Irish Water Asset Operations Plan

Interim Price Control Submission 2014 - 2016 Document No: IW-IPC-005

Contents

1 Executive Summary 4

2 Introduction 5

3 Background 6

3.1 Overview 6 3.2 Legislative Background 7 3.2.1 European Directives 7 3.3 Key Stakeholders 7 3.3.1 Department of Environment Community and Local Government 7 3.3.2 Environmental Protection Agency 8 3.3.3 Health Service Executive 9 3.3.4 Group Schemes and Private Water Supplies 9 3.4 Local Government Efficiency Review 10 3.5 Approach to Water Loss Management 10 3.6 Data Deficit 12

4 Approach to Operations and Maintenance 13

5 Service Level Agreements 15

5.1 Service Level Agreements 15 5.2 Annual Service Plan 15 5.3 Local Authority Capabilities and Protocols 16 5.4 Transformation of Water Services Delivery via SLAs 16

6 Operation and Maintenance of Water Services 17

6.1 Introduction 17 6.2 Irish Water Utility Model 17 6.3 Asset Operations & Maintenance Function 18 6.4 Asset Operations & Maintenance Delivery 19 6.5 Data Collection 20 6.6 Work and Asset Management 21 6.7 Transition of Key Operational Capabilities 22

7 Operational Improvements and Efficiency Initiatives 24

7.1 Introduction 24

2 7.2 Operational Improvements 24 7.2.1 Water & Wastewater Incident Response Plan 24 7.2.2 Information Flow / EPA reporting 25 7.2.3 Water Safety Plans 25 7.2.4 Standard Operating Procedures 26 7.2.5 Plant Performance Improvement 27 7.2.6 SCADA/Telemetry 27 7.2.7 Geographical Information System 29 7.2.8 Water Loss Management 29 7.2.9 Licensing of Trade Effluent Discharges to Sewers 31 7.3 Operational Efficiencies 31 7.3.1 Transforming Service Delivery 32 7.3.2 Standardisation of Drinking Water and Waste water Operations 32 7.3.3 Procurement & Optimisation Initiatives 34 7.3.4 Reduction in spend under Irish Water’s DBO contracts 35 7.4 Summary 35

8 Operational Expenditure 2014- 2016 37

8.1 Summary 37 8.2 Explanation of Movement from 2014-2016 37 8.2.1 Materials 38 8.2.2 Plant Hire (Repairs & Maintenance) 39 8.2.3 Contractor Costs 39 8.2.4 Labour 40 8.2.5 Energy 40 8.2.6 Central Overheads 41 8.2.7 Budget Totals 41 8.3 Approach to Management and Control of Costs 42

9 Constraints and Risks 44

3 1 Executive Summary

The delivery of water services in has suffered from a severe lack of adequate investment for several decades. The existing infrastructure and network are in a perilous state, at high risk of failure, and not fit for purpose for Ireland’s future needs.

To date, a myriad of systems, processes and work practices have operated across the 34 Local Authorities (LAs). The approach to service delivery has relied significantly on personal knowledge and commitment of staff in individual LAs across the country. Management of water services delivery has suffered from incomplete or very poor data collection, inconsistent and inadequate asset analysis, varied local application of policy and standards, ad-hoc investment planning and limited application of risk management. This is not a sustainable approach to achieve effective and efficient service delivery.

The establishment of Irish Water (IW) and the transfer of functions and assets, previously undertaken by the LAs, is a significant development for the State and an opportunity to deliver a more effective and efficient service.

IW’s main priority, during the transfer of functions and assets, is to ensure that there is continuity of service and no negative impact on customers at this time. The focus from 2014 will be to continue with the work of the Irish Water Programme (IWP) in establishing the people, processes and systems required to deliver water and wastewater services across Ireland. IW will, during the Interim Price Control period, identify areas where opportunities for improvement and efficiencies exist and deliver them for customers. This is against a backdrop of increased pressure on operational costs due to growth in the services delivered, in particular compliance driven growth.

The key challenge for IW will be to transition processes and systems from the 34 LAs, circa 1,000 Water Supply Zones (WSZs) and circa 1,100 waste water agglomerations to a single set of processes and systems in a High Performance Utility Model. Central to this will be a concerted effort to collect data on the existing assets and operations and convert it to information and knowledge that can be used to deliver affordable services to meet the needs and expectations of IW’s 1.8m customers.

The Operations & Maintenance function in IW will play a key role in the delivery of safe, affordable and environmentally compliant water services to all customers. To this end, IW will require sufficient funding and resources to meet its vision, objectives and obligations. The absence of adequate funding would severely constrain the level to which services can be improved, economic growth supported and environmental compliance achieved.

4 2 Introduction

This document sets out the framework, systems and processes for operation and maintenance of water services following the transfer of assets from the 34 LAs to a single national utility, Irish Water.

The objectives of this submission are:

. To provide an overview of operations and maintenance activities associated with the delivery of public water services prior to transfer of responsibility to Irish Water on 1st January, 2014; . To outline IW’s plans to integrate water services delivery from 34 LAs into a single public utility to improve the asset operations and maintenance function; . To outline the roadmap for improved service delivery; . To outline the measures that IW will take to improve efficiencies in the delivery of water services and highlight the impact these efficiency measures; and, . To set out the budget for Operations & Maintenance.

The scope of this document includes the following:

. The operation and maintenance of public water supplies from source to tap, including the abstraction, treatment, storage and distribution of drinking water and treatment and disposal of all wastes and residues; . The operation and maintenance of all public waste water services, including the collection, transfer, treatment and disposal of wastewater and the treatment and disposal of all wastes and residues.

A glossary of terms and abbreviations used in this document is included in Appendix No. 1.

5 3 Background

Prior to 1st January, 2014, public water and waste water services in Ireland were managed by 34 Water Services Authorities (WSAs.

3.1 Overview

The IW Operations & Maintenance function will be responsible for assets which are used in the provision of water and wastewater services. They include:

. The above ground assets for water supply (abstraction works, treatment plants, pumping stations and storage reservoirs) and below ground assets (trunk and distribution mains) used in the provision of drinking water for public water supplies; and . The above ground assets (wastewater treatment, sludge treatment, pumping stations) and below ground assets (foul and combined sewers, sewage rising mains and outfall pipelines) used in the provision of public wastewater services.

There are 1,027 Water Supply Zones (WSZs) and 1,069 Wastewater Agglomerations, spread across the State. There is a considerable difference in the scale of these WSZs and Waste water Agglomerations as shown in Tables 1 and 2 below.

Category Throughput (m3/day) No. of Water Supply Zones E > 20,000 16 D 10,000 to 20,000 11 C 5,000 to 10,000 32 B 1,000 to 5,000 178 A <1,000 790 Total for Water 1,027 Table 1: Water Supply Zones

Population Equivalent (p.e.) No. of Agglomerations

>10,000 67 > 2,000 - 10,000 149 1,001 - 2,000 140 500 -1000 176 <500 537 Total for Wastewater 1,069 Table 2: Wastewater Agglomerations1

1 Best available information on plant size; based on EPA Data

6 The operation and maintenance of waste water treatment plants (WWTP) serving the majority of the larger cities and larger towns in Ireland have been contracted by LAs under operational agreements to private service providers, under Design, Build and Operate (DBO) contracts or in a small number of cases operations and maintenance (O&M) contracts. There are c. 163 WWTP, serving approximately 75% of the total wastewater load, currently being operated by private service providers; a full listing is included in Appendix 4. The DBO model has not been used to the same extent for water treatment works (WTW); there are circa 36 WTW currently operated by private service providers; a full listing is included in Appendix 5.

3.2 Legislative Background

Prior to the enactment of the Water Services (No. 2) Act, 2013, LAs were defined under the Water Services Act 2007 as the WSAs and were responsible for the provision of water services in their respective areas. Prior to the introduction of the Act in 2007, the LAs provided the service in their role as Sanitary Authority, based on a suite of legislation, dating back to the Public Health (Ireland), Act, 1878.

3.2.1 European Directives

The European Union has been responsible for introducing a number of Directives that impact directly or indirectly on the delivery of water and wastewater services in Ireland as they are transposed into Irish legislation. These Directives together with the Water Services Act 2007, were the key legislative instruments governing water services provision and operation in Ireland2.

3.3 Key Stakeholders – Previous model

3.3.1 Department of Environment Community and Local Government

The Department of Environment, Community and Local Government (DECLG) controlled the water service capital expenditure programme. Investment by the LAs in water services was guided by the policies and procedures of the DECLG. The DECLG provided capital expenditure funding under two programmes, namely the Water Services Investment Programme (WSIP) and the Rural Water Programme (RWP).

Each LA applied to the DECLG for funding under the WSIP by completing and submitting an assessment of needs. On review, and subject to funding availability, a prioritised list of schemes was selected to form the Department’s rolling three year WSIP. The process involved a considerable number of steps from the Assessment of Needs to the preparation

2 Following the enactment of the Water Services (No. 2) Act, 2013, Irish Water takes over the role of the local authorities und er these legislative instruments in relation to public water and wastewater services.

7 of a Preliminary Report, various approvals and on to obtaining approval of tenders. The RWP was an annual programme under which funds were allocated to WSAs for smaller public water schemes.

3.3.2 Environmental Protection Agency

The Environmental Protection Agency (EPA) is responsible for technical/environmental regulation in Ireland and is responsible for setting out and enforcing standards as provided for under national regulations.

Some of the EPA’s main functions with respect to water and wastewater services include:

. Licensing and permitting of wastewater discharges (under S.I. 684 of 2007) . Supervisory Authority for public water supplies (under S.I. No. 278 of 2007) . Monitoring and inspecting treatment plants . National environmental enforcement . Preparation of reports on the provision and quality of drinking water and urban wastewater discharges . Publication of guidance documents . Co-ordinating research on environmental issues

A significant amount of work has been carried out by LAs in recent years when submitting applications for Waste Water Discharge Licences and Certificate of Authorisations to the EPA.

The EPA is required to report on the performance of urban wastewater treatment plants on a bi-annual basis. The most recent “Focus on Urban Waste Water Discharges in Ireland” report3 was published by the EPA in February 2012. The report includes a review of the operation of waste water treatment plants at all urban areas that are subject to the waste water discharge licencing regime, mainly covering data for 2008 and 2009. Recommendations from this report can be found in Appendix 2 and include a number of recommendations that impact directly on operations and maintenance.

As part of its supervisory role under the Regulations, the EPA maintains a list of public water supplies where remedial action or management action is required to ensure compliance . The EPA uses its RAL to focus attention on resolving any deficiencies in public water supplies and to ensure that WSAs prepare and implement an action programme for each public water supply on the list.

3 “Focus on Urban Waste Water Discharges in Ireland” report, published by the EPA in February 2012

8 The EPA also publishes an annual report on the Quality of Drinking Water Supplies in Ireland. The most recent report for the year 2012 4 was published in December 2013. The report noted that the general improvement in quality of public water supplies over previous years was impacted by poor weather conditions in the summer of 2012, with an increase in the number of non-compliances for some chemical parameters. Extracts from the Report, including a paragraph on IW and key findings and recommendations for public water supplies are included in Appendix 3.

3.3.3 Health Service Executive

The Health Service Executive (HSE) is responsible for the control of infectious diseases under Health Legislation and has a role in drinking water quality under the European Communities (Drinking Water) (No. 2) Regulations of 2007. The HSE has a key role in determining whether a supply of water intended for human consumption constitutes a potential danger to human health, deciding when “Boil Water Notices” should be issued and subsequently when they can be lifted.

3.3.4 Group Schemes and Private Water Supplies

Approximately 80% of the population receive their drinking water from public water supplies. Group Water Schemes (GWSs), as voluntary cooperatives, provide potable water to rural communities in a number of counties and are represented by the National Federation of Group Water Schemes. It is estimated5 that there are 632 Public GWSs (serving 2.3% of the population) and 433 Private GWSs (serving 4.3% of the population). LAs have statutory responsibilities under the Drinking Water Regulations 2007 in their role as “Supervisory Authority” for group water schemes.

There group schemes can be divided into two categories as referenced above:

. Public Group Water Schemes are schemes where the water is provided by the WSA but responsibility for distribution of the water rests with the group scheme. In some cases, there is no longer a management structure in place to operate these schemes and LAs, in some cases, are de facto operating these schemes. . Private Group Water Schemes are schemes where the owners of the scheme (usually representatives of the local community) source and distribute their own water.

From 2014 Public GWSs will receive their water from IW and will consequently become customers of IW.

4 The Provision and Quality of Drinking Water in Ireland - A Report for the Year 2012 5 The Provision and Quality of Drinking Water in Ireland - A Report for the Year 2012. These figures are somewhat at variance with data from Census 2011 which indicates 8.8% of households are supplied by Public Group Schemes and 2.8% of households are supplied by Private Group Schemes.

9 Small private supplies and private wells provide drinking water to over 10% of the population.

3.4 Local Government Efficiency Review

A Local Government Efficiency Review (LGER) was initiated following the downturn in the Irish economy in 2008. Some of the main achievements in the local authority sector resulting from the Local Government Efficiency Review are outlined below6:

. The achievement of gross savings of €839m in the period 2008-2012 . The sector has reduced staffing levels by 24%, or 8,899 from June 2008 . The saving of €109m through procurement between 2010 and 2012.

As water services account for approximately 20% of local authority budgets, the water services function would also have been impacted by the reform, including reductions in staff and cutbacks in expenditure. Typically budgets and staff were cut without any changes to systems and processes and impacting on maintenance of the asset base. It is generally accepted that there has been deterioration in the asset base during this period.

One of the outcomes is that there is not an understanding of what the cost base for maintenance should be in order to achieve an optimal approach in the management of water services assets.

3.5 Approach to Water Loss Management

A number of water conservation initiatives have been advanced over the last decade by LAs with support from DECLG under the Department’s Water Conservation Programme. The National Water Conservation Programme divided water conservation works into three distinct phases:

. Stage 1 – Network Management Systems; . Stage 2 – Active Leakage Control Programme; . Stage 3 – Mains Rehabilitation.

The majority of LAs have completed Stage 1 and Stage 2 of the programme and have progressed to Mains Rehabilitation, in some cases cutting back on Stage 2 work. However, Stage 2 should be viewed as an on-going activity as part of an optimised water loss management strategy.

6 Summary document of CCMA submission to Local Government Efficiency Review Implementation Group County & City Managers’ Association (CCMA), July 2013

10 Unaccounted for Water7 (UFW) is one of two Service Level Indicators currently reported on by LAs through the LGMA8 .Notwithstanding the work undertaken over the last decade under the National Water Conservation Programme, UFW still remains above 40% on average across all of the LAs.

There are a number of shortcomings in the current approach to water loss management:

. While there has been an improvement in the infrastructure to support water loss management over the last decade, there has been limited deployment of networ k management systems to assist operational staff detect leaks; . Poor maintenance of field equipment, such as flow meters and data loggers; and, . Variations in approaches to calculation of Non-Revenue Water, or UFW, across the LAs.

The most recent data on UFW is for the year 2011 and there is a concern that UFW has increased since then due to cutbacks on active leakage control

7 The term "unaccounted f or water” has been replaced by “Non-rev enue Water” as the term f or Water Loss. 8 Serv ice Indicators in Local Authorities 2011, Eighth Annual Report to the Minister for the Environment, Community and Local Government by the Local Gov ernment Management Agency , April 2013

11 3.6 Data Deficit

At the core of asset management is a requirement for good quality data, which presents a major challenge to IW due to the limited asset data records and inconsistency of approach across LAs to date. There is reasonable information on the water supply networks; however, in many instances the data has not been updated in recent years. The waste water network has very limited information, with poor or fragmented mapping and although manhole and CCTV surveys were carried out occasionally, they are not centrally stored and lack referencing for confident integration to IW databases.

The collection of data will be an on-going programme for IW as the business records information on several thousand above ground assets on operational sites and the water and waste water pipeline network. Data capture for the waste water collection network will be particularly challenging as this will require physical surveying for asset location, type and size and a CCTV survey for asset condition, where reliable data is not available.

12 4 Approach to Operations and Maintenance

IW’s approach to operations and maintenance is framed by organisation’s vision and values. The IW vision is to provide a world class water infrastructure that ensures secure and sustainable water services for communities, the economy and the environment.

The Operations & Maintenance values can be divided into four key themes:

. Responsibility; . Expertise; . Efficiency; . Integrity.

IW has been established to develop a progressive and efficient asset management operating model. IW has developed a roadmap transitioning asset operations and maintenance to a unified and integrated model which will deliver benefits for our customers. Key steps for the transition include:

. Establishing the people, systems and processes that are required to deliver the Operations & Maintenance functions in IW. This phased approach is reflected in the arrangements with LAs under Service Level Agreements (SLAs); . Ensuring that there is continuity of service as responsibility for water services delivery and assets transfer to IW; . Gathering data and building knowledge on water services assets and their operational performance; and, . Working with partners, and in particular LAs, through SLAs and Annual Service Plans (ASPs) to improve on the effectiveness and efficiency in water services delivery.

IW plans to achieve significant improvements in the delivery of water services that will in turn significantly improve service quality for customers, while improving efficiency. The improvements that are linked to the Operations & Maintenance function include:

. Fewer water supply restrictions . Better pressure management . Reduce unplanned interruptions . Improve drinking water quality compliance . Service request experience . Water consumption and customer side leakage . Network water loss/leakage . Sewer flooding . Wastewater discharge compliance

13 . Energy efficiency and greenhouse gases emissions

The challenges facing IW are great. Water services and infrastructure have suffered from decades of underinvestment while consumption, compliance obligations and customer/stakeholder expectations have increased substantially. The Operations & Maintenance function in IW has a key role to play in meeting these challenges. Data collection and harnessing the information and knowledge of LAs is a key priority for establishing a baseline for current service delivery and making improvements on a planned and phased basis. This will also allow IW to establish appropriate KPIs, baseline and target quantitative metrics in the coming years.

14 5 Service Level Agreements

5.1 Service Level Agreements

The Water Services (No. 2) Act 2013 allows for the performance of functions by LAs on behalf of IW through SLAs and are subject to certain provisions under the Act. The SLAs put in place with each LA provide for continuity of service to customers, security for staff and LA revenues. At the same time, SLAs accommodate a degree of flexibility to deliver operational improvements and efficiencies from year to year, through Annual Service Plans (ASPs), in line with the strategic priorities of the business. SLAs are put in place for a period of 12 years and cover a range of topics from finance and communication to support services and technical and customer service.

IW oversee SLAs through central and regional management to develop centres of excellence, to identify and implement best practice across the LAs, and coordinate all investment and maintenance planning. Improvements and efficiencies will be driven by:

. Procurement - driving quality and value in procured goods and services; . Capital investment to save operational cost (energy, chemicals, storm flows and sludge reductions); . Reducing demand at source (lower water consumption and reduced trade waste loads to sewers through enhanced license implementation and monitoring); . Reduced waste in leakage from water mains and into/out of sewers; . Extending automated asset monitoring systems across the asset base to central and regional control; . Planned maintenance of critical plants; . Integrated workflow management to optimise work on asset operations and customer response; and, . Shared resources at regional level.

5.2 Annual Service Plan

Each year IW and each LA will work together to prepare an Annual Service Plan (ASP) to articulate the operational objectives and initiatives for the following year. The ASP sets out the longer term goals and actions agreed to advance a 5 Year Plan. The ASPs will cover business transformation and change management, continuous improvement plans, transition from reactive to planned maintenance cycles and cost management.

15 5.3 Local Authority Capabilities and Protocols

From 1st January, 2014 LAs will generally continue to deliver services as they did prior to the transfer of assets and functions to IW, albeit operating under new protocols and procedures. Changes will be introduced on a phased basis, transitioning from the initial operating state to an enduring state. Water services have been divided into different capabilities each with its own protocols under the SLA. These protocols are the agreed ways of working between IW and LAs and are supported by a process flow map and process description. The capabilities include reporting, incident management, HSQE, procurement and customer contact.

5.4 Transformation of Water Services Delivery via SLAs

The SLAs will minimise any risk to the continuity of service during the period of the transfer of assets and responsibilities to IW. Newly established regional offices will play a pivotal role in spearheading the transition of responsibilities and services from the LAs. The SLA will help promote collaboration between the LAs and IW and will achieve efficiencies and value for money. There is explicit recognition within the SLAs that efficiencies must be delivered, and that IW and the LAs will work together to define and deliver these efficiencies and other initiatives.

A number of mechanisms built into SLAs will help manage performance and deliver efficiencies, including:

. Performance Management Frameworks to set baselines for current performance standards of the assets as operated by LAs; . Annual Service Plan sets targets for improvement and identifies initiatives to help achieve these targets; . Five Year Plan will capture long term transformation initiatives, capital programmes and re-organisation plans; and, . SLA Reviews will be carried out by both parties at intervals to review commercial and operational performance.

Achieving operational improvements and efficiencies through SLAs will require appropriate capital investment from IW. It will also take time to embed standardised processes and gather a comprehensive data set to help IW identify and prioritise improvements in assets and service delivery.

16 6 Operation and Maintenance of Water Services

6.1 Introduction

This section outlines how the IW Asset Operations & Maintenance function will deliver water services over the period 2014- 2016 and details the framework and approach that will be adopted by IW across a range of functions.

6.2 Irish Water Utility Model

Asset management is the best practice approach for water utilities in managing and operating water services infrastructure. The LAs capital investment, operations and maintenance functions have typically been operated as separate silos with poor or limited information available on the existing infrastructure and operations and no focus on the total lifecycle costs of owning and operating the assets. Part of the Government rationale to establishment of IW within BGÉ was to draw on the experience the networks business and their approach to asset management. This included experience from the Networks Transformation Programme which created a new Networks Operating Model to centralise the Asset Management function and optimise the use of Asset Management capabilities across the organisation. The Irish Water Programme (IWP), in conjunction with its service providers, has created an asset management system based on a high performance utility model for IW. The IWP has developed systems, processes and undertaken recruitment to implement the operating model for IW outlined in Figure 1 below.

Figure 1: Irish Water Operating Model.

17 While the establishment of an asset management approach for the delivery of water services in Ireland is a major undertaking and will take time to fully implement, it is expected that the systems and processes put in place will deliver significant benefits to IW and its customers over time including:

. Integrated delivery of public water services in Ireland, optimally positioned to meet the challenges of the changing environment; . High Performing Business Processes and supporting information systems, to ensure on going operational efficiencies and better customer service; . An enhanced approach to supply chain management resulting in significant savings over time; . Asset optimisation to reduce operating costs while improving outputs; . Improved control and management of risk; . A 360o view of assets through a centralised business solution; and, . Improved data quality and ability to capture data in the field.

6.3 Asset Operations & Maintenance Function

The high level Organisation Chart for the Asset Operations & Maintenance function is shown in Figure 2 below.

Operations & Maintenance

Operational Regional Operations Workflow Planning & Operations Support Services Management Control Centre

Figure 2: Asset Operations & Maintenance Organisation Chart

The team roles are as follows:

. Regional Operations: o Responsible for managing service provision via SLAs, DBOs, or other contractors; o Manage water conservation and connections; o Plan and oversee water and wastewater operations; o Oversee SCADA Alarm responses.

18 . Operations Support Services: o Responsible for managing water and wastewater process analysis and optimisation; o Provision of sampling services for water and wastewater to ensure compliance. . Operational Planning and Control: o Review and maintain contingency plans and coordination across LAs ; o Manage the short-term water production requirements for IW; o Manage contract delivery and vendor performance across operational contracts; o Manage alarms and events including 24/7 control of asset base. . Workflow Management: o Oversee the initiation of service requests; o Identify bundling opportunities; o Identify work pre-requisites; o Create work orders to be progressed to LAs, service providers and IW’s own Scheduling & Dispatch team.

Given that there are over 1,000 WSZs and over 1,100 wastewater agglomerations spread across the country, the IW Operations & Maintenance function has been divided into 3 regions with 8 regional offices as follows:

1. Eastern and Midlands a. Dublin b. 2. Southern a. Mallow b. Limerick c. Kilkenny 3. Connaught and Ulster a. Castlebar b. Cavan c. Donegal

6.4 Asset Operations & Maintenance Delivery

A fundamental objective for the Operations & Maintenance function is to ensure that there is continuity of service to customers and that contingency arrangements are in place to deal with any issues that may arise during the transfer of responsibility. IW has identified a

19 number of key deliverables for the Operations & Maintenance function over the period 2014 to 2016:

. Implement SLAs and protocols; . Improvements to water supply and wastewater treatment plants most at risk of non- compliance with regulations; . Improve service delivery through efficient use of resources and levels of service; . Rationalise Laboratory Facilities; . Implement new workflow management process and systems; and, . Identify opportunities for load management and plan efficiency improvements.

Activities that will be undertaken by the Operations & Maintenance function in the period include:

. Management of 34 SLAs, including over 40 protocols, annual service plans and 5- year plan for each LA; . Central approach to incident management; . Improved compliance monitoring and reporting; and, . Implementation of new workflow management and process on a phased basis.

6.5 Data Collection

The creation of a robust baseline of data and information will enable IW to make correct and informed decisions for the future benefit of all of its stakeholders. The Interim Price Control period provides IW with an opportunity to address the existing data deficit. This will be achieved through greater engagement with water services personnel in LAs, suppliers and other stakeholders and will provide greater visibility of water services assets, operations, systems and skills. This will result in some improvements in 2014 but more importantly will be invaluable in establishing the operating regimes for 2015 and beyond. Significant gaps in data to be addressed include:

. Operational costs at a more granular level; . The operation of the DBO contracts and the payment charges for the various contracts; . Personnel engaged in various elements of water services delivery; . Water supply and wastewater above ground assets; . Water supply and wastewater linear assets to feed into an integrated GIS for IW; SCADA and Telemetry systems and reports on water loss/UFW at LA, WSZ and DMA level; . Sampling, testing and reporting, in particular the arrangements in place in the various LAs for laboratory analysis; and,

20 . Liaison with and reporting to the EPA on water supply and wastewater.

As discussed in Section 4, data collection is a key priority for establishing a baseline for current service delivery and KPIs. The data collection exercise is significant and further work will be required in the next regulatory period in order to establish the level of data, information and knowledge required to support an effective and efficient asset management model for the delivery of water services.

6.6 Work and Asset Management

IW will be responsible for the provision and management of a national Work and Asset Management (WAM) system as part of an integrated systems architecture that includes the following:

. Utility management systems; . Procurement; . Workflow management; . Field staff management; . Maintenance management systems; . Stock control; . Geographic information systems (GIS); . Supervisory, Control and Data Acquisition (SCADA) and Telemetry systems etc.

The system is based on the software systems Maximo, Syclo and Click which, between them support the core processes of work and asset management (WAM) in addition to providing the back office support to field staff. The system will include the deployment of field force mobility (FM), or mobile technology, in the operation and maintenance of water services assets. It will involve the use by field operatives of portable hand-held devices which are integrated with the WAM/FM solution as follows:

. Maximo determines what work needs to be done based on maintenance schedules, reported incidents, customer orders, and certain categories of project work a nd passes the workload to Click; . Click determines the optimal scheduling of that work to field crews by reference to business rules and its knowledge, received from hand-held devices, of the available resources in the area. The information is then passed back to Maximo which relays it onward to Syclo; and, . Syclo is responsible for communication with the hand-held devices and sends work instructions to the field staff. It is also used to receive job information back from field staff via the hand-held devices to the core WAM/FM solution.

21 The WAM/FM solution facilitates the effective management by:

. Tracking costs associated with operating the assets; . Analysing maintenance costs of all water services assets; . Managing asset risk; . Creating a repository and register for assets and associated information; . Providing a more effective and efficient response to customer service requests; and, . Reporting of all assets in the organisation.

While the deployment of the WAM/FM solution is a fundamental part of the IW strategy to provide an integrated and consistent service delivery across the state, it will involve a significant change for field staff working with the various local authorities. The significance of this change has been taken into account in the design and deployment of the system which involves a number of stages as follows:

. Design . Build . Testing in a number of phases . Impact Assessments . Training . Deployment, initially on a pilot basis in a number of local authority areas . Post-Go-Live support

6.7 Transition of Key Operational Capabilities

IW has identified a number of key objectives as it takes control of the Operation & Maintenance of water services via SLAs with LAs:

. Customer services should not suffer as a result of changes implemented at the time of the transfer of water services IW; . Designing and implementing change at an operational level in treatment plants and networks will be done on a phased approach to avoid risks to service; and, . IW’s regional structure will support access to key operational data and new reporting and control lines.

The transformation journey from the existing operational landscape to IW’s enduring vision for the organisation will, in practice, be completed in a series of steps or “operating states”. IW and each LA will journey through a series of, up to three operating states for each of the ten functional capabilities outlined previously. Progression through the operating states will be contingent on both IW’s and each LAs capability. IW’s proposal for asset operations and maintenance during the Interim Price Control period will be centred on the management of

22 the aforementioned capabilities and their progression from “Operations State” 1 to the Enduring State.

23 7 Operational Improvements and Efficiency Initiatives

7.1 Introduction

IW and LAs will work together to drive improvements in service delivery and meet cost efficiency requirements. IW will support and incentivise LAs to identify and deliver such initiatives. SLAs will facilitate the adoption of changes to operating procedures and the introduction of new technology to the water sector in Ireland. Anticipated benefits include:

. Savings arising from an optimal regional structure; . Supply chain synergies from purchasing against centralised contracts; and, . Performance improvements from increased preventative maintenance, improved asset management and adoption of modern technologies to manage activity in networks and plants.

Although operations are traditionally thought of as field-based activities, there are a number of operational responsibilities and efficiency initiatives that are best undertaken and coordinated at a national level to drive consistency and efficiency and promote compliance with regulatory standards. IW has identified a number of structural, process and plant and network improvements and efficiency initiatives which over time will deliver tangible benefits to its customers. These initiatives are described in the following sections.

7.2 Operational Improvements

7.2.1 Water & Wastewater Incident Response Plan

LAs have an excellent reputation of being able to mobilise to deal with water and wastewater emergencies and protecting citizens and the environment. IW will manage emergency situations through SLAs and benefit, on behalf of customers, from LA experience and competency in this area. IW will also augment systems and processes to address incident response for both water and wastewater emergencies to ensure that there is a consistency in approach and national coverage.

Drinking Water Incident Response: The Drinking Water Incident Response Plan (DWIRP) is a strategy and set of protocols for responding to contamination incidents or other incidents impacting the potable water supply. Each LA should have a DWIRP in place, in accordance with national guidelines, for its functional area. While the majority of LAs have already developed a DWIRP, IW will develop the policy, systems and processes to ensure that national coverage is in place. IW will review the existing DWIRP landscape and prepare an overarching plan to include information specific to each LA.

24 IW will provide management and technical support at both central and local levels in the event of an incident. It is anticipated that revised incident management protocols will benefit from the aggregation of both technical and physical resources that are currently available within the existing LAs, and ensure that national resources are available to overcome local incidents.

Waste water Incident Response: Under the Waste water Discharge Licences (WWDL), the EPA stipulates that an Emergency Response Procedure (ERP) is required for each waste water agglomeration. Broad guidelines are provided by the EPA on the formulation of an ERP, however, a standardised document dealing with waste water incidents and suitable approaches to deal with the different stages of an incident (similar to the DWIRP) does not currently exist. IW has developed a Wastewater Incident Response Plan template that will be rolled out to all LAs between 2014--2015.

7.2.2 Information Flow / EPA reporting

There has been an increase in the frequency and standard of reporting required under the Waste Water Discharge Authorisation Regulations, 2007, particularly relating to EPA licence applications. The establishment of IW provides an opportunity to have a more streamlined approach to meeting these requirements. IW will undertake a number of initiatives to support these reporting requirements including:

. A more streamlined and integrated approach to the compliance monitoring of drinking water and waste water discharges, including sampling, transporting, testing, analysis and reporting; . An effective and efficient laboratory service to meet the various monitoring needs of drinking water and wastewater. This will require that compliance monitoring is undertaken in accredited laboratories by the end of 2015, in order to meet EPA requirements; and, . Robust processes for monitoring from point of sampling to report outputs.

7.2.3 Water Safety Plans

The EPA and the World Health Organisation (WHO) promote and encourage producers of potable water to adopt the concept of Water Safety Plans (WSPs). These plans ensure the safety of a drinking water supply through the use of a comprehensive risk assessment and risk management approaches that encompass all the steps in the water supply process from catchment to consumer. Work has commenced on the preparation of WSPs for 45 WSZs and three WSPs have been completed. It is clear to IW that considerable work will be required to complete WSPs for all WSZs. IW will learn from the work undertaken to date and

25 engage with LAs that have built up a knowledge base in the preparation of WSPs in order to complete the remaining WSPs to be rolled out to other WSZs on a prioritised basis. The plans are considered to be an effective means of monitoring and mitigating operational risks and ensuring that potable water supply is both safe and secure. The benefits of WSPs to IW and its customers include the following:

. Increased compliance levels . Integrated management tools to facilitate a safe and secure water supply; . A structured approach to rationalising and documenting existing operational procedures, leading to gains on efficiency, improvement of performance and quicker response to incidents; . Better targeted capital investments based on risk assessment; . Improved management of existing staff knowledge and identification of critical gaps in skills for staff; and, . Improved stakeholder relationships.

7.2.4 Standard Operating Procedures

Standard Operating Procedures (SOPs) are used to maintain quality control and assurance processes and, above all, ensure compliance with regulatory/legal requirements. Operational work practices in the areas of water and wastewater treatment and network management differ greatly as each LA employs its own work practices and procedures. SOPs do not currently exist in all LAs therefore operations are often carried out using tacit knowledge. IW will develop a unified set of SOPs that will detail the organisation’s expectations and standards for all operational field work. The SOPs will be developed with LAs and document the way activities are to be performed to create a consistent approach to product quality and system performance. They can be used to support the collection of good quality performance data.

In the first instance, IW will rollout minimum standards which will be improved as LAs mature through the “Operating States” defined in the SLAs. The procedures will provide IW with a mechanism to carry out the following necessary operational tasks:

. Share best practice operating processes between regions through the exchange of documented knowledge; . Carry out quality audits at a regional level; . Understand the root causes of differences in performance between the existing LAs and use as a basis to improve performance across the asset base; and, . Carry out continuous efficiency improvements and thereby minimise whole life costs of business operation.

26 Over time, and as the organisations operating model develops, IW will be better able to use the SOPs to minimise variation and promote quality through consistent implementation of processes across the organisation. The SOPs can be used to indicate compliance with organisational requirements.

7.2.5 Plant Performance Improvement

IW is developing the policy, systems and processes for both water and waste water treatment plants in order to identify improvement and efficiency opportunities. WSPs will identify water treatment plants that will benefit from a plant performance improvement review. Similarly, the preparation of an Annual Environmental Report for each waste water agglomeration will identify waste water treatment plants that could benefit from a similar review. The plant process review for both water and waste water plants will be used to identify measures that, when rolled out on a wider scale, will produce quick gains for IW in delivering effective and efficient services.

7.2.6 SCADA/Telemetry

IW has taken responsibility for a very significant asset base that provides essential services across the country. With this responsibility comes a need to develop a robust framework for managing infrastructure. To accommodate this IW will need an asset management regime that is driven by:

. An understanding of the risk of failure due to asset deterioration and/or capacity constraints; . An understanding of the impact of increasing (or decreasing) levels of service on the remaining useful life of the assets; . An understanding of the risk of asset failure as a result of external events that threaten their resilience (such as floods or fire); and, . Whole-of-life cost optimisation where the assets will be operated, maintained and renewed as appropriate to support IW’s level of service obligations.

Crucially, each of these drivers can only be fully understood if reliable data is available in a timely manner to inform both short term and long term decision making. To that end, a Supervisory, Control and Data Acquisition (SCADA) system occupies a prominent position within the suite of tools and systems available to IW for collection, communication and analysis of data. While SCADA has been installed in the majority of larger water and waste water treatment plants constructed in the last 20 to 25 years, there has been no consistent approach to the deployment of the technology. The establishment of IW provides an opportunity to take a more integrated approach and deliver a roadmap which will maximise

27 the use of existing equipment and provide the right information in a timely manner and deliver significant benefits in terms of effective service delivery and efficiency.

The inconsistent approach to deployment of SCADA poses a number of risks and issue, namely:

. Lack of software and security patch update policies; . Security issues particularly the control element arising from the undefined communications, access control and software management . Poor access control; . Widespread use of unsecured low powered radio; . Poor backup and disaster recovery systems. . Imminent regulation of low powered radios by ComReg; . Cyber security concerns; . Extent of visibility of DBO plants via SCADA; . Availability; . Data compatibility; . Cost including duplication of systems.

IW is developing a strategy for SCADA/Telemetry that will be implemented on a phased and prioritised basis over this and the next regulatory cycle. In addition to meeting the needs of its stakeholders, it is envisaged that SCADA will play a significant role in achieving efficiencies for IW by:

. Providing visibility of water and waste water supply and assets at local, regional and central level; . Building robust and secure communications infrastructure that takes account of the varying requirements at each site and geographical constraints; . Reducing unnecessary visits to smaller plants and reducing need for 24/7 on site cover for larger plants; . Supporting regulatory requirements on control, monitoring and alarms for chlorine disinfection and general compliance; . Optimising active leakage control and pressure management; . Supporting energy management and cost reduction activities; and, . Moving, on a phased basis, toward a Central Operations Control Centre with regional, district and local access.

The main benefits of investing in SCADA & Telemetry for IW include:

. Early intervention to resolve plant issues; . Reduced operating costs;

28 . Improved customer service; . Mitigated risk of failure; and, . Exploiting existing capacity.

7.2.7 Geographical Information System

A Geographical Information System (GIS) is a critical tool in the management of linear assets such as water distribution and wastewater networks. This tool will used by IW to capture underground assets. An integrated GIS system for all IW assets will deliver significant benefits in managing linear assets, including improved response to customer queries and providing an essential tool for water loss management. It is expected that the system will be functional by the end of 2014, however the data capture exercise will take a number of years to complete and will run into the next regulatory cycle.

7.2.8 Water Loss Management

Leakage or water loss management is a critical part of water services delivery and impacts both operational expenditures and capital investment plans. While the list of drivers for a leakage control strategy is extensive, the following drivers are considered most pertinent:

. Postponing infrastructure upgrades and optimising capex - focusing on areas where reduced leakage will postpone need for treatment plant expansion; . Improving plant performance - some existing assets are operating at over 100% capacity, presenting compliance and operational issues; . Sustainable water resource management; . Reducing variable costs - leakage reduction will reduce energy and chemical demand and combined with pressure management, can significantly reduce unplanned burst repair costs; and, . Stakeholder requirements - customers will rightly demand value for money and a quality of service. Revenue collection activities may suffer in the absence of demonstrable leakage reduction.

Leakage management is integral to, and has dependencies on, almost all IW functions. Figure 3 illustrates the leakage management pillars including active monitoring and detection, speed and quality of leak repairs, pressure management and pipeline rehabilitation. All four pillars need to be considered to achieve optimum results from a Leakage Strategy.

29

Figure 3: Four Pillars of Leakage Management.

IW is committed to making significant improvements in Water Loss Management in the coming years, by following a number of steps:

1. Establish the systems and resources to provide a consistent and robust baseline of water loss across all IW Assets; 2. Achieve a balance across the four pillars of Water Loss Management so as to achieve best value from investment in the reduction in water loss; 3. Prioritise the WSZs and District Meter Areas for water loss reduction initiatives, based on factors such as limited or no headroom and drinking water quality; 4. Deploy established international methodologies for water loss estimation and management; 5. Establish and implement a roadmap to transition from the current situation of high losses to a future scenario where targets are based on sustainable economic levels of leakage; and, 6. Establish performance indicators to support the execution and performance management of the Water Loss Management Strategy for IW.

30 As reported previously UFW is estimated at over 40% across the country. There is a concern that UFW has increased since it was last reported in 2011 due to cutbacks on active leakage control. IW is taking steps to deal with this by rebalancing resources between active leakage control and water main rehabilitation. It is estimated that the installation of domestic water meters will lead to a reduction of circa 10% in domestic consumption and should result in a reduction of customer side leakage. Reduction in domestic consumption and customer side leakage will in some cases result in increased pressure in distribution mains and a consequential rise in leakage in the mains. However, measures are in place to deal with this issue and should minimise additional leakage from this source.

7.2.9 Licensing of Trade Effluent Discharges to Sewers

IW will put in place a standardised approach for the management of trade effluent discharges to sewers across the country under Section 16 licences9. Standardisation will lead to improved turnaround times for the issue of licences. This will be combined with appropriate monitoring of compliance and processed to control and minimise the discharge of fats, oils and grease (FOG) to sewers.

FOG is generated in significant quantities from food service establishments and can cause blockages in pipes, pumping stations and equipment. These blockages can then cause flooding, pollution of rivers and streams, basement flooding and problems at waste water treatment works. While a national guidance document has been prepared on the matter by the LA Services National Training Group, there has not been consistent implementation of FOG reduction measures amongst the 34 WSAs. The Operations & Maintenance regional teams will work with the Asset Management function in implementing a more integrated approach to licensing of discharges to sewers, including control of FOG. Work will commence in 2014 and will be implemented on a phased and prioritised basis across all waste water agglomerations.

7.3 Operational Efficiencies

Following the transfer of responsibility for services to IW, a significant proportion of the operating expenditure incurred for the provision of water and waste water services will be funded through SLA payments from IW to the individual LAs. The process of spend consolidation and the standardisation of methodologies under a Public Utility Model is expected to deliver significant savings on the original operating expenditure base. A number of the initiatives that are being advanced by IW are included in the following sections. The benefits on operating costs are set out in Section 8.2 below.

9 Licensing of discharges to sew ers under Section 16 of the Local Government (Water Pollution) Act, 1977

31 7.3.1 Transforming Service Delivery

The transformation of the water industry in Ireland can only be achieved in partnership with local government. This partnership, managed through SLAs and ASPs set out the headcount in LAs for the coming year and will be reviewed annually. The optimum level of resource needed to deliver services, as part of a managed transformation, will be determined by the business needs (including public health) and will be subject to scrutiny by the CER.

The transformation of the way water services are delivered may lead to a change in the resourcing level required in the LAs. There is scope to do this through natural attrition, given that the age profile of the workforce is estimated to be 50% over the age of 50. In addition, Government may decide to introduce Voluntary Redundancy Schemes in the LAs and redeployment to other service areas within the LA may also be an option. Previous reports on the water sector have noted that the standardisation of operating procedures and benchmarking across LAs has not been achieved on a comprehensive basis10 and, in general, staff from one LA will not cross the relevant city or county boundary to work in another LA area11. It is expected that a number of factors will improve productivity in the workforce and result in efficiency savings; these include:

. The transition to a regionalised management model; . A commercially driven SLA agreement; . The transition to planned and preventative maintenance; . The standardisation of key operating procedures; . The prioritisation of maintenance works enabled by improved asset and work management data; . The introduction of enabling technology such as scheduling and mobile field technologies; . The further use of plant automation and SCADA; and, . The creation of continuous improvement teams to analyse performance and implement process changes.

7.3.2 Standardisation of Drinking Water and Waste water Operations

Installation of Water Meters The installation of water meters on domestic water connections and the introduction of a charging system based on consumption will provide customers with an incentive to reduce consumption and is thus expected to reduce the overall requirement to produce treat ed

10 Pg. 34, ‘Irish Water: Phase 1 Report’ , PWC

11 Pg. 35, ‘Irish Water: Phase 1 Report’ , PWC

32 water. Based on international experience it is expected that average household consumption will be reduced by approximately 10% as a result of the Metering Programme. This reduction in demand, coupled with a targeted strategy on customer-side leakage (subject to funding), should result in a reduction in operating costs. This reduction is expected to deliver savings predominantly in chemical and energy costs.

Reduction in Network Leakage IW intends to focus efforts and increase investment to reduce UFW to 35% by 2021. UFW was previously estimated in the LA Indicator Report for 201112 at approximately 41% of distribution input and the target corresponds to a reduction in leakage of approximately 20%. While a number of water conservation initiatives have previously been advanced by LAs with support from the DECLG, the establishment of IW creates an opportunity to make significant progress on reducing water loss through its asset management approach comb ined with supporting systems and technical resources. To achieve this, IW, working with LAs, will be required to increase repairs and maintenance investment over the period 2014 -2021.

Transition to Predictive and Preventative Maintenance. IW will also introduce a standardised asset planning and operations capability across all of their assets. This is expected to support the introduction of more reliable and efficient system designs and enable a transition to planned and predictive maintenan ce methodologies. This transition is expected to safeguard the delivery of IW’s regulatory outcomes and to reduce repair and maintenance spending.

Trade Effluent Monitoring and Fats, Oils and Greases Campaigns IW will drive down repair and maintenance costs through the introduction of FOGs campaigns and improved trade effluent monitoring. After initial piloting in key regions these schemes are expected to:

. Decrease waste water treatment requirements leading to a reduction in energy spend; and, . Decrease sewer damage and blockages leading to a reduction in repairs and maintenance spending.

Other Tactical Initiatives IW will also focus on the implementation of tactical measures to reduce cost including the rollout of treatment optimisation techniques and energy efficiency schemes based on the introduction of plant Energy Performance Indicators (EnPIs). The IW Industry Procurement and Optimisation Programme, has also been established and is based on a similar initiative

12 Serv ice Indicators in Local Authorities 2011, Eighth Annual Report to the Minister for the Environment, Community and Local Government by the Local Gov ernment Management Agency , April 2013

33 undertaken by BGÉ Networks to identify initiatives that will deliver significant operational efficiencies.

7.3.3 Procurement & Optimisation Initiatives

Despite the National Procurement Service on energy and regional procurement initiatives on consumables, to date procurement contracts for operations have generally been offered on a city or county basis13. IW will consolidate this spend and introduce a standardised procurement capability that will partner with IW’s individual business functions to drive supplier performance and economies of scale. IW’s strategy can be broken down into three elements:

. Contract Negotiation & Management including the creation of standard contracting strategies, implementing consistent contracts and terms and conditions and creating robust contract management processes to manage existing contracts. . Category Management & Spend Consolidation to introduce a centralised category management methodology and using contract frameworks to consolidate spending, developing supplier relationship management and market intelligence tools. In addition to implementing governance and controls to improve accountability and budget compliance. . Supply Chain Optimisation to implement flexible agreements to reduce long term costs, consolidating supplier to increase buying power and reducing risk through the supply chain process. Introduction of supply side management paired with the integration of functions and collaboration of business units will also reduce demand.

The introduction of a standardised procurement methodology will also improve the compliance of each contract issued in line with national procurement guidelines and EU procurement legislation. Compliance is a leading indicator of the level of commercial risk carried by an organisation and, by following due process, Irish Water will ensure it fully understands and reduces the organisation’s commercial risk. Framework contracts are now in place for approximately 70% of the overall operational spend.

Delivery of the Procurement and Optimisation Programme The measures being implemented under the IW Industry Procurement and Optimisation Programme include the following:

. PMO: to provide structure and direction and manage issues and risks; . Process & Governance: to define how benefits shall be qualified, validated and tracked through the process;

13 Pg. 35, ‘Irish Water: Phase 1 Report’, PWC

34 . Joint Category Teams: multifunctional teams supporting the identification of opportunities, facilitation of workshops and delivery of benefits; and, . Data: to provide structure and take ownership of spend data analysis and input into savings calculations.

There are a number of challenges facing IW that will affect the delivery of benefits in the short term:

. Bringing together 34 separate buying organisations into one organisation using a standard procurement and contract management system; . The large number of current contracts and frameworks not up for re-negotiation until Q1/2 2015; . The new Commercial and Procurement Team currently being recruited will need to understand the internal IW requirements and market landscape; . Currently no accurate view of spend or volumes to establish a benchmark; . Regulatory requirements to improve quality and customer service will incur new costs; and, . Ageing asset base with high operating and maintenance costs.

7.3.4 Reduction in spend under Irish Water’s DBO contracts

The cost of current DBO contracts is based on the volume and load input into individual DBO plants. IW will target a reduction in volume and load input to wastewater treatment plants through trade effluent monitoring and targeted FOGs campaigns. IW’s Commercial function will also introduce dedicated teams to manage its DBO contracts. These teams will focus on monitoring and enforcing the DBO contractors’ compliance with the commercial terms of its agreement and will assess and pursue opportunities for renegotiation where it is in IW’s interests to do so. No further savings have been estimated in this area as many of the current DBO contracts were put in place within the past 10 years with limited scope for renegotiation, long lifetimes, prohibitive exit fees and only periodic break clauses 14. As stated in Section 3.1, approximately 75% of the total wastewater load is treated at treatment plants operated by DBO Contractors and consequently these contract costs are a significant element of IW’s annual operational costs.

7.4 Summary

IW has outlined significant operational improvements and efficiency gains across the Operations & Maintenance function in this submission. The achievement of these efficiencies are, inter alia, dependant on the appropriate and continuing investment in

14 Irish Water Establishment Programme: Capital Inv estment Project

35 systems such as SCADA, telemetry, high speed connectivity to water and waste water plants and network points, automation of a growing number of components of the plants and networks and related IT systems. The combination of these activities will enable and support the achievement of the proposed operational improvements and efficiency gains. The budgets for these systems and activities are included in the Capex budgets.

36 8 Operational Expenditure 2014- 2016

8.1 Summary

The budget for IW’s external Operations & Maintenance costs for the period Q4 2014 to 2016 are outlined in Table 3.

O&M Expenditure Category Q4 2014 2014 2015 2016 Materials 12 47 47 48 Plant Hire 7 27 28 29 Maintenance 3 11 12 12 Contractor Costs 36 145 148 152 Labour (LA) 48 191 187 189 Energy 14 55 51 49 Overheads – LA Charges 20 80 76 73 Total 139 556 548 551 Table 3: O&M Budgets for Interim Regulatory Period (Q4 2014, 2015 and 2016).

A review of current available data shows the split between the overall Opex for water and wastewater at approximately 50% of Opex. Accordingly, it can be assumed that the opex for water supply and wastewater are each 50% of the costs shown in the table above.

8.2 Explanation of Movement from 2014-2016

The change in budget from 2014-2016 can be considered in terms of cost drivers under two main headings:

. Growth - an increase/decrease in operational cost as a result of change in Operations & Maintenance outputs or activities, resulting from a number of factors: o Growth in demand for water services; o Change in environmental regulatory requirements; o Operation of additional infrastructure as part of the CIP; o Cost of additional activities resulting from strategic initiatives by IW e.g. increase in leak detection and repairs; o Cost of additional activities resulting from exceptional events e.g. dealing with backlog in repairs and maintenance. . Operational Efficiencies - resulting from the various initiatives outlined in the previous section namely, volume and unit cost efficiencies and cost efficiency relating to a reduction in the number of activities performed, services rendered or materials procured, including changes in activity levels due to operational efficiencies described above.

The change in budget is examined in the section below for each of the budget lines in the context of the drivers outlined above.

37 8.2.1 Materials

Repairs & Maintenance (65%) There are three main factors that will impact on Opex on materials used in repairs and maintenance for the period 2014- 2016:

1. Growth: It is anticipated that there will be a growth in Repairs & Maintenance output due to a number of factors: a. Increase in opex linked with capital investment in new and upgraded infrastructure and more demanding environmental standards; b. Increase in leak detection and repairs as part of an overall Water Loss Management Strategy being implemented by IW; c. Dealing with a backlog in repairs and maintenance following a number of years of deficits in Opex budgets. 2. Volume Efficiencies: It is expected that the rollout of a more active approach to the management of trade effluent monitoring, and sewer campaigns to reduce FOG will result in less activity and consequent Opex efficiencies in wastewater delivery. 3. Unit Cost Efficiencies: It is estimated that contract negotiation and management and category management paired with spend consolidation will result in a reduction of unit prices of approximately 4% and 3% in 2015 and 2016 respectively.

In summary, based on the combined effect of the factors above, it is estimated that there will be an increased expenditure on materials used in Repairs & Maintenance of approximately 2.6% and 6.3% in 2015 and 2016 respectively, with respect to the baseline year of 2014.

Consumables (35%) The factors that will impact on Opex, the main element of which is chemicals for water supply, in the period 2014- 2016 are as follows:

1. Growth: It is anticipated that there will be a minor increase in Opex on consumables resulting primarily from production at new and upgraded water treatment plants. 2. Volume Efficiencies: It is expected that the following measures will result in reduced consumption of chemicals in the period 2014- 2016 of approximately 4% and 3.5% in 2015 and 2016 respectively, caused by: a. Reduced consumption due to introduction of water charges on a metered basis; b. Reduced water production as a result of a more active approach on Water Loss Management; c. Chemical Optimisation at water treatment plants.

38 3. Unit Cost Efficiencies: It is estimated that contract negotiation and management and category management paired with spend consolidation will result in a reduction of unit prices for consumables of approximately 3% and 1% in 2015 and 2016 respectively.

In summary, it is estimated that there will be a decrease in expenditure on consumables of approximately 6.5% and 10.2% in 2015 and 2016 respectively, with respect to the baseline year of 2014.

8.2.2 Plant Hire (Repairs & Maintenance)

The factors that will impact on expenditure on Plant Hire used in Repairs & Maintenance in the period 2014 to 2016 are described in Section 8.2.1 above. It is estimated that there will be an increase in expenditure on Plant Hire used in Repairs & Maintenance of approximately 2.6% and 6.3% in 2015 and 2016 respectively, with respect to the baseline year of 2014.

8.2.3 Contractor Costs

DBOs (75%) There are two main factors that will impact on DBO Opex costs in the period 2014 - 2016:

1. Growth: There has been significant growth in DBO Opex over the last decade as new treatment plants, particularly in waste water, have been commissioned. For example, the increase from 2013 to 2014 is 9% and with lower annual growth rates of 4% estimated for subsequent years based on the best available data. 2. Volume efficiencies: It is estimated that the measures outlined in Section 7.3.4 will achieve savings in Opex on DBO contracts of approximately 2% in 2015 and 2016.

There is limited scope for unit cost efficiencies, given the terms and duration of the existing contracts. It is estimated that there will be an increase of Opex on DBO contracts of approximately 2% and 4% in both 2015 and 2016 respectively, with respect to the baseline year of 2014.

Repairs & Maintenance (25%) The factors that will impact on expenditure on contractors used in repairs and maintenance in the period 2014-2016 are described in Section 8.2.1 above. It is estimated that there will be an increase of Opex on contractors used in Repairs & Maintenance of approximately 2.6% and 6.3% in 2015 and 2016 respectively, with respect to the baseline year of 2014.

In summary, it is estimated that there will be an increase of Opex on Contractor Costs for DBOs and Repairs & Maintenance of approximately 2.1% and 4.5% in 2015 and 2016 respectively, with respect to the baseline year of 2014.

39 8.2.4 Labour

Section 7.3.1 sets out the opportunities to achieve labour efficiencies as part of the transformation of the water industry. While the main productivity gains will be achieved over the medium to long term, the budget has included for a reduction in labour cost in 2014 due to the impact of personnel transferring from LAs to IW, whose roles are not backfilled, and further efficiency gains in 2015 and 2016. In summary, it is estimated that there will be efficiency gains and cost avoidance in labour expenditure of approximately 6.2%, 7.9% and 6.9% in 2014, 2015 and 2016 respectively, with respect to the opening position for 2014.

8.2.5 Energy

The factors that will impact on Opex on Energy in the period 2014- 2016 are as follows:

1. Growth: It is expected that there will be a minor increase in Opex on Energy resulting primarily from operation of new and upgraded water treatment plants as new wastewater infrastructure is for the main part accounted for under DBOs. 2. Volume Efficiencies: It is expected that the following measures will result in reduced energy consumption in the period 2014-2016 caused by: a. Improved energy efficiency due to implementation of various measures and improvement works as part of the IW Energy Policy; b. Reduced consumption due to introduction of water charges on a metered basis; c. Reduced water production as a result of a more active approach on Water Loss Management; d. Decrease in waste water treatment load, leading to a reduction in energy spend, due to the rollout of a more active approach to the management of trade effluent monitoring, and sewer campaigns to reduce FOGs. 3. Unit Cost Efficiencies: Negotiation of energy contracts; due for renewal in October 2014.

In summary, it is estimated that there will be efficiency gains in expenditure on energy of approximately 7.2 % and 10.4% in 2015 and 2016 respectively, with respect to the baseline year of 2014. These efficiencies need to be considered in the context of the gains made to date by LAs in reducing spend on energy through consolidation of procurement into a single national framework with the National Procurement Service (NPS) and various energy efficiency initiatives. There is a general trend of rising energy prices which may impact on the ability to achieve any unit cost efficiencies and indeed could have negative impacts on IW energy costs.

40 8.2.6 Central Overheads

It is anticipated that there will be volume efficiencies that will impact on opex on LA Central Overhead Charges and resulting in reductions in expenditure of approximately 5.5% and 8.9% in 2015 and 2016, respectively with respect to the baseline year of 2014.

8.2.7 Budget Totals

The net result of all of the growth and efficiency factors, as described above, is that the budget figures for 2014, 2015 and 2016 are estimated respectively at 2.2%, 3.6% and 3.1% below the 2014 baseline figure. Table 4 shows the relative impacts of growth and efficiencies on the Opex for the period 2014- 2016.

Year on Year Change 2014 2015 2016

Volume Efficiencies -2.2% -2.6% -1.3%

Unit Cost Efficiencies 0.0% -1.0% -0.8% Total Efficiencies -2.2% -3.6% -2.1% Growth 0.0% 2.1% 2.6% Net -2.20% -1.50% 0.50%

Table 4: Impact of Cost Drivers (Year on Year Change Expressed as a %)

The budget for the 2014-2016 period provides for the commencement of various operational efficiencies which set IW on a glide path to more substantial Opex efficiencies by the end of the Regulatory period 2017- 2021. Furthermore, it is estimated that without these operational efficiencies that the Opex would increase to 4.6 % above the baseline for 2014 by 2016, which equates to overall efficiency gains and cost avoidance over the period of circa €80m. Figure 4 shows the projected Opex for 2014 to 2016 against a baseline with no efficiency initiatives.

€800m

€600m

€400m

€200m

- 2014 2015 2016

IW Projected Opex Baseline

Figure 4: Irish Water Projected Opex v Baseline

41 8.3 Approach to Management and Control of Costs

A significant proportion of the IW Operations & Maintenance costs are incurred on foot of the work of LAs, carried out under SLAs. In recognition of the importance of controlling these costs, a Managing Costs Protocol was developed and rolled out to all LAs and supported by a training programme for LA staff. The Managing Costs Protocol outlines the steps involved in managing operational costs in a timely manner by identifying the following objectives:

. Planning and mapping the financial impact of water and waste water activities arising from the Annual Service Plan (ASP); . Prioritising initiatives to be implemented in water and waste water operations; . Capturing and appropriately coding payroll and procurement spend to enable production of accurate and complete management accounts; . Comparing actual expenditure against budgets in a timely manner thereby enabling corrective action to be taken as necessary; . Making payment for all reasonably incurred LA inputs into delivery of the SLAs in line with agreed budgets and approved cost variations; and, . Identifying new initiatives and improvements related to managing costs to be implemented in future years.

IW and LAs work together each year to prepare an ASP to articulate the operational objectives and initiatives for the following year and the budget costs are derived from these operational plans. A reporting process takes place each month which facilitates effective understanding and monitoring of water related expenditure. In addition each LA prepares a year end forecast of anticipated material expenditure in excess of that already reflected in the agreed budget. Approval may be provided for additional expenditure in a particular area; however savings will have to be made in other areas so that the overall agreed budget is not exceeded, which may impact on the ASP delivery.

The protocol document applies to the following cost management processes:

. Payments for LA staff; i.e. reimbursement of payroll costs and related expenses; and . Operational expenditure in respect of goods and services.

These processes are linked with other protocol documents, such as the Procurement- Purchasing Process Protocol, which address the authorisation of work and activities to be completed. Reports of spend value by appropriate cost classification and location will be required to support each payment claim made under the SLA. For goods and services, it is intended that all procurement will go through IW’s Oracle system. In the initial stages of the SLA there are some exceptions where an LA procures directly. In these circumstances

42 these costs are recharged to IW and supporting documentation is provided, including details of cost classification and location.

43 9 Constraints and Risks

There are a number of constraints that will impact the IW Asset Operations & Maintenance function in the delivery of effective and efficient water services, including:

. Legislative requirements relating to SLAs; . Extent of the existing supply and services contracts that will transfer to IW; . A significant proportion of waste water loads (estimated at circa 75% of total load) are treated at plants that are operated under the DBO contracts, these contracts are typically of 20 year duration and many of the contracts have over 10 years to run ; and, . The Asset Operations & Maintenance function in IW is faced with the operation of the water services assets in their current state. In general, the assets have not been designed and constructed in a manner that is optimal from an operations and maintenance perspective and furthermore have not been properly maintained. Irish Water faces higher operations and maintenance costs as a result.

IW also faces a number of risks in developing an Operations & Maintenance Plan and associated budgets:

. Poor data on the existing water services assets make it difficult to effectively and efficiently operate and maintain the assets; . Uncertainty as to the role and responsibility of IW for Public Group Water Schemes with no operational governance structures that are supplied from public water supplies and being de facto operated by local authorities on an informal basis; . Time taken to transition from existing different and varied approaches to operations and maintenance of water services assets across 34 LAs to an integrated asset management approach; . The number of agglomerations requiring Licences and Certificates is 544 and 546 respectively. At the end of 2013 there were 512 Certificates but only 301 licences in place. There is a potential impact on Opex in meeting the requirements of these new licences; . There is a general acceptance that there is need for improvement in Drinking Water Quality in some WSZs and with a more significant issue with regard to waste water discharges. Improving performance will in many cases require capital investment and other improvements in operations and maintenance; resulting in uncertainty on the impact of this investment on Opex, which represents a risk to IW;

44 . While some provision has been made for growth in terms of new DBO contracts, there is limited data available to support this assessment and there is a risk that Opex on additional DBO contracts may not be adequately covered; . No provision for contingency has been include in the Opex budget; . The baseline Opex has been determined following a period of 6 years of budgetary constraint by LAs and significant savings on LA expenditure under the guidance of the Local Government ; . The delayed transfer of assets may have implications for Opex incurred by IW during the first year of operations and more significantly, in collecting data on the existing asset base; . It is expected that a further Water Services Act will be brought before the Oireachtas in 2014 to deal with a number of issues that were not addressed in the Water Services (No. 2) Act, 2013. This poses a double risk to IW as it may place constraints on IW pending enactment of this legislation and it may result in additional requirements being imposed on IW that would impact Operations & Maintenance and as a consequence on Opex for IW.

45

Appendices Appendix No. 1 - Glossary of Terms and Abbreviations

Term/Abbreviation Description

AER Annual Environmental Report

Agglomeration “agglomeration” means an area where the population and/or economic activities are sufficiently concentrated for urban waste water to be collected and conducted to an urban waste water treatment plant or to a final discharge point15;

ASP Annual Service Plan

Capex Capital Expenditure

CCMA City and County Manager’s Association

CIP Capital Investment Plan

CMC Central Management Charge

CSL Customer Side Leakage

DBO Design Build & Operate [form of procurement where Service Provider builds, operates and maintains the infrastructure, typically for a period of 20 years]

DWIRP Drinking Water Incident Response Plan

EPA Environmental Protection Agency

ERP Emergency Response Procedure

FOG Fats, Oils and Grease (used in the context of control of FOG to sewers)

GHG Green House Gases

HSE Health Service Executive

IW Irish Water

IWIP&OP Irish Water Industry Procurement and Optimisation Programme

LA Local Authority

LGER Local Government Efficiency Review

15 Regulation 2 of S.I. No. 254/2001 - Urban Waste Water Treatment Regulations, 2001

46 Term/Abbreviation Description

LGMA Local Government Management Agency

NPS National Procurement Service

Opex Operational Expenditure

O&M Operations & Maintenance p.e. Population Equivalent, a measure of the pollution load on a wastewater treatment plant

RAL Remedial Action List created and maintained by the EPA to focus attention on resolving the most serious deficiencies in public water supplies.

RWP Rural Water Programme

SLA Service Level Agreement

SOPs Standard Operating Procedures

Transfer Day The 1st day of January 2014 is appointed as the transfer day for the purposes of the Water Services (No. 2) Act 2013 (No. 50 of 2013) under S.I. No. 576 of 2013

UFW Unaccounted for Water

UWWTD Urban Waste Water Treatment Directive

WAM Work and Asset Management

WHO World Health Organisation

WSA Water Services Authority

WSIP Water Services Investment Programme

WSP Water Safety Plan

WSTO Water Services Transition Office

WSZ A water supply zone is a geographically defined area within which drinking water comes from one or more sources and water quality is uniform 16.

WWTP Wastewater Treatment Plant

16 The Provision and Quality of Drinking Water in Ireland - A Report for the Year 2012

47

Appendix No. 2 – Extracts from EPA Urban Wastewater Report17, 2012

5. Recommendations

Urban waste water is one of the principal pressures on water quality in Ireland and continued financial investment in waste water infrastructure is vital to ensure that infrastructural improvements specified in licences are completed in a timely manner and that Ireland meets its obligations under the Urban Was te Water Treatment Directive and the Water Framework Directive.

To achieve this goal the EPA will pursue five intermediate outcomes. These outcomes can be applied to all agglomerations, both licensed and at application stage. The EPA makes the following re commendations in relation to actions to achieve these intermediate outcomes:

5.1 Progress on infrastructural improvements

 The provision of secondary treatment for the 11 agglomerations that did not have the required level of treatment at the time of reporting should be progressed as a matter of priority (see Table 2- 2 for the list of 11 agglomerations).  Nutrient reduction must be provided at the 8 agglomerations greater than 10,000 p.e. that continue to discharge to sensitive areas in the absence of such treatment (see Table 2-3 for the list of 8 agglomerations).  Water services authorities should ensure that appropriate treatment is provided at the 26 locations identified in Appendix I of this report where waste water is being discharged with either no treatment or preliminary treatment only. For the 71 agglomerations with primary treatment in place, it must be determined whether primary treatment is appropriate depending on site specific conditions. These agglomerations are listed under the county reports in Appendix B. Higher priority should be given to those where there is environmental pollution and/or risk to high quality waters.  Water services authorities should implement programmes of improvements required by the waste water discharge licence within the specified timeframes as these improvements are now legally binding.  National capacity for sludge treatment needs to improve and the future needs reviewed in light of new legislation to control on-site waste water treatment systems.

5.2 Reducing the environmental risk profile of agglomerations

 Water services authorities should ensure that waste water discharges from the 35 agglomerations listed in Appendix C (Waste water treatment plants prioritised for enforcement to protect freshwater pearl mussel catchments) of this report do not impact on the habitat of freshwater pearl mussels.  The 8 waste water works listed in Appendix D (Seriously polluted river locations where the source of pollution is attributed to urban waste water discharges) of the report as causing serious pollution must be upgraded or improved by the relevant water services authorities in order to minimise the impact of discharges on the receiving waters and restore the waters to at least good status.  Water services authorities should ensure that discharges from the 52 waste water works listed in Appendix E (Moderately or slightly polluted river locations where there is a high probability that the

17 “Focus on Urban Waste Water Discharges in Ireland” report, published by the EPA in February 2012

48 principle cause of pollution can be attributed to urban waste water discharges) are improved in order to protect the receiving waters, as there is a high probability that these discharges are the principle cause of moderate or slight pollution.  Water services authorities should ensure that the impacts of urban waste water discharges on designated bathing areas are minimised. Discharges of urban wastewater that continue to be the principal cause of poor quality bathing water should be upgraded to improve discharge quality and restore the bathing waters to at least good status.  Water services authorities should ensure that discharges from the 55 waste water works listed in Appendix F (Urban waste water works identified in Pollution Reduction Programmes as key pressures on designated shellfish waters) of this report do not adversely affect the aquatic habitat of shellfish within designated shellfish waters.  Urban waste water discharges should be managed and controlled in order to minimise risks to any drinking water abstractions downstream of waste water discharge points.

5.3 Compliance with effluent quality standards in WWDLs and the UWWTD

 Water services authorities should review the operation of, and develop corrective action programmes for, all urban waste water treatment plants in their functional areas that fail to meet effluent quality standards, including those less than 500 p.e. Particular priority should be placed on plants whose discharges are causing or contributing to environmental pollution of receiving waters (Appendices D & E).  Water services authorities should review sampling programmes to ensu re sufficient sample numbers are taken each year. Failures due to insufficient sampling should be eliminated.  Key equipment necessary to monitor plant performance, such as composite samplers and flow meters, should be installed where necessary and maintained.  Water services authorities should continue to invest in the training of plant operators in order to improve the management and operation of waste water treatment plants.

5.4 Environmental incidents and complaints

 Maintenance and operation programmes should be put in place for all plant and equipment to ensure the correct operation of the waste water works at all times and to prevent environmental pollution. These programmes also serve to improve effluent quality. This programme should also address the provision of back up equipment (duty and standby) such as mobile generators and pumps.  All environmental complaints should be dealt with in accordance with the national environmental complaints procedure.

5.5 Comprehensive and accurate reporting by water service authorities to the EPA

 Water services authorities should ensure that all monitoring and analysis is reported in accordance with the requirements of UWWTD and the individual WWDLs.  Sampling and analyses should be carried out using the methods specified in the WWDL. In particular, time-based twenty-four hour or flow-proportional composite samples should be taken.  The Annual Environmental Reports should be prepared in accordance with EPA guidelines and submitted by the 28th February each year.

49  Water services authorities should assess all storm water overflows from their waste water works for compliance with the ‘Procedures and Criteria in relation to Storm Water Overflows’ and report the findings to the EPA. Any storm water overflows that are not in compliance should be upgraded to ensure compliance, or decommissioned.  Water services authorities must improve compliance with the licence condition that covers financial provision to cover risks or liabilities identified in their environmental liability ri sk assessments.

50 Appendix No. 3 – Extracts from EPA Drinking Water Report for 201218

IRISH WATER Next year marks a new beginning for the delivery of water services in Ireland with the responsibility for the provision of water services moving from the 34 Local Authorities to one national water authority, Irish Water, a semi-state company. The EPA will continue to be the environmental regulator with regard to public water supplies. Irish water is charged with delivering drinking water to homes, businesses and other organisations with greater efficiency, economies of scale and better strategic infrastructural planning than has existed in Ireland to-date. There are a number of challenges that Ireland faces to provide safe and secure drinking water. These include:  Reducing the population on long-term boil water notices.  Addressing delays to the provision of major water supply projects, and upgrade supplies with no Cryptosporidium barriers.  Ensuring that supplies are capable of delivering drinking water during all weather conditions and variations in raw water supply.  Elimination of lead pipes from the distribution mains and service lines.  Provision of up-to-date monitoring results which allows consumers to gain timely information about the quality of their drinking water.  Operation of the Water Safety Plan approach in the provision of water supplies. As the environmental regulator, the EPA will continue to update, track and report the number of supplies on the Remedial Action List; drinking water exceedances notifications; active boil water notices on public water supplies; supplies with no Cryptosporidium barriers, the number of water safety plans in place and progress made in making Ireland a leader in the provision of drinking water. In addition, the Agency will continue to publish the results of all drinking water audits on our website (www.epa.ie).

3. FINDINGS AND RECOMMENDATIONS The main recommendations presented in this chapter are based on an assessment of monitoring results for 2012 and EPA enforcement of the Drinking Water Regulations in 2012. While some of the recommendations are similar to previous years they are still considered relevant and in need of implementation by WSAs. New recommendations have been added where issues have been identified and remedial actions are needed. Recommendations are aimed at all WSAs and should be adopted for all public water supplies, public group water schemes, private group water schemes, and private supplies, as applicable. Findings – Water Supply in Ireland 1. 1. In Ireland, 82% of the population is served by 932 WSA operated public water supplies. The remaining 18% is served by 632 public group water schemes (serving 2.3% of the population), 433 private group water schemes (serving 4.3%), 1,705 small private supplies (serving 0.8%) and private wells that are exempt from the regulations (serving 10.6%). Findings – Public Water Supplies 2. 237 (70%) of the original 339 public water supplies placed on the EPA Remedial Action List (RAL) have completed the necessary action programmes and have been either replaced, upgraded or have improved operations. 3. There are now 147 supplies on the EPA Remedial Action List. The WSAs have indicated that remedial works in a further 70 supplies will be complete by the end of 2013. 4. E. coli was detected in 7 (0.8%) public water supplies during compliance monitoring in 2012 as compared to 12 (1.3%) supplies in 2011. The number has reduced from 87 in 2005, representing a 92% reduction in the past seven years. 5. At the end of 2012, one public water supply did not have a chlorine monitor or alarm in place. 6. Nitrate exceedances were reported in five public water supplies in both 2011 and 2012. However, the population affected by nitrate exceedances decreased from 3,293 in 2011 to 820 in 2012. 7. Public water supply compliance with the chemical standards disimproved from 99.5% in 2011 to 99.3% in 2012.

18 The Provision and Quality of Drinking Water in Ireland - A Report for the Year 2012

51 8. The number of public water supplies failing to meet the trihalomethanes parametric value disimproved from 10.9% in 2011 to 14.9% in 2012. This was due to the poor weather conditions in the summer of 2012 and the inability of some treatment plants to adequately cope with raw waters during this period. 9. Aluminium compliance was 98.8% in both 2011 and 2012 while turbidity (at the water treatment plant) compliance improved from 95.5% in 2011 to 96.0% in 2012. 10. Pesticide exceedances were notified to the EPA in respect of 16 public water supplies in 2012; an increase from 6 in 2011. Notably, the herbicide MCPA has increased both in the number of notifications and in its prevalence over other pesticides. 11. In 2012, WSAs issued 42 Boil Water Notices (BWN) and Water Restrictions (WR) affecting approximately 50,000 consumers while 66 BWN and WR affecting approximately 57,000 consumers were lifted. 12. EPA Groundwater E-Audits undertaken in 2012 found that 13 of 47 supplies visited had poor source protection, poorly protected springs or well heads and 10 had evidence of microbiological contamination in raw water sampling. A significant proportion of the groundwater supplies audited, therefore, were of questionable integrity and security. 13. EPA general audits in 2012 found that, in tandem with improvements across some key indicators at drinking water treatment plants visited, there were disimprovements in other equally critical areas. The findings highlighted the need for further improvements in the operation of filters, the achievement of final water turbidity of less than 1.0 NTU and in the protection of spring and well head sources from surface water ingress. Prolonged periods of heavy rainfall experienced during 2012 appear to have tested the robustness and of treatment processes in many cases and their ability to respond to changing raw water conditions. 14. The 2012 drinking water returns showed that 66 Water Safety Plans are in pre paration and two are complete. Recommendations - Public Water Supplies 15. WSAs should prioritise improvement works on supplies with a boil water or water restriction notice in place on all or part of the supply in order to have the required works completed as a matter of urgency. Following completion of the works, the WSA should liaise with the Health Service Executive in order to determine whether the completed works allow the removal of the boil water notice or restriction. 16. WSAs should ensure that all failures to meet the microbiological, chemical and indicator parametric values are investigated to ensure that the cause of the failure is identified and the appropriate corrective action is taken. Lessons learnt and corrective measures should be implemented in other supplies in the county. 17. WSAs should implement the World Health Organisation (WHO) Water Safety Plan approach to the management of water supplies. The EPA recommends that, in the first instance, Water Safety Plans should be prepared by the seven WSAs who provide drinking water to the largest populations in Ireland (Drinking Water Safety Plan Working Group members). WSAs should also commence the preparation of Water Safety Plans for selected small supplies. 18. WSAs should prioritise remedial works in supplies that are on the Remedial Action List of Public Water Supplies. The actions outlined to the EPA should be completed as soon as possible and within the timeframe specified to the EPA. Where the necessary works are complete, the WSA should collate and submit monitoring data without delay, so the EPA can verify the effectiveness of the remedial works to enable the supply to be removed from the RAL. 19. WSAs should review the management of chlorine monitors and alarms and ensure that such monitors are managed correctly (i.e. in the correct location and with an appropriate alarm setting) and that documented response protocols are in place for dealing with activations of the alarm. Where issues are outstanding in relation to the response to out of hours alarm remain these should be resolved without delay. 20. WSAs should carry out chlorine residual monitoring in the network at a frequency which allows WSA personnel to respond quickly to any deviation in chlorine levels in the network. 21. WSAs should ensure that all disinfection systems are operated in such a way that undisinfected water does not enter the distribution mains at any time. WSAs should have regard to EPA Advice Notes and the EPA Water Treatment Manual on Disinfection and should optimise the operation and management of the disinfection system to minimise disinfection by- product formation. Disinfection contact times should be calculated for all supplies and it should be ensured that adequate contact time is achieved prior to serving the first consumer. 22. WSAs should ensure that filters are managed correctly and their performance reviewed regularly as a matter of priority. Final water turbidity should be closely monitored and

52 responsive action taken as is necessary in order to achieve levels of less than 1.0 NTU at all times 23. WSAs should ensure that sources of drinking water supplies are adequately protected against potential sources of contamination. Potential sources of pollution should be identified and managed so as to reduce risk of contamination in line with the Water Safety Plan approach. 24. Where public water supplies are using surface water or water influenced by surface water as their source, WSAs should ensure that a Cryptosporidium treatment barrier is in place. If these barriers are not in place, WSAs should implement an appropriate improvement plan without delay which may involve upgrading, replacing or closing the plant. Cryptosporidium risk assessments should be carried out on all supplies to assist in the identification of high risk supplies and the actions that are necessary to reduce this risk. 25. WSAs should examine the cause of trihalomethanes exceedances and should optimise plant operation and management of the distribution network to reduce the levels of THMs in supply. The formation of THMs can be minimised by effective coagulation, sedimentation and filtration by removing organic precursors prior to final disinfection or by additional treatment to slow sand filters. However, the efficiency of the disinfection system must never be compromised in an attempt to reduce THM levels. WSAs should have regard to the recently published EPA Advice note on disinfection by-products in drinking water. 26. WSAs detecting pesticide exceedances in public water supplies should have regard to Advice Note No. 13: Pesticides in Drinking Water in determining the appropriate actions to take. 27. When conducting a lead survey, WSAs should have regard to the new lead parametric value of 10 μg/l (effective from 25th December 2013) and to the EPA Advice Note No. 1: Lead Compliance Monitoring and Surveys. 28. WSAs should remove lead distribution mains as a priority in accordance with EPA Advice Note No. 2: Action programmes to restore the quality of drinking water impacted by lead pipes and lead plumbing. Such works should be completed no later than 25 December 2013 (i.e. when the more stringent parametric value of 10 μg/l becomes effective. 29. WSAs should review the type and format of information provided to the public and as a minimum should implement the requirements of Ministerial Direction WSP6/09. 30. Prolonged heavy rainfall events experienced during the summer of 2012 challenged many treatment processes in public water supplies. WSAs should ensure that treatment process are both robust and responsive to changing raw water quality order to effectively and reliably treat water that meets the standards set in the Drinking Water Regulations in all conditions. 31. WSAs should have in place operational Drinking Water Incident Response Plans (DWIRP) in accordance with the requirements of the Department of the Environment, Community and Local Government (DEHLG) Circular letter L4/09 issued in April 2009 (including for adverse weather conditions). An annual review and rehearsal of the DWIRP procedures should be carried out so that all personnel involved understand and are familiar with exactly what they have to do when an incident or emergency occurs. 32. All drinking water operators should undergo appropriate training in the provision of drinking water such as that delivered by the Water Services Training Group (www.wsntg.ie). As a minimum, each operator should be trained for each treatment process for which they are required to operate at the plant.

53 Appendix No. 4 – DBO Contracts Wastewater Treatment Plants

Plant Design Organisation Name/ Employer Scheme/Agglomeration Name PE

Dublin City Council Ringsend 1,640,000

Cork City Council Cork City Carrigrenan 413,000

Waterford City Council Waterford city 190,600

Dun Laoghaire Rathdown County Council Shanganagh 186,000

Louth County Council Dundalk 179,000

Limerick City Council Limerick (Bunlickey) 130,000

Louth County Council Drogheda 101,000

Galway City Council Galway (Mutton Island) 91,600

South Tipperary County Council Clonmel WWTP 80,000

Fingal County Council Balbriggan/Skerries 70,000

Fingal County Council Portrane/Donabate/Rush/Lusk 65,000

Westmeath County Council Mullingar 55,000

Sligo County Council Sligo WWTP 50,000

Offaly County Council Tullamore 45,000

Wexford County Council Wexford town 45,000

Laois County Council Portlaoise WWTP 39,000

Mayo County Council Castlebar 34,000

Wicklow County Council Wicklow 32,000

Wicklow County Council Greystones 30,000

Waterford County Council Dungarvan 25,000

Donegal County Council Letterkenny WWTP 20,000

Cork County Council Fermoy 20,000

Waterford County Council Tramore 20,000

Cork County Council Mallow 18,000

Wexford County Council New Ross 16,000

Cork County Council Clonakilty WWTP 15,000

Cork County Council Midleton 15,000

Clare County Council Shannon Town 12,500 Donegal County Council Donegal Town

54 Plant Design Organisation Name/ Employer Scheme/Agglomeration Name PE 12,000

Leitrim County Council Carrick on Shannon 11,500

South Tipperary County Council Carrick-on-Suir 11,000

Cork County Council Kinsale WWTP 10,000

South Tipperary County Council Tipperary Town 9,800

Wexford County Council Rosslare Harbour 9,400

Kildare County Council Monasterevin WWTP 9,000

South Tipperary County Council Cashel 9,000

Kildare County Council Kildare Town 7,000

Meath County Council Duleek 7,000

Wexford County Council Bunclody 6,500

Donegal County Council Ballyshannon WWTP 6,100

Wicklow County Council Blessington 6,000

Cork County Council Bantry WWTP 6,000

Meath County Council Athboy 5,800

Sligo County Council Enniscrone 5,000

North Tipperary County Council Templemore 5,000

South Tipperary County Council Cahir 5,000

Cork County Council Skibbereen 4,700

Sligo County Council Ballysadare 4,500

Donegal County Council Killybegs 4,200

Cork County Council North Cobh 4,000

Limerick County Council Kilmallock 4,000

Wicklow County Council Rathdrum 3,500

Cork County Council Dunmanway 3,500

Mayo County Council Kiltimagh 3,333

Longford County Council Granard 3,200

Cork County Council Buttevant 3,150

Meath County Council Summerhill 3,000

Galway County Council Dunmore WWTP 3,000

55 Plant Design Organisation Name/ Employer Scheme/Agglomeration Name PE

Galway County Council Headford 3,000

Cork County Council Whitechurch 3,000

South Tipperary County Council Fethard WWTP 3,000

Longford County Council Edgeworthstown 2,700

Leitrim County Council Roosky (Co. Roscommon) 2,600

Sligo County Council Carney 2,500

Sligo County Council Gurteen 2,500

Sligo County Council Coolaney 2,500

Sligo County Council Dromore West & Environs 2,500

Kilkenny County Council Kilmacow 2,500

Leitrim County Council Dromahair 2,200

Longford County Council Ballymahon 2,125

Leitrim County Council Kinlough 2,100

Roscommon County Council Strokestown 2,076

Cork County Council Castlemartyr 2,000

South Tipperary County Council Ballyclerihan 2,000

Longford County Council Newtownforbes 1,800

Cork County Council Doneraile 1,675

Cork County Council Cloughduv 1,500

Cork County Council Cloyne 1,400

Clare County Council Kilmurry Ibrickane (Quilty) 1,365

Kerry County Council Barraduff 1,316

Clare County Council Scarriff 1,300

Cork County Council Schull 1,266

Roscommon County Council Creagh 1,220

Longford County Council Drumlish 1,200

Meath County Council Donore 1,200

Mayo County Council Achill Sound 1,200

Cork County Council Mogeely 1,200 South Tipperary County Council Killenaule

56 Plant Design Organisation Name/ Employer Scheme/Agglomeration Name PE 1,200

Cork County Council Baltimore 1,150

Meath County Council Kilmainhamwood 1,000

Donegal County Council Rossnowlagh WWTP 1,000

Roscommon County Council Ballyleague WWTP 1,000

Cork County Council Belgooly 1,000

Cork County Council Killeagh 1,000

South Tipperary County Council Ardfinnan 1,000

South Tipperary County Council Ballyporeen 1,000

South Tipperary County Council Clogheen 1,000

South Tipperary County Council Kilsheelan 1,000

Cork County Council Ladysbridge 950

Roscommon County Council Tulsk 820

Meath County Council Moynalty 800

Meath County Council Rathmolyon 800

Roscommon County Council Ballinlough 800

Roscommon County Council Elphin 800

Roscommon County Council Hodson Bay 800

Cork County Council Kilbrittain 800

Sligo County Council Aclare & Environs 750

Roscommon County Council Loughlynn 700

Roscommon County Council Arigna WWTP 650

Clare County Council Feakle 635

Longford County Council Clondra 600

Roscommon County Council Cootehall 600

Cork County Council Cill Na Martra 600

Roscommon County Council Knockcroghery WWTP 590

Kildare County Council Allenwood 560

Galway County Council Leenana 550

Cork County Council Riverstick WWTP 550

57 Plant Design Organisation Name/ Employer Scheme/Agglomeration Name PE

Galway County Council Kilkerrin 500

Roscommon County Council Frenchpark 500

Roscommon County Council Lisacul 500

Sligo County Council Cloonacool and Environs 500

Clare County Council Corofin 500

Cork County Council Aghabullogue 500

Cork County Council Kilbrin 500

Kerry County Council Waterville WWTP 500

Cork County Council Ballygarvan 463

Sligo County Council Easkey 450

Cork County Council Halfway 450

Cork County Council Rylane 450

Cavan County Council Stradone Waste Water Works 400

Cork County Council Ardgroom 400

North Tipperary County Council Terryglass 400

South Tipperary County Council Clonoulty 400

South Tipperary County Council Hollyford 400

Cavan County Council Mountnugent Waste Water Works 350

Longford County Council Abbeyshrule 300

North Tipperary County Council Clonmore 300

North Tipperary County Council Loughmore 300

North Tipperary County Council Upperchurch 300

South Tipperary County Council Cullen 300

Cavan County Council Crosskeys Waste Water Works 275

Leitrim County Council Cloone 250

Cork County Council Courtbrack 250

Cork County Council Kilmacsimon 225

Leitrim County Council Killarga 200

Leitrim County Council Kiltyclogher 200 Leitrim County Council Tullaghan

58 Plant Design Organisation Name/ Employer Scheme/Agglomeration Name PE 200

Leitrim County Council Drumcong 150

Kerry County Council Firies 150

Leitrim County Council Ballinagleragh 100 Longford County Council Ardagh Longford County Council Aughnacliffe Longford County Council Ballinalee Kilcogy Sewerage Scheme Contract 2 - M&E Cavan County Council Plant Cavan County Council Redhills Waste Water Works Leitrim County Council Drumkeeran Leitrim County Council Jamestown Mayo County Council Killala WW Sligo County Council Bunninadden WWTP Cork County Council Grenagh Cork County Council Ros Ard Upper Glanmire Kerry County Council Milltown WWTP Waterford County Council Ballynagaul

59 Appendix No. 5 – DBO Contracts Water Treatment Plants

Population Local Authority SchemeName Served

Limerick City Council Limerick City Water Supply 55,000 Kildare County Council Barrow Abstraction Scheme At Srowland

Clare County Council Ennis PWS 30,000

Donegal County Council Letterkenny Pws 14,075

Sligo County Council Foxes Den Public Water Supply 11,375

Kildare County Council Monasterevin PWS 4,500

Kildare County Council Rathangan 4,000

Cavan County Council Ballyconnell P.W.S.S. 1,220

Sligo County Council Kilsellagh WTP 1,038

Galway County Council Cleggan/Claddaghduff 1,025

Carlow County Council Hacketstown 982

Kerry County Council Waterville PWSS 075H 890

Wicklow County Council Hollywood Donard Public Supply 701

Laois County Council Swan Pws (South Bundle) 572

Monaghan County Council Newbliss 492

Monaghan County Council Inniskeen 489

Monaghan County Council Smithboro 483

Wicklow County Council Ballyknockan Public Supply 450 Roscommon County Council Knockcroghery PWS 450

Wicklow County Council Coolboy Coolafancy Public Supply 337

Wicklow County Council Stratford Public Supply 321

Wicklow County Council Kiltegan Public Supply 294

Cavan County Council Bawnboy P.W.S. 280

Wicklow County Council Knockanarrigan Davidstown Public Supply 255

Wicklow County Council Knockananna Public Supply 165

Wicklow County Council Rathdangan Public Supply 153

Wicklow County Council Barndarrig Public Supply 135

Wicklow County Council Thomastown Public Supply 126 Wicklow County Council Kirikee Public Supply

60 Population Local Authority SchemeName Served 92

Wicklow County Council Grangecon Public Supply 49

Wicklow County Council Ballycoog Public Supply 46

Galway County Council Clonbur Ps/Cornamona P.S. - Westmeath County Council Water Treatment Plant Cavan County Council Knockataggert P.W.S.S. Roscommon County Council Lecarrow Cork County Council Bantry PWS

61