential to obstruct delivery of key infrastructural projects. There is high demand for both public and private sector investment, this will be for the foreseeable future as key investments required are also highlighted in the National Development Plan and Project Ireland 2040.

Section 4: Draft Social Risks Section 4.2 – Skilled Labour Shortages: As part of the supply chain challenges Ireland is facing, it is important to note the current lack of experienced/middle management resources in the engineering sector – this is a

skilled labour area critical to the delivery of our major infrastructure projects. In addition, this section focuses heavily on the university/technical colleges constraints on educating in the digital/ICT area. The impact of the collapse of the traditional apprenticeship path in Ireland on the manufacturing and construction/engineering sectors should also be emphasised.

Section 5: Draft Environmental Risks

Section 5.3 – Delivery of Public Infrastructure It is worthwhile flagging the prolonged duration of the Irish planning approval process which has a significant schedule impact for public infrastructure projects.

In addition, this section refers to the range of reforms being progressed in light of the recent experiences with certain infrastructure projects including those relating to the National Children’s Hospital. However the document should recognise that unless these proposed reforms are confirmed and implemented in a timely manner, there will be consequential budgetary impacts on infrastructure projects due to the delays in approvals pending these reforms. This is currently a significant risk to the delivery of Ervia’s infrastructure projects.

Section 5.5 – Supply and Affordability of Housing This section does should recognise the criticality of progressing our infrastructure projects in order to enable housing solutions to progress. The planning authorities will not be in a position to approve new housing developments in the absence of adequate wastewater, water and gas infrastructure capacity. This dependency should be emphasised.

Section 6: Draft Technological Risks 6.1 Cyber Security Ervia agree that there is a ‘rapidly expanding threat landscape that will follow on from increased digitisation in society’. We also agree that the ‘immediate risks to businesses and individuals include the loss or theft of personal or business information’ and that our introduction of the General Data Protection Regulation (GDPR) (May 2018) across Ervia will assist us in ensuring we are protecting our data optimally.

We also feel that the document should make reference to the Network and information Systems (NIS) Directive. From our perspective Ervia operates in an Operational Technology (OT) threat landscape, in this rapidly evolving landscape the NCSC-IE approach to defining a NIS Directive incident for gas and water will have a significant impact on Ervia and the depth of IT and OT security controls required to ensure compliance with the directive. In particular for the water infrastructure it will have a large impact as the National Telemetry System is being implemented and the Water Integrated Operating Framework is being concluded. This water infrastructure is currently being maintained under a distributed support / operating model across a variety of local authorities. It is important to ensure that the identification of in scope assets are commensurate with what constitutes a NISD incident and this is something that GNI and Irish Water are fully engaged with the NCSC to deliver.

1. GNI response to specific risks raised

Ireland’s Gas Network – introduction Gas Networks Ireland (GNI) owns, operates, builds and maintains the gas network in Ireland and ensures the safe and reliable delivery of gas to its customers. The company is responsible for transporting natural gas through 14,172km of pipeline networks. The gas network supplies energy to 700,000 customers, including businesses, domestic users and power stations. GNI believes that gas and the gas network are integral to Ireland’s energy system and future. The gas network has been developed since gas was established in the late 1970’s, with network investment of over €2.5 billion to meet the evolving demands of the Irish economy.

Transportation of gas is unobtrusive, with pipelines buried underground and particular attention taken to minimise the impact on local flora and fauna. GNI is committed to biodiversity & archaeology through the minimisation of the environmental impact of any construction and development activities1. This involves a partnership approach with environmental and heritage groups on all construction projects, as well as employing engineers and environmental specialists to carry out environmental assessments at the planning and construction phases of developments. GNI returns all land to its original state following construction.

1 Gas Networks Biodiversity & Archaeology Commitment

Moving energy through gas pipelines is considered the most efficient method of transporting energy and there is potential for this efficiency to be further exploited by connecting new customers to both the transmission and distribution networks. The existing transmission and distribution networks have spare capacity to accommodate new connections.

Section 2: Draft Geopolitical Risks 2.1 Departure of the UK from the EU As the consultation document has highlighted, there is persisting uncertainty regarding the ratification of the Withdrawal Agreement in the UK parliament and the risk of the UK departing from the EU in October 2019 continues to be a possible outcome.

From an energy perspective, Ireland and the UK are heavily interconnected. Ireland is connected to Great Britain through two subsea interconnector gas pipelines. Great Britain is one of the most liquid and transparent natural gas markets in the world and has a diverse range of natural gas sources from indigenous production to Liquefied Natural Gas (LNG) and subsea interconnector pipelines to Europe, i.e. Belgium, the Netherlands and Norway. Ireland’s two sub-sea gas interconnectors transport natural gas from Scotland to Ireland. The interconnector system is made up of an onshore system in Scotland and two high pressure gas interconnectors that come to shore just north of Dublin. The interconnector system has transported up to 93% of Ireland’s natural gas demand, prior to gas flowing from the Corrib gas field. The close proximity of the subsea Interconnectors to Dublin ensures increased security of supply and a high level of system capacity in the area. Northern Ireland (NI) owns and operates a pipeline that is connected to the onshore Scotland section of the Irish interconnector system and relies heavily on this connection for its supply of natural gas. In addition, NI has a pipeline of over 150km in length that runs from Dublin into the North which provides security of supply as an alternative route for gas to NI. The Isle of Man (IOM) is also supplied natural gas via Ireland’s second sub-sea interconnector (IC2).

GNI believes that the UK’s decision to leave the EU may pose some potential risks from an energy perspective we have continued to work with our counterparts in both Great Britain and Northern Ireland in order to ensure that the necessary arrangements are in place to ensure that gas will continue to flow, particularly in a no deal scenario. Additionally, GNI is cooperating with parties in Europe such as GIE (Gas Infrastructure

Europe) and, ENTSOG (European Network of Transmission System Operators for Gas), in order to ensure that any potential impacts that Brexit might have on the operation of the Irish gas market are identified and addressed, where possible in advance of the UK’s departure from the EU.

Given that a vast amount of Ireland’s gas supplies are currently imported from the UK, any imposition of tariffs on gas will inevitably increase the cost of gas to the end users. Currently, all members of the EU Single Market benefit from having zero tariffs on imports. If a free trade agreement is not agreed between the UK and the EU before Brexit takes place, there will be a default to World Trade Organisation tariffs. In the case of gas, this would infer a default tariff of between 0% and 0.7%. As both the UK and EU are net importers of natural gas, it is unlikely either would suggest implementing a tariff. Our current understanding is that both the EU and the UK have confirmed that no tariff will apply to gas imports both from the UK and from the EU.

The Ireland / UK inter-governmental gas treaty, which was signed in 1993, governs the operation of the interconnectors. This treaty still remains in place today and will remain in place post Brexit. In addition, NI and IOM are both connected to Great Britain’s gas supplies via GNI infrastructure and so there is a shared interest in maintaining and developing the interconnector infrastructure as it is beneficial to a number of parties.

GNI concurs with the view set out in the document that our interest is in the closest possible relationship between the EU and the UK.

Section 4: Draft Social Risks 4.2 Skilled Labour Shortages GNI Ireland is in agreement with the statement “As the economy continues to expand, increasing the participation rate and sourcing skilled international talent will be important supplements necessary in the context of growing labour market demand as well as existing skills shortages in specific areas”. As the economy improves it is expected there will be increased staff turnover which may result in a loss of knowledge and skills from GNI. There are also associated costs of replacing experienced personnel and training new resources.

4.5 Social Cohesion Including Perceptions of Rural and Regional Imbalances There is significant risk that urban areas are viewed as benefitting more from economic prosperity than rural areas. GNI is driving the development of renewable gas2 injection infrastructure in rural areas which will support the introduction of anaerobic digestion (AD) plants. These AD plants will produce renewable gas through the digestion of organic wastes and residues from the agricultural sector providing benefits to rural areas. Anaerobic digestion plants provide additional revenue sources for rural communities, from the sale of feedstocks for the AD plants, bio-fertiliser and renewable gas. The SEAI estimate that stimulating a renewable gas industry in Ireland could contribute directly to over 5000 jobs during plant construction and over 3000 jobs in plant operations3. With ongoing uncertainty regarding agricultural exports to the UK, post Brexit supplementary income streams for farming are important.

In addition to the creation of rural employment renewable gas is a carbon neutral fuel which will help Ireland reduce carbon emissions. GNI believes that both policy support and financial incentives are needed to develop Ireland’s renewable gas industry. There is a risk that a renewable gas industry will not develop should these incentives and supports not materialise.

Section 5: Draft Environmental Risks Section 5 identifies “Climate Change & Biodiversity” and “Ensuring an affordable, sustainable and diverse energy supply” as key risks. GNI is involved in projects which will mitigate against these risks.

5.1 Climate Change & Biodiversity GNI is undertaking actions to embed sustainability and decarbonisation principles at the core of its business decisions and strategy. This year, Managing Director Denis O’Sullivan along with 100 CEOs from a variety of companies and industry sectors in Europe, joined

2 Renewable Gas 3 SEAI, 2017 Assessment of Costs and Benefits of Biogas and Biomethane

forces for a New Deal for Europe. In doing so, he endorsed a call-to-action to accelerate sustainable growth, tackle climate change and create inclusive prosperity.

GNI has considered the potential impact of climate change on the gas network. Ireland’s natural gas network consists of buried pipelines, which are not subject to the vulnerability of storms that can impact the delivery of oil or the transport of electricity through overhead wires. In addition, the routing of the gas network is designed to take account of flood plains, avoiding areas prone to flooding where possible.

In recent years GNI has been undertaking remedial action on transmission pipes in floodplains to ensure that transmission pipelines in floodplain areas are properly protected in extreme weather conditions. The existing gas pipelines have been designed to the highest standards and have proven their resilience to extreme weather conditions for over 40 years. Materials are specified for an operating temperature range of -20°C to 60°C. The gas network is capable of withstanding extreme weather events. Winter 2017/18 had two severe weather events – extreme wind during Storm Ophelia that resulted in widespread loss of electricity supplies and there was a prolonged cold period with high winds during storm Emma. No gas outages were experienced as a result of either of these extreme events. In June and July 2018 when there were low levels of wind electricity generated from natural gas reached highs of 90% with an average of 70% for that two-month period. The gas network is a large piece of critical infrastructure in Ireland that is highly resilient.

In terms of mitigating greenhouse gas emissions (in both the energy and agriculture sectors) the provision of renewable gas injection infrastructure by GNI, will support the injection of renewable gas into the Irish gas grid, reducing greenhouse gas emissions. This reduction in greenhouse gas emissions can be attributed to the fact that renewable gas is carbon neutral. It is identical in function to natural gas so existing gas customers do not need to change equipment. GNI is currently working to develop renewable gas injection points on the gas network with a target of 20% renewable gas on the gas network by 2030.

The cost of mitigating against greenhouse gas emissions needs to be considered when taking any mitigating action. With respect to decarbonising domestic heat, GNI suggests that consideration be given to a study on Decarbonising Domestic Heating in Ireland4

4 Decarbonising Domestic Heating in Ireland

which was commissioned by Ervia (GNI’s parent company). KPMG developed and evaluated potential scenarios for the decarbonisation of one million Irish residential homes currently connected to, or within close proximity to the existing gas network, while also increasing their energy efficiency. The study concluded that renewable gas is the lowest cost option to decarbonise the domestic heat sector and avoids the need for deep retrofits to convert properties to high energy ratings required for electric heating to work effectively.

With respect to reducing transport emissions GNI is developing Compressed Natural Gas (CNG5) infrastructure for gas in transport. CNG is a mature and proven technology which delivers significant carbon savings compared to diesel, and also offers improved air quality with 99% less particulate matter, 70% less Nitrogen Oxide, and 80% less Sulphur Dioxide relative to diesel. GNI is installing 14 fast fill CNG stations across the Core TEN- T road network via a project called the Causeway Study 6 that is supported by the European Commission through the CEF Transport Fund7. This project helps support the ‘National Policy Framework: Alternative Fuels Infrastructure for Transport in Ireland (2017 to 2030)’, which sets out a target network of 70 CNG refuelling stations by 20258. This document also forecasts Alternative Fuelled Vehicles for 2025 and 2030 i.e. 4,050 CNG commercial vehicles and 1,000 CNG buses in Ireland by 2025, growing to 6,050 CNG commercial vehicles and 1,500 CNG buses by 2030. This change from diesel to CNG will make the commercial transport sector less sensitive to international oil prices and supply disruptions.

In December 2018 a new public CNG station opened in Dublin Port. CNG can contribute to decarbonisation of high energy usage vehicles, such as heavy goods vehicles (HGVs) and buses, where electricity is currently not a viable alternative to diesel. Additionally when production of renewable gas is increased on the gas network, and this gas used to fuel CNG vehicles, carbon neutral transport can be achieved.

5 Compressed Natural Gas (CNG) is a fuel used in the transport sector which reduces transport emissions. 6 Causeway Study 7 CEF Transport Fund 8 National Policy Framework: Alternative Fuels Infrastructure for Transport in Ireland (2017- 2030)

Biodiversity

“There are significant threats to Ireland’s biodiversity” and that “This requires Ireland to develop a comprehensive series of measures to maintain and where necessary restore these habitats”.

With climate change now more significant than ever from a global perspective, biodiversity is uppermost on our agenda. In Paris this month, representatives from 130 nations approved the most comprehensive assessment of global biodiversity ever undertaken. Spearheaded by the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES), the report found that nature is being eroded at rates unprecedented in human history. One million species are currently threatened with extinction and we are undermining the entire natural infrastructure on which our modern world depends.

At Gas Networks Ireland, we have embraced an important role in promoting the importance of biodiversity not only amongst our substantial stakeholder network, but also among our staff and the communities where we work. We’ve sought advice from leaders in the field, including the National Biodiversity Data Centre, and Business in the Community Ireland, in relation to supporting the All-Ireland Pollinator Plan and taken guidance from their “Businesses: actions to help pollinators”.

As a key part of this, we have identified that our large asset base is ideal for creating a network of pollinator-friendly habitats nationwide, and in turn, that we can have an impact on enhancing biodiversity by implementing biodiversity management initiatives. Examples of these include: conducting ecology surveys, planting of wild flower meadows, reducing the use of pesticides and erecting bird boxes.

Through our Biodiversity Enhancement Programme, we support the All-Ireland Pollinator Plan and contribute to Ireland’s efforts to meet the UN’s Sustainable Development Goals targets. We have committed to the promotion of red clover, good for bees and the soil, encouraging farmers to grow it as a feedstock crop to be used for the production of renewable gas.

In February, 2019, Gas Networks Ireland’s Biodiversity Enhancement Programme won the ‘Working Together for Biodiversity’ award at Ireland’s first National Biodiversity Conference. At this event, Gas Networks Ireland was also announced as one of 14

founding members of the Irish Business and Biodiversity Platform, making a commitment in the ‘Our Seeds for Nature’ charter to protect nature and biodiversity.

5.2. Ensuring an Affordable, Sustainable and Diverse Energy Supply

Security of Energy Supply – Gas Indigenous sources of natural gas and renewable gas, combined with the gas interconnectors, which are linked to the competitive and highly liquid UK gas market, provides Ireland with a secure energy future. The Corrib gas field came on stream in 2015 with indigenous gas supply meeting 55% of demand in 2018. The Corrib gas field will also further enhance Ireland’s security of supply for the next ten years and make a significant contribution to generating Ireland’s electricity, heating Irish homes and providing the energy for industry and businesses to drive the Irish economy. Ireland is connected through two subsea interconnector pipelines to Great Britain and these interconnectors are up to 200 km in length and can be utilised as a storage facility and to provide backup to indigenous gas supplies. The subsea interconnectors are connected to the British National Transmission System (NTS) at Moffat in Scotland via an onshore pipeline in Southwest Scotland.

GNI completed the twinning of this onshore pipeline in December 2018 with the commissioning of a new 50km parallel pipeline between Cluden and Brighouse Bay in Scotland. This pipeline enables GNI to operate both interconnectors independently, enhances security of supply to the island of Ireland, and increased the technical capacity at Moffat Entry Point. The Ballough Bypass which is due for construction in 2020 will separate the entry of the two interconnectors into Ireland and will facilitate up-rating of gas to the western region and will provide reinforcement to the southern region of the island of Ireland.

The development of an indigenous renewable gas industry would greatly contribute to security and diversity of supply in the near term. GNI worked with a renewable gas producer to develop a Renewable Gas Network Entry Point and the first injection to the Network is expected shortly. The development of Power to Gas, which converts excess intermittent renewable energy, such as wind or solar energy, into gas through electrolysis and methanation will also provide a sustainable source of renewable gas into the future.

Security of Energy Supply - Transport Transport in Ireland is 97% dependent on imported oil. As discussed above (the section on Climate Change & Biodiversity) GNI is actively developing CNG refuelling infrastructure. This will provide an alternative to diesel for trucks, buses and vans and will reduce Ireland’s reliance on imported oil.

As the production of renewable gas is scaled up and used in transport as bio-CNG commercial vehicles will be running on locally produced gas. This indigenous source of transport fuel will enhance Ireland’s security of energy supply for transport. The transportation of fuel through the existing gas network will also provide fuel security in all weather conditions.

Security of Energy Supply - Electricity Gas is used as a fuel in the power sector and typically accounts for half of Ireland’s annual electricity generation. Gas-fired power stations are a vital system component to accommodate sudden changes in electricity demand or supply. Ireland has one of the highest levels of wind penetration in Europe and requires the security and flexibility of gas fired power plants and the gas network to back up this intermittent source of renewable energy. This was demonstrated in June and July 2018 when there were low levels of wind, therefore, electricity generated from natural gas reached highs of 90% with an average of 70% for that two-month period. GNI believes that an increase in installed wind capacity would not reduce the high dependency on conventional generation for backup, particularly during weather events similar to those experienced in summer 2018.

Ervia (GNI’s parent company) is working on a feasibility study for Carbon Capture and Storage (CCS) which could help Ireland to meet its 2050 climate change targets by decarbonising the power sector while continuing to use natural gas which provides flexibility and stability to the electricity sector. CCS is a technology which could decarbonise up to 100% of CO2 emissions from power plants and as a result provide ‘zero emission firm power’.

Climate Change, the Economy and Infrastructure 9 Heating and transport account for 70% of Ireland’s energy-related CO2 emissions due to the dependence of these sectors on oil as their primary fuel source. Little has been done to sustainably address renewable energy in these key energy demand areas and Ireland is currently behind on meeting its targets for renewable energy which could result in referral to the European Court of Justice, with significant fines and sanctions

likely. The adoption of renewable gas and CNG will reduce CO2 emissions, and assist Ireland in meeting the EU targets set out in a number of Directives. This will help reduce or mitigate the potential fines as well as having other economic benefits such as job creation and rural development. Ireland’s growing economy and population will place increased pressure on our infrastructure. However as previously discussed, Ireland’s gas network has been designed with the foresight to facilitate substantial new loads. Gas has significant environmental benefits over other heating sources such as oil. It would be a risk to the Irish economy to ignore the benefits that Ireland’s gas infrastructure provides. Developing and maintaining the gas network as a strategic asset is important for Ireland from an economic and environmental perspective.

2. IW response to specific risks raised

IW introduction Irish Water (IW) is responsible for providing clean and safe water for millions of people across Ireland. We operate and maintain water and wastewater infrastructure including thousands of treatment plants and assets, as well as tens of thousands of kilometres of pipe network. We provide our customers with a safe and reliable supply of drinking water. We collect their wastewater and safely return it to the environment. In delivering these vital services, which underpin social and economic growth for present and future generations, we are leveraging capabilities across Ervia to transform Ireland’s ageing and broken water network, under a single modern and efficient national utility.

9 SEAI CO2 Emissions

Section 5: Draft Environmental Risks Section 5.1 Climate Change & Biodiversity IW supports the government statement in the overview that ‘in terms of climate change mitigation, we know that the cost of inaction exceeds the cost of action, and that this differential will rise steeply with time’. There remains a significant investment requirement in our water services infrastructure to increase its resilience to climate change impacts including those recognised as the ‘most immediate’ risks in document such as ‘floods, precipitation and storms’. However, in light of the drought experienced in the summer of 2018, its impact on water services delivery and residual effect on a number of critical water sources, the risk of water shortages in summer should be also viewed as a more immediate risk which impacts both the supply of drinking water and the impact on the environment from wastewater discharges.

Biodiversity

Protecting and improving the future, long term quality of the water environment is fundamental to providing safe water services and for the protection of human health and biodiversity. The water environment is inextricably linked to the wider environment and it is important to consider protection of the environment in a holistic way. Irish Water protects the water environment in its role in delivering water services, but also the broader environment in terms of the impacts of our activities, for example in our use of energy and our carbon footprint. An enhanced water environment results in a reduced requirement for water treatment and supports recreational activities, biodiversity, tourism and the natural character of our countryside.

The need to protect and improve the water environment and the environment generally has been recognised in a number of European Directives that afford special protection to identified areas that are important for drinking water supply, nature conservation, bathing and fisheries. Examples include the Birds Directive, Habitats Directive, Bathing Water Directive and the Water Framework Directive (WFD). The WFD is the overarching Directive within which all matters impacting the water environment are managed.

Irish Water has set out in our Water Services Strategic Plan for the period to 2040 the measures to support our objectives in protecting and enhancing the environment.

Circular Economy

Research by National Economic and Social Council (NESC - October 2017) identified the range of circular economy practices underway in Ireland, and their associated benefits, including reduced resource use, related environmental benefits, economic benefits from cost savings and value creation, and social impacts such as job creation and wider social innovation. However, it also found that there are multiple financial, policy and regulatory constraints to future progress. The research points to the need to establish enabling conditions to nurture and support innovation, as well as chart out pathways to progress towards a circular economy. In particular, the current regulatory approach to waste management does not facilitate the trialling of activities that could develop innovative processes and technologies in this area. A supportive approach to the circular economy could help to gain Ireland competitive advantage.

Section 5.3 Infrastructure constraints This section identifies the risk of overheating in the economy from the high level of population growth ‘coupled with an under-supply of housing and associated affordability issues, a tightening labour market and the continued strength of economic growth’. As outlined in last year’s submission, Irish Water has identified a strain on the supply chain as an emerging risk with the potential to obstruct delivery of key projects, and would like to restate our position that economic overheating would have disastrous consequences in this regard. We would also reaffirm the requirement for a robust and efficient development consent system in order to maximise certainty and minimise delay in converting capital projects as an issue which needs to be addressed in the short term.

While Section 5.1 recognises the ‘potential costs to the exchequer…with not achieving compliance without EU GHG emissions and renewable energy targets to 2020 & 2030’, similarly there is a cost risk in failing to deliver infrastructure which will lead to compliance with EU drinking and waste water directives and also the Water Framework Directive objectives, and this should also be recognised.

5.5 Supply & Affordability of Housing The report identifies the supply of housing as one of the most ‘critical challenges currently facing the state’. Ervia recognises the social, economic and environmental impacts of this challenge and is committed to supporting delivery of housing infrastructure. As outlined last year, we have proposed a number of vital infrastructural projects, such as the Eastern and Midlands Water Supply Project, which will ensure water/wastewater services capacity does not hinder the development goals outlined in the NPF, particularly the construction of new housing units to address the current housing shortage. As mentioned previously, a multi-year funding commitment from the Government would assist Irish Water in planning for major water infrastructure projects and could help encourage new entrants into the supply chain.

Section 6: Draft Technological Risks 6.3 Anti-Microbial Resistance Anti-microbial resistance (AMR) is rightly identified as an increasing concern and also referenced are increasing concerns about the role the environment may play in the spread of clinically relevant antimicrobial resistance. However, the focus of this document is on environmental regulators monitoring and controlling the possible pathways responsible for the release of antimicrobials into the environment, e.g. through water contamination and agricultural run-off and enhancing the delivery of environmental protection from AMR. Irish Water would encourage the Government to consider the role control at source can play to prevent, or at least reduce, the potential for antimicrobials entering the environment through, for example, a combination of developing alternative medications, addressing medical practice in prescribing such medication, and/or pre-treatment of discharges from identified hotspots such as acute hospitals and nursing homes prior to discharge to sewer.