Dublin Waste Water Treatment

EX POST EVALUATION OF INVESTMENT PROJECTS CO-FINANCED BY THE EUROPEAN REGIONAL DEVELOPMENT FUND (ERDF) OR COHESION FUND (CF) IN THE PERIOD 1994-1999

DUBLIN WASTE WATER TREATMENT

PREPARED BY: DKM ECONOMIC CONSULTANTS, DUBLIN IN PARTNERSHIP WITH CSIL, CENTRE FOR INDUSTRIAL STUDIES, MILAN

Prepared for: European Commission DIRECTORATE-GENERAL REGIONAL POLICY POLICY DEVELOPMENT EVALUATION

MILAN, SEPTEMBER 5, 2012

This report is part of a study carried out by a Team selected by the Evaluation Unit, DG Regional Policy, European Commission, through a call for tenders by open procedure no 2010.CE.16.B.AT.036.

The consortium selected comprises CSIL – Centre for Industrial Studies (lead partner – Milan) and DKM Economic Consultants (Dublin).

The Core Team comprises: - Scientific Director: Massimo Florio, CSIL and University of Milan; - Project Coordinators: Silvia Vignetti and Julie Pellegrin, CSIL; - External experts: Ginés de Rus (University of Las Palmas, Spain), Per-Olov Johansson (Stockholm School of Economics, Sweden) and Eduardo Ley (World Bank, Washington, D.C.); - Senior experts: Ugo Finzi, Mario Genco, Annette Hughes and Marcello Martinez; - Task managers: John Lawlor, Julie Pellegrin and Davide Sartori; - Project analysts: Emanuela Sirtori, Gelsomina Catalano and Rory Mc Monagle.

A network of country experts provides the geographical coverage for the field analysis: Roland Blomeyer, Fernando Santos (Blomeyer and Sanz – Guadalajara), Andrea Moroni (CSIL – Milano), Antonis Moussios, Panos Liveris (Eurotec - Thessaloniki), Marta Sánchez-Borràs, Mateu Turró (CENIT – Barcelona), Ernestine Woelger (DKM – Dublin).

The authors of this report are John Lawlor and Rory Mc Monagle of DKM.

The authors are grateful for the very helpful comments from the EC staff and particularly to Veronica Gaffey, José-Luís Calvo de Celis and Kai Stryczynski. They also express their gratitude to all stakeholders who agreed to respond to the team’s questions and contributed to the realisation of the case study. The authors are responsible for any remaining errors or omissions. Quotation is authorised as long as the source is acknowledged.

Cover: Dublin Bay. Source: Dublin City.

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... 1 1 PROJECT DESCRIPTION ...... 7

1.1 KEY FEATURES OF THE INFRASTRUCTURE AND SERVICE DELIVERED...... 7 1.2 CONTEXT ...... 11 1.3 TARGET POPULATION ...... 12 1.4 CURRENT PERFORMANCE ...... 16 2 ORIGIN AND HISTORY ...... 23

2.1 CONTEXT FOR THE PROJECT ...... 23 2.2 KEY STAKEHOLDERS AND MANAGEMENT STRUCTURES ...... 33 2.3 MAIN DEVELOPMENTS SINCE COMPLETION ...... 41 2.4 HAS THE PROJECT STABILISED? ...... 46 3 LONG-TERM DEVELOPMENT EFFECTS ...... 49

3.1 KEY FINDINGS ...... 49 3.2 DIRECT ECONOMIC GROWTH ...... 53 3.3 ENDOGENOUS DYNAMICS ...... 55 3.4 SOCIAL COHESION ...... 56 3.5 ENVIRONMENTAL EFFECTS ...... 58 3.6 TERRITORIAL COHESION ...... 58 3.7 INSTITUTIONAL QUALITY ...... 58 3.8 SOCIAL HAPPINESS ...... 60 4 DETERMINANTS OF PROJECT OUTCOMES ...... 61

4.1 KEY FINDINGS ...... 61 4.2 APPROPRIATENESS TO THE CONTEXT ...... 62 4.3 PROJECT DESIGN ...... 64 4.4 FORECASTING CAPACITY ...... 64 4.5 PROJECT GOVERNANCE ...... 65 4.6 MANAGERIAL RESPONSE ...... 66 4.7 INFLUENCE OF AND INTERPLAY BETWEEN DRIVERS ...... 67 4.8 THE ROLE OF THE EU ...... 68 5 CONCLUSIONS ...... 69 ANNEX I. METHODOLOGY OF EVALUATION ...... 73 ANNEX II. COST-BENEFIT ANALYSIS ...... 79 ANNEX III. GLOSSARY OF TERMS ...... 99 ANNEX IV. LIST OF INTERVIEWEES ...... 101 ANNEX V. REFERENCES ...... 103

LIST OF ABBREVIATIONS

ABP An Bord Pleanála/Planning Appeals Board

AD Anaerobic Digestion

BOD5 Biochemical Oxygen Demand

CAW Celtic Anglian Water, the DWWT concessionaire

CBA Cost-Benefit Analysis

CF Cohesion Fund

CFU Colony Forming Unit

COD Chemical Oxygen Demand

CSO Central Statistics Office

DBO Design Build Operate

DBWQMP Dublin Bay Water Quality Management Plan

DCC Dublin City Council

DDDA Dublin Docklands Development Authority

DOE Department of the Environment (now the Department of Environment, Community and Local Government, DECLG)

DG Regio Directorate General for Regional Policies

DWWT Dublin Wastewater Treatment

EAP Environmental Action Programme

EIA Environmental Impact Assessment

EIS Environmental Impact Statement

EC European Commission

EPA Environmental Protection Agency

ERDF European Regional Development Fund

ERU Environmental Research Unit

EU European Union

EUR Euro

FF Fíanna Fáil, Irish Political Party

GDA Greater Dublin Area

GDP Gross Domestic Product

GVA Gross Value Added

IFSC International Financial Services Centre

IPPC Integrated Pollution Prevention Control

Km Kilometre(s) m Metre(s)

MACL McCarthy Acer Consultants Limited mm Millimetre(s)

M&E Mechanical & Electrical

MSW Municipal Solid Waste

MW Megawatts

NUTS Nomenclature of Territorial Statistical Units

NPV Net Present Value

PE Population Equivalent

PDs Progressive Democrats, Irish Political Party

R&D Research and Development

SBR Sequencing Batch Reactors

ToR Terms of Reference

TSS Total Suspended Solids

WtE Waste to Energy (i.e. incineration)

WTP Willingness to pay

EXECUTIVE SUMMARY

This case study analyses the construction and operation of the Dublin Waste Water Treatment plant (DWWT). The purpose of the evaluation is to assess the socio-economic long-term effects generated by the project and to disentangle the possible determinant factors that may have contributed to producing these effects. More details on the overall evaluation approach are presented in the following Box and, more extensively, in Annex I.

OVERALL APPROACH AND METHODOLOGY The Conceptual Framework delivered in the First Intermediate Report has been developed from the evaluation questions included in the ToR1, and further specified and organised in accordance with the study team’s understanding. In particular, the Team identified three relevant dimensions of analysis: a. The object of the evaluation (the ‘WHAT’): this relates to the typologies of long-term contributions that can be observed. Starting from the typologies identified in the ToR (socio-economic development and quality of life) the Team developed the following classification of long-term effects: ‘Economic development’ (including effects on GDP growth and endogenous dynamics) and ‘Quality of life’, taken here to be synonymous with additional social wellbeing, i.e. including effects that are not captured by the economic variables. ‘Quality of life’, in turn, has been divided into: social cohesion, territorial cohesion, institutional learning, environmental effects and social happiness. b. The timing of the long-term effects (the ‘WHEN’): this dimension relates to the point in the project’s lifetime at which the effects materialise for the first time (short-term dimension) and stabilise (long-term dimension). The proper timing of an evaluation and the role it can have in relation to the project’s implementation is also discussed here. c. The determinants of the project’s performance (the ‘HOW’): the assumption here is that five aspects of project’s implementation and their interplay are crucial for the project’s final performance. These aspects are: project design, forecasting capacity, governance, context and managerial response. Five Working Hypotheses are related to these dimensions and explain how each of them can influence the generation of the project’s short or long-term effects. On the basis of this conceptualisation, a set of detailed evaluation questions are developed, which aim to guide the entire study and to support the provision of conclusions and recommendations. The methodology developed to answer the evaluation questions consists of a combination of quantitative (Cost Benefit Analysis) and qualitative (interviews, surveys, searches of government and newspaper archives, etc.) techniques, integrated in such a way as to produce ten project histories. CBA is an appropriate analytical approach for the ex-post evaluation because it can provide quantification of or indications of some of the long-term effects produced by the project. However, the most important contribution of the CBA exercise is to provide a framework of analysis to identify the most crucial aspects of the projects’ ex-post performance and final outcome. Qualitative analysis on the other had is more focussed on understanding the underlying causes and courses of action of the delivery process. On the basis of the findings of the ten case studies, the Final Report will draw lessons along the key dimensions identified of ‘what’, ‘when’ and ‘how’. Source: CSIL Milano

1 They are the following: What kind of long-term contributions can be identified for different types of investment in the field of environment and transport infrastructure? How are these long-term contributions generated for different types of investment in the field of environment and transport infrastructure, i.e., what is the causal chain between certain short-term socio-economic returns and long-term returns from investment? What is the minimum and average time needed for a given long-term contribution to materialise and stabilise? What are these time spans for different types of investment in the field of environment and transport infrastructure? What are the existing evaluation methods to capture a given long-term contribution for different types of investment in the field of environment and transport infrastructure?

The context and objective of the project can be considered as:

 The requirement to comply with the Urban Waste Water Directive 91/271/EEC, along with other Directives such as the Bathing Water Directive;

 The availability of very high funding rates from the EU Cohesion Fund for investments to address the requirements of the Directive; and

 The increasingly well-established need to improve water quality in Dublin Bay, independent of the requirements of the Directive, driven by increased population and prosperity.

In more detail, the project, completed in 2003, consisted primarily of a comprehensive expansion and up-grading of the Ringsend treatment plant, as well as a pumping station and underwater pipeline to carry wastewater from the north of the city to the Ringsend plant. The objective was to accommodate most of the waste water arising in the Dublin region (a human population of approximately 1.1 million) and comply with the Urban Waste Water Directive. There is also planned substantial future investment to increase capacity and cater for the sensitive status of the Liffey estuary, to be completed by 2015.

This was an exceptionally large and complex project, and at the time was the largest wastewater project grant-aided by the Cohesion Fund. The project was delivered using a Public Private Partnership (Design-Build-Operate - DBO2) procurement process, and used a number of innovative technologies to cater for the large pollution load on a constrained site (15 hectares). The public authority in charge of the project was Dublin City Council (DCC), and the concessionaire awarded the DBO contract was the ABA consortium, which included Celtic Anglian Water (CAW) as the plant operator.

The construction phase took place between 1995 and 2003. Elements of the upgraded plant commenced operations in 1999 but the plant became fully operational in 2003.

The project involved a total initial investment of EUR 297 million (2011 prices, VAT exclusive), 53% of which co-financed through the Cohesion Fund. The remaining investment cost was covered through national public contribution (37%) and contributions by large industrial users (10%). The EC contribution was primarily justified by reference to the requirement to meet the standards of the already mentioned Urban Waste Water Directive.

After the project was finalised, the designation of the Liffey estuary as a sensitive water body requiring full tertiary treatment forced to implement additional investments. A further EUR 147.3 million (2011 prices, VAT exclusive) is to be spent between now and 2015 to increase

2 Design-Build-Operate or DBO is a type of Public Private Partnership (PPP), whereby the public authority appoints a concessionaire to Design, Build and Operate a piece of infrastructure. The concessionaire is free to design the plant as they see fit, to deliver an agreed outcome. The concessionaire then builds the plant according to this design and operates the plant for a set period of time (typically 20-25 years), at the end of which the plant is transferred back to the public authority. Ownership remains with the local authority throughout. Under traditional procurement the public authority (the “employer”) designs the plant and employs a contractor to build it according to the employer’s specification. Upon completion the public authority takes over the operation of the plant.

capacity and make the plant fully compliant with the Urban Waste Water Directive. Thus the total cost of the project will be EUR 443.3 million.

OVERVIEW OF INVESTMENT COSTS AND SOURCES OF FINANCING Financing period 1995-2003 First year of operation 2003 Total investment costs (2011 prices) EUR 296 million 100% Sources of financing and co-funding rates over the total investment costs Cohesion Fund EUR 157 million 53.1% European Regional Development Fund EUR 0 0% European Investment Bank EUR 0 0% National-regional-local public contribution EUR 109 million 36.8% Private capital EUR 29.9 million 10.1%

There were no major time overruns on delivery of the project, but the whole project was subject to a cost overrun of approximately EUR 23 million, as a result of the overrun on one aspect of the project – the underwater pipeline from Sutton in north Dublin to the treatment plant.

Design capacity of the plant (originally not expected to be reached until 2020) was 1.64 million population equivalent, split roughly 70:30 between domestic and non-domestic customers. However, the plant was operating at above design capacity - 1.8 to 1.9 million population equivalent - from the day it opened. This created significant operational problems, and contributed to serious odour problems during the early years of the plant’s operations. The latter were eventually resolved, albeit at significant additional cost to Dublin City Council, which has also had to compensate the concessionaire for the above design capacity pollution load.

Current performance is satisfactory, indeed the plant is seen as a flagship for the technology used. Operation of the plant represents a significant financial burden on Dublin City Council. In particular, there are no water charges on households, although it is planned to introduce metered household water charges in the coming years. This will contribute significantly to financial sustainability of the overall public water services, as well as potentially having a moderating impact on demand. Commercial customers, whose discharges are similar in nature to domestic wastewater, currently pay a combined water/wastewater charge (EUR1.90/m3 in 2012). Industrial customers pay based on a formula in accordance with the constituents of their wastewater discharges and their licences. The formula is designed to capture the marginal cost of treating their waste water. As such, the European “polluter pays” principle3 is only partly implemented at the moment, although it is expected to be fully implemented in the coming years with the introduction of metered household charges.

3 Stated in Directive 2004/35/EEC.

Project impacts are analysed using two broad methodological approaches – quantitative (i.e. Cost Benefit Analysis) and qualitative. From an economic viewpoint (taking into account household willingness to pay for improved water quality in Dublin Bay and conversion from market to shadow prices), the project generates highly positive returns: an economic net present value of EUR 355 million and an internal rate of return of 11.7%.

There were some positive endogenous dynamics effects, particularly in terms of technological progress: many of these benefits may be mainly felt outside Ireland. The project may also have uncovered technological inadequacies, which had negative impacts on the subsequent operations of the plant, initially at least.

Social cohesion may have on balance been somewhat negatively impacted, through the impacts of the odour problems on the Ringsend district of the city, which is less well-off than the average, and sees itself as being poorly treated by Dublin City Council (a municipal incinerator is also proposed for the area, which has exacerbated this perception). On the other hand, the extension of waste water capacity facilitated increased housing and commercial development, particularly in the north of the city where development had been constrained due to lack of water services.

It can be argued that the absence of domestic water supply and wastewater treatment charges contributes to social cohesion, by avoiding financial burdens on less-well-off households, but of course this has negative consequences for both financial and environmental sustainability. Avoidance of undue burdens on households can be more efficiently achieved through general social welfare transfers.

Environmental quality was strongly enhanced by the project, with a significant improvement in water quality in the bay, and further improvement possible with the installation of increased capacity and a long sea outfall in the coming years. This has resulted in a number of beaches along the bay achieving Blue Flag status in the years since the new treatment plant opened. The absence of metered domestic water supply and wastewater treatment charges has negative consequences for environment, as economic theory indicates that this contributes to the excessive load on the plant.

The plant as designed (and as operated) is in compliance with the basic requirements of the Urban Waste Water Directive, but on designation of the Liffey Estuary as a sensitive water body in 2001, further investment (to be completed by 2015) is required to deliver full compliance.

There is limited impact on territorial cohesion, except in so far as development in Fingal County in the north of the city has been facilitated.

It is open to question whether the project had an impact on institutional quality. The project does appear to have uncovered a lack of institutional quality at local authority level, in terms of capacity to plan and design the physical plant and the Design-Build-Operate (DBO) contract.

Social happiness impacts, in terms of perception of the project, are mixed. Those using the amenity of Dublin Bay have largely positive perceptions, while the residents immediately neighbouring the plant have a negative perception due to the serious odour problems in the early years of the plant’s operations, reinforced by the current plans for a municipal waste incinerator on an adjacent site.

The assessment of the key determinants of project outcomes highlights that the context for the project was in large part highly positive, specifically inadequate or no treatment of wastewater discharges from the largest city in Ireland into an enclosed bay with a high amenity value; growing population, housing and prosperity; the Urban Waste Water Directive, which brought the requirement for improved treatment into sharp legal focus; and finally the availability of very high levels of EU grant aid for projects aimed at meeting the requirements of the Directive.

Some weaknesses were highlighted under the heading of project design, under which we would include contract design. Although the DBO procurement approach apparently enabled the accommodation of the plant on a constrained site, shortfalls in the contract design made it difficult and time-consuming to resolve operational problems and allocate responsibility.

Forecasting capacity likewise was a significant source of weakness in the project, most notably in terms of projecting the design load, which was exceeded from day one of operations. That said, the acceleration of growth during the “Celtic Tiger” period exceeded all expectations. Failure to anticipate important environmental constraints was also an issue. Between them, these have had significant consequences for the technical solution, the cost and the operations of the plant.

In general, governance for EU co-funded projects is stronger than for unfunded projects, because of the discipline imposed by EU procedures. However, it can be said that governance of this project exhibited weaknesses in many respects, most notably in respect of the forecasting issues discussed above, but also in terms of contract design.

Managerial response exhibited positive and negatives. The project had to adapt to a number of unforeseen events, albeit that many of these should have been foreseen. It appears to have been able to cater for the above design capacity demand quite well, but took a number of years – and high cost - to deal with the odour problem. A number of environmental designations that constrained the project also had to be dealt with. Positive managerial response can be seen in the construction of the Sutton to Ringsend pipeline, and in the decision by DCC to change its consulting engineers.

Looking forward, the project will involve significant further investment to increase capacity and deliver full compliance with the Urban Waste Water Directive (to be completed in 2015). The planned introduction of metered domestic water service charges in the coming years will enhance financial sustainability and should moderate demand.

A lesson from the project is to be aware of vulnerabilities with complex and innovative infrastructure projects, subject to significant constraints, in a dynamic environment. This may

be particularly problematic in contexts where technical expertise is weak, and demand data or forecasting capacity is limited.

1 PROJECT DESCRIPTION

1.1 KEY FEATURES OF THE INFRASTRUCTURE AND SERVICE DELIVERED Wastewater from most of the Dublin NUTS III Region4 is treated at the treatment plant at Poolbeg in the docks area of Dublin city. The current plant was completed in 2003, but there has been a treatment plant on the site since the early 1900s.

Poolbeg is a narrow spit of land jutting into Dublin Bay, which has been extended on either side over the years via land reclamation. It is a long-established port/industrial area; as well as the wastewater treatment plant, it is home to a gas-fired power station5, several used and unused industrial and port sites, and it is also the site for a proposed new MSW incinerator6 to serve the Dublin region. The plant site is quite constrained (covering 15 hectares), a factor that has shaped much of the evolution of the project (see further discussion in later Sections).

Figure 1.1 LOCATION OF WASTEWATER TREATMENT PLANT IN DUBLIN

Legend: Proposed Incinerator ; Wastewater Treatment Plant ; Poolbeg Power Station Source: Authors

Although situated in Poolbeg, the plant is most often referred to as the Ringsend plant or the Ringsend works (Ringsend being the most immediately adjacent district of the city - see Figure

4 Which comprises Dublin City and the administrative counties of Fingal, Dún Laoghaire-Rathdown and South Dublin. Small parts of the neighbouring counties of Kildare and Meath are also served by the plant. 5 Capacity 463MW. 6 http://www.dublincity.ie/WATERWASTEENVIRONMENT/WASTE/Pages/WastetoEnergy.aspx

1.1). “Poolbeg” and “Ringsend” are often used interchangeably in the literature when referring to the plant.

Figure 1.2 DUBLIN WASTEWATER TREATMENT PLANT

Source: Wordpress, 20107

The treatment works are the centre of a broader infrastructure project which was constructed in the 1990s to service the four main catchment areas of Dublin – north, south (Dún Laoghaire) central (Inner City/Grand Canal) and south-west (Dodder Valley) – as set out in Figure 1.3 below8. Wastewater is channelled to pumping stations in the north, central and south catchment areas from where it is pumped to the treatment plant (via underwater pipelines across Dublin Bay in the case of the north and south catchments). The Dodder Valley sewer which serves the south-west of the city drains by gravity.

7 http://conorcreighton.wordpress.com/2010/05/. 8 Some wastewater from the neighbouring counties of Kildare and Meath also accesses the treatment plant via the Grand Canal sewer.

Figure 1.3 CATCHMENT AREA FOR DUBLIN WASTEWATER TREATMENT PLANT

Source: Author’s elaboration of Dublin Corporation & MACL, DWWT Environmental Impact Statement

At the plant wastewater is treated in three main stages (see Figure 1.4)9:

 Primary: Heavy material (paper, plastics, etc.) is removed as the waste water passes through 6mm mesh screens. It passes to tanks where fats, oils and grease are allowed to float to the top, and are “skimmed” off. It then moves to the main primary lamella settlement tanks. Suspended solids are allowed to settle to the bottom and are removed. This process removes 40-50% of the pollutants10. In both processes the removed material is sent to the sludge treatment facility.

 Secondary: The waste water then passes to the Sequencing Batch Reactors (SBRs). Biological agents remove organic matter as well as reducing ammonia and nitrogen content. There are 24 SBRs at the facility and uniquely they were constructed in two storeys due to the space limitations of the site (see Figure 2.3). They are the largest of their kind in the world. Sludge is generated during this process and it is sent to the sludge treatment facility.

9 For a useful video tour of the plant, see http://www.youtube.com/watch?v=TTEz8NguqfM. 10Source: Project brochure for Ringsend Plant.

Figure 1.4 SCHEMATIC OF TREATMENT PLANT

Source: Celtic Anglian Water

 Tertiary: Finally, during the months of May to September, ultraviolet radiation is passed through the water to kill any remaining pathogens11. It is discharged into Dublin Bay, where it is further diluted by mixing with the cooling water outfall from the neighbouring power station.

The sludge undergoes thermal hydrolysis, whereby it is heated to 265°C and subjected to 10 bar of pressure. This increases the digestibility and viscosity of the material, and pasteurises it12. It then undergoes anaerobic digestion. The main outputs of this process are:

 Biogas (methane), which is used to generate electricity, which serves 40% of the plant’s power needs, and

 After subsequent drying, Biofert (a stabilised compost-like material, dried to 92% solid matter), which is supplied to farmers in the south-east of Ireland as agricultural fertiliser13.

Figure 1.5 FINAL BIOFERT PRODUCT BEING LOADED ONTO TRUCK

Source: DKM tour of the plant

Due to capacity limitations in the Anaerobic Digestion (AD) plant, a proportion of sludge does not undergo anaerobic digestion, but is dried to 24% solid matter, as “sludge cake”, which can also be spread on land as a fertiliser. Plant operators are actively working to minimise the proportion of this product produced over time, and to subject all sludge to anaerobic digestion.

1.2 CONTEXT The context for the investment can be seen as threefold:

11 UV ttreatment outside these months is considered unnecessary, as the water temperature is too low for bacteria to survive. Note the plant would not be considered a full tertiary treatment plant, as it lacks chemical nutrient (phosphorus and nitrogen) removal capability. 12 The so-called CAMBI process, which was adopted as being highly suited to a constrained site. 13 Locational usage of the biofert reflects the locational base of the contractor who removes the material as well as the land conditions which are suitable for taking the material.

 The requirement to meet the standards set out in the Urban Waste Water Directive 91/271/EEC, that wastewater from all substantial urban agglomerations should undergo at least secondary treatment before release to the environment, along with other Directives such as the Bathing Water Directive (76/160/EEC);

 The availability of very high funding rates from the EU Cohesion Fund for investments to address the requirement of the Urban Waste Water Directive; and

 The increasingly well-established need to improve water quality in Dublin Bay, independent of the requirements of the Directive. Population and economic activity grew rapidly in the Greater Dublin Area (GDA)14 over the last two decades (see below), and as a result the strain on the existing infrastructure and on the receiving environment, as well as public demands for better quality water, were increasing.

This was an exceptionally large and complex project, and at the time was the largest wastewater project grant-aided by the Cohesion fund.

The context for the project is discussed in more detail in Section 2.1.

1.3 TARGET POPULATION There are four main components of the wastewater treated at the plant:

 Domestic,

 Commercial (shops, offices, restaurants etc.),

 Industrial (large factories, including the famous Guinness brewery),

 Rainwater (most of the sewers draining to the plant carry mixed rainwater and foul water).

The design capacity of the plant is as follows, expressed in Population Equivalents (PE):

14 The Greater Dublin Area (GDA) is generally taken to comprise the NUTS III regions of Dublin and Mid-East. The Dublin NUTS III region comprises Dublin City, South Dublin, Final and Dun Laoghaire-Rathdown. The Mid-East region comprises Kildare, Meath and Wicklow.

Table 1.1 DESIGN CAPACITY OF THE POOLBEG WASTEWATER TREATMENT PLANT ('000S PE) Ringsend* North Dublin Total %age Split Human Population 831 314 1,145 69.8% Hospitals & Commuters 10 1 11 0.7% Design Margin 31 31 1.9% Industry 366 87 453 27.6% Total 1,207 433 1,640 100.0% *”Ringsend” includes all the wastewater treated at the plant with the exception of that originating from North Dublin. Source: Fehily (2008)

In rough terms the split of capacity was domestic:non-domestic in the ratio 70:30. This design capacity was expected to be reached in 2020; however, as discussed in Section 2, the plant found itself operating at in excess of design capacity from the day it opened in 2003.

As indicated, the plant serves the population of the Dublin NUTS III region, along with small parts of the neighbouring counties of Kildare and Meath (see Figure 1.6).

Figure 1.6 COUNTIES AND REGIONS IN IRELAND SERVED BY PLANT

Source: Authors’ elaboration of Andi Knight (2004)15 and volunteer.ie16

Table 1.2 and Figure 1.7 summarise the evolution of the relevant population over the last decade and a half.

15 http://www.gogolfing.ie/Maps/Ireland.htm 16 http://www.volunteer.ie/Find-Your-Local-Volunteer-Centre.html

Table 1.2 POPULATION COUNTIES IN THE PLANT’S CATCHMENT AREA, 1996 -2011 Area 1996 2011 %age Growth Dublin City 481,854 525,383 9.0% Fingal 167,683 273,051 62.8% Dún Laoghaire-Rathdown 189,999 206,995 8.9% South Dublin 218,728 265,174 21.2% Dublin (NUTS III) 1,058,264 1,270,603 20.1% Meath 109,732 184,034 67.7% Kildare 134,992 209,955 55.5% State 3,626,087 4,581,269 26.3% Source: CSO Census of Population, 1996 and 2011

The strength of population growth is clear over the period, as is the variability in that growth. Fingal, the most peripheral and least developed part of the Dublin region, to the north of the city, has experienced the strongest growth, matching that in the surrounding counties. Dublin City and Dún Laoghaire-Rathdown, the most developed parts, experienced the least growth. Notably, the Dublin region as a whole experienced less than average population growth compared to the State. This reflects a classic urban sprawl or “donut” pattern of urban development, partly caused by constraints on development in Fingal due to a lack of wastewater treatment (and water supply) capacity until the Ringsend plant upgrade was in place.

Figure 1.7 COUNTY LEVEL POPULATION GROWTH, INDEX 1991 = 100

Source: CSO Census of Population, various years

Figure 1.8 shows the trend in economic activity in the relevant NUTS III regions. The Dublin region’s outperformance is clear, as is the Mid–East region’s17 relative underperformance. Despite strong population growth in the Mid–East region, this has not been accompanied by commensurate economic growth. This is explained by the development of the region as a commuter belt for Dublin.

Figure 1.8 REGIONAL GROSS VALUE ADDED PER CAPITA (EUR , 2009 BASIC PRICES18)

Source: CSO County Incomes and Regional GDP, 2009

Evidence for an emerging strong commuting pattern can also be found in Census data (Table 1.3). There was very strong growth in total employment in the State as a whole: the numbers of people at work increased by 66% from 1991 (1.14 million) to 2006 (1.89 million). The strong growth in the workforce in Counties Kildare, Meath and Wicklow is also apparent, with cumulative growth of 123%, 133% and 87% respectively, much higher than in Dublin itself (57% increase).

Typical distances travelled to work demonstrate the development of a strong daily commuting pattern to Dublin from the neighbouring counties. Some examples are illustrative. In 1991, 19% of the working population of Kildare travelled more than 25 km to work from their home. By 2006 this figure had increased to 27%. Similarly in Meath the corresponding figure increased from 20% to 36%.

17 The “Mid – East” NUTS III region comprises the counties of Meath, Kildare and Wicklow. 18 Basic prices of goods and services, similar to factor cost, are the value received by the producer, as opposed to the market prices of goods and services, which are the prices paid by consumers. In essence, basic prices plus product taxes less product subsidies equal market prices.

1.4 CURRENT PERFORMANCE The construction of the plant has resulted in significant environmental benefits. The quality of water in Dublin Bay has notably improved and this has resulted in a number of beaches along the bay achieving Blue Flag19 status in the years since the new treatment plant opened, namely:

 Dollymount strand20, the nearest beach north of the treatment plant (Figure 1.9);

 Portmarnock, (north-side)21;

 Seapoint22 (south-side); and

 Killiney (south-side).

It should be noted however that these beaches have from year to year lost and regained their blue flag status23.

Figure 1.9 DOLLYMOUNT STRAND, WITH POOLBEG POWER STATION IN BACKGROUND

Source: Sarah777 (2007)24

Table 1.4 shows the reduction of faecal coliforms at key points in the bay over last 25 years. A number of samples were taken for each period and summary statistics are presented.

19 http://www.blueflag.org/ 20http://www.dublincity.ie/Press/PressReleases/PR2009/PressReleasesJune2009/Pages/Dublin'sDollymountStrandretainsBlueFlag AwardandGreenCoastAward.aspx. 21 http://www.independent.ie/national-news/top-beaches-fail-to-retain-blue-flag-despite-300m-investment-2220666.html 22 http://www.labour.ie/niamhbhreathnach/news/12018137651010311.html. 23 Dollymount strand lost its Blue Flag in 2011, based on water quality standards achieved in 2010, but we understand it is on course to regain the status in 2012, based on 2011 standards achieved. 24 Picture originally uploaded and released into the public domain by its author at en-wikipedia (http://en.wikipedia.org/wiki/File:IMGDollymountStrand_3649w.JPG).

Table 1.3 FAECAL COLIFORM READINGS DUBLIN BAY, 1986 - 2005 1986 1987- 2000 2003 2005 1988 Sandymount/Merrion Strand Minimum 2 0 10 18 36 Median 92 141 60 364 119 Maximum 9,200 4,860 46,600 800 430 Bull Wall Minimum 220 40 10 18 18 Median 3300 1560 480 91 27 Maximum 18,000 24,080 100,000 1,800 270 Dollymount Strand Minimum 10 0 65 27 9 Median 127 230 234 96 23 Maximum 51,000 11,360 2,300 636 191 Source: Dublin City Council; Environmental Research Unity (1991)

It is clear that the maximum readings, and in most cases in the minimum and median readings, have fallen dramatically since the plant opened in 2003.

However, since the plant opened it has operated above its original design capacity. It was designed for a PE of 1.64 million (Table 1.1)25, but typically has been receiving and processing volumes of approximately 1.9 million PE26.

The operations of the plant have not been without problems. Apart from the over-loading of the plant, there was a serious odour problem in the early years of operation27, which particularly affected residents in the nearby Ringsend and Sandymount districts (Figure 1.1). This required additional investments to confine the odour emissions within the plant. These works were completed in November 200828 and resulted in a dramatic drop in complaints from nearby residents (Figure 1.10). Plans are now underway to upgrade the capacity of the plant to 2.4 million PE to address the overloading29; this is expected to be operational by 2015.

25 The original design incorporated the ability to increase capacity to 2.4 million PE in the future. 26 “Ringsend sewage plant overall to cost EUR220m” http://www.irishtimes.com/newspaper/ireland/2011/1003/1224305144991.html. 27 See more detailed discussion later. 28http://www.dublincity.ie/WATERWASTEENVIRONMENT/WASTEWATER/RINGSEND%20WASTE%20WATER%20TREATMENT/Pages /RingsendWasteWaterTreatment.aspx. 29 The up-graded capacity of the plant is sometimes quoted as 2.1 million PE. This refers to “firm capacity”, i.e. capacity when the single largest piece of plant in the works is not working. When all plant is working properly the facility will be capable of catering for 2.4 million PE when upgraded.

Figure 1.10 NUMBER OF ODOUR COMPLAINTS RECEIVED ATTRIBUTABLE TO THE PLANT30

140

120

100

juil.-03 juil.-08

mai-04 mai-09

juin-06 juin-11

avr.-07

oct.-04 oct.-09

déc.-03 déc.-08

nov.-06 nov.-11

févr.-08

août-05 août-10

janv.-06 janv.-11

sept.-07

mars-05 mars-10

Source: Dublin City Council

30 DCC indicates that the high level of complaints in 2007 is attributed to mechanical problems with one of the sludge dryers which was subsequently upgraded.

Box 1.1 KEY METRICS AND CONCEPTS IN WASTEWATER TREATMENT31 BOD (Biochemical Oxygen Demand) and COD (Chemical Oxygen Demand) – Polluted water contains both biodegradable and non-biodegradable polluting matter which will deplete oxygen levels in the water thus making it uninhabitable for marine life. BOD measures the amount of dissolved oxygen needed by aerobic biological organisms to break down the organic polluting matter in the water. COD measures the oxygen depletion by both biodegradable and non-biodegradable polluting matter, and so will typically be a higher number than BOD.

Testing for BOD is carried out by the BOD5 test by measuring the dissolved oxygen concentration before and after the incubation of a sample at 20C for five days in the dark. Testing for COD is much quicker (three hours) so is more useful as a quick indicator of the level of water pollution. The Environmental Protection Agency (EPA) stipulates that after secondary treatment the water should have a BOD of no higher than 25mg/l, and a COD of less than 125mg/l. The EPA indicates that typically before treatment wastewater has a BOD of 100–300 mg/l, and a COD of 250–800 mg/l. TSS (Total Suspended Solids) – This is the sum of organic and inorganic particulate matter in the water, including sand, gravel, silt, human and other solid waste. The EPA indicates that polluted water has TSS level of 100–350 mg/l and requires clean water to have a concentration of less than 35 mg/l. Population equivalent (PE) – Wastewater comes from a number of sources, including domestic, commercial and industrial. PE is the metric that allows comparison between the various sources, converting them to a single equivalent number. Regulations (and Directive 91/271/EEC) define one population equivalent as the load resulting in a BOD of 60g.

Daily organic load – A compound measure of the total volume of wastewater passing through a treatment plant which takes into account both the volume and pollution concentration of the waste water. It is defined as Organic load (kg/day) = Daily flow (m3/day) x BOD (mg/l) 1,000 Faecal Coliforms – (for example E. Coli) Indicative of water contamination by sewage, and thus the possibility of the presence of pathogenic bacteria and viruses. It is a key variable to gauge the threat bathing waters are to human health. Typically unpolluted waters should show very low counts, but small numbers may be present due to waste from birds and wild mammals. Densities in excess of 2000 organisms per 100ml would indicate an appreciable level of contamination32. Eutrophication – enrichment of water by nutrients, typically nitrogen and phosphorous compounds, causing accelerated algal growth which leads to oxygen depletion in the water to the detriment of other water plant and animal life.

Source: Authors

The plant as designed (and as operated) is in compliance with the basic water quality requirements of Directive 91/271/EEC. However, on foot of the regular reviews required under the Directive, the Liffey Estuary was designated as a sensitive area in 2001, which means that

31 Unless otherwise indicated the source for the data in this table is http://www.epa.ie/downloads/advice/water/wastewater/EPA_water_%20treatment_manual_primary_secondary_tertiary1.pdf 32 Dublin Bay Water Quality Management Plan – Technical Report 5 – Water Quality Surveys (1991).

current discharges into Dublin Bay from the plant do not meet the required standards (full tertiary treatment with nutrient removal). Because of the constraints on the site, it has been concluded by DCC and their consultants CDM that the most feasible means of meeting the terms of the Directive is to build a 9 km underwater tunnel from the plant to discharge the treated wastewater beyond the sensitive waters area. A similar solution has been applied in a number of cities around the world, including Barcelona, Boston, Lisbon, Miami and Sydney33.

The construction of this tunnel will be undertaken in conjunction with the works to expand the plant’s capacity. The plant’s licence from the Environmental Protection Agency requires it to meet the standards of Directive 91/271/EEC by 2015. It should be noted that these plans are subject to the approval by the EPA of the Environmental Impact Statement, which is currently in draft form.

DCC’s site engineer indicates that while the capital cost of the tunnel is higher than installing nutrient removal on site, when operating costs are taken into account it is less expensive in the long run. Full tertiary treatment would also increase the sludge output of the plant, greenhouse gas emissions, chemical usage and energy usage34.

The decision to build a tunnel rather than a seabed pipeline is based on the need to avoid delays and cost escalations in construction, as happened with the underwater pipeline from the Sutton pumping station to the Ringsend plant, due to inter alia the discovery of a shipwreck on the route. The need to minimise environmental damage to sea life was also a consideration. According to the engineer, “there are hundreds of shipwrecks in Dublin Bay”.

The overloading of the plant has also had financial consequences for Dublin City Council, which has had to pay additional fees to the operators of the plant, Celtic Anglian Water as compensation for dealing with the extra load35. DCC also ended up having to pay for the bulk of the works to deal with the odour problem.

33 http://www.dublincity.ie/WaterWasteEnvironment/WasteWater/RingsendWastewaterTreatmentWorksExtension/Documents/Du blin_Bay_Project_Brochure(Final_Phase).pdf 34http://dublincity.ie/WaterWasteEnvironment/WasteWater/RingsendWastewaterTreatmentWorksExtension/Documents/Ringse nd_FAQs%5b1%5d.pdf 35 http://www.rte.ie/news/2008/0630/waste.html

Figure 1.11 AREAS (IN YELLOW) TO BE USED ON THE CURRENT SITE FOR THE PLANT’S PROPOSED CAPACITY EXPANSION

Source: Dublin City Council

2 ORIGIN AND HISTORY

2.1 CONTEXT FOR THE PROJECT Until the early 1990s the treatment plant at Ringsend only offered primary treatment for wastewater generated in its catchment area, which at that point comprised only the central city area. The waste sludge generated at the plant was loaded onto ships and dumped in the Irish Sea untreated. The original plant was constructed in 1906 and designed for a population of 325,00036; it replaced the previous practice of directly discharging wastewater into the River Liffey. However, outside of the catchment of the plant, wastewater was still discharged untreated, into either the various rivers running through Dublin or into the sea at Dublin Bay.

As the city population rapidly expanded in the 1940s and 1950s, the central sewers of the city became overloaded37. These pressures were relieved with the completion in 1958 of the North Dublin Drainage Scheme38.

In 1975 the Dodder Valley sewer was built, collecting wastewater from the city’s southern suburbs (including Dundrum, Templeogue and the rapidly expanding suburb of Tallaght) and sending it to Ringsend for primary treatment. Previous to this, raw sewage from these districts had been discharged to the Dodder River.

Sewage generated in the Northern and Dún Laoghaire areas was collected at outfall points on the coast and discharged largely untreated into the Irish Sea (apart from some rudimentary screening).

Pollution in Dublin Bay became an increasingly important issue of public debate in the 1980s39. The quality of the water was the subject of much criticism40, including concerns that swimming in the area could cause serious health problems such as gastroenteritis41. The polluted nature of the bay was referred to in environmental debates in the Irish parliament, with specific references to waste material washing up on beaches along the coast42.

36 http://www.greaterdublindrainage.com/history-of-dublin-drainage/. 37 Irish Times 20th Many 1950 “Growth of Dublin causes alarm” http://www.irishtimes.com/newspaper/archive/1950/0520/Pg003.html. Irish Times 15th November 1952 “Housing sites difficulty met” http://www.irishtimes.com/newspaper/archive/1952/1115/Pg004.html. Irish Times 9th March 1955 “Minister outlines new draining scheme for Dublin” http://www.irishtimes.com/newspaper/archive/1955/0309/Pg007.html. 38 Dublin Corporation and McCarthy Acer Consultants Ltd (1993). 39Irish Times 23rd June 1988 “Flynn approves sewage pipeline for Dublin Bay” http://www.irishtimes.com/newspaper/archive/1988/0623/Pg009.html. 40Irish Times 19th January 1988 “Dublin Bay ‘safer than swimming pool’ http://www.irishtimes.com/newspaper/archive/1988/0119/Pg004.html . 41 Irish Times 20th July 1984 “Dublin bay dump for a city’s rubbish” http://www.irishtimes.com/newspaper/archive/1984/0720/Pg013.html. 42 http://historical-debates.oireachtas.ie/D/0395/D.0395.199002140093.html http://debates.oireachtas.ie/dail/1986/05/06/00032.asp.

In general it was felt that Ireland as a whole complied reasonably well with the 1976 Bathing Water Directive, but the Dublin was an exception43.

Review of the media of the time conveys a sense that the public authorities and Government were failing to keep up with public opinion with regard to the environment. That said, it should also be noted that a European survey at the time found “the Irish, once again least concerned about environmental matters”44 (see also Figure 2.1).

Figure 2.1 AVERAGE WILLINGNESS TO TAKE ACTION TO PROTECT THE ENVIRONMENT AS A FUNCTION OF PER CAPITA GDP, BY COUNTRY (1986)

Source: Europeans and their Environment (1986)

The general perception was that local authorities, who had primary responsibility to protect Ireland’s environmental assets, lacked the capacity for the task45. Calls were made by senior civil servants to establish a statutory authority to regulate environmental matters46.

43 Irish Times 26th August 1988 “Clean bill of health this week for all beaches” http://www.irishtimes.com/newspaper/archive/1988/0826/Pg006.html. 44 Irish Times 5th May 1987 “Europe’s grubby relations” http://www.irishtimes.com/newspaper/archive/1987/0505/Pg019.html. 45 See Callanan and Keogan (2003) page 266. Also see Irish Times 18th August 1986 “Councils unlikely to take over water pollution control” http://www.irishtimes.com/newspaper/archive/1986/0818/Pg008.html. 46 Irish Times 23rd January 1986 “New agency proposed to protect the environment” http://www.irishtimes.com/newspaper/archive/1986/0123/Pg005.html.

In a bid to maintain pressure on the Department of the Environment (DOE)47 to deal with discharges from the Ringsend plant, environmental groups attempted to show that sewage from Ringsend was being deposited on Dollymount strand48.

Around this time, the bodies representing spatial planners in Ireland took the unusual step of criticising the “inadequate” approach of the Minister of the Environment in implementing EU Directives on Environmental Impact Assessments49.

The economic context at the time was also relevant. During the 1980s Ireland experienced a severe recession and fiscal crisis. The State body at the time that conducted environmental research and provided environmental information was An Foras Forbartha (AFF). But in the late 1980s it was proposed to abolish this agency in the context of “a radical reduction in (public) expenditure”50 51. AFF was absorbed into the Department of Environment, to form the Environmental Research Unit (ERU), but crucially was not thereafter allowed to make its research public without the consent of the DOE, thus effectively losing its independence52. This move was understandably criticised by environmental groups.

In 1989 there was a general election in Ireland, and the dominant political party, Fíanna Fáil (FF), was forced to form a coalition with a new smaller party the Progressive Democrats (PDs). Here, it appears was the impetus to give environmental matters more consideration53. The Joint Programme for Government promised the formation of an Environmental Protection Agency (EPA) to enforce and monitor environmental standards and also to inform the public. Ms Mary Harney, the new junior minister for the environment, was described thus in the media:

“One thing that marks out Mary Harney from most of her predecessors in the Custom House is her refusal to treat environmentalists as cranks or weirdos. When she talks about the “scandal” of sewage in Dublin Bay, she sounds like one of them rather than a Minister charged with responsibility to do something about it”.

47 Over the years this government department has undergone numerous name changes. Pre-1977 it was the “Department of Local Government”. In 1977 it was renamed the “Department of the Environment”, in 1997 it was renamed the “Department of the Environment and Local Government, in 2003 it was renamed the “Department of the Environment, Heritage and Local Government, and finally in 2011 it was renamed the “Department of the Environment, Community and Local Government”. 48Irish Times 14th November 1988 “Group to trace flow to sewage from Ringsend” http://www.irishtimes.com/newspaper/archive/1988/1114/Pg011.html. 49 Irish Times 29th July 1988 “Flynn action on EC order criticised by planners” http://www.irishtimes.com/newspaper/archive/1988/0729/Pg008.html. 50Irish Times 26th October 1987 “’Liquidation’ of Foras Forbartha” http://www.irishtimes.com/newspaper/archive/1987/1026/Pg010.html. 51 This period was characterised by harsh fiscal budgets to control the national debt, and the finance minister of the time, Mr Ray MacSharry, later to become EU Agriculture and Rural Development Commissioner, was popularly known as “Mac the Knife” for his severe fiscal cutbacks. 52Irish Times 10th September 1988 “Foras staff made to sign pledges on secrets Act” http://www.irishtimes.com/newspaper/archive/1988/0910/Pg001.html. 53Irish Times 13th November 1989 “Watchdogs with real teeth – or white elephants?” http://www.irishtimes.com/newspaper/archive/1989/1113/Pg015.html

Irish Times 13th November 198954

A major evolution in Irish Government thinking came with the publication of the Environmental Action Programme in 1990, albeit largely in anticipation of policy changes at EU level. Inter alia, this programme:

 Acknowledged the significant increase in environmental awareness among the public;

 Proposed to establish Enfo55, a public environmental information service;

 Committed to ending the dumping of sewage sludge at sea by 1998, and to develop alternative sludge treatments;

 Committed to eliminating untreated sewage discharges at sea by 2000;

 Committed to the construction of a new sewer in Dublin to eliminate sewage discharges to the River Poddle;

 Directed DCC to prepare plans for secondary treatment of sewage at Ringsend;

These developments were given extra momentum by the commitment of funding by the EU for scientific studies into water quality in Dublin Bay56. Issues regarding the public availability of information on drinking water quality were also emerging in media during this time57.

In 1991 a pumping station at Dún Laoghaire was completed which transferred untreated sewage from the south eastern suburbs of the city to the Poolbeg plant via an underwater pipeline across Dublin Bay58 59. At the same time interim works at Ringsend were carried out to provide capacity to deal with this increased demand.

Notwithstanding growing public dissatisfaction with water quality, the key catalyst for change was the Urban Wastewater Directive 91/271/EEC60, which made secondary treatment mandatory for Dublin, and meant that the dumping of untreated sewage and primary sludge into water bodies would be prohibited from 1998.

54 By contrast, the senior Minister for the Environment at the time, Mr Pádraig Flynn, in a TV interview, infamously described the environmental movement as “political queers”. A radio programme of the time satirised Mr Flynn’s conservatism in a sketch entitled “The Flynnstones”. 55 www.enfo.ie 56 Irish Times 6th February 1990 “EC to help fund pollution protection in Dublin Bay” http://www.irishtimes.com/newspaper/archive/1990/0206/Pg008.html 57Irish Times 8th February 1990 “Minister urged to act on aluminium in drinking water” http://www.irishtimes.com/newspaper/archive/1990/0208/Pg009.html Irish Times 9th February 1990 “Department denies secrecy over water quality data” http://www.irishtimes.com/newspaper/archive/1990/0209/Pg008.html 58Irish Times 23rd June 1988 “Flynn approves sewage pipeline for Dublin Bay” http://www.irishtimes.com/newspaper/archive/1988/0623/Pg009.html. 59 Subsequently an untreated outfall at Bullock Harbour slightly further south was also diverted to the Dún Laoghaire pumping station for eventual treatment at Ringsend. In 2008 the sewage outfall at Coliemore Harbour (PE 1,000) was similarly discontinued. http://www.erbd.ie/Reports/CR/Section7.pdf 60http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:1991:135:0040:0052:EN:PDF.

Box 2.1 KEY ELEMENTS OF THE URBAN WASTEWATER DIRECTIVE 91/271/EEC The Directive61 sets out a number of scientific criteria and definitions for the treatment of Urban Wastewater and assigns responsibility in rather general terms to suit local procedures in each Member State.  One Population Equivalent (PE) is defined as the organic biodegradable load having a five-day Biochemical Oxygen Demand (BOD5) of 60g of oxygen per day.  Primary and secondary treatment is the minimum standard of treatment for all population agglomerations with a population greater than 10,000. Water quality discharges from plants must satisfy the following standards:

Parameter Concentration % Reduction from incoming load

BOD5 25 mg/l 70%-90% Chemical Oxygen demand (COD) 125mg/l 75% Total Suspended Solids (TSS) 35mg/l (optional) 90%

 In addition to these requirements, Member States have the option to identify water bodies as “sensitive” to eutrophication from treatment plant discharges. Areas deemed sensitive must comply with the following standards62 (for PEs greater than 100,000).

Parameter Concentration % Reduction from incoming load Total Phosphorus 1mg/l 80% Total Nitrogen 10mg/l 70%-80%  Member States were given until 31st December 1993 to identify water bodies sensitive to eutrophication. These classifications were to be reviewed every four years thereafter. Once a sensitive classification is made by the national authorities they must ensure compliance with the additional standards within seven years.  Member States could also designate water bodies as “less sensitive”, thus requiring only primary treatment, but these had to be subject to regular review.

Source: Authors

Several environmental studies were underway during this time, most notably the Dublin Bay Water Quality Management Plan (DBWQMP). Local opinion was generally favourable to the plant upgrading to deal with pollution in the bay.

One issue, prominent in the media at this time63, was whether the proposed upgrade of the plant should incorporate full tertiary treatment (i.e. nutrient removal). Environmental groups were in favour of tertiary treatment, while the authorities favoured secondary treatment only. A number of studies were conducted at the time to assess the “sensitivity” of the bay in terms of Directive 91/271/EEC, including:

 Technical Report 7 of the DBWQMP; and

61 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:1991:135:0040:0052:EN:PDF 62 The technical interpretation of these standards was amended by directive 98/271/EEC. 63Irish Times 11th August 1992 “Sewage shortfall holds up north Dublin progress” http://www.irishtimes.com/newspaper/archive/1992/0811/Pg007.html.

 Wilson et al., (1993) “Particulate Nutrient Inputs and their role in Macro-algae Development in Dublin Bay”.

They concluded that secondary treatment would be adequate for the bay, and would remove sufficient nutrients to eliminate eutrophication, but acknowledged that this was subject to review in the future.

The issue of what level of treatment was to be provided at the plant took on a further political dimension as elected councillors in Dublin Corporation passed a motion in 1994 calling on the Minister of the Environment to designate the Liffey estuary sensitive64. However, the Corporation did not have the resources to upgrade the plant, and was dependent on the Department (and the EU) to fund investments, so the DOE effectively had the power to decide the level of treatment to be adopted65.

At the same time it emerged that the Corporation intended to discontinue plans for a separate treatment plant at Baldoyle, and instead to transfer wastewater from the north of the city to Ringsend for treatment (see further discussion below). This increased local resentments in Ringsend and Sandymount. According to the councillors, this strengthened need for tertiary treatment, as increased levels of discharge by the addition of the north Dublin catchment would “destroy” the local amenity of Sandymount Strand, as well as damaging Bull Island and the inner bay66.

When Directive 91/271/EEC was incorporated into Irish law in December 199467, ten water bodies were deemed “sensitive”, comprising a mix of lakes and rivers (including a portion of the river Liffey), but no estuaries. The omission of the Liffey estuary was again criticised in the media68.

Our search of the archives at the DECLG indicates that uncertainty surrounding the scientific evidence regarding the causes of eutrophication in the bay, combined with a desire to spend EU funds wisely and in a timely fashion, was the key logic behind the decision not to designate the Liffey estuary as sensitive in 1994. Extracts from an internal communication69 at the department are indicative:

“All available evidence and studies point to the association between particulate nitrogen and macroalgal growth. As a consequence, the most effective strategy would be to achieve a reduction in the average particulate nitrogen load entering the Bay through the provision of secondary treatment.”

64 Irish Times 27th June 1994 “Councillors cite EU in demand for sewage plan” http://www.irishtimes.com/newspaper/archive/1994/0627/Pg002.html. 65 The matter was raised in parliament when the original plant up-grade was being debated, in the mid-1990s http://debates.oireachtas.ie/dail/1995/02/02/00012.asp. 66 Irish Times 27th June 1994 Op. Cit.. 67 http://www.irishstatutebook.ie/1994/en/si/0419.html. 68Irish Times 28th December 1994 “Sewage treatment designations criticised” http://www.irishtimes.com/newspaper/archive/1994/1228/Pg003.html. 69 “Sewage Treatment Requirements for Dublin” note addressed to Dr. T. Collins, special advisor to the Minister for the Environment from F. Gallagher, Water Quality Section 18th January 1995. Reproduced with permission.

“Apart from the water quality considerations outlined above, the financial implications in providing treatment facilities in Ringsend should also be borne in mind.”

“The estimated cost of the Dublin facilities at a minimum of £250 million70 must be seen in the context of the total cost of meeting the requirements of the Directives and limitations on the future availability of funds. The current estimated cost to end 2005 of implementing the Directive is £1.15 billion.”

“Apart from the need to develop an alternative to dumping sewage sludge in Dublin Bay by end 1998 (estimated cost £30 million) and the need to provide for more stringent than secondary treatment in respect of the recently designated 10 sensitive areas (estimated cost £52 million), the most critical deadline for us from the point of view of implementing the requirements of the Directive is end 2000.”

“The above requirements must be viewed in the context of future provision for expenditure of sewerage services. Under the National Development Plan expenditure on these services between 1994 and 1999 is projected at £335 million. This is clearly a long way short of requirements and provides a focus for consideration of demands for costlier solutions to treatment requirements where serious evidence of need has not been established.”

In the early 1990s, planning commenced for upgrading to secondary treatment at Ringsend. In 1993 Dublin Corporation71 with consultant engineers McCarthy Acer Consultants Ltd (MACL) published the Ringsend Sewage Treatment Works Expansion – Preliminary report. Population and wastewater projections were generated to the year 2040, based on Census data from 1991. The report outlined the next steps needed in the project’s lifecycle, as follows:

 Completion of the Environmental Impact Statement;

 Arrangement of funding;

 Procurement of site and land reclamation works72; and

 Commencement of detailed designs.

At the same time plans were drawn up to deal with north Dublin’s wastewater (then being discharged largely untreated from the nose of Howth), in the context of Directive 91/271/EEC. In September 1994 Dublin Corporation with MC O’ Sullivan & Co. Ltd Consulting Engineers (MCOS) published the North Dublin Drainage Scheme Catchment Area Study – Preliminary Report.

A range of options was considered, from a separate secondary treatment plant to be built at Baldoyle, a greenbelt area in the north of the city, to an underwater pipeline to the Ringsend

70 Fixed exchange rate is IR£1 = EUR 1.27. 71Changed to Dublin City Council (DCC) in 2001 http://www.dublincity.ie/YOURCOUNCIL/ABOUTTHECOUNCIL/Pages/DublinCityCouncilHistory.aspx. 72 At that time part of the proposed site was actually in the sea.

plant via a pumping station at Sutton that would take all of the wastewater from the north of the city. A number of intermediate options foresaw a treatment plant at Baldoyle combined with some piping of wastewater to the Ringsend plant, but were dismissed on financial grounds. The report did not make a recommendation as between the two main options – a separate plant at Baldoyle or expansion of Ringsend to accommodate the wastewater from the entire Dublin catchment.

Newspaper articles at the time73 74 75 reported that local residents and councillors at Baldoyle were not willing to accept the plant because a flooding problem in the area over the previous thirty years had never been addressed, and also because of a desire for the area to remain undeveloped (it was zoned greenbelt).

Considering the capital costs of the options outlined in the 1994 Preliminary Report, the Baldoyle option had the lowest capital cost. However, when Dublin Corporation and MACL published the Ringsend Wastewater Treatment Plant Works Expansion – Supplementary Report (1995), a single plant at Ringsend was the only treatment option considered.

The EIS of the project lists a number of reasons for the rejection of the option of a separate plant at Baldoyle, namely76:

 Additional pipework necessary for the Baldoyle option.

 Stormwater overflows would discharge into Sutton Creek.

 Negative landscape impacts due to the elevation of the proposed site.

 The sludge generated at Baldoyle would have to either be treated separately or piped to Ringsend for additional treatment, thus incurring additional operational costs.

 A second large-scale high technology plant in Dublin would result in higher overall operating costs.

Perhaps most tellingly, the EIS indicates:

“A single works can be planned at Ringsend and procured in the site of the existing works, within the timetable set down in the EU Wastewater Directive and S.I. 419. A second works at Baldoyle would involve a major planning process. Including site acquisition planning approval on lands zoned agricultural. This process would have a higher risk of failure to satisfy the deadline.”

73 Irish Times 31st July 1993 “Baldoyle seen as likely site for new £32 m sewage treatment works” http://www.irishtimes.com/newspaper/archive/1993/0731/Pg004.html. 74 Sunday Business Post 2nd May 1993 “Sewage farm may be for Baldoyle”. 75 Irish Independent 3rd May 1993 “Council may want green belt site for sewage plan”. 76 Drawn from an internal DECLG report on the Environmental Impact Assessment of the Ringsend Treatment Works.

It is also worth noting that, when in 1997 the Environmental Impact Statement (EIS) was approved for the plant by the Minister for the Environment, it was stipulated that the design and layout of the plant should allow for denitrification facilities to be installed if it was later proved necessary (i.e. that further research would show that the Liffey Estuary was sensitive to eutrophication).

DCC personal indicate that allowances were made in the SBRs to have de-nitrification facilities installed as a contingency for the Liffey being deemed sensitive. However, this would reduce the capacity of the works.

A further relevant development was that in 1994 the Irish Government designated a substantial section of Sandymount Strand, close to the site to be reclaimed, as a Special Protection Area (SPA) in accordance with the EU Birds Directive 79/409/EEC77. The 1995 Supplementary Report states that:

“Because of anticipated consequent difficulties in obtaining permission to use this site, DC (Dublin Corporation) decided to assess the feasibility of using only the existing Ringsend STW (sewage treatment works) site for a compact secondary treatment works. This solution was found to be feasible and DC then commissioned the SR (supplementary report) on the basis that this existing site would accommodate the complete proposed works”. (p.5/6).

Interviews with DECLG technical staff indicate that a “market testing” exercise was undertaken, whereby leading international firms in the sector were asked to confirm that the required treatment plant could be built on the site, and all those consulted agreed that it was feasible. Interestingly, the DECLG interviewee added that:

“It (building a single plant on the Ringsend site) was only feasible using Design-Build-Operate. Traditional design is inherently conservative. A traditional design would never have been put on that site.” 78

The decision to proceed with the single plant option had a number of design consequences, including:

 The Sequence Batch Reactors (SBRs), where waste water is subjected to secondary (bacteriological) treatment, were built in two storeys to save space (see Figure 2.2).

 An important consequence of up-grading from primary to secondary wastewater treatment is that it leads to a significant increase in the volume of sludge generated. In

77 http://www.irishstatutebook.ie/1994/en/si/0059.html The “Birds Directive” has subsequently been replaced by 2009/147/EC 78 Design-Build-Operate or DBO is a type of Public Private Partnership (PPP), whereby the public authority appoints a concessionaire to Design, Build and Operate a piece of infrastructure. The concessionaire is free to design the plant as they see fit, to deliver an agreed outcome. The concessionaire then builds the plant according to this design and operates the plant for a set period of time (typically 20-25 years), at the end of which the plant is transferred back to the public authority. Ownership remains with the local authority throughout. Under traditional procurement the public authority (the “employer”) designs the plant and employs a contractor to build it according to the employer’s specification. Upon completion the public authority takes over the operation of the plant.

addition, the dumping of untreated sludge was to be discontinued. A key issue in the plant’s design therefore was how sludge was to be processed and disposed of. As a result, it was decided to adopt the CAMBI thermal hydrolysis process79, which subjects the sludge to temperatures of 265°C and 10 bar of pressure, and facilitates subsequent anaerobic digestion. This was novel technology however, and had never before been used on such as scale. To quote the Fehily (2008) in his review of the plant:

“This process is relatively new, and the Dublin plant was the biggest plant of its kind to be built anywhere in the world. The first Cambi plant was built in Norway in 1996 and had only one- tenth the capacity of the Dublin plant.” (p.54)

Figure 2.2 FIRST AND SECOND STOREY SEQUENCE BATCH REACTORS, RINGSEND WASTE WATER TREATMENT PLANT

Source: DKM tour of plant

Other consequences flowed from this decision, which had impacts subsequent to the commissioning of the plant, as are discussed later.

As indicated, it was decided to procure the plant using the Design-Build-Operate (DBO) format in view of the complexities and site characteristics, and a 25-year concession was offered. The contact was awarded to ABA consortium, comprising:

 Ascon (construction firm)80,

 Black & Veatch (plant designers and suppliers)81 and

 Anglian Water International82,

79 For background on the CAMBI process, see http://www.cambi.no/wip4/ , http://www.seai.ie/Archive1/Files_Misc/JaneBickerstaffeCelticAnglianWater.pdf, and http://www.cambi.no/photoalbum/view2/P3NpemU9b3JnJmlkPTIxOTg3NiZ0eXBlPTE. 80 Now BAM Contractors (http://www.asconrohcon.com/live/index.html). 81 http://www.bv.com/. 82 http://www.anglianwater.co.uk/.

Anglian now operates the plant via Celtic Anglian Water (CAW)83, a 50:50 joint venture with National Toll Roads84.

Construction commenced in 1998 and the upgraded plant opened in 2003.

Box 2.2 KEY EVENTS IN DEVELOPMENT OF THE DUBLIN REGION’S WASTEWATER TREATMENT INFRASTRUCTURE 1881 – Rathmines and Pembroke Scheme – Drainage for wastewater from south east Dublin completed. 1906 – Opening of Ringsend Primary Treatment Plant. 1958 – North Dublin Drainage Scheme – interceptor sewers built to discharge raw sewage off the Nose of Howth. 1975 – Dodder Valley Drainage Scheme – diverting sewage from Dundrum, Templeogue and Tallaght to Ringsend plant, previously discharged untreated to the River Dodder. 1982 – Grand Canal Scheme. Connected the Blanchardstown sub-catchment area to Dublin’s Central catchment area. 1986 – Completion of drainage works for Tallaght, Lucan, Clondalkin and Blanchardstown areas to Ringsend for primary treatment. Rathmines and Pembroke areas also connected to treatment works at Ringsend; previously raw sewage from these areas was discharged into Dublin Bay. 1990 – Irish government publishes Environmental Action Programme, a comprehensive programme to deal with management of the environment, contains the provision to ban the dumping of raw sewage in Irish coastal waters in major urban areas by the year 2000, in line with Directive 91/271/EEC. 1993 – Dun Laoghaire Main Drainage Scheme – pumping station and underwater pipeline to Ringsend treatment plant. 1992 – Dublin Bay Water Quality Management Plan published by Dublin local authorities. 1997 – Environmental Impact Statement choosing the single option of treating all of Dublin’s wastewater is approved by the Minister of the Environment 2001 – Completion of underwater pipeline from Sutton (North Dublin) to Ringsend. 2001 – EPA publishes “An Assessment of the Trophic Status of Estuaries and Bays in Ireland”, recommending that the Liffey Estuary is “sensitive” to eutrophication 2003 – Opening of new Ringsend wastewater treatment plant. Source: Authors

2.2 KEY STAKEHOLDERS AND MANAGEMENT STRUCTURES A schematic of the key stakeholders involved in the delivery of the new infrastructure is set out in Figure 2.3. Institutional and management structures evolved over the timeframe of the project, and this is reflected in the diagram. The main stakeholders and their roles are discussed below.

The EU Commission with the Irish Government are the providers and controllers of funding, via the Department of Finance. The next level is the Department of the Environment, Community and Local Government (DECLG), which was jointly in charge of delivery of the Operational Programmes with other Government Departments.

At the next level are the Local Authorities, who are the water drainage authorities in Ireland (as well as the planning authorities), and are responsible for providing and maintaining all

83 http://www.caw.ie/. 84 http://www.nationaltollroads.ie/.

drainage infrastructure within their territories. The relevant Local Authorities were Dublin Corporation (later Dublin City Council) and Dublin County Council (which in 1994 was split into Fingal, Dún Laoghaire-Rathdown and South Dublin County Councils), and Meath and Kildare County Councils.

Figure 2.3 CHART OF STAKEHOLDERS

EU Supreme Irish Court Commission Government

Department of Finance

High Court Department of Environmental the Environment, Protection Community and Environmental Agency Local NGOs Government (Founded 1992)

Planning Other Local Dublin City Appeals Authorities Council Board

ABA Celtic Consortium Anglican Recreational Local Water Users of Bay Residents

Key: Contractual Relationships Provides licenses for the discharge of waste material, enforces and monitors those licenses Provides judicial recourse in planning process Provides judicial oversight in planning process Disperses funds, provides policy guidance Principal stakeholders in planning approval process Informs public on environmental issues, allows input in license approvals Writes EU wide national directives to be transposed into Irish Law Transposes EU directives into Irish Law Elects councilors, accepts lobbying Source: Authors

Statutory responsibility for water management and protection rests primarily with local authorities. The Water Pollution Acts, 1977 and 1990 and regulations made thereunder, including regulations giving effect to EU Directives, constitute the main national legislation in this regard. However, as local authorities have limited tax-raising powers, they must invariably secure funding from central government for capital investment in waste water (and other) infrastructure.

Since the majority of funding for the local authorities is sourced from central government via the DECLG, the department has major leverage over the actions of the local authorities. It is divided into a number of policy sections:

 It forms and implements national policy on wastewater treatment for Ireland.

 It prioritises schemes for investment, allocates central government funding for those schemes to the local authorities and secures the funding from Irish government and EU sources.

 Civil servants (including engineering inspectors) form steering committees with the local authorities during the project’s implementation.

Department personnel thus have had significant knowledge and influence over the project’s evolution, even though they were not ultimately responsible for its implementation. The Minister for the Environment also has large significant influence over how EU Directives are applied.

During the implementation of the Cohesion Fund programme, these government, local authority and EU stakeholders met every six months to review and assess the progress made on the various infrastructure projects approved for EU funding.

The Environmental Protection Agency (EPA) is the regulator charged with maintaining water quality standards (and other environmental standards) as set out in Irish Law. It was established in 1993 by the Environmental Protection Agency Act, 199285. Under section 61 of the Act, the EPA is required to report biennially on the quality of effluents being discharged from treatment plants controlled by local authorities. The report is based on data collected and submitted by local authorities and audited by the EPA. Since 200786, local authorities must apply for an emitting license to the EPA in order to establish wastewater treatment facilities. Standards to be met are set out in the license, and the agency has responsibility to monitor and enforce these standards.

During the application for the license, the public is free to view the license application documentation and make their submissions regarding license approval87.

Local residents are a key stakeholder group. Ringsend/Irishtown has historically been a working class district of the inner city. During Ireland’s Celtic Tiger period (Box 2.3) the area and the nearby Docklands experienced major urban renewal. The Dublin docklands until the late 1980s was a rundown and under-utilised area of the city.

The Irish Government’s decision to locate the International Financial Services Centre (IFSC)88 at the western end of the Docklands, and the establishment of the Dublin Docklands

85 http://www.irishstatutebook.ie/1992/en/act/pub/0007/print.html 86 http://www.attorneygeneral.ie/esi/2007/B25648.pdf 87 http://www.epa.ie/whatwedo/licensing/wwda/ 88 Dublin’s financial district where many international banks have offices

Development Authority (DDDA) subsequently led to its rapid development in the 1990s, including significant new work and living space. More recently a number of technology multinationals, such as Google and Facebook, have located their European headquarters in the Ringsend district. Consequently there has been some gentrification of the area, but Ringsend/Irishtown has still maintained its traditional close-knit community. To the south is the historically more affluent Sandymount neighbourhood.

Box 2.3 RELEVANT EU DIRECTIVES FOR DUBLIN WASTEWATER TREATMENT 1975 –Directive 76/160/EEC – Bathing Water Directive – Sets water quality standards for bathing areas in member states designated by national authorities. 1976 – Directive 76/464/EEC – Water Pollution by Discharges of Certain Dangerous Substances – gives directions regarding pollution caused by certain dangerous substances discharged into the aquatic environment. 1979 – Directive 79/923/EEC – The Shellfish Directive – sets water quality standards for areas designated by the national authorities for the purpose of farming shellfish. 1979 –Directive 79/409/EEC – The Birds Directive. Designed to protect the habitat and populations of wild birds. The Directive lists wild bird species whose habitats must be protected under the Directive. Member states are required to designate Special Protection Areas (SPAs) where these species populations can be maintained. This directive has been updated several times. The latest version is 2009/147/EEC. 1985 –Directive 85/337/EEC – Sets procedure for completion of EIA1991 - Directive 91/271/EEC – Urban Waste Water Directive, prohibited the dumping of raw sewage in coastal waters by 1998. 2000 –Directive 2000/60/EC89 – Water Framework Directive- requires national governments to take a new holistic approach to managing their waters. It applies to rivers, lakes, groundwater, estuaries and coastal waters. It directs that all waters by 2015 must be of good quality (as defined in the Directive) and that there is no deterioration in standards. 2006 – Directive 2006/113/EEC90 - Repealing original Shellfish Directive 79/923/EEC so as to codify changes motivated by Directive 91/692/EEC, concerning standardizing reporting methods across the EU 2006 – Directive 2006/7/EC – New Bathing Directive repealing 76/160/EEC. Defines new categories of bathing water quality which are much stricter than those standards set out in the old directive Source: Authors

The courts influence developments in infrastructure through the procedure of judicial review. Both in the planning stage of infrastructure, where the local authorities, the Planning Appeals Board (ABP) and local residents are the main stakeholders, and when the EPA issues licenses for pollution control, stakeholders have recourse to challenge the decisions of the EPA or ABP in the courts. The domain of this challenge is only in regards to the legality of the decision, i.e. whether the correct statutory procedures were followed by the authorities. If the courts decide that the correct statutory procedures were not followed they can overturn decisions made by ABP or the EPA.

Other stakeholders include:

89 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2000:327:0001:0072:EN:PDF 90 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:376:0014:0020:EN:PDF

 Domestic, commercial and industrial customers of the plant (industrial customers contributed EUR 44 million [current prices VAT inclusive] to the initial capital cost of the plant);

 Plant operators CAW; and

 Amenity users of Dublin Bay, and other citizens who gain benefit from the improved environmental status of the bay without being users.

Box 2.4 IRISH LEGISLATION RELEVANT TO DUBLIN WASTEWATER TREATMENT 1977 - 1990- Local Government (Water Pollution) Acts - empowers local authorities to issue permits to companies for the discharge of industrial effluent into sewers or waters91. The decision of the local authority may be appealed to the local authority and then to The Planning Appeals Board (ABP). These regulations do not apply to sewage treatment plants operated by local authorities. 1988 –Statutory Instrument (S.I.) No. 84/1988, giving effect to the Directive 76/160/EEC, and designating Burrow Beach, Killiney, Portmarnock and Dollymount strand as bathing areas92. 1989 – Statutory Instrument No. 349/1989 –Giving effect to EC Directive 85/337/EEC. 1992 - Quality of Bathing Waters Regulations, 1992 (S.I. 155 of 1992) – updating SI 84/1988 and adding Seapoint to the list of designated bathing areas. 1992 – Environmental Protection Agency Act93 – empowers the Minister of the Environment to make regulations, and establishes the Environmental Protection Agency (EPA)94 to enforce standards for the management of sewage treatment plants. A major innovation of these acts was the establishment of Integrated Pollution Control Licenses (IPCs), covering facilities involved a range of “scheduled” activities95. Thus the EPA took over responsibility from the local authorities for large facilities such as Guinness Brewery. These licenses were enhanced in later Irish legislation (Protection of the Environment Act 200396) in response to EU Directive 96/61/EC97 to become Integrated Pollution Prevention Control (IPPC) licenses. It should be noted that the local authorities still issue the majority of licenses for discharges into sewers, covering activities other than the “scheduled” list. 1994 – Statutory Instrument No. 200/1994 – Irish Legislation implementing the Shellfish Directive, designated shellfish areas are mostly in the west of Ireland. 1998 – Irish Government implements Water Quality Standards for Phosphorous Regulations98 - Implements elements of EC Directive 76/464/EEC regarding pollution by phosphorus. 1998 – SI No 177/1998 – Further amendments to list of designated bathing areas, adding Merrion Strand and Sandymount Strand to the designated list of bathing areas. 2001 – Urban Wastewater Treatment Regulations (SI No. 254/2001) – Designated the Liffey Estuary as a body “sensitive” to eutrophication as defined in the UWWTD. 2003 – European Communities (Water Policy) Regulations (SI 722/200399) – Incorporating the Water Framework Directive into Irish Law. Where river basins encompass multiple local authorities, particular

91 http://www.envirocentre.ie/includes/documents/BPGEffluentlicence.pdf. 92 http://www.irishstatutebook.ie/1988/en/si/0084.html. 93 http://www.irishstatutebook.ie/1992/en/act/pub/0007/index.html. 94 http://www.irishstatutebook.ie/1992/en/act/pub/0007/index.html. 95 http://www.epa.ie/whatwedo/licensing/ippc/whoneedsalicence/ 96 http://www.irishstatutebook.ie/pdf/2003/EN.ACT.2003.0027.pdf 97The Integrated Pollution Prevention and Control Directive http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:1996:257:0026:0040:EN:PDF, the updated form is 2008/1/EC http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:024:0008:0029:EN:PDF 98 http://www.irishstatutebook.ie/1998/en/si/0258.html. 99 http://www.irishstatutebook.ie/2003/en/si/0722.html.

local authorities are designated to co-ordinate management the basins. Seven river basins were defined on the island of Ireland by the EPA. For each river basin, local authorities whose borders partially or wholly encompass the basin boundaries had to submit a management plan to the Minister for the Environment for that particular basin. The EPA is required to co-ordinate and collate information at a national and international level (for submission to the EU Commission), and monitor the efforts of the local authorities. The Minister for the Environment and the EPA must co-ordinate efforts between Irish and the relevant UK authorities for those river basins which cross the Irish border. 2006 – Statutory Instrument No. 268/2006 – Update of Irish legislation on the Shellfish Directive. National bodies are specified to assist the Minister of the Environment in enforcing the Shellfish Directive. Four additions (none in the Dublin area) are made to the list of designated shellfish areas. 2007 – Waste Water Discharge (Authorisation) Regulations100 (SI 684/2007) – Requiring local authorities to obtain a license for wastewater treatment plants operated by them or their contractors. 2008 – New Bathing Water Regulations (SI 79/2008101) – incorporating Directive 2006/7/EC into Irish Law. 2009 – Statutory Instruments No.s 55 and 464 of 2009 – Implementing the new EU Shellfish Directive 2006/113/EEC. Significant additions are made to the list of designated shellfish areas, including some in north county Dublin (Malahide, Balbriggan/Skerries), but no designations are made for Dublin Bay. Source: Authors

Figure 2.4 BEACHES IN THE DUBLIN BAY AREA

Postmarnok

Burrow Beach, sutton Dollymount Strand

Wastewater treatment plant

Sandymount Strand

Merrion Strand

Seapoint

Killney

Source: Authors’ elaboration based on a NASA radar image102

100 http://www.environ.ie/en/Legislation/Environment/Water/FileDownLoad,16869,en.pdf 101 http://www.environ.ie/en/Legislation/Environment/Water/FileDownLoad,16953,en.pdf. 102 http://visibleearth.nasa.gov/useterms.php and http://www.archive.org/details/nasa.

Figure 2.5 QUALITY OF BEACHES ACCORDING TO EU BATHING WATER DIRECTIVE

Year 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 Portmarnock Burrow Beach, Sutton

Dollymount Strand

Sandymount Strand

Merrion Strand

Seapoint

Killiney

KEY: BLUE = meets mandatory and guide values GREEN = meets mandatory values RED = does not meet mandatory values BLANK = no data Source: European Environment Agency

Box 2.5 THE “CELTIC TIGER” From 1994 to 2000 Ireland went through a period of exceptional growth, rarely seen in the developed world. During this period it was the fastest growing economy in the OECD, with average GNP growth per annum of over 8% (McAleese, 2000) and GDP growing at over 9% per annum (Figure 1.5). In terms of GNP per capita, Ireland went from less than 60% of the EU average in the late Eighties to converge with the average by the early 2000s. At the peak (2007) GDP per capita in Ireland was 148% of the EU27 average (Eurostat, 2011). The economy was transformed during this period, with unemployment falling from 15.7% in 1993 to trough at 3.7% as of Mid-2001, while the national debt fell from 118% of GDP in 1987 to 39% by the end of 2000 (Figure 2.6). This remarkable performance is in stark contrast to the previous experience of the Irish economy, when it had been a notable laggard (Lee, 1989). The reasons for this turnaround have been widely debated, but there is consensus around a number of factors, which can be summarised as follows: a) By the late 1980s, Ireland was slowly emerging from a major fiscal crisis, which had seen public debt rise above 100% of GDP, despite increasing tax rates and falling public investment (McCarthy, 2009) and the return of large-scale emigration which had not been experienced since the 1950s (Figure 2.7). The crisis had only been halted by painful fiscal retrenchment, introduced by a minority Government but made possible by broad political and social consensus on the remedies required. This consensus included a process that became known as “social partnership”, involving the State, trade unions and employers’ representatives, which traded tax reductions for pay restraint. It was a watershed moment in the history of the Irish State, and triggered a significant turnaround in the fortunes of the economy (often held forth as an example of an “expansionary fiscal contraction”, Considine and Duffy, 2007). b) A large amount of underutilised labour resources, as evidenced by the unemployment rate. The unemployment statistics actually understate the position, as the large number of Irish workers who emigrated during the 1980s started to return during the 1990s when the economy improved (Figure 2.7). For a long time this gave the economy the capacity to expand rapidly without increasing general inflation (Figure 2.8), although asset price inflation did begin in the 1990s. c) The improving quality of that labour force, following the introduction of free secondary education in 1967 and the increasing numbers attending third level education. d) The EU Structural and Cohesion Funds from the late 1980s onwards, which facilitated the implementation of infrastructure investment plans that had been on hold since the 1960s, thus freeing up constraints on the physical capital side. The funds themselves also had a direct economic impact, particularly during the 1990s. Between these two effects it is estimated the EU funding added approximately 2% to the level of GDP during the 1990s (Honohan, 1997, Walsh, 2000). e) Globalisation, and the rapid expansion of US multi-nationals internationally during the 1990s. Labour availability, English language and Ireland’s low corporate tax rate proved attractive to

these firms. During the 1990s Ireland captured a disproportionately high share of US foreign direct investment (Murphy, 2000). f) The Northern Ireland peace process improved the international image of the entire island, and freed up resources that had previously been devoted to security. g) Small size was a factor also, in the context of an increasingly globalised economic system. “An increase in a small share of a large number can make a huge difference to a small country” (McAleese, 2000). Source: Authors

Figure 2.6 IRELAND GOVERNMENT DEBT TO GDP RATIO, 1980 TO 2011

Source: CSO

Figure 2.7 NET MIGRATION IRELAND 1987-2010 (‘000S)

Source: CSO

Figure 2.8 CPI INFLATION 1990-2011 (%)

Source: CSO

2.3 MAIN DEVELOPMENTS SINCE COMPLETION The plant officially opened in September 2003 (although it had been in operation since June of that year), initially to a positive reception in the media. In a newspaper article of the time it was claimed that103:

 Nearby beaches had already achieved standards close to Blue Flag.

 The smaller Tolka and Santry rivers in the north of the city had seen their water quality improve as a result of the plant.

 The opening of the north interconnector sewer would also make available more serviced land to accommodate development (planning permission had recently been granted for approximately 14,000 houses in the northern and central parts of the city).

Environmental impacts have generally been positive since the opening of the plant. In the years subsequent to the plant’s opening there has been an improvement in the quality of water at the principle beaches in Dublin bay, notably Dollymount strand, Merrion strand and Sandymount strand (Figures 2.4 and 2.5).

The plant also produces 40% of its own energy needs through the production of biogas, and the remaining by-product is spread on agricultural land as fertiliser.

It should be noted that Dublin Corporation and MACL (1993) indicated that the treatment works would only have the potential to improve bathing water quality at Dollymount strand. In this context, a number of other initiatives may have had positive impacts on the environmental

103 Irish Times 9th September 2003 “Dublin beaches ‘now meet Blue Flag standards’” http://www.irishtimes.com/newspaper/archive/2003/0909/Pg005.html Irish Independent 8th September 2003 “Massive sewerage projects flushes into action” http://www.independent.ie/national-news/massive-sewerage-project-flushes-into-action-203933.html

quality of the rivers following through Dublin and of Dublin Bay, not least the Upper104 and Lower105 Liffey Valley Regional Sewerage Schemes, which serve a number of towns and major industries upriver of Dublin city. These investments were also instigated on foot of the Urban Waste Water Directive, and benefited from significant EU assistance106.

However the operating of the plant since then has been beset by a number of significant problems, most notably related to (1) capacity and (2) odour. These are discussed in detail below.

2.3.1 Capacity Problems From day one of operations, it was clear that the plant had inadequate capacity. Design capacity, forecast to be reached in 2020, was 1.64 million PE. However, in 2003 the plant received a load of 1.85 million PE, and the annual load since has ranged between 1.8 million and 1.95 million PE. This is a remarkable situation, and numerous reasons have been put forward by various commentators, including the Celtic Tiger boom, rigidities in the DBO contract may have constrained the scope for change to reflect increasing demand107, and a failure by industry to reduce pollution load in response to the introduction of charging108.

Fehily (2008) undertook a comprehensive review of the operations of the plant on behalf of the Minister for the Environment, concentrating on the capacity and odour problems. With respect to the former, he concluded:

 In fact, industry did reduce its pollution load in line with expectations.

 Likewise, population growth in Dublin per the Census was in line with expectations, although he does highlight that some commentators claimed that there was a significant problem of “unaccounted for persons” in the Censuses of the time.

 However, the impact of commuters (reflective of urban sprawl), and day tourism were under-estimated.

 Commercial demand (restaurants, etc.) had been ignored, and this was a major oversight (see further discussion below).

104 http://kildare.ie/CountyCouncil/WaterServices/WasteWaterDischargeLicenceApplications/UpperLiffeyValleyRegionalSewerageSch eme/ 105 http://kildare.ie/CountyCouncil/WaterServices/WasteWaterDischargeLicenceApplications/LowerLiffeyValleyRegionalSewerageSch emeLeixlipWWTP/ 106 While these schemes certainly improved the water quality in the River Liffey, and possibly in the estuary and Dublin Bay, it has not proved possible to isolate their impacts from that of DWWT. However given the DWWT’s location and pollution load, it is reasonable to assume that it is responsible for the bulk of impacts on the estuary and the bay. 107 John Walsh former desk Officer for Ireland in DG Regio, quoted in COWI (2009). 108 The design capacity included a 50% reduction in industrial load in response to the introduction of charging, reflecting international experience and in particular the experience of the Lynetten municipal waste water plant in Copenhagen.

 The design measure for population equivalents, of 60g BOD/litre, although the standard set in Directive 91/271/EEC, may understate that true population load for advanced countries109.

With regard to the commercial demand issue, the 2004 DECLG report National Urban Wastewater Study contains guidelines for local authorities for best practise regarding treatment plant design. According to this document, once domestic population projections are made they should be inflated by a factor of 16% to take account of the additional wastewater generated by commercial premises. It further notes that:

“This relationship has been used extensively in the estimation of flow and load for design purposes and is widely accepted at a local and national level in Ireland”. (p.14 Volume 2, Part A Methodology, No. 4 Flow and Load Assessment)

Fehily (2008) confirms that this approach was not used by DCC and MACL in their demand forecasts. In effect, they assumed that all waste generated in commercial premises related to the human resident population, and added no additional load demand in respect of them (see Table 1.1). He further notes that at the time, most commercial establishments were not metered, and many used food macerators which effectively converted solid waste to waste water, thus adding to the pollution load at the plant (these have since been prohibited).

Since opening, the plant has continued to operate at above design capacity, and DCC has had to compensate the concessionaire for the operational consequences of treating the excess volumes. The original design did allow for expansion to 2.4 million PE, and it is intended to put this additional capacity in place between now and 2015.

2.3.2 Odour Problems Almost immediately after opening, it was apparent to the residents of Dublin City that the treatment plant was emitting malodorous fumes, which had a significant impact on their quality of life, particularly in the immediate neighbourhoods of the plant110. The main chemical which causes odour pollution is hydrogen sulphide (H2S), which has a smell of rotten eggs.

A number of reasons have been put forward for this problem, including the fact that the plant was operating at above capacity. Fehily (2008) in his investigation identified a range of issues that contributed to the problem, notably:

 H2S levels at the inlet to the plant were higher than expected, perhaps because waste material was turning septic in the pipeline from Sutton pumping station;

 “Leaking valves and fugitive emissions” in the CAMBI thermal hydrolysis process;

 Lack of odour control at the extractor fans;

109 Fehily (2008) indicates that 80g/litre is the norm used in the USA. DECLG engineering personnel indicate that a BOD of 75g/litre is often used for large cities. 110Irish Times 12th August 2003 “Sewerage plant cause of odour problem” http://www.irishtimes.com/newspaper/archive/2003/0812/Pg006.html

 The fact that this was novel technology;

 “Odour emissions from the primary lamellae tanks (settling tanks) were untreated;

 There was no individual odour extraction from the sludge presses which are highly odoriferous;

 High levels of ammonia were being released from the treated sludge;”

 Perhaps most remarkably, that the contract for the construction of the plant grossly mis-specified the threshold value for odour emissions.

With regard to this last point, Fehily (2008) reports that the World Health Organisation reports a nuisance threshold value of 3.5 parts per billion (ppb) of H2S as an hourly average concentration. In the Environmental Impact Statement in 1997, a threshold of 5ppb was stipulated. Fehily then notes that the contract documents stipulated that the odour emission threshold for hydrogen sulphide was set at 100ppb, well in excess of levels stipulated in the EIS and WHO guidance levels. By way of explanation Fehily notes that the odour modelling undertaken as part of the EIS may have created a false sense of security for the designers; failing that it was a “serious error of judgement” (p.48).

Furthermore, the terms of the contract did not oblige the plant operator to deal effectively with the odour problem when it did occur. Fehily reports that protracted negotiations between DCC and the operator to address the odour problem eventually led them agreeing to share costs of EUR 1.2 million in August 2004.

However, reference to Figure 1.4 shows that this did not solve the problem. Media reports indicate that DCC eventually had to make a much more substantial investment in the plant to solve the problem111, and this is confirmed by a recent statement by Mr Bob Gaudes112, senior vice president of CDM, who indicated a cost of up to EUR 30 million to resolve the issue113.

Discussions with one of the operator’s site engineers identified what in his opinion had been the main causes of the odour problems, as hot summers in the mid-2000s, and the fact that the primary lamellae tanks were uncovered. He did not believe that problems with the CAMBI process were primarily responsible.

He indicated that covering the lamellae tanks played a major part of solving the problem. Another factor that contributed was the heating of gases released from the thermal dryers (post digestion) to 850°C for two minutes in a closed environment, which oxidised most of the volatile compounds in the emissions.

111 http://www.rte.ie/news/2008/0630/waste.html. 112http://www.dublincity.public-i.tv/core/portal/webcast_interactive/67901and http://cdmsmith.com/en-EU/Insights/Features/A-Tunnel-to-Clean-Waters.aspx. 113 An interview with one of DCC’s site engineers confirms Fehily’s interpretation of the contracts, and indicates that these contract issues influenced DCC in changing their consulting engineers from MACL to CDM, and that the matter is currently the subject of arbitration between DCC and MACL.

DCC’s site engineer has indicated that the problem with leaking valves was reflective of a number of problems with quality of the physical plant, which caused difficulties in the early years of the plant’s operations. He indicated that Design-Build-Operate was adopted in an effort to avoid these problems. However, it was not entirely successful in doing so.

Other difficulties have included:

 There have been some controversies regarding the use of Biofert114 and sludge cake115 from the plant, with disputes between the users of the material and Dublin City Council116 ;

 The newly constructed Sutton pumping station flooded raw sewage on two occasions in 2003, resulting in damage to nearby housing117.;

 A fire/explosion in one of the sludge dryers occurred in November 2004118..

One other major development has been the designation of the Liffey Estuary as a sensitive water body in 2001. This means that treated water currently discharged into Dublin Bay from the Ringsend plant does not meet the required standards (full tertiary treatment with nutrient removal).

Because of the constraints on the site and the capacity problems that the plant is currently experiencing, it has been concluded that the most feasible option is to build a 9 km underwater tunnel from the plant to discharge the treated wastewater beyond the sensitive waters area, rather than build the necessary works on site119. In the words of Bob Gaudes120, senior vice president of CDM, the site constraints and the projected plant size were “very limiting” in the final choice to deal with the new regulations (Figure 2.9).

114 By-product of the sludge treatment, used as agricultural fertilizer. 115 Irish Independent 13th May 2007 “Outrage as raw human waste ‘mistakenly’ spread on land” http://www.independent.ie/national-news/outrage-as-raw-human-waste-mistakenly-spread-on-land-655660.html 116 http://www.rte.ie/news/2005/0421/ringsend.html. 117 Irish Independent 2nd April 2004 “Sewage still dumped into Dublin bay bypassing 300m sieve” http://www.independent.ie/national-news/massive-sewerage-project-flushes-into-action-203933.html. Irish Times 12th September 2003 “Sewage traps Sutton students in school” http://www.irishtimes.com/newspaper/archive/2003/0912/Pg006.html. 118 Irish Independent 3rd November 2004 “Dryer fire in 300m waste plant probed”. Dried biofert can be unstable if stored for long periods, the solution being to remove the material from the plant as quickly as possible and to minimise volumes in storage. http://www.independent.ie/national-news/dryer-fire-in-300m-waste-plant-probed-141469.html. 119 Stated advantages include lower energy usage, lower sludge volumes, and a longer useful life. http://dublincity.ie/WaterWasteEnvironment/WasteWater/RingsendWastewaterTreatmentWorksExtension/Documents/Ringsend _FAQs%5b1%5d.pdf 120http://www.dublincity.public-i.tv/core/portal/webcast_interactive/67901and http://cdmsmith.com/en-EU/Insights/Features/A-Tunnel-to-Clean-Waters.aspx.

Figure 2.9 PROPOSED SEA OUTFALL AT RINGSEND TO COMPLY WITH URBAN WASTEWATER DIRECTIVE (DESIGNATION OF LIFFEY ESTUARY AS SENSITIVE)

Source: CDM

As stated, the option of retro-fitting the SBRs with denitrification was built into the design at the time of approval of the EIS. However, DCC personnel have indicated that a difficulty with choosing this option would reduce the capacity of the SBRs, thus further exacerbating the current capacity problems that the plant is experiencing.

2.4 HAS THE PROJECT STABILISED? The volume of waste water arriving at the Ringsend plant for treatment has in large part stabilised in recent years at approximately 1.9 million PE. Despite this, it is arguable in fact that this project has not yet stabilised, on two counts:

 Most obviously, the plant is operating in excess of capacity. Within two years of the plant’s opening, DCC announced plans for an expansion of the plant, which originally it was not expected would be necessary until after 2020. This led to much opposition from local political representatives, who threatened to block any proposed extension until the odour problem was resolved121. It is now planned to proceed with the extension, to be completed in 2015.

 Designation of the Liffey Estuary as a sensitive body of water, and the subsequent decision, because of the constraints of the site, to build a 9 km underwater tunnel from the plant to discharge the treated wastewater beyond the sensitive waters area

121 http://www.rte.ie/news/2005/0420/ringsend.html.

to deal with the problem. The construction of this tunnel will be undertaken in conjunction with the works to expand the plant’s capacity. The plant’s licence from the EPA requires it to meet the standards of the Directive by 2015.

These developments will have impacts on investment and operating costs, as well as on environmental quality (via the removal of nutrient-rich effluent from the estuary. Environmental and as well as some ongoing financial benefits may accrue from the fact that the plant will be operating within capacity, although the actual load in terms of PE has stabilised in recent years.

One further potential development is the plan to build a new wastewater treatment plant in Fingal in north Dublin122, to cater for growing demand and consolidate treatment infrastructure along the north Dublin coast. It is noted that the Ringsend plant currently treats 70% of the waste water from Fingal County, and options to redirect some of this load to the new plant are being explored. However, there is concerted public opposition to this new plant123, which argues inter alia, that since the economic downturn the population projections on which the plant is based are out of date (Skerries Community Association, 2011), and it is unlikely to proceed in the short term.

122 http://www.greaterdublindrainage.com/2011/12/15/preliminary-screening-report-presentation/. 123 See for instance http://www.skerriesca.com/node/503.

3 LONG-TERM DEVELOPMENT EFFECTS

3.1 KEY FINDINGS This Section describes the main long-term development effects provided by the project. In accordance with the guidance set out in the First Interim Report, seven categories of effects (listed below) are considered and for each of them an assessment of the contribution of the project to that specific effect is given. On the most relevant effects, either positive or negative, descriptions of the timing of their materialisation and evolution are presented. The seven categories of effects are:

 Direct economic growth

 Endogenous dynamics

 Social cohesion

 Environmental effects

 Territorial cohesion

 Institutional quality

 Social happiness.

As discussed earlier, these categories are analysed using two broad methodological approaches – quantitative (i.e. Cost Benefit Analysis) and qualitative. As a starting point, we can summarise the nature and strength of the long term impacts of the investment across the above categories, as well as the degree to which these impacts have been identified and analysed quantitatively or qualitatively (Table 3.1 overleaf). We also consider the degree to which short term as well as long term impacts arise (Table 3.2 overleaf). The criteria considered to assign the scores shown in these Tables are presented in Annex I.

In broad terms, the direct economic impact is identified quantitatively in the CBA, while the other categories are largely identified qualitatively. However, elements of these other categories are captured to some extent in the quantitative analysis also.

The project clearly has both short term and long term impacts. While the key driver for the project was compliance with Directive 91/271/EEC, there were increasing societal concerns regarding the water quality in Dublin Bay. There was an immediate and noticeable improvement in water quality and in the amenity quality of beaches and the coastline following the plant’s opening, and this has been maintained.

The plans to disperse the plant’s outfall via a 9 km tunnel has the potential to deliver further benefits in the inner bay in the medium term, and the increase in the plant’s capacity should safeguard the improvements already achieved.

Table 3.1 NATURE AND STRENGTH IMPACTS Strength* Level Identified and Analysed (-5 to +5) Quantitatively Qualitatively (CBA) 1. Direct economic growth +3 Local, regional √ 2. Endogenous dynamics +2 Regional, national √ √ 3. Social cohesion -1 Local, regional √ 4. Environmental effects +4 Regional, national √ √ 5. Territorial cohesion +1 Local, regional √ 6. Institutional quality +1 Regional, national √ 7. Social happiness -1 Local, regional √ *-5 = net highly negative effect; 0 = net neutral effect; +5 = net highly positive effect.

Table 3.2 TEMPORAL DYNAMICS OF THE EFFECTS Short run Long run Future Comments (years 1-5) (years 6- years 10) 1. Direct economic + ++ +++ Immediate positive effect, improved in long-run growth as initial odour problems resolved; future investment will generate further benefits. 2. Endogenous dynamics + ++ ++ Positive effect stabilised in the long-run. 3. Social cohesion - - - Slightly negative effect stabilised in the long- run. 4. Environmental effects + ++ +++ Immediate positive effect, improved in long-run as initial odour problems resolved; future investment will generate further benefits. 5. Territorial cohesion + + + Slightly positive effect stabilised since the short-term. 6. Institutional quality + + + Slightly positive effect stabilised since the short-term. 7. Social happiness - - - Slightly negative effect stabilised in the long- run. Note: + or - Positive or negative effect; ++ or -- Positive of negatively effects reinforced (in positive or negative direction) with respect to the previous stage; +++ or --- Positive of negatively effects further reinforced (in positive or negative direction) with respect to the previous stage; +/- Mixed effect, it is not possible to assess whether the net impact was positive or negative (see Annex I).

There was one notable short term environmental negative, i.e. the serious odour problem, which had a significant impact on the quality of life of the plant’s neighbours. However, this appears now to have been resolved, albeit at substantial cost.

Economically, our CBA indicates that the project generated a positive socio-economic return compared to the counterfactual (Economic NPV EUR 335 million), with the largest benefit

related to household Willingness To Pay (WTP) for improvements in water quality in Dublin Bay.

Short term impacts were felt directly from the planning, construction and operations of the plant. We estimate that construction to date has generated 3,300 man years of employment, while future investments have the potential to generate a further 1,300 man years of work.

The plant current employs approximately 50 people, including 30 working in five shifts of six over 24 hours, with the balance as day staff.

The plant has enabled water-using industry in the city (notably Guinness Brewery) to have its waste water treated to the required standard (industry made a contribution of EUR 44 million124 to the initial capital investment cost). It has also facilitated an expansion of housing and population, by providing proper waste water treatment in accordance with Directive 91/271/EEC.

Table 3.3 overleaf summarises our assessment of the dispersal of impacts across the various stakeholders.

Notable is the negative impacts on the residents of neighbouring districts, who had to suffer serious odour problems in the early years of operation of the plant. They also have a continuing negative perception of the plant, which has been exacerbated by further plans by DCC to build an MSW incinerator on an adjacent site at Poolbeg.

The positive impacts of economic growth are concentrated among the plant designers, builders and operators, customers of the plant and the local authorities who have benefited from increased commercial rates (property tax) and development levies.

The plant does represent a significant financial burden for Dublin City Council, as it recovers no revenues from domestic customers, and it only charges non-domestic customers on a marginal cost basis, whereas it must pay the concessionaire the full cost of operating the plant.

124 Current prices VAT inclusive.

Table 3.3 DISTRIBUTION OF IMPACTS ACROSS STAKEHOLDERS Stakeholders Customers of the plant Plant Operators Designers, Government & Citizens Builders, etc. EPA Department Neighbouring residents Users (& non- Local/ EU of users) of Dublin Regional Environment Bay Amenities Authorities 1. Direct economic growth +3 +5 +5 +1 +/- 2. Endogenous dynamics +2 +2 +2 +2 +3 3. Social cohesion +2 -4 4. Environmental effects +5 +3 +3 -1 +5 +5 5. Territorial cohesion +1 6. Institutional quality +2 +1 +1 +1 7. Social happiness -4 +2 *-5 = net highly negative effect; 0 = net neutral effect; +5 = net highly positive effect; +/- = mixed positive and negative effects Note: the numbers in this table do not necessarily match those in Table 3.1, as the latter relates to the aggregate impacts, while the above relates to impacts on individual stakeholder groups, at which level the impact may be more significant. The aggregate impact can be interpreted as the weighted average of the individual stakeholder values (see Annex I).

3.2 DIRECT ECONOMIC GROWTH We summarise here the findings of our CBA, details of which are continued in Annex II.

The project has been compared with a ‘Do Nothing’ option of continuing to subject waste from the centre and south of Dublin city to primary treatment only, with wastewater from the north of the city continuing to be discharged with little or no treatment.

This was a very substantial project costing almost EUR 300 million in 2011 money, with a further almost EUR 150 million to be spent in the coming years to increase capacity and install a long sea outfall.

From a financial point of view, the results are:

Table 3.4 FINANCIAL CBA OF DWWT Investment Return FNPV(C) FRR(C) FBCR(C) EUR million Do Project -862 -11.6% 0.10 Do Nothing -53 * 0.47 Net NPV for Project -809 -11.4% National Return (net of EU subvention) FNPV(K) FRR(K) FBCR(K) EUR million Do Project -611 -11.2% 0.13 Do Nothing -53 * 0.47 Net NPV for Project -558 -11.0% *not calculated.

Clearly, the project is not self-reliant on a purely financial basis, generating very significant costs for the Irish public sector, even after EU subvention. This reflects inter alia the lack of domestic waste water charges.

While the plant represents a financial burden for commercial/industrial customers (due to increased waste water charges), it represents a particular burden for Dublin City Council, since commercial/industrial charges are on a marginal cost basis only, and domestic customers – the main users of the plant – do not pay for the service. On the other hand the terms of the DBO contract impose significant regular costs on the local authorities (approximately EUR 23 million per annum or EUR12.10 per PE per annum), and there is also a capital replacement fund, designed to fund the replacement of all M&E plant in the year before hand-back (funded jointly by DCC and the concessionaire)125. For a discussion of tariff-setting for customers of the plant, see Box 3.1.

The ‘Do Nothing’ option is preferable financially to ‘Do Project’, because of the low ongoing capital and operating costs of the primary treatment plant. However, it should be noted that

125 DCC’s site engineer points out that, while this does represent a significant financial burden, it also ensures that the plant is operated and maintained to the highest standard, implying that if the local authorities were operating it directly themselves they might be tempted to cut corners.

this calculation ignores the possibility of substantial EU fines being levied on Ireland for non- compliance with Directive 91/271/EEC.

However, when assessed from a socio-economic viewpoint (mainly taking into account household WTP for improved water quality in Dublin Bay but also conversion from market to shadow prices), the results are as follows:

Table 3.5 SOCIO-ECONOMIC CBA OF DWWT PROJECT ENPV ERR EBCR EUR million Do Project 246 10.3% 1.20 Do Nothing -89 * 0.37 Net NPV for Project 335 11.7% *not calculated.

On this basis, the project clearly generates a positive return.

Direct economic benefits are felt by:

 The designers, builders and operators of the plant and related infrastructure, as well as their employees;

 Industrial firms whose waste water is treated at the plant to the required standard, and their employees;

 The house building sector in north Dublin, whose expansion was facilitated by the provision of proper wastewater treatment in the region, as well as the households buying these properties (not included in the above calculations, but partly captured in the WTP);

 Improved quality of life and general amenity value among Dublin residents, particularly those using the waters and beaches of the bay for amenity and recreation purposes;

 Property owners in the Dublin region, whose property values have been increased by the project (captured in the WTP calculations);

 Similar benefits for tourists, and thus the tourism-related sectors of the Dublin economy (not valued – the main users of Dublin Bay are residents rather than tourists).

Box 3.1 TARIFFS FOR THE DUBLIN WASTE WATER TREATMENT PLANT Almost all discharges of wastewater to public sewers in the Dublin region are brought to the Ringsend plant for treatment. Customers of the plant fall into the following broad categories: domestic, commercial and industrial. Domestic customers pay no charges for waste water (or for water supply). Commercial customers, who discharge waters which are similar in nature to domestic discharges (including schools and similar institutions), are charged on a water-in, water-out basis, and in 2012 pay a combined water/waste water charge of EUR 1.90/cubic metre126. It is not clear how much of this relates to water supply, as compared to waste water services. Most industrial customers operate under a Local Authority license, which sets the limits on what they are allowed to discharge. Their tariffs are calculated on the basis of the marginal cost of treating their effluent at the plant. The tariff is worked out by means of a formula which includes volumetric load, BOD, COD and suspended solids. Industrial customers in certain industries (for example brewing) are licensed by the EPA under the Integrated Pollution Prevention Control (IPPC) system, which covers all types of pollution in a single licence. Their tariffs are calculated on the same basis as other industrial customers Total revenue from industrial customers is currently approximately EUR 3.3 million per annum. This compares with annual payments from Dublin City Council to the operating concessionaire CAW of approximately EUR 23 million. The largest industrial customers also made a capital contribution to the cost of the plant, based on the marginal capital cost of adding the required capacity to cater for them, amounting to EUR 44 million (current prices, VAT inclusive). This represented approximately 10% of the capital cost of the project. Source: Authors

3.3 ENDOGENOUS DYNAMICS The three main headings under which endogenous dynamics are considered to positively impact on long term economic growth in the context of infrastructural investment are:

 Human capital;

 Technological progress (including R&D investments); and

 Organisational development.

The DWWT project was a major infrastructure investment, which will cost almost EUR 450 million when future investments are considered (2011 money, VAT exclusive). It is the largest wastewater treatment plant in Ireland, and includes a number of innovative engineering elements in response to the constrained site (first international use of the CAMBI process at this scale, the two-storey SBRs) as discussed in Section 2.

There would have been an increase of knowledge and expertise in the institutions and firms involved in the design, delivery and operations of the plant, given the scale and innovative characteristics of the plant, thus improving Irish human capital (see later discussion of institutional quality). This increased knowledge and expertise could be expected to overflow into the building of subsequent plants, and possibly into other areas of civil engineering. While

126http://www.dublincity.ie/WaterWasteEnvironment/DrinkingWater/WaterChargingandMetering/Pages/Findoutaboutwaterchar ges.aspx

the plant suffered significant “teething problems”, partly due to the use of the CAMBI process on a scale never before attempted, CAW’s site engineer describes it now as “a flagship project”. Apparently it receives regular international site visits by students, engineering firms and other interested bodies, including a recent visit by a delegation from Hong Kong, specifically interested in how the constrained site issue was dealt with127.

On the other hand, the technical complexity of the plant and the constrained site did create significant problems and added costs, and we note that DCC has in recent years changed its consultant engineers, apparently as a result of dissatisfaction with the quality of their work on the Ringsend project (see fuller discussion in Section 2).

Technological progress would also have resulted from the project, specifically in terms of the use of innovative technology at scale (the CAMBI process) on the constrained site at Ringsend. That said, it may be that this will have more relevance outside Ireland than in the State. We are not aware of any other treatment plant in Ireland that has used or intends to use a similar technical solution.

In terms of organisational development it is not clear that there have been specific developments, apart from technical capability, in the stakeholders as a result of this project. One can perhaps point to the lesson apparently learned by Anglian Water International in terms of the need to have a hands-on approach to the design and construction of plants that they would subsequently be operating.

3.4 SOCIAL COHESION 3.4.1 Inequality and social cohesion in Ireland Ireland went through a period of exceptional economic growth over the last two decades, and as is the case in many countries in similar circumstances, there was an increase in income inequality over that period. As recently as 2006, a Government-sponsored report indicated that Ireland was one of the most unequal societies in the developed world128.

That said, unemployment fell very rapidly between 1994 and 2008 (from approximately 17% to 4.6%) and this had a very significant impact on incomes across the population. It facilitated a very significant expansion of public and social services, which helped to improve social inclusion129, including increases in health expenditure, which is partly credited with significantly increasing life expectancy130. At a general level, EU funding of this and other infrastructure projects may have allowed the Government to redirect expenditure to areas of social spending.

127 The Hong Kong delegation was considering the feasibility of constructing SBRs on three storeys, as opposed to two at Ringsend. 128 Based on relative measures such as comparing incomes of the top 20% with the bottom 20%; National Social & Economic Forum (2006), Creating a More Inclusive Labour Market, report No. 33. http://www.drugsandalcohol.ie/6053/1/NESF_No-33- Creating-a-More-Inclusive-Labour-Market%5B1%5D.pdf f. 129 Whether all of the progress made under this heading will survive the current requirement for fiscal rebalancing is a moot point. 130 Walsh (2008).

3.4.2 The Ringsend Plant The plant has had mixed social cohesion impacts:

 By removing constraints on development, notably on the north-side of the city (many parts of which are generally less well-off than the average for Dublin), it enabled the provision of new housing and economic opportunities where they were not previously available.

 At a more localised level, the residents of Ringsend/Irishtown, a less affluent part of the city, would have borne the brunt of the serious odour problem in the early years of the plant’s operation. There remains a significant degree of resentment in the area on account of this, intensified by the perception that all the city’s waste was being “dumped on their doorstep”, particularly the waste from the north of the city.

With regard to the latter, there is a perception that better off and more politically connected residents neighbouring the proposed plant at Baldoyle managed to have that plant cancelled, to the detriment of the Ringsend residents. Our analysis of this issue in Section 2 indicates that this in fact does not appear to have been the case, although the prospect of a drawn-out planning process for a new waste water treatment plant to be built on land zoned agricultural was a factor in the decision. A new treatment plant anywhere in Dublin would likely have experienced a similar planning timeframe, however.

DCC’s plan to build an MSW WtE plant (incinerator) on a site adjacent to the wastewater plant has exacerbated negative local feelings131 132, particularly since the EIS for the WtE plant describes the option of incinerating 80,000 tonnes of sludge per annum, if the option of land- spreading is removed133. It is likely also that the odour problems have made it less likely that the incinerator will be acceptable to local residents, although it must be said that incinerators have a low level of acceptance in general in Ireland, and the first MSW WtE plant to be successfully developed in Ireland only commenced operations in September 2011.

This WtE plant, to be built as a Public Private Partnership (PPP) has been particularly dogged by controversy, and has been subject to considerable delays, apparently due to difficulties with financing134.

131 For example http://www.rte.ie/news/2010/0130/incinerator.html, and http://www.indymedia.ie/article/78759?save_prefs=true&userlanguage=ga 132 That said, another neighbouring district, Sandymount, is a notably affluent district of Dublin. 133 Land spreading might become politically or socially unacceptable, or it might prove impossible to find farmers willing to accept it in the future. Health concerns might potentially become an issue (see for instance http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2094820/). Currently, DCC pays approximately EUR60 per tonne to have the biofert removed. 134 See for instance http://www.irishtimes.com/newspaper/ireland/2012/0202/1224311113163.html and http://www.rte.ie/news/av/2012/0131/media-3184978.html.

Avoidance of undue burden can be more efficiently achieved through general social welfare transfers.

3.5 ENVIRONMENTAL EFFECTS The Ringsend wastewater treatment plant has had a broadly positive impact on the environment. As demonstrated in Section 1, water quality has improved significantly, and can be expected to improve further when the long sea outfall and the increased capacity are in place. This will also enable full compliance with Directive 91/271/EEC, in the context of the Liffey Estuary being designated a sensitive water body.

The plant also incorporates state-of-the art sludge treatment, which contributes 40% of the plant’s energy needs and stabilises the sludge into a useful product.

On the other hand, energy usage would have increased significantly in order to operate the more sophisticated plant (notwithstanding energy generated internally), and there has been a serious odour problem in the early years of the plant’s life, albeit it is now resolved.

In addition, the absence of domestic water supply and wastewater treatment charges has negative consequences for environmental sustainability.

3.6 TERRITORIAL COHESION By its nature, this project would have had limited if any impact on territorial cohesion at a national level. There would be positive territorial cohesion effects within the catchment of the Ringsend plant (effectively the Dublin NUTS III region) in terms of providing a uniform level of wastewater treatment throughout the region (free at the point of use to all domestic customers). Some parts of the region (particularly Fingal), had been development constrained due to lack of water and waste water services prior to the commissioning of this plant and the extension of water supply services.

3.7 INSTITUTIONAL QUALITY The impact of this project on institutional quality is an interesting question. It is not clear that there has been a specific impact from the plant as such. Irish Local Authorities, the DECLG and the EPA would have had to upgrade their respective technical capacities in order to design, operate and oversee the operations of this and other WWT plants around the country, a large number of which have been built over the last two decades on foot of Directive 91/271/EEC and other Directives, and part-funded by the EU.

The main institutional development over that period has been the establishment of the EPA in 1992, which took over a number of environmental regulatory and supervisory roles from the DECLG in the intervening years, notably in the water supply, wastewater treatment and solid waste management sectors. Many of the technical staff from the Department would have transferred to the Agency on foot of these role transfers.

Unlike the roads sector in Ireland, the Local Authorities remain the operational and management authorities in respect of water and wastewater. It is intended, however, to establish a “semi-state” company135 in the near future to take over and operate the water sector in Ireland on a commercial basis, including the introduction of metered water charges for all users136. The exact details and timeframe for this development remain uncertain, although recent statements from Government are that it is to be fully in place by 2017137.

The Ringsend project uncovered some institutional/technical limitations, in terms of the various problems that arose with the plant, notably:

 Under-estimation of the load on the plant (over-capacity from day one), in the context of clearly apparent economic growth, increased commuting and partly due to miscalculation of the commercial load;

 The odour problem, which has been traced to, inter alia, design problems, build quality 138 problems and a gross misspecification of the threshold value for H2S emissions ;

 Failure to anticipate the designation of Sandymount strand as an SPA, which constrained expansion of the site;

 Failure to anticipate the designation of the Liffey Estuary as a sensitive water body (the design allowed for installation of nutrient removal, but the capacity problems meant that this solution would not be feasible);

Weaknesses in the contract design, which inter alia, made it difficult to force the concessionaire to pay for resolving the odour problem.

At a more general level, some local residents have argued to the effect that the decision to direct all of Dublin’s wastewater for treatment to a single constrained site, at the centre of Dublin Bay and the Liffey Estuary, and particularly to abandon the option for a separate plant at Baldoyle, was a sign of institutional/political weakness in the face of public opposition to the Baldoyle plant. Our analysis indicates that this decision was more pragmatic than reflective of a waivering to public opposition. We do note the observation by one interviewee that the prospect of a long planning process in the face of a rapidly approaching deadline for meeting the terms of Directive 91/271/EEC was a factor in choosing to concentrate all investment at the existing Ringsend site. However, this would have been the case regardless of the location of any new waste water treatment plant.

At a more general level, abolition of domestic water charges in Ireland in 1997139 undermined the application of the “polluter pays” principle140 as well as placing a significant financial

135 A commercial company whose shares are owned by the State. 136 http://www.irishtimes.com/newspaper/ireland/2011/0930/1224305001574.html. 137 http://www.environ.ie/en/Publications/Environment/Water/FileDownLoad,29193,en.pdf 138 Having said that, the odour issue represented a major lesson for local engineers, and retro-fitting measures taken to alleviate the problems at Ringsend have become “standard practice” in Ireland (see http://www.youtube.com/watch?v=TTEz8NguqfM).

burden on local authorities who are responsible for providing water and wastewater services. The inclusion in the Water Framework Directive of a clause that allowed the Irish Government to avoid having to reintroduce domestic water charges consolidated the position.

3.8 SOCIAL HAPPINESS Social happiness impacts are to do with perceptions, over and above the impacts already considered. The main perception issues have been dealt with under the Social Cohesion and Environmental Effects headings. Worth reiterating are:

 The negative experiences of residents of neighbouring districts in terms of the odour problems in the first few years of the plant’s operations, and

 The generally positive experiences of those who use Dublin Bay as an amenity. This has effectively been captured in the household WTP calculations included in the economic CBA.

As indicated, the Poolbeg peninsula incorporates another public infrastructure project that suffers from significantly negative public perceptions, i.e. the proposed WtE plant. Interviews with local representatives as well as reviews of the media indicate that the two projects are generating mutually reinforcing negative perceptions. Overall, because of these issues, the net “social happiness” impact is likely to be slightly negative.

139 Domestic water charges were abolished for blatantly political reasons – to help the Government to win a by-election in a constituency in West Dublin where opposition to domestic water charges was strong. The Government lost the by-election and later that year lost the general election. 140 According to the ”polluter pays” principle, stated in Directive 2004/35/CE, the operator whose activity has caused the environmental damage or the imminent threat of such damage is to be held financially liable. The objective of this principle is to induce operators to adopt measures and develop practices to minimise the risks of environmental damage so that their exposure to financial liabilities is reduced.

4 DETERMINANTS OF PROJECT OUTCOMES

4.1 KEY FINDINGS Overall this project was worthwhile from a socio-economic point of view, delivering a positive ENPV, has delivered significant environmental improvements, and has/will meet the terms of Directive 91/271/EEC. The determinants of performance that we consider are:

 Appropriateness to the context

 Project design

 Forecasting capacity

 Project governance

 Managerial response

Table 4.1 summarises the relative strength of each of these determinants:

Table 4.1 IMPACT OF KEY DETERMINANTS ON PROJECT’S PERFORMANCE Strength* 1. Appropriateness to the context +4 2. Project design -2 3. Forecasting capacity -3 4. Project governance -2 5. Managerial response +1 *-5 = very strong negative effect; 0 = no effect; 5 = very strong positive effect (see in Annex I the criteria considered to assign these scores)

The project is highly appropriate to the context, in terms of the requirement to meet the terms of Directive 91/271/EEC, increasing population and economic activity, and the clearly inadequate pre-existing level of treatment for waste water in Dublin Bay.

Project design was innovative in terms of responding to the constrained site, but problematic in a number of ways, albeit these issues have in large part been resolved.

Forecasting capacity was clearly problematic, as the plant had inadequate capacity from the start of operations.

Governance appears to have caused some difficulties, in terms of the capacity to deal with the early operational problems with the plant, and contract design.

Managerial response had some positive impacts, in terms of overcoming the problems caused by inadequate capacity at the plant, and some of the governance issues. However, resolution of the odour problem did take some time and ultimately cost DCC a lot of money to resolve.

These determinants are discussed in more detail in the rest of this section, after which the interplay between the determinants is also considered. We also include a brief discussion of the role of the EU as a determinant of outcome.

4.2 APPROPRIATENESS TO THE CONTEXT The context for the project was highly positive, and the project addressed that context well:

 Inadequate or no treatment of wastewater discharges from the largest city in Ireland into an enclosed bay with high amenity value;

 Growing population, housing (Figure 4.1) and prosperity, leading to increased human environmental impact on the one hand and increased demand for improved environmental quality on the other;

 A system of sewers in place, already taking most of the waste water in Dublin to the Ringsend site141;

 Directive 91/271/EEC and other Directives, which brought the requirement for improved treatment into sharp legal focus; and finally

 The availability of very high levels of EU grant aid for projects aimed at meeting the requirements of Directive 91/271/EEC.

As demonstrated in the earlier discussions on the context, Ireland and Dublin have had a history of playing catch-up in terms of wastewater treatment. The Operational Programme for Water, Sanitary and Other Local Services 1989-1993 report (1990) noted that during the 1980s government priorities were to deal with “the historically low level of infrastructure provision and the impact of rapid population growth and urbanisation in the 1970s”. (p.24)

The Operational Programme report further notes that, as a consequence, priority was given to the more immediate problem of supplying water to newer development areas and a greater proportion of capital expenditure (60%) was devoted to water supply infrastructure than to wastewater treatment.

From Figure 4.1 we can see that the housing stock in the Dublin NUTS III region showed a stronger than average growth until the 1970s. This created a number of legacy issues with regard to the city’s drainage infrastruture. Growth accelerated in the 1970s but was also matched in the Mid–East region. Growth in the latter sharply accerated in the 1990s with the

141 With the exception of a small number of recently completed sewers, the Dublin sewerage network is mixed (foul water and storm water). This generates some uncertainty in the volumetric flow to the plant, and in extreme circumstances can lead to an overflow of poorly treated sewage into the Bay.

start of the Celtic Tiger period, reflecting a pattern of urban sprawl that in turn created a significant inward commuting pattern to Dublin.

Figure 4.1 LONG TERM GROWTH IN PERMANENT PRIVATE DWELLINGS IN SELECTED IRISH REGIONS, 1946 - 2006 (1946 = 100)

Source: CSO Census of Population

The project was not financially viable (at least in the context of a lack of domestic water charges), and thus required subsidisation. DCC would not have been able to fund it, and it is questionable whether the Irish Government could have done so, given the multiple requirements facing it under Directive 91/271/EEC (inland waters would – or should – have been a priority)142.

Given the foregoing, the project was in large part a trait-taker143 in terms of the context – the environmental and legal need for improved waste water treatment, growing demand, and the availability of funding with the Operational Programmes during the 1990s.

It is the case also that the plant was something of a trait-maker144, in terms of the innovative technological approach taken, and the decision to direct all the wastewater arising in Dublin to a single plant using novel technology on a shared and constrained site. It was also one of the first wastewater treatment plants in Ireland to be delivered under a DBO contract.

142 It is worth noting that it was open to the Irish Government under Directive (91/271/EEC) to apply to have water bodies declared “less sensitive”, thus only requiring primary treatment. The Government chose not to avail of this option. One wonders if that would have been the case in the absence of large-scale CF funding. That said, it would on the face of it have been difficult to argue that Dublin Bay fitted the “less sensitive” criteria. 143 Following Hirschman (1967), a trait-taking project is one which accepts the context without trying to change it. 144 Following Hirschman (1967), a trait-making project is one which attempts to change the pre-existing context.

4.3 PROJECT DESIGN As discussed in Sections 2 and 3, project design was innovative, but in some ways problematic. Certainly it had consequences for the satisfactory operating of the plant in the initial years at least.

It is informative to refer to Dublin Corporation & MACL (1993), which states the rationale for choosing from the various technologies available for treating the capital’s wastewater. The 1993 report did not foresee wastewater from North Dublin coming to the Ringsend plant. The criteria considered most important at that time were:

 “Process suitability to meet objectives,

 Satisfactory demonstration of the process on a comparable scale to the Ringsend Works,

 Ease of up-rating the plant to meet stricter effluent consent standards,

 Land requirements,

 Capital costs,

 Operating costs and energy efficiency.” (p.96)

One can argue that the chosen solution failed a number of these criteria (notably 2, 3 and 4), so it appears that the criteria applied to the project evolved (or perhaps were forced to evolve by the circumstances) over time.

Furthermore, there were significant teething problems with the plant, notably with regard to odour, which along with inadequate capacity forecasting must be laid at the door of project design. Notable is the apparent misspecification of the emission threshold for hydrogen Sulphide in the contract documents, which also caused difficulties with solving the problem and allocating responsibility.

That said, it must be acknowledged that the plant is now working satisfactorily (after the initial teething problems), and the objectives of improving water quality and amenity value in the bay have been achieved. Further investments in the coming years are expected to further enhance its working and the environmental benefits delivered. However, the teething problems (particularly with regard to odour) have compromised the perceptions of benefits in the minds of the public.

4.4 FORECASTING CAPACITY Forecasting capacity is key to minimising risk factors and uncertainty in the delivery of major infrastructure projects. Such risk factors can include over- or under-design in terms of capacity delivered, failure to anticipate difficult geology or the presence of archaeology, poor estimation of costs, under-anticipated inflation, etc.

It is clear that poor forecasting capacity was a major problem with this project, most specifically under-estimation of the load on the plant (a plant that was supposed to have sufficient capacity until 2020 was over-capacity in 2002), in the context of clearly apparent economic growth, and partly due to miscalculation of the commercial load.

Scope to deal with increased demand was included in the design, as was scope to increase the treatment level to full tertiary treatment, if required. Designation of Liffey Estuary as a sensitive water body meant that this treatment was in fact required. However, the plant as designed could not deliver both increased capacity and tertiary treatment. That is, it was vulnerable to unexpected developments in more than one dimension.

These have had significant consequences for the technical solution, in terms of the cost and the operations of the plant. In particular, the fact that the plant had inadequate capacity:

 put extra strain and cost on the operations,

 possibly contributed to the odour problem,

 meant that not all sludge could be fully treated as per the technical design solution, and

 meant that the foreseen technical solution, should full tertiary treatment be required (retro-fitting denitrification to the SBRs) could not be acted upon because it would further reduce the capacity of the plant.

Hence it can be said that forecasting capacity was a significant negative determinant of the project’s performance.

4.5 PROJECT GOVERNANCE Governance structures for the delivery of the Ringsend Treatment Plant are as follows: the over-arching Community Support Frameworks (CSF) 1989-1993 and 1994-1999 had a Monitoring Committee, as did the Operational Programmes for Peripherality and Environmental Services. These committees included representatives from:  the Departments of Environment, Transport and Finance,

 Local Authorities,

 State bodies such as the EPA,

 external evaluators (usually economic consultants who undertook appraisals of proposed investments), and

 the EU Commission.

These committees as well as the Commission itself had regular reporting requirements with regard to physical and financial delivery of the various investment programmes. The discipline of complying with these reporting and other requirements in general added to the quality of

the governance and decision-making process in the course of the delivery of the programme. Our examination of the Irish files confirms for instance that more detailed reports were kept for infrastructure which was eligible for EU funding.

However, it can be said that governance of this project exhibited weaknesses in many respects, most notably regarding the forecasting issues discussed above, and in terms of contract design

(threshold values for H2S, channels for dealing with operational problems). Certainly, the criteria DCC and MACL set down for themselves in 1993 (see section 4.3 above) with respect to technical choices were not followed in a number of important areas.

The DBO approach to project delivery, which apparently enabled the location of the plant on the constrained site (“traditional procurement would not have put the plant on this site”145), also created a more complex governance structure. Also, it seems, along with the related contract design, it has made the resolution of operational problems more difficult and time consuming, and ultimately it appears that the cost of resolving unexpected problems (inadequate capacity, odour) has fallen on DCC, which somewhat defeats the purpose of DBO, which is supposed to transfer significant risk to the concessionaire.

Another aspect of DBO which has been pointed out to us is that the operational standards to be met as per the concession contract mean it is more expensive for DCC than if the Council was operating the plant itself. In effect, the Council would “cut corners” in the operations if it were free to do so. It has been confirmed to us by the DECLG that DBO-operated plants in general are operated to a better standard than those directly operated by Local Authorities146. DCC’s site engineer indicates that this is a short term burden but is likely to be a positive for the Council in the long run, in terms of the operation of the plant and its longevity.

4.6 MANAGERIAL RESPONSE We are concerned here with the adaptability /flexibility of project management to unforeseen events. In many ways the project reacted well to unforeseen events, leaving aside for the moment that many of these events should not have been unforeseen.

The designation of Sandymount strand as an SPA meant that part of the original site could not be reclaimed from the sea, and a smaller site was needed. DCC and the DOE reacted by confirming the feasibility of a “compact secondary treatment plant”, via a market testing exercise, and adopting a DBO approach (the decision not to proceed with a separate treatment plant for the north of the city was also a driver). The compact secondary treatment plant approach was found to be feasible, but it seems it drove some of the technological solutions that subsequently caused problems.

At the project operational level, there is evidence of adaptation to unforeseen events. The main such events were the unexpectedly high load on the plant from day one, and the odour

145 Source: interviewee, engineering section, DECLG. 146 A parallel can be found with the maintenance standards of motorways in Ireland (such as the M1) that is operated under a PPP tolling concession.

problem. It has proved possible to operate the plant satisfactorily at higher than design capacity, although there have been cost implications.

Reaction to the odour issues was less successful, and it took a number of years to adequately deal with the problem. Resolution of both the capacity and the odour problems eventually had to be paid for by DCC. Correspondence we have seen between DCC and DECLG indicates that contractual problems and capacity problems contributed to this. DCC were constrained in their dealings with the concessionaire CAW because the plant was operating at above design capacity, and CAW could argue that the odour problem was largely due to this. DCC could have taken the matter to arbitration but this would have been a lengthy and potentially expensive process, and a speedy resolution of the odour problem was required.

The designation of the Liffey Estuary as a sensitive water body brought into sharp focus the fact that there the capacity problems had invalidated the contingency plan to cater for nutrient removal (retrofitting denitrification on the SBRs). As a result, a long sea outfall will be used to bring the outfall beyond the limits of the sensitive area. Further, this will be a tunnel rather than a pipeline, to avoid similar problems147, as well as generating less environmental impact148.

Finally, it appears that DCC’s decision to change their consulting engineers from MACL to CDM have been as a result of many of the shortcomings highlighted above.

4.7 INFLUENCE OF AND INTERPLAY BETWEEN DRIVERS There are clear interplays between the drivers of performance.

The requirements of Directive 91/271/EEC would have put pressure on DCC and the Irish Government to treat Dublin’s wastewater to a higher standard, as would the rising population and living standards. Meanwhile the CF co-funding made it financially possible (without the politically unpalatable option of re-introducing water charges).

Project design and forecasting capacity are clearly linked, as forecast demand is a key input to design. Likewise governance and managerial response – the governance structures set the means by which managerial response can happen. In particular, the choice of a DBO approach facilitated the technical solution to the constrained site, but the related contract arrangements had impacts on the capacity to respond to unforeseen events, and who eventually had to pay for the resulting actions. By the same token, governance structures had an influence on forecasting capacity, which set the degree to which events were unforeseen.

Governance also influenced the technological solutions chosen which had implications for the operations of the plant, especially in the early years. The operator’s site engineer maintains that the plant is now “a flagship”, and attracts attention internationally because of its

147 According to DCC’s site engineer, there are “hundreds of shipwrecks” in Dublin Bay. 148 The basic limitation of the site remains however, which may become binding if at some future point all sea outfalls of nutrient enriched material is prohibited (subject to advances in technology).

technology. While benefits will accrue to other countries, but the knowledge and experience gained on the project has also been used elsewhere in Ireland, for instance in terms of dealing with odours.

4.8 THE ROLE OF THE EU The EU clearly had a significant role in this project, firstly as a catalyst for the requirement for the plant (via various Directives, especially Directive 91/271/EEC), and secondly as a provider of a high proportion of the total initial investment cost.

As described, it also had a strong governance role, via its participation in CSF and Operational Programme steering committees, and the imposition of the discipline of regular reporting of physical and financial progress.

It has been indicated by interviewees, furthermore, that the time constraints imposed by the need to comply with Directive 91/271/EEC in particular, was a factor in deciding to concentrate all waste water treatment at the single existing site in Ringsend, as a second new plant (such as that originally planned for Baldoyle) would have entailed a long planning process.

However, a key problem with the water sector in Ireland has been the lack of full cost recovery and in particular the complete lack of domestic water charges, in contravention of the “polluter pays” principle. The abolition of domestic water charges in the late 1990s was a very poor political decision (to put it at its mildest), and was accommodated in the Water Framework Directive149. This placed a significant ongoing financial burden on the Irish local authorities; however, it should be resolved by the planned reintroduction of domestic water charges in the coming years.

149 Water Framework Directive, Article 9(4). See also http://www.philiplee.ie/Libraries/Publications/Water_Framework_Directive_Council_Review_-_Issue_30.sflb.ashx

5 CONCLUSIONS

Here we present the results and lessons learnt from our quantitative and qualitative analysis of the project. Impacts have been considered under seven headings, as summarised in Table 5.1:

Table 5.1 NATURE AND STRENGTH OF IMPACTS Strength* Level Identified and Analysed (-5 to +5) Quantitatively Qualitatively (CBA) 1. Direct economic growth +3 Local, regional √ 2. Endogenous dynamics +2 Regional, national √ √ 3. Social cohesion -1 Local, regional √ 4. Environmental effects +4 Regional, national √ √ 5. Territorial cohesion +1 Local, regional √ 6. Institutional quality +1 Regional, national √ 7. Social happiness -1 Local, regional √ *-5 = net highly negative effect; 0 = net neutral effect; +5 = net highly positive effect.

The strongest impacts were felt in terms of direct economic growth and environmental quality.

While the project was not self-sustaining financially and thus required subvention (partly due to the lack of domestic water charges), it generated a positive socio-economic return compared to the counterfactual (NPV of EUR 335 million), with the largest benefit related to household Willingness To Pay (WTP) for improvements in water quality in Dublin Bay.

Short term economic impacts were felt directly from the planning, construction and operations of the plant. We estimate that construction to date and in the future will generate some 4,600 work years of employment. The plant itself current employs approximately 50 people.

Environmental quality was strongly enhanced by the project, with a significant improvement in water quality in Dublin Bay, and further improvement possible with the installation of increased capacity and a long sea outfall in the coming years. The proper treatment of sludge has been a further positive. Some negatives arise in terms of the odour problem in the initial years (now resolved), and the fact that not all sludge can be fully treated because of the greater than expected pollution load on the plant.

The plant has enabled water-using industry in the city (notably Guinness Brewery) to have its waste water treated to the required standard (industry made a contribution of EUR 44 million [current prices, VAT inclusive] to the initial capital investment cost). It has also facilitated an expansion of housing and population, by providing proper waste water treatment in accordance with Directive 91/271/EEC.

Endogenous dynamics effects were also positive, in terms of technological progress, and many of these benefits may be felt outside Ireland. Worthy of note also are the social happiness

impacts, which experienced positives and negatives. Those using the amenity of Dublin Bay have largely positive perceptions, while the residents immediately neighbouring the plant have a negative perception due to the serious odour problems in the early years of the plant’s operations, reinforced by the plans for a municipal waste incinerator on an adjacent site.

With regard to determinants of performance, Table 5.2 summarises the findings:

Table 5.2 IMPACT OF KEY DETERMINANTS ON PROJECT’S PERFORMANCE Strength* 1. Appropriateness to the context +4 2. Project design -2 3. Forecasting capacity -3 4. Project governance -2 5. Managerial response +1 *-5 = very strong negative effect; 0 = no effect; 5 = very strong positive effect

Appropriateness to the context was the most important positive determinant for the project, specifically:

 Inadequate or no treatment of wastewater discharges from the largest city in Ireland into an enclosed bay with a high amenity value;

 Growing population, housing and prosperity, leading to increased human environmental impact on the one hand and increased demand for improved environmental quality on the other;

 Directive 91/271/EEC, which brought the requirement for improved treatment into sharp legal focus; and finally

 The availability of very high levels of EU grant aid for projects aimed at meeting the requirements of Directive 91/271/EEC. In the context of a lack of domestic water charges, it is unlikely that this project would have proceeded without EU co-funding.

On the other hand, forecasting capacity was a significant negative determinant, most notably in terms of projecting the design load, which was exceeded from day one of operations. Failure to anticipate important environmental constraints was also problematic. Between them, these have had significant consequences for the technical solution, the cost and the operations of the plant.

There are clear interplays between the drivers of performance. For instance, the requirements of Directive 91/271/EEC put pressure on Dublin City Council and the Irish Government to treat Dublin’s wastewater to a higher standard, as did the rising population and living standards. Meanwhile CF co-funding made it financially possible.

The key lesson from the project is to be aware of vulnerabilities with complex and innovative infrastructure projects, subject to significant constraints, in a dynamic environment. This may

be particularly problematic in contexts where technical expertise is weak, and demand data or forecasting capacity is limited.

ANNEX I. METHODOLOGY OF EVALUATION

The present Annex summarises the methodological approach undertaken for carrying out the project case studies and presented in the First Intermediate Report of this evaluation study. Moreover, the Annex further elaborates on and specifies the definition of long-term effects considered throughout the case study and the typology of determinant mechanisms analysed in interpreting the project outcomes. The main objective is to provide the reader with a set of information describing how the project evaluation was conducted and to enable him/her to replicate this methodology.150

The Annex is divided into three parts: in the first one, the overall conceptual framework of the evaluation study is recalled and the definition of long-terms effects and project determinants are laid out; in the second one, the methodology of analysis followed to implement the ex-post evaluation is discussed; finally, the structure of the case study reports and the tools used to standardise them is described in the third part.

CONCEPTUAL BASIS The Conceptual Framework of this evaluation study is based on three dimensions of analysis: the object of the evaluation (the ‘What’), the timing of the long-term effects (the ‘When) and the determinants of the project’s outcomes (the ‘How’).

The ‘What’ dimension

The Team developed a classification of long-term effects, with the aim of identifying all the possible impacts of public investments on social welfare. A broad distinction of project effects is among effects on ‘Economic development’ or ‘Quality of life’. Investment projects can foster economic development, which is generally quantifiable by aggregate indicators, such as the Gross Domestic Product; although economic development is not disconnected from the wellbeing of society, it is acknowledged that there are a number of other factors that may affect public welfare, that are not captured by the traditional economic indicators151. For the purpose of this study, the notion of quality of life152 refer to the factors that affect social development, the level of social satisfaction, the perception of social reality and other dimensions which are outside the conventional economic dimension. Under these two broad categories, a taxonomy of more specific long-term development effects of investment projects has been developed. The definition of each type of effect is provided in Table I.1.

150 Specific recommendations which may enable application of the same evaluation methodology to future projects are discussed in the Final Report of this evaluation study. 151 Dasgupta, 2011 and Stiglitz et al., 2009. 152 Used also as synonymous with wellbeing, as mentioned in the ToR.

Table I.1 TAXONOMY OF LONG-TERM DEVELOPMENT EFFECTS Effects Definition Checklist Economic development Direct economic Following the traditional growth theory153, both Did the project have effects on the endowment of growth public and private investment contribute to increasing labour or capital production factors? Did it the stock of capital and thus economic growth. The contribute to employment creation? Did it attract direct contribution of a project to economic growth, new investments? Did it create new business in terms not only of real growth of GDP, but also, opportunities? Did it produce time savings for more generally, on economic welfare is discussed business trips? Did it produce decreases in travel within this category of effect. costs? Endogenous Endogenous dynamics comprise all the factors that Did the project contribute to the improvement of dynamics have an indirect effect on economic growth, by the productivity of the economic system? Have improving the productivity of inputs: the increase of social behaviours changed as a result of the project? the stock of competences and knowledge of human Did the project provide new/improved skills, R&D capital154, the introduction of a more advanced investment, organisational changes that translated technology155 and changes in the organisational into an increase in labour productivity? model of economic actors, making them more efficient156, are analysed insofar they contribute to increasing the production function. Quality of life Social cohesion Public investment can affect social cohesion, by Did the project promote social inclusion? Did it minimising disparities, avoiding social marginalisation improve the conditions of specific segments of the and reducing income inequalities across different population (e.g. elderly, migrants)? Did it improve socio-economic, gender or ethnic groups. the affordability of services? Environmental Polluting emissions, biodiversity loss and depletion of Did the project improve the quality of the natural effects natural resources caused by large infrastructural environment? Did it alter wildlife habitats? Did it projects can affect social wellbeing of both the affect the ecosystem? Were there any present and future generations. environmental issues related to project implementation? Territorial The project can contribute to reducing welfare Did the project improve the territorial cohesion of cohesion disparities caused by unequal distribution of the region/country? Did it play any role in urban- resources and opportunities among regions and their rural or core/periphery or cross-border dynamics? population. The focus, in particular, is on core- Did it expand the territorial coverage of the delivery periphery and urban/rural differences. of a basic service? Institutional Investment projects can bring wide spill-over effects Did the project induce any institutional learning at learning to the quality of Public Administration and other regional administrative level? Did it raise political institutions at national, regional or local level. awareness regarding a specific theme? Did it have Institutional quality is strongly related to economic effects on the level of corruption? growth157, but it can also affect the quality of life of people, because of the intrinsic value that individuals can attribute to a well-ordered society158. Social happiness This category encompasses all those variables which Are the project beneficiaries overall satisfied with may affect the subjective perception of people’s the project’s implementation and outcomes? Did wellbeing, and have to do with their psychology, the project have any effect on the perception of family context, religion and cultural traits. quality of life? Did it affect the sense of security of the target population?

In researching all the possible long-term effects of project investments, it is acknowledged that there is a risk of duplication and double-counting: for example, a project for water treatment clearly has effects on environment, which may contribute to the development of new economic activities that foster economic growth.

153 Solow, 1956. 154 Becker, 1962. 155 Griliches, 1992 and Griffith, 2000. 156 Tomer, 1982 and Martinez, 2009. 157 See, for instance, Easterly et al., 2006. 158 Sen, 1987.

The ‘When’ dimension

The temporal dimension of analysis relates to the point in the project’s lifetime at which the effects materialise for the first time, how they develop over time and whether they have already stabilised or are still evolving. A clear distinction emerges between short-term and long-term effects, with the former being the first contributions made by the project and enjoyed by society after a relatively short time following project completion (about 1-5 years); the latter, on the other hand, become visible after a longer period of time and tend to stabilise over many years. It is acknowledged that, given the varying timeframe for different effects to appear and stabilise, the choice of the time horizon and the timeframe at which the ex-post evaluation is carried out can significantly affect the results of the evaluation.

The ‘How’ dimension

Project outcomes, i.e. the way projects affect the generation of certain effects and the varying timeframe for effects to appear and stabilise, are not certain, but result from a non- deterministic combination of different and interrelated factors. Five stylised determinants of project outcomes have been identified: appropriateness to the context, project design, forecasting capacity, project governance and managerial response. Five Working Hypotheses are related to these dimensions and explain how each of them can influence the generation of the project’s short or long-term effects (see Table I.2).

The three dimension of analysis are logically interconnected and by combining the ‘What’, ‘When’ and ‘How’ dimensions the evaluator can disentangle the causal chain between the project’s inputs and the outputs.

METHODOLOGY OF ANALYSIS The methodology developed to answer the evaluation questions consists of a combination of quantitative (Cost Benefit Analysis) and qualitative (personal interviews, surveys, searches of government and newspaper archives, etc.) techniques. Qualitative techniques are probably better at determining why certain effects are generated, along what dimensions, and underlying causes and courses of action of the delivery process. The media (including websites or blogs), in particular, have proved to be an excellent source of evidence identifying or revealing both objective information and perceptions about the project, thus concurring to assess the project’s impact on social happiness. At the same time, quantitative data can provide an important support to test and validate certain findings derived from interviews and other sources. The most important contribution of the CBA exercise is to provide a framework of analysis to identify the most crucial aspects of the projects’ ex-post performance and final outcome159.

159 More details on the approach adopted to carry out the ex-post CBA exercise and, in particular, indications on project identification, time horizon, conversion factors and other features are extensively described in the First Intermediate Report of this evaluation study.

Table I.2 KEY DETERMINANTS OF PROJECT OUTCOMES CONSIDERED Determinant Definition Working Hypothesis Questions to be answered Appropriatene Includes the consideration of Context traits can be more or less favourable for project performance and Has the (political, cultural, socio-economic, institutional, regulatory) ss to the institutional, cultural, social deserve early and careful consideration about which to take or to make. context played a role in influencing the attainment of long-term effects? context and economic environment The terminology of context traits that can be either ‘taken’ (that is, Were there any political, social, cultural, economic, regulatory, or into which the project is accepted, as they are considered unchangeable) or ‘made’ (by changing institutional constraints to project implementation and performance? inserted. existing or creating new traits) is drawn from Hirschman (1967). Was the project ‘trait taking’ or ‘trait making’ in its nature? If it was intended to be trait making, did it succeed? Project design Refers to the technical capacity The technical and engineering capacity to design an infrastructure and to To what extent and in what way did the technical, structural and financial to design the infrastructure provide the appropriate mechanism for its financial sustainability should features of the project influence its performance? project and to select the best be sufficiently disciplined to reduce future risks; at the same time it should Did the option selection process lead to the implementation of the most project option. leave some degrees of ‘latitude’ to enable adjustments for unforeseen promising project idea? circumstances. Was project design capacity a relevant factor in determining the observed Following Hirschman, latitude is the characteristic of a project that permits ex-post performance of the project? the project planner and operator to mould it, or to let it ‘slip’, in one Was the project design flexible enough to be adjusted, if needed, to direction or another. Some projects are so structured that latitude is external and unexpected constraints? severely restricted or completely absent: in these cases, the project is considered highly ‘disciplined’. Forecasting Relates to the feasibility and A good initial investment in building the forecasting capacity does not Were the ex-ante forecasts based on a sound methodology and a capacity capacity to predict future eliminate risks, but it increases the knowledge of the context, improves comprehensive set of information? variables, such as the demand the project design and optimises the distribution of responsibilities Were some important factors not sufficiently considered ex-ante? level. without lowering the commitment to performance. Was the forecasting capacity a relevant factor in determining the observed ex-post performance of the project? Project Concerns the number and type High stakeholder involvement, well-defined roles and responsibilities and What are the interests and motives of different actors and incentives for governance of stakeholders involved incentive mechanisms require commitment of resources and increase the decision-making? How did they change over the time-span considered? throughout the project cycle complexity of the decision-making process, which may be subject to Was the ownership of the project clearly identified? and how responsibilities are particular pressures, but they can favour the project performance and its Did contractual arrangements improve the co-ordination of different attributed and shared. sustainability over time. stakeholders towards achievement-oriented results? Was project visibility a relevant political incentive to foster proper project implementation? Was the project subject to political or other forms of pressure? Managerial Defined as the managerial and Unpredicted events that occur and undermine the sustainability of the How did the project react to exogenous, unpredictable, events? response professional ability to react to project and its capacity to lead to expected benefits can be overcome by What remedial actions were put in place? What mechanisms were used unforeseen events. prompt and adequate response from the decision-makers and project to incentivise proactive responses? managers, driven either by professionalism and experience or by creativity Why were these events unexpected? Was it due to their purely and imagination. exogenous and ex-ante unpredictable nature? Or, was it due to poor planning capacity?

STRUCTURE OF CASE STUDIES AND STANDARD TABLES OF RESULTS Qualitative and quantitative findings are integrated in a narrative way, in order to develop ten project ‘histories’ and to isolate and depict the main aspects behind their long-term performance. All case study reports share the same outline, presented in the following Table:

Table I.3 OUTLINE OF THE CASE STUDY REPORT SECTION CONTENT Projects The first section provides a brief sketch of the unit of analysis. It describes the key structural description features of the infrastructure and the service delivered, the context in which it takes place, the target population and the current performance of the project. Origin and history This section describes the background in which the decision to initiate the project was taken, the need and objectives expected be met and the key stakeholders involved and their role. The section should present a brief chronicle of the main developments after the construction phase and the most recent facts. Description of long- This section should describe the main long-term development effects provided by the term development project. The seven categories of effects should be considered and for each of them an effects assessment of the contribution of the project to that specific effect, and the timing of their materialisation and evolution, should be given. Determinants of The main drivers influencing the performance observed are described and elaborated here. project outcomes The evaluators should provide their own assessment for each of the five key determinants of project outcomes identified in the conceptual framework. Conclusions The key messages in terms of lessons learnt are developed here. Annexes Ex-post cost-benefit analysis report, list of interviewees, other ad hoc analysis if relevant (such as stakeholder mapping).

In order to maintain the structure of all the case study reports as similar as possible, and facilitate the cross-project analysis of findings, a set of standard tables is used to summarise the main evaluation results related to three dimensions of analysis (‘What’, ‘When’ and ‘How’). Section 3 and 4 of each case study include standardised tables in which scores are assigned to each type of long-term effect and each determinant. Scores ranging from -5 to +5 are given in order to intuitively highlight which are the most important effects generated for each case study and which are the most relevant determinants explaining the project outcomes. In other words, scores are used to rank the effects and determinants, showing which ones are the most relevant. Moreover, the plus or minus signs indicate the nature of the effects produced by the project (was the impact positive or negative?) and of the determinant of project performance (did the determinant positively or negatively contribute to the project outcome?).

The same scores are used to disentangle the project’s impacts on different stakeholders. This table allows one to better interpret the aggregated score given to each effect, by understanding on which actor the project impacted the most: for example, a +3 score to “Direct economic growth” may be reflected by a very high positive effect on the infrastructure operator (valued, for instance, +5) and a slightly negative effect on other actors (valued -2). As shown by this example, the aggregate score of each effect and the scores related to different stakeholders should be consistent with each other and should results from a sort of weighted average of the impacts on individual stakeholders: an aggregate positive score is inconsistent with negative impact scores on all the different stakeholders involved.

Table I.4 SCORES ON PROJECT’S IMPACT AND DETERMINANTS OF PROJECT OUTCOMES Score Meaning +5 Given the existing constraints, the highest positive effects have been generated. +4 Given the existing constraints, high positive effects have been generated, but more could have been achieved under certain conditions. +3 Moderate positive effects have been generated, with large scope for further improvement. +2 Some positive effects have been produced. +1 Very little, almost negligible, positive effects have been generated. 0 No effects have been generated. -1 Very little, almost negligible, negative effects have been generated. -2 Minor negative effects have been produced. -3 Moderate negative effects have been generated, but they could have been worse. -4 Highly negative effects have been generated. -5 The highest negative effects have been generated. Note: The same scores have been used for assessing both the project’s impacts and determinants. In the first case, they have to be interpreted as the nature and strength of effect generated by the project; in the latter, they indicate the strength of each determinant factor in influencing the project outcomes.

The ‘When’ dimensions results are synthetically presented by means of another table: for each kind of effect, a score is given to explain how the nature and strength of the impact evolved over the years, by focusing in particular, on the short-run (approximately 1-5 years after the project’s completion), the long-run (6-10 years after the project’s completion) and the future period. The Table contains information that allows the reader to immediately understand whether the project impacts have already stabilised or not. The meaning of the symbols used and an example of their application is presented in the following two Tables.

Table I.5 SYMBOLS USED TO DESCRIBE THE TEMPORAL DYNAMICS OF THE EFFECTS Symbol Meaning + or - Positive or negative effect. ++ or -- Positive or negative effects reinforced (in positive or negative direction) with respect to the previous stage. +++ or --- Positive or negative effects further reinforced (in positive or negative direction) with respect to the previous stage. +/- Mixed effect, it is not possible to assess whether the impact was positive or negative.

Table I.6 EXAMPLES OF TEMPORAL DYNAMICS OF THE EFFECTS Short run Long run Future Comments (years 1-5) (years 6- 10) years + + + The positive effect stabilised in the short-run. + ++ ++ The positive effect stabilised in the long-run. + ++ +++ The effect has grown over the years and will increase also in the future.

- + ++ The effect was at first negative; after some years it turned positive and it is still not stabilised yet. +/- + ++ Effects have been mixed in the initial stage, became positive in the long- run and are expected to further increase in the future.

ANNEX II. COST-BENEFIT ANALYSIS

This annex presents the ex-post CBA of the Dublin Wastewater Treatment project (DWWT). The purpose is to quantitatively assess the performance of the project. The methodology applied is in line with the technical note provided in the First Interim Report and, more generally, with the EC Guide (European Commission, 2008). This annex presents in more detail the assumptions, inputs and results of the CBA, along with scenario and risk analysis.

METHODOLOGY, ASSUMPTIONS AND DATA GATHERING The CBA incorporates the following assumptions:

 Project identification

The unit of analysis comprises the following elements of infrastructure:

i. the major improvements to the Ringsend wastewater treatment plant, in the centre of Dublin, incorporating –

 “interim sludge treatment” improvements at the start of the project,

 upgrade to secondary and partial tertiary (UV) treatment,

 a major increase in capacity to cater for almost all the wastewater arising in the Dublin NUTS III region,

 full sanitary sludge treatment to generate biogas and fertilizer (“biofert”),

 Electricity generation from the biogas, for internal consumption.

ii. The northern interceptor sewer, to collect wastewater from the northern fringe of the city;

iii. The pumping station at Sutton and the submarine pipeline, to convey the wastewater from the northern interceptor sewer to the Ringsend plant;

iv. A pumping station at Bullock Harbour to facilitate connection to the pre- existing Dun Laoghaire pumping station;

v. Other minor upgrade works;

vi. Subsequent investments in the plant, primarily to deal with the problem of odour;

vii. The planned future increase in capacity and installation of a long sea outfall to discharge final effluent outside the Liffey estuary area, thus avoiding the requirement to upgrade the plant to full tertiary treatment level (i.e. nutrient removal).

In addition, as part of the Design-Build-Operate contract, both Dublin City Council and the concessionaire Celtic Anglian Water (CAW) are required to contribute to a plant replacement fund, which will fund the entire replacement of plant and machinery in the final year of the concession (2020). This will clearly represent a major cost; however, it will also contribute substantially to the residual value of the plant at the end of the evaluation period (2025). The cost of this replacement programme is difficult to estimate, and the respective share of the cost between DCC and the concessionaire CAW is not disclosed. We have ignored this investment cost item, as it will make little net difference to the net return on the project.

On this basis, the total capital cost of the project, as well as funding sources, is summarised in Table II.1 (current Euros).

Table II.1 CAPITAL EXPENDITURE AND FUNDING DWWT (EUR’000S, CURRENT PRICES, VAT EXCL.) Total Funding Funding %age Cost Stage I & II EU CF Industri Irish EU Industri Irish al Public CF al users Public users* Sector Sector Interim sludge Treatment 16,214

Bullock Harbour & Related Works 27,794 Sub-total 44,008 35,93 8,072 81.7 0.0% 18.3% 6 % Stage IV - Submarine Pipeline Sutton to 57,497 23,00 34,49 40.0 0.0% 60.0% Ringsend** 0 7 % Stage V Pumping Station Sutton 20,708 Northern Interceptor Sewer 47,415 Ringsend Plant 187,997 Sub-total 256,120 130,7 36,099 89,30 51.0 14.1% 34.9% 16 5 % Total Investment Cost to Date 357,625 189,6 36,099 131,8 53.0 10.1% 36.9% 52 74 %

Estimated Future Expenditure (2012-2015) Capacity Increase 25,997 25,99 100.0% 7 Long Sea Outfall 121,317 121,3 100.0% 17 Grand Total 504,938 189,6 36,099 279,1 37.6 7.1% 55.3% 52 88 % *Industrial users were required to pay the marginal capital cost of the additional capacity required to treat their wastewater, in accordance with Lawlor & Scott (1995). **Very significant cost overruns were experienced on this stage of the project. This led to a dispute between the contractor and the client (DCC), which went to arbitration and was eventually settled for EUR 23 million (included above). Source: Department of Finance, DCC, DECLG

In current money, total capital cost amounts to EUR 505 million; in constant 2011 money it amounts to EUR 443 million (both VAT exclusive). It is notable that in constant 2011 prices, the project costs less than in current prices. This reflects the relative market conditions in the construction and civil engineering sectors in Ireland in the relevant years. The sectors have experienced severe deflation in recent years, and prices are now back at the levels of the late 1990s160.

 Time horizon

The time horizon has been set at 30 years for all the project case studies. This means that the timeframe for the CBA of the DWWT project spans from 1995 (year zero), the year in which construction of the first element of the project – the interim sludge works – commenced, to 2025 (year 30). Since the point of view is today (2011), the analysis presents a mix of historical and forecast data.

 Constant prices

The analysis is carried out in constant 2011 Euros. Data from 2012 et seq. are estimated in real terms (2011 prices, no inflation), while available data up to 2011 are historical and therefore have been inflated to convert them into 2011 Euro.

 Discount rates

Discount rates are as per the guidance in the First Interim Report. The financial discount rate is 5.0% real for both backward and forward analysis. In the economic analysis, specific social discount rates for Ireland for past and the future periods have been calculated. A real backward social discount rate of 9.1% and a real forward social discount rate of 4.0% have been used.

 Counterfactual scenario

All cash flows are incremental against a ‘Do Nothing’ scenario, i.e. a continuation of the position prior to the project, whereby the Ringsend plant only treated waste water from the centre and south of Dublin, and then only to primary treatment level. Waste water from the north of Dublin would continue to be discharged untreated from the Nose of Howth. This scenario would of course be in contravention of the Urban Waste Water Directive, among others, and would in time have attracted significant financial fines from the EU. However, we do not include the possibility of such financial sanctions in the analysis161. The purpose of the counterfactual is to have a physically feasible basis for comparison of the costs and benefits of ‘Do Project’, rather than present a fully realisable alternative project per se.

160 Based on a Water & Sanitary Services deflator provided to DKM by the Water Services section of the DECLG. 161 On the same basis that cost is not stated net of EU grant aid, except in the “national return” as part of the financial analysis.

An alternative ‘Do Something’ scenario does present itself, in terms of proceeding with a separate secondary waste water treatment plant for the north of Dublin at Baldoyle, and upgrading the Ringsend plant to deal purely with its pre-existing load. However, it did not prove possible to estimate an accurate set of investment and operational costs for this alternative, and we are forced to deal only with ‘Do Project’ and ‘Do Nothing’.

The capital investment required for ‘Do Nothing’ is based on estimates from COWI (2011), and involves expenditure of approximately EUR 25 million (2002 Euros) over a number of years starting in 1998, and again in 2018. Operating costs are based on a continuation of the Ringsend operating costs prior to the implementation of ‘Do Project’, adjusted for inflation.

We also assume that EU grant aid would not be available for this counterfactual, as there would be no basis for the EU to co-fund such a project (indeed, as indicated, it would be potentially subject to substantial EU fines).

 Data sources

The main project-specific data sources have been DCC, CAW, Department of Finance, DECLG, and the EU Commission DG Regio, as well as interviews, review of the media and previous CBAs.

At a more general level, the usual economic and demographic data are available, including population census data for 1991, 1996, 2002, 2006 and 2011. In particular, population and GDP data were available for the at NUTS III regional level. Future long term economic forecasts are based on Central Bank and IMF sources, while demographic forecasts are derived from DKM’s regional demographic model.

 Residual Value

The civil engineering elements of built assets are taken to have a useful life of fifty years, and this useful life is assumed to depreciate on a straight-line basis. As of project year 30, the undepreciated residual value of these assets is credited back to the project. Land is taken to have an infinite life, but since there has been a waste water treatment plant on the site since 1906, it has been ignored. All machinery and equipment is taken to have a NIL value at year 30162.

FUTURE SCENARIO This CBA is a combination of an ex-ante and an ex-post analysis, since the time horizon covers 17 years in the past (1995-2011), for which historical data are available and 14 years in the future (2012-2025).

162 This is notwithstanding the requirement to replace all the M&E plant in the final year of the DBO concession, as explained in an earlier footnote.

A number of capital investments – to expand capacity and install a long sea outfall tunnel - are expected to occur in the future, as discussed above and summarised in Table II.1.

Future operating costs, in terms of the payments DCC make to the concessionaire CAW, will increase in line with these capital investments. The concession ends in 2022, at which point DCC may put out a new concession to tender or decide to operate the plant itself (which would eliminate the concessionaire’s profit from the apparent operating costs). For convenience, we assume a new concession period is put in place, and that operating costs remain unchanged in real terms thereafter.

One issue not specifically taken into account is the fact that the Government plans to introduce metered water charges for all domestic users over the coming years. This is likely to have some dampening effect on the pollution load reaching the plant, in volumetric terms at least, and hence the requirement for increased capacity. However, we were not in a position to model this.

FINANCIAL ANALYSIS Sources of financing

The financing of the project is summarised in Table II.1 above. In terms of expenditure to date, The EU has contributed 53% of costs, the Irish public sector contributed 37% and local industry made capital contributions totalling 10%. Future capital expenditure is expected to be fully funded by the Irish public sector.

Operating cost and revenues

Operating costs with respect to the project as it stands now are expected to remain at their 2011 level (approximately EUR 23 million paid by DCC to the concessionaire)163. Additional operating costs will apply when the plant capacity is upgraded and the long sea outfall is put in place, adding an estimated net EUR 1.8 million and EUR 4 million per annum respectively to operating costs (2011 prices)164.

DCC does earn revenues with respect to the treatment plant, from the major industrial customers of the plant. These make a contribution towards the DCC’s payments to the concessionaire. In Ireland, commercial and industrial customers pay water charges to their respective local authorities, mostly based on metered water usage. Total revenues in 2010 were approximately EUR 3.3 million (current Euros).

However, the water industry is not commercialised and there is little transparency in the charging system. Most importantly, domestic customers pay no water charges, although it is

163 Ideally, we would use the actual operating costs incurred by the concessionaire CAW, but this information is not available. While CAW’s financial statements are lodged with the Irish Companies Registration Office (www.cro.ie), because the company operates a number of water supply and wastewater treatment plants around Ireland, it is not possible to isolate operational financial data for the Ringsend plant. 164 Operating costs are as per COWI (2011), confirmed by DCC.

planned that charges will be introduced in the coming years, in the context of a commercialisation of the entire water industry. Because of this, we only consider the industrial revenues to DCC in the financial analysis below, and ignore them for the purposes of the socio- economic analysis.

Results of Financial analysis

Using the cost-benefit methodology described above, we calculated:

 the Financial Net Present Value and the Financial Rate of Return on investment – FNPV(C) and FRR(C), and

 the Financial Net Present Value and Financial Rate of Return on national capital – FNPV(K) and FRR(K), i.e. net of EU grant aid.

The results are presented in Table II.2, comparing ‘Do Project’ and ‘Do Nothing’ (detailed tables at back of Annex).

Table II.2 FINANCIAL CBA OF DWWT Investment Return FNPV(C) FRR(C) FBCR(C) EUR million Do Project -862 -11.6% 0.10 Do Nothing -53 * 0.47 Net NPV for Project -809 -11.4% National Return FNPV(K) FRR(K) FBCR(K) EUR million Do Project -611 -11.2% 0.13 Do Nothing -53 * 0.47 Net NPV for Project -558 -11.0% *not calculated.

The table confirms that, on a purely financial basis, the project as an investment would not have been viable, and required subvention. Financial NPV of the project is approximately –EUR 0.86 billion. With EU grant aid, it generates a financial return on national capital of approximately –EUR 0.61 billion. The highly negative result is due in large part to the annual payments to the concessionaire, which is not recovered via user charges.

On the basis of our assumptions, the Do Nothing option is also non-viable, generating a Financial NPV of –EUR 53 million. This is reflective of very limited capital investment and low operating costs for the pre-existing primary treatment plant. It is worth keeping in mind that in the financial analysis we ignore the likelihood that Ireland would be subject to a substantial fine for failure to comply with Directive 91/271/EEC under this option. These fines could exceed EUR 40 million per annum165.

165 See http://www.greenstar.ie/docs/2010/DKM%20-%20Greenstar%20paper%20on%20EU%20fines.pdf.

ECONOMIC ANALYSIS Having assessed the purely financial performance of the project and compared it with the ‘do nothing’ counterfactual, the next step is to consider the project from a socio-economic viewpoint. This involves:

 conversion of market prices to accounting (true economic or shadow) prices, and

 Inclusion of external costs and benefits.

FROM MARKET TO ACCOUNTING PRICES Financial Costs and Benefits

In the economic analysis all input data are converted from financial to shadow prices, in order to reflect their opportunity costs. The conversion factors defined in the First Interim Report have been applied, namely:

Table II.3 SHADOW PRICE CONVERSION FACTORS DWWT Resource Conversion Factor Source

Land n/a 1st Interim Report, Volume 1, Table AII.8

Labour 1.00 1st Interim Report, Volume 1, Table AII.13 traded goods & Services* 0.989/1.00 1st Interim Report, Volume 1, Table AII.8 non-traded goods & Services* 0.989/1.00 1st Interim Report, Volume 1, Table AII.8

Other* 0.989/1.00 1st Interim Report, Volume 1, Table AII.8

Public funds 1.25/1.5 See discussion below. *backward/forward.

The shadow price of public funds is relevant to actual public sector expenditure (net of EU funding and industrial wastewater revenue earned by DCC), to reflect the distortionary impact of non-optimal taxes raised to fund public expenditure on the project as well as crowding out of private expenditure. The EU Commission 2008 Guide to CBA indicates that “If there are no national guidelines on this issue, MCPF (marginal cost of public funds) = 1 is the default rule suggested in this Guide” (p.54).

National guidelines do exist for Ireland. CSF evaluation Unit (1999) states: “we recommend that a shadow price of 150% be applied to Exchequer cash flows (taxes, subsidies and grants) to take account of the distortionary effect of taxation” (p.15). This is in line with the recommendations in Honohan (1998), who noted that the appropriate figure in the mid-1980s would have been in excess of 200%, the reduction over time reflecting lower marginal income tax rates.

More recently, Murphy et al. (2003) in a report to the State enterprise promotion authority, have recommended using 1.25, reflecting further reductions in marginal income tax rates.

On this basis, we apply a rate of 1.5 for expenditure in the 1980s and 1990s, and 1.25 for expenditure in the 2000s and the current decade166.

Externalities and their Valuation

The key benefit of this project from a socio-economic viewpoint is the improvement in the water quality of Dublin Bay. This is largely an external benefit, which is not captured in the market (given the lack of household wastewater charges in Ireland), although some of the benefit may be reflected in increased property valuations.

The methodology adopted to estimate this benefit is the same as used in the Ría de Vigo project, and is based on Pearce et al’s (2004) approach for the evaluation of environmental projects, and on WATECO (2003)167. This approach identifies user benefits (related to actual, planned or possible use) and non-user benefits, which in turn are divided into:

 existence (unrelated to usage by anyone),

 altruistic (related to usage by others now) and

 bequest (related to usage by future generations) benefits.

Two notable key differences between Ría de Vigo and DWWT are that:

i. there is no commercial fishing in Dublin Bay, and as far as we are aware, no concrete plans to develop such a fishery in the future. That said, in Ría de Vigo no economic benefits were identifiable from the project in respect of these fisheries168.

ii. Dublin Bay, while a valuable amenity for the population of Dublin, and a valuable addition to the attractions of Dublin, is not a major tourism focus per se.

However, fisheries and tourism benefits would not be expected to be reflected in households’ WTP for the environmental benefits delivered. In the Ría de Vigo case study, a valuation of EUR86.24 per household was derived, based on a sample of 30 Contingent Valuation Method (CVM) studies in advanced countries, and weighted by reference to national GDP per capita169.

Eurostat indicates that in 2010 GDP per capita in Ireland was 28% higher than in Spain (PPP)170; on this basis WTP per household in Ireland would be EUR 110.39171. This would vary by year in

166 Irish marginal income tax rates have risen again in the current decade, with the prospect of further increases. On this basis one might argue that a shadow price in excess of 1.25 should be used for the current decade. However for simplicity we leave the rate unchanged. 167 See European Commission (2008) Annex F for a more detailed discussion. 168 It is noteworthy that Spain incurred a significant fine from the EU related to the failure to comply with the Shellfish Waters Directive, because of the importance of Ría de Vigo as a commercial fishery. 169 These 30 cases were drawn from the following meta-analyses of CVM/WTP studies: Barton (1999); US Environmental Protection Agency, Office of Water (2000); US Environmental Protection Agency, Office of Policy, Economics and Innovation (2000); US Environmental Protection Agency, Office of Policy, Economics and Innovation (2000a); Källstrøm et al. (2010). 170 http://epp.eurostat.ec.europa.eu/tgm/table.do?tab=table&init=1&language=en&pcode=tec00114&plugin=1

line with economic growth. It is generally accepted in the literature when applying Benefits Transfer to adjust valuations by reference to relative income levels (see Pearce [2003] and European Commission [2008], Annex F)172; this is subjected to further testing under the Scenario & Sensitivity Analysis sub-section below.

The population of the Dublin NUTS III region in 2011 was 1.27 million, and we use this as representative of the affected households173. Average household size in Dublin is estimated by DKM at 2.63 in 2011, implying 470,000 households.

Economic performance

The economic performance of the project – Economic Net Present Value (ENPV), Economic Rate of Return (ERR) and Benefit-Cost Ratio (EBCR) – is summarised in Table II.4 (detailed tables at back of Annex).

Table II.4 SOCIO-ECONOMIC CBA OF DWWT PROJECT ENPV ERR EBCR EUR million Do Project 246 10.3% 1.20 Do Nothing -89 * 0.37 Net NPV for Project 335 11.7% *not calculated.

As can be seen, at a socio-economic level, the project generates significant benefits for society, generating an ENPV of EUR 246 million. The valid measure is compared to the counterfactual of no up-grade or increase in capacity at the plant, which generates an ENPV of - EUR89 million. Therefore the net benefit to society of the project is an ENPV of EUR 335 million.

‘Do Project’ is significantly more positive on a socio-economic basis than on a pure financial basis, compared to ‘Do Nothing’. This is due to the inclusion of the WTP by households for the improvement in the waters of Dublin Bay (see further discussion below).

PREVIOUS CBAS A number of CBAs has been undertaken on this project in the past, namely:

a) Ex ante CBA of the project by the Project Directorate, Water, waste and Agriculture Department, EIB (1999).

171 It is widely recognised that GDP overstates the true level of income in Irish households, because of the high level of foreign direct investment (FDI) in Ireland. In 2011, GDP exceeded GNP in Ireland by 24.1% (ESRI, 2012). However, income levels in Dublin are significantly higher than in the rest of Ireland, and in view of this we have decided to use GDP in the current analysis. 172 Although there is debate as to whether the income elasticity of WTP is equal to one; e.g. Schlepfer (2007) and Hokby & Soderqvist (2001) 173 CAW estimates at the moment that the plant serves 1.1 million people. A proportion of people living in the region are relatively remote from Dublin Bay, or their nearest seaside area is outside the Bay. However, large numbers of people commute to and visit Dublin from outside the region, and our valuation incorporates non-use values which could potentially extend well beyond the region.

This estimated investment cost at EUR 188 million, and additional net operating costs of EUR 79 million, compared to benefits of only EUR 48 million (all present values at 1999 prices, evaluated over 20 years at 5% discount rate).

On this basis, it concluded that

“the principal justification of the scheme does not rest in direct benefits to the local population, but rather in the presumed externalities accruing to persons and countries further afield.” (p.16)

However it does not elaborate on what these externalities might be.

It must be noted that actual capital and operating costs are well in excess of those used in the EIB project appraisal. Benefits were user only, and made up of sludge as fertilizer EUR 12 million; revival of commercial fisheries EUR 3.2 million; recreation EUR 32.8 million. In reality, disposal of sludge as fertilizer represents a cost, while there appears no prospect at the moment of the development of commercial fisheries in the bay. The last of the categories of benefits is estimated on the basis of 100,000 households using Dollymount strand per annum, and a mean WTP of EUR 25 per household per annum with respect to compliance with EU Bathing Water Directive (aggregate EUR 2.5 million per annum). Our assessment of WTP is considerably wider, covering the entire population of Dublin and the total range of user and non-user benefits.

b) Ex Ante CBA by Dublin Corporation (now DCC) in 1999.

This ex ante CBA was an update of a CBA undertaken at preliminary report stage (in 1993). It estimated a capital cost of EUR 182 million and annual operating costs of EUR 7.3 million (1999 prices). It derived a highly positive return of 13.6% for the project, but included a number of arbitrary benefits notably:

 2.5% of the estimated tourism value added in the catchment;

 2% of industrial and commercial value added;

 An additional 5% for “other benefits”.

The methodology was thus not comparable with the current analysis.

c) Ex Post CBA by MCAL in 2004.

This ex post CBA derived an ENPV of EUR 119 million, and an ERR of 6.71%. It differs from the current methodology in a number of respects, notably:

 Annual operating costs appears to be significantly underestimated, at EUR 10.7 million per annum;

 It includes a benefit in respect of an estimated 45,000 housing units that it would not have been possible to build in the Dublin region in the absence of the plant, due to

lack of wastewater treatment capacity174. We have not included this element separately in the current study.

It adds:

“It should also be noted that it was too early in the life of the project to determine ecological benefits due to water quality improvements in the Bay. The future inclusion of these benefits would further increase the rate of return on the project.”

d) Most recently, the ex post CBA by COWI (2011). It generated the following results:

Table II.5 RESULTS OF COWI (2011) CBA OF DWWT (2010 PRICES) Financial FNPV FRR EUR million Do Project -674.6 -11.4% Socio-economic ENPV ERR EUR million Do Project -324.6 -4.3% Source: COWI (2011)

The financial results are reasonably similar to our own, as one would expect, given the relative timing of the studies. The socio-economic results differ greatly, however, and reflect a significantly different methodology, notably:

 COWI includes the benefit in respect of an estimated 45,000 housing units that it would not have been possible to build in the Dublin region in the absence of the plant, as per the 2004 ex post CBA.

 COWI only include a very modest external benefit in terms of improved bathing water quality, of EUR 1.2 million per annum, in accordance with the 2005 ex post CBA by MACL.

SCENARIO AND SENSITIVITY ANALYSIS A number of scenarios can be tested, based on alternative forecasts, namely:

 Higher and Lower economic growth, which will translate into higher and lower future WTP for environmental improvements;

 As an alternative to the base case social discount rates, we also test a rate equivalent to the social opportunity cost of capital, i.e. the return that can be generated on the marginal project in the private sector175. The Guide to Cost Benefit analysis of

174 In accordance with a methodology developed by DKM et al. (2004). 175 In a closed economy with perfect information, no distortions and no externalities the social discount rate and the social opportunity cost of capital are equivalent.

Investment Projects recommends 5% real as a benchmark figure, and this is what we use.

It is also worth testing the project’s sensitivity to the level of household WTP for improvements to the waters of Dublin Bay (as opposed to future growth), given the relative importance of this variable in the CBA calculations. We test scenarios whereby WTP is varied by +/-10%.

The results are presented in the tables below (socio-economic analysis only).

Table II.6 SOCIO-ECONOMIC CBA OF DWWT PROJECT - HIGH ECONOMIC GROWTH ENPV ERR EBCR EUR million Do Project 300 10.7% 1.25 Do Nothing -89 * 0.37 Net NPV for Project 390 12.1% *not calculated

Table II.7 SOCIO-ECONOMIC CBA OF DWWT PROJECT – LOW ECONOMIC GROWTH ENPV ERR EBCR EUR million Do Project 185 9.7% 1.15 Do Nothing -89 * 0.37 Net NPV for Project 275 11.2% *not calculated

Table II.8 SOCIO-ECONOMIC CBA OF DWWT PROJECT – SOCIAL OPPORTUNITY COST OF CAPITAL (5% THROUGHOUT) ENPV ERR EBCR EUR million Do Project 345 10.3% 1.35 Do Nothing -69 * 0.40 Net NPV for Project 414 11.7% *not calculated

Table II.9 SOCIO-ECONOMIC CBA OF DWWT PROJECT – WTP +10% ENPV ERR EBCR EUR million Do Project 381 11.9% 1.32 Do Nothing -89 * 0.37 Net NPV for Project 470 13.4% *not calculated

Table II.10 SOCIO-ECONOMIC CBA OF DWWT PROJECT – WTP -10% ENPV ERR EBCR EUR million Do Project 111 8.5% 1.09 Do Nothing -89 * 0.37 Net NPV for Project 200 9.9% *not calculated

While the various scenarios have the expected impact on the results, none overturns the ranking of the alternative projects, and the project ENPV remains positive throughout. Thus we can conclude that our results are robust to these scenarios.

With regard to the sensitivity to WTP, so long as the average household WTP in the Dublin region is EUR83 or more per annum, then the Project is worthwhile on a socio-economic basis (Figure I.1). Since our estimated household WTP is approximately EUR110, this gives a reasonable degree of reassurance that the project is worthwhile. So long as actual WTP is at least 75% of our estimate, the project will generate a positive socio-economic return.

Figure II.1 SENSITIVITY OF NET ENPV TO HOUSEHOLD WTP FOR WATER IMPROVEMENTS

Source: Authors

RISK ANALYSIS Monte Carlo Analysis was also performed on our CBA model, assigning a triangular distribution to five input variables, to simulate the future uncertainty associated with these variables. The

peak of the distributions and their upper and lower bounds (at which points their probabilities fall to zero) are outlined in Table II.11176.

Table II.11 PARAMETERS FOR PROBABILITY DISTRIBUTIONS FOR MODEL INPUTS Input Variable Peak (Baseline Lower Bound Upper Bound (Annual Growth Rates) Scenario) Value (Probability=0) (Probability=0) Future GDP Growth 2.8% 5.0% 0.8% Value of CO2 emissions 4.0% 8.0% 0.0% growth Population Growth Dublin 0.0% 2.0% -1.0% NUT III region Avg Household size growth in -0.76% 0.50% 1.50% Dublin NUTS III region Future Investment cost 0.0% 100% -20% variance

The last of these variables, relating to the cost of future investments, captures the risk that these costs will be significantly higher than expected, as often happens with major infrastructure investments.

The results (Table II.12) confirm a strong economic NPV and internal rate of return for the project. The simulations were run two thousand times. The computed expected value of ENPV EUR 236 million and ERR 10.1% compare to the base case values of EUR 246 million and 10.3% respectively.

Table II.12 OUTPUT STATISTICS OF MONTE CARLO SIMULATIONS Economic Net Economic Internal Present Value Rate of Return (EUR million) Computed Expected Value 236 10.1% Standard deviation 49 0.5% Minimum value 97 8.3% Maximum value 400 11.5%

Probability of being not higher than the reference value 51.4% 49.2% Probability of being higher than the reference value 48.6% 50.8% Probability of being lower than EUR NIL (ENPV) and 4% NIL NIL (EIRR) Source: Authors

The results are further elaborated in the charts overleaf.

176 The software used to generate the Monte Carlo results is Risk Analyzer Release 11.02 (http://www.add- ins.com/analyzer/index.htm).

Figure II.2 PROBABILISTIC DISTRIBUTION OF ECONOMIC NET PRESENT VALUE (EUR MILLION)

Source: Authors

Figure II.3 CUMULATIVE PROBABILISTIC DISTRIBUTION OF THE ECONOMIC NET PRESENT VALUE (EUR MILLION)

Source: Authors

Figure II.4 PROBABILISTIC DISTRIBUTION OF ECONOMIC INTERNAL RATE OF RETURN

Source: Authors

Figure II.5 CUMULATIVE PROBABILISTIC DISTRIBUTION OF ECONOMIC INTERNAL RATE OF RETURN

Source: Authors

Table II.13 DETAILED CBA – DO PROJECT (EUR’000) DIRECT COST DIRECT BENEFITS DIRECT IMPACTS EXTERNAL/INDIRECT IMPACTS SHADOW PRICE ADJUSTMENTS SOCIO-ECONOMIC CBA FACILITY OPERATIONS

year Capital Operating TOTAL Expendit costs DIRECT ure OPERA TOR COSTS

Total Total Waste TOTAL UNDISCOUNT DISCOUN DISCOUN WTP for TOTAL SHADO Oth TOTAL NET INDIRECT SHADOW NET SOCIO- NET SOCIO- Investme operating Water FINANC ED TED (@ TED @ Improveme W PRICE er SHADOW DIRECT / PRICE ECONOMIC ECONOMIC nt cost costs Treatmen IAL financial social nts in Bay OF PRICE IMPACT EXTERNA ADJUSTME BENEFIT BENEFIT

t revenue BENEFI discount discount PUBLIC ADJUSTME L NT (UNDISCOUN (DISCOUNT

TS rate) rate FUNDS NT IMPACTS TED) ED)

calendar project 1995 0 -5,196 0 -5,196 0 0 -5,196 -11,343 -20,936 0 0 2,103 29 2,131 -5,196 0 2,131 -3,065 -12,350

1996 1 -8,664 0 -8,664 0 0 -8,664 -18,011 -31,995 0 0 -1,234 48 -1,186 -8,664 0 -1,186 -9,850 -36,375

1997 2 -8,795 0 -8,795 0 0 -8,795 -17,414 -29,771 0 0 -278 48 -230 -8,795 0 -230 -9,025 -30,548

1998 3 -15,293 0 -15,293 0 0 -15,293 -28,837 -47,446 0 0 8,732 84 8,816 -15,293 0 8,816 -6,476 -20,094

1999 4 -3,798 -421 -4,219 0 0 -4,219 -7,576 -11,997 0 0 -728 23 -705 -4,219 0 -705 -4,924 -14,003

2000 5 -60,962 -2,276 -63,238 0 0 -63,238 -108,158 -164,834 0 0 15,437 348 15,785 -63,238 0 15,785 -47,452 -123,689

2001 6 -100,992 -1,905 - 0 0 -102,897 -167,609 -245,839 0 0 -3,911 566 -3,345 -102,897 0 -3,345 -106,243 -253,832 102,897 2002 7 -45,900 -2,554 -48,454 0 0 -48,454 -75,168 -106,109 0 0 6,209 266 6,476 -48,454 0 6,476 -41,978 -91,928

2003 8 -17,547 -5,731 -23,278 6,458 6,458 -16,821 -24,852 -33,763 45,076 45,076 -191 57 -134 -16,821 44,681 -134 27,726 55,653

2004 9 -28,868 -9,089 -37,957 6,458 6,458 -31,499 -44,323 -57,953 47,533 47,533 6,027 138 6,165 -31,499 47,100 6,165 21,765 40,044

2005 10 0 -14,615 -14,615 5,125 5,125 -9,490 -12,718 -16,004 50,251 50,251 -3,654 24 -3,630 -9,490 49,776 -3,630 36,656 61,815

2006 11 0 -19,022 -19,022 4,613 4,613 -14,410 -18,391 -22,273 52,917 52,917 -6,951 54 -6,897 -14,410 52,396 -6,897 31,089 48,054

2007 12 0 -18,304 -18,304 3,793 3,793 -14,511 -17,638 -20,559 55,978 55,978 -4,576 59 -4,517 -14,511 55,408 -4,517 36,380 51,542

2008 13 0 -19,021 -19,021 3,383 3,383 -15,638 -18,103 -20,307 54,627 54,627 -4,755 67 -4,688 -15,638 54,001 -4,688 33,675 43,731

2009 14 0 -21,690 -21,690 3,895 3,895 -17,795 -19,619 -21,181 51,097 51,097 -5,423 76 -5,346 -17,795 50,863 -5,346 27,721 32,996

2010 15 0 -24,357 -24,357 4,408 4,408 -19,949 -20,946 -21,764 51,170 51,170 -6,089 85 -6,004 -19,949 50,869 -6,004 24,917 27,184

2011 16 0 -23,946 -23,946 4,387 4,387 -19,559 -19,559 -19,559 53,330 53,330 -5,986 83 -5,903 -19,559 52,994 -5,903 27,532 27,532

2012 17 0 -23,947 -23,947 4,367 4,367 -19,580 -18,648 -17,947 54,421 54,421 -5,987 0 -5,987 -19,580 54,196 -5,987 28,630 26,242

2013 18 0 -23,947 -23,947 4,346 4,346 -19,601 -17,779 -16,468 56,304 56,304 -5,987 0 -5,987 -19,601 56,040 -5,987 30,452 25,584

2014 19 -73,657 -23,948 -97,605 4,326 4,326 -93,279 -80,578 -71,831 58,651 58,651 15,263 0 15,263 -93,279 58,345 15,263 -19,671 -15,148

2015 20 -73,657 -23,949 -97,606 4,305 4,305 -93,301 -76,759 -65,855 61,095 61,095 15,263 0 15,263 -93,301 60,746 15,263 -17,292 -12,205

2016 21 0 -29,895 -29,895 4,285 4,285 -25,610 -20,066 -16,569 63,766 63,766 -7,474 0 -7,474 -25,610 63,371 -7,474 30,287 19,594

2017 22 0 -29,896 -29,896 4,264 4,264 -25,632 -19,127 -20,257 65,987 65,987 -7,474 0 -7,474 -25,632 65,545 -7,474 32,439 25,637

2018 23 0 -29,896 -29,896 4,244 4,244 -25,653 -18,231 -19,494 68,353 68,353 -7,474 0 -7,474 -25,653 67,860 -7,474 34,733 26,394

2019 24 0 -29,897 -29,897 4,223 4,223 -25,674 -17,377 -18,760 70,666 70,666 -7,474 0 -7,474 -25,674 70,120 -7,474 36,972 27,015

2020 25 0 -29,898 -29,898 4,203 4,203 -25,696 -16,564 -18,053 73,058 73,058 -7,475 0 -7,475 -25,696 72,457 -7,475 39,286 27,602

2021 26 0 -29,899 -29,899 4,182 4,182 -25,717 -15,788 -17,374 75,530 75,530 -7,475 0 -7,475 -25,717 74,890 -7,475 41,698 28,170

2022 27 0 -29,900 -29,900 4,162 4,162 -25,738 -15,049 -16,719 78,086 78,086 -7,475 0 -7,475 -25,738 77,406 -7,475 44,193 28,707

2023 28 0 -29,901 -29,901 4,141 4,141 -25,760 -14,344 -16,090 80,729 80,729 -7,475 0 -7,475 -25,760 80,007 -7,475 46,772 29,214

2024 29 0 -29,902 -29,902 4,121 4,121 -25,781 -13,672 -15,484 83,461 83,461 -7,475 0 -7,475 -25,781 82,697 -7,475 49,440 29,692

2025 30 248,264 -29,903 218,361 4,100 4,100 222,461 112,358 128,466 86,285 86,285 -7,476 0 -7,476 222,461 85,477 -7,476 300,462 173,509

Total -195,064 -557,709 - 101,783 0 0 101,783 -650,990 -861,889 - 0 1,438,370 0 0 1,438,3 -61,462 2,05 -59,406 -650,990 1,427,244 -59,406 716,848 245,739 752,773 1,094,726 70 7

Investment Return NPV IRR BCR (EURm) (discounted) Financial -862 - 0.10 11.6 % Socio-economic 246 10.3 1.20 %

Table II.14 DETAILED CBA – DO NOTHING (EUR’000) DIRECT COSTS (OPERATOR) DIRECT BENEFITS (OPERATOR) DIRECT IMPACTS (OPERATOR) EXTERNAL/INDIRECT IMPACTS SHADOW PRICE ADJUSTMENTS SOCIO-ECONOMIC CBA FACILITY OPERATIONS year Capital Operating TOTAL Expenditure costs DIRECT OPERAT OR COSTS

Total Total Waste TOTAL UNDISCOUNT DISCOUNT DISCOUNT WTP for TOT SHADO Oth TOTAL NET INDIRECT SHADOW NET SOCIO- NET SOCIO- Investment operating Water FINANCI ED ED (@ ED @ Improveme AL W er SHADOW DIREC / PRICE ECONOMIC ECONOMIC cost costs Treatment AL financial social nts in Bay PRICE PRICE T EXTERNA ADJUSTME BENEFIT BENEFIT revenue BENEFI discount discount OF ADJUSTME IMPAC L NT (UNDISCOUN (DISCOUNTE

TS rate) rate PUBLIC NT T IMPACTS TED) D)

FUNDS

calendar project 199 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 5 199 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 6 199 2 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 7 199 3 -832 0 -832 0 0 -832 -1,569 -2,581 0 0 -416 5 -411 -832 0 -411 -1,243 -3,857 8 199 4 -832 0 -832 0 0 -832 -1,494 -2,366 0 0 -416 5 -411 -832 0 -411 -1,243 -3,535 9 200 5 -3,327 0 -3,327 0 0 -3,327 -5,691 -8,673 0 0 -832 18 -814 -3,327 0 -814 -4,141 -10,794 0 200 6 -3,327 0 -3,327 0 0 -3,327 -5,420 -7,950 0 0 -832 18 -814 -3,327 0 -814 -4,141 -9,894 1 200 7 -5,823 0 -5,823 0 0 -5,823 -9,034 -12,752 0 0 -1,456 32 -1,424 -5,823 0 -1,424 -7,247 -15,870 2 200 8 -6,552 -3,075 -9,627 3,178 3,178 -6,552 -9,681 -13,152 0 0 -1,638 19 -1,620 -6,552 0 -1,620 -8,172 -16,403 3 200 9 103 -3,075 -2,973 3,178 3,178 103 144 189 0 0 26 -18 8 103 0 8 110 203 4 200 10 -553 -3,075 -3,628 2,522 2,522 -553 -741 -933 0 0 -138 -11 -149 -553 0 -149 -702 -1,184 5 200 11 -805 -3,075 -3,880 2,270 2,270 -805 -1,028 -1,245 0 0 -201 -8 -209 -805 0 -209 -1,015 -1,568 6 200 12 -1,209 -3,075 -4,284 1,866 1,866 -1,209 -1,469 -1,713 0 0 -302 -4 -306 -1,209 0 -306 -1,515 -2,146 7 200 13 -1,411 -3,075 -4,486 1,664 1,664 -1,411 -1,633 -1,832 0 0 -353 -1 -354 -1,411 0 -354 -1,765 -2,292 8 200 14 -1,158 -3,075 -4,233 1,917 1,917 -1,158 -1,277 -1,379 0 0 -290 -4 -294 -1,158 0 -294 -1,452 -1,729 9 201 15 -906 -3,075 -3,981 2,169 2,169 -906 -952 -989 0 0 -227 -7 -234 -906 0 -234 -1,140 -1,243 0 201 16 -916 -3,075 -3,991 2,159 2,159 -916 -916 -916 0 0 -229 -7 -236 -916 0 -236 -1,152 -1,152 1 201 17 -926 -3,075 -4,001 2,149 2,149 -926 -882 -849 0 0 -232 0 -232 -926 0 -232 -1,158 -1,061 2 201 18 -936 -3,075 -4,011 2,139 2,139 -936 -849 -787 0 0 -234 0 -234 -936 0 -234 -1,171 -983 3 201 19 -947 -3,075 -4,022 2,128 2,128 -947 -818 -729 0 0 -237 0 -237 -947 0 -237 -1,183 -911 4

201 20 -957 -3,075 -4,032 2,118 2,118 -957 -787 -675 0 0 -239 0 -239 -957 0 -239 -1,196 -844 5 201 21 -967 -3,075 -4,042 2,108 2,108 -967 -757 -625 0 0 -242 0 -242 -967 0 -242 -1,208 -782 6 201 22 -977 -3,075 -4,052 2,098 2,098 -977 -729 -772 0 0 -244 0 -244 -977 0 -244 -1,221 -965 7 201 23 -1,810 -3,075 -4,885 2,088 2,088 -1,810 -1,286 -1,376 0 0 -453 0 -453 -1,810 0 -453 -2,263 -1,719 8 201 24 -1,820 -3,075 -4,895 2,078 2,078 -1,820 -1,232 -1,330 0 0 -455 0 -455 -1,820 0 -455 -2,275 -1,663 9 202 25 -4,300 -3,075 -7,375 2,068 2,068 -4,300 -2,772 -3,021 0 0 -1,075 0 -1,075 -4,300 0 -1,075 -5,375 -3,776 0 202 26 -4,310 -3,075 -7,385 2,058 2,058 -4,310 -2,646 -2,912 0 0 -1,078 0 -1,078 -4,310 0 -1,078 -5,388 -3,640 1 202 27 -6,790 -3,075 -9,865 2,048 2,048 -6,790 -3,970 -4,411 0 0 -1,697 0 -1,697 -6,790 0 -1,697 -8,487 -5,513 2 202 28 -7,623 -3,075 -10,698 2,038 2,038 -7,623 -4,245 -4,761 0 0 -1,906 0 -1,906 -7,623 0 -1,906 -9,529 -5,952 3 202 29 -1,047 -3,075 -4,122 2,028 2,028 -1,047 -555 -629 0 0 -262 0 -262 -1,047 0 -262 -1,309 -786 4 202 30 18,700 -3,075 15,625 2,017 2,017 18,700 9,445 10,799 0 0 -264 0 -264 18,700 0 -264 18,435 10,646 5 Tot -42,262 -70,725 -112,987 50,083 0 0 50,083 -42,262 -52,845 -68,370 0 0 0 0 0 -15,921 36 -15,884 -42,262 0 -15,884 -58,146 -89,416 al

Investment Return NPV IRR BCR (EURm) (discounted) Financial -53 #NU 0.47 M! Socio-economic -89 #NU 0.37 M!

ANNEX III. GLOSSARY OF TERMS

Biofert Dry stabilised compost-like material output of anaerobic digestion of sewage sludge, suitable for use as agricultural fertiliser. Biogas Gaseous output of anaerobic digestion process, containing approximately 55% methane and suitable for combustion to generate electricity. Biochemical Oxygen Demand The amount of dissolved oxygen needed by aerobic biological organisms to break down the organic polluting matter in the water. One of the main indicators used to measure water pollution. The EPA stipulates that after secondary treatment the water should have a BOD of no higher than 25mg/l, typically before treatment wastewater has a BOD in the range of 100 – 300 mg/l.

Daily organic load A compound measure of the total volume of wastewater passing through a treatment plant which takes into account both the volume and pollution concentration of the waste water. It is defined as Organic load (kg/day) = Daily flow (m3/day) x BOD (mg/l) 1000 Design Build Operate (DBO) Design-Build-Operate or DBO is a type of Public Private Partnership (PPP), whereby the public authority appoints a concessionaire to Design, Build and Operate a piece of infrastructure. The concessionaire is free to design the plant as they see fit, to deliver an agreed outcome. The concessionaire then builds the plant according to this design and operates the plant for a set period of time (typically 20 - 25 years), at the end of which the plant is transferred back to the public authority. Ownership remains with the local authority throughout. Under traditional procurement the public authority (the “employer”) designs the plant and employs a contractor to build it according to the employer’s specification. Upon completion the public authority takes over the operation of the plant. Eutrophication Enrichment of water by nutrients, typically nitrogen and phosphorous compounds, causing accelerated algal growth which leads to oxygen depletion in water to the detriment of other aquatic life. Faecal Coliforms Bacterial count Indicative of water contamination by sewage, and thus the possibility of the presence of pathogenic bacteria and viruses. It is a key variable to gauge the threat bathing waters are to human health. Typically unpolluted waters should show very low counts, but small numbers may be present due to waste from birds and wild mammals. Densities in excess of 2000 organisms per 100ml would indicate an appreciable level of contamination177. For example E. Coli. E. Coli. Escherichia coli; a type of bacteria found in and indicative of the presence of faecal matter, particularly in water. Lamella Settlement tanks A water treatment process that features a rack of inclined metal plates, which cause material to precipitate from water that flows across the plates. Inclined plate settlers or lamella® clarifiers are primarily used in the water and wastewater treatment industries to separate solids from liquids in effluent streams. (http://en.wikipedia.org/wiki/Lamella_clarifier).

177 Dublin Bay Water Quality Management Plan – Technical Report 5 – Water Quality Surveys (1991)

Less Sensitive Areas Marine water bodies or areas where the discharge of waste water does not adversely affect the environment as a result of morphology, hydrology or specific hydraulic conditions which exist in the area. When identifying less sensitive areas, Member States shall take into account the risk that the discharged load may be transferred to adjacent areas where it can cause detrimental environmental effects. Sensitive Areas Sensitive areas, within the meaning of the directive 91/271/EEC, include: • freshwater bodies, estuaries and coastal waters which are eutrophic or which may become eutrophic if protective action is not taken; • surface freshwaters intended for the abstraction of drinking water which contain or are likely to contain more than 50 mg/l of nitrates; • areas where further treatment is necessary to comply with other Directives, such as the Directives on fish waters, on bathing waters, on shellfish waters, on the conservation of wild birds and natural habitats, etc. Population Equivalent Wastewater comes from a number of sources, including industry. PE is the metric that allows comparison between the various sources that generate wastewater converting them to a single equivalent number. UWWT regulations define one population equivalent as the load resulting in a BOD of 60g/litre. Primary Treatment Treatment of urban waste water by a physical and/or chemical process involving settlement of suspended solids, or other processes by which the BOD5 of the incoming waste water is reduced by at least 20% before discharge and the total suspended solids of the incoming waste water are reduced by at least 50%. Secondary Treatment Treatment of urban waste water by a process generally involving biological treatment with a secondary settlement or other process in which the requirements established in Table 1 of Annex I of Directive 91/271/EEC are met. Sequencing Batch Reactors Sequencing batch reactors (SBR) or sequential batch reactors are industrial processing tanks for the treatment of wastewater. SBR reactors treat waste water in batches. Oxygen is bubbled through the waste water to reduce biochemical oxygen demand (BOD) and chemical oxygen demand (COD) to make it suitable for discharge into sewers or for use on land. (http://en.wikipedia.org/wiki/Sequencing_batch_reactor) Sewerage Pipes or networks of pipes carrying waste water and/or Stormwater, whether to a treatment plant or for discharge untreated into water bodies. Tertiary Treatment Advanced treatment of urban waste water employed when specific wastewater constituents which cannot be removed by secondary treatment must be removed. Usually relates to UV treatment to kill pathogens remaining after secondary treatment, and/or nutrient (nitrogen, phosphorus) removal.

100

ANNEX IV. LIST OF INTERVIEWEES

The following is a list of interviews undertaken as part of this evaluation. We are grateful to all participants, as we are to the Department of Finance, DECLG and DG Regio Ireland desk for access to their files on the project.

Interviewee Affiliation Position Date Eoin Gaffney Swim Ireland Secretary of Masters Telephone conversations – various dates Committee Kenneth Irish National Sailing Sailing Coach Telephone conversation – 15th February 2012 Rumball School Donal Dublin Bay Sailing Honorary Secretary Email correspondence O’Sullivan Club Ger Looney Dun Laoghaire – Senior Engineer – Water Telephone conversation – 8th February 2012 Rathdown County Services Council Aideen Dublin City Council Senior Executive Telephone conversations – various dates Carney Scientific Officer, Central Laboratory Imelda Avril Dublin City Council Telephone conversation – 13th March 2012 James Trinity College Dublin Professor, Zoology Telephone conversation – 10th February 2012 Wilson Department May Kane Ringsend/Irishtown Former Committee 17th February 2012 – Telephone conversation Residents’ Association Member Frances Corr Ringsend/Irishtown Committee Member 17th February 2012 – Telephone conversation Residents’ Association Joan Sandymount and Chairperson 1st March 2012 – Telephone conversation MacArthur Merrion Residents Association Lorna Kelly Sandymount and Committee Member 1st March 2012 – Telephone conversation Merrion Residents Association Pat Cronin Dublin City Council Executive Manager – Telephone conversations – various dates Drainage and Wastewater Services Michael Dublin City Council DCC site engineer, 27th February 2012 (after site tour) Kenny Ringsend WWTP Ciarán Celtic Anglian Water Operations Engineer, 27th February 2012 (with site tour) McCausland Ringsend WWTP Declan Celtic Anglian Water Operations Director Telephone conversation – 13th March 2012 Maguire Gerry Department of Senior Advisor, Water 20th March 2012 – Telephone conversation O’Donoghue Environment, Services Community and Local Government Tom Walsh Department of Assistant Principal Various meetings and telephone Environment, Officer conversations Community and Local Government Declan Sea Fisheries Telephone conversations – various dates MacGabhann Protection Authority Cathal Inland Fisheries Head of Research and Telephone conversations – various dates Gallagher Ireland Development

101

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