Public consultation on the Significant Water Management Issues for the third cycle River Basin Management Plan for 2022-2027

December 2019

Consultation Response Template

Note: The purpose of the document is to simplify and streamline the consultation response process for all respondents and to simplify and streamline the evaluation process for the Department. The information provided by respondents will be used in order to shape the content and focus of the third River Basin Management Plan.

Respondents are asked to follow the response template. However, it is not necessary to provide responses to all the questions. Respondents are also invited to supplement their responses with any relevant information, reports and/or analysis.

Before completing this response document respondent are encouraged to read the accompanying document in full as this contains important information on the significant issues currently identified.

The public consultation process will run until Friday, 26th June 2020. Please provide your feedback as a word document (not PDF) by email to [email protected] by close of business on that date.

Receipt of submissions will be acknowledged but it will not be possible to issue individual responses.

Section A: Respondent Profile (Optional)

Name THOMAS DEEGAN

Organisation TROUT & SALMON ANGLERS’ ASSOCIATION

Email Address [email protected]

Sector (Please place an X in the appropriate box)

Government Department Non Governmental Organisation

Local Authority Group Water

Other Public Sector Body Individual

Angling x Other (please specify) Club

When seeking information in relation to water issues, which source(s) are you most likely consult?

(a) WWTP Monitoring Results, (b)Ballymore Eustace Water/Sludge Treatment Plant Planning Condition 8 Monitoring Results, (c)Ballymore Eustace WWTP Monitoring Results. (d)Catchment Newsletter

Section B: Submission discretion

Submission confidentiality

We will treat your information in line with data protection laws and policies when we are analysing and publishing the results of this consultation. Overall results that are given by individuals will be anonymous, that is, it will not be possible for you to be identified in the final report.

All submissions and comments submitted to the Department for this purpose are subject to release under the Freedom of Information (FOI) Act 2014 and the European Communities (Access to Information on the Environment) Regulations 2007- 2014. Submissions are also subject to Data Protection legislation.

Personal, confidential or commercially sensitive information should not be included in your submission and it will be presumed that all information contained in your submission is releasable under the Freedom of Information Act 2014.

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 2 of 18 Section C: Consultation questions

Issue 1 - Prioritisation Please provide your responses to any or all questions in the blank boxes below.

Q1. Of the current priorities in the RBMP, which do you consider to be the most relevant?

There is little point in investing of €1.7 billion in waste-water infrastructure over the period of the present plan to 2021 if Irish Water can obtain planning permission by submitting false information to planning authorities to gain planning permission. Also, Irish Water must be made comply with EPA WWDL and An Bord Pleanala planning conditions.

Q2. Are there any additional priorities you think should be included in this RBMP cycle?

Q3. Would you amend any of the existing priorities?

Q4. Are there any external factors you think should be considered in setting priorities for this RBMP cycle?

Q5. Do you have any additional comments to make on this issue?

Listen to people on the ground who visit waterways on a regular basis and have no vested interests or hidden agenda.

Issue 2 – Public Participation Please provide your responses to any or all questions in the blank boxes below.

Q1. Do you feel people are given the opportunity to engage in the way our waters are managed? Please provide examples to support your answer including ways this may be improved.

Yes, people are given an opportunity to engage in order to cover the Department’s backside in respect of public consultation and then their contributions/submissions are totally ignored.

Q2. Do you have any additional comments to make on this issue?

Unless the Department listens and takes submissions seriously, from the people on the ground who visit waterways regularly, instead of relying on false information supplied by Consultants, Local Authorities, EPA then this whole process is a total waste of time and cover ups will continue. If my previous submissions had been listened to, the mess that is now Golden Falls Lake/Reservoir (i.e. Irish Water obtained planning permission for the upgrading of Blessington WWTP to 9000 P.E. from County Council and An Bord Pleanala by means of false information) could have been

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 3 of 18 Issue 2 – Public Participation Please provide your responses to any or all questions in the blank boxes below. avoided. (See attachments, Submission on Draft ERBDMP, Recommended Areas for Action RBMP 2018-2021)

Needless to say my submission as an Member of the ERBMAC on the Draft ERBMP was totally ignored as was my submission on the Recommended Areas For Action WFD River Basin Management Plan 2017 with appendices. If they had been listened to and not ignored, the complete mess-ups on Golden Falls Lake/Reservoir and the at Ballymore Eustace could have been avoided.

Why will no one listen. The flow of the Liffey is shut off for most of time at Poulaphouca Dam, hence . This all happened about 80 years ago, long enough for even slow learners to cop on. There is no river flowing from the back of Poulaphouca Dam. Poulaphouca Power Station is fed by underground pipelines from the Dam.

The flow of water from Poulaphouca Dam into Golden Falls Lake/Reservoir is normally by means of an intermittent flow through Poulaphouca Power Station when the Station is on load i.e. generating electricity. Golden Falls Lake/Reservoir is known as a buffer Lake/Reservoir to take the large water flows when Poulaphouca Station (28MW) is on load. The water flow is then released into the River Liffey proper, from Golden Falls Reservoir at the ESB’s discretion, at a rate of 1.5 M3/sec when the ESB are not generating electricity at Golden Falls Power Station and up to 30 M3/sec when the ESB are generating electricity at Golden Falls Power Station (4MW)

Percentage of time that water flows from Poulaphouca Reservoir into Golden Falls Lake/Reservoir. Based on Appendix 3 of Further Information supplied to the Planning Authority Reg Ref 18255 – ‘ESB Flow Data for the Poulaphouca Reservoir and Golden Falls Lake’ The Data reveals the shocking truth about what happens to the flow from Poulaphouca Reservoir/Dam/ Power Station into Golden Falls Lake. We learn that for the 5 days data at the end of June 2017 there was no flow into Golden Falls Lake for 94.2% of the time. Similarly, for the month of July 2017 there was no flow into Golden Falls Lake for 95.7% of the time, August 2017 no flow into Golden Falls Lake for 94.9% of the time, September 2017 no flow into Golden Falls Lake for 83.5% of the time, October 2017 no flow into Golden Falls Lake for 16.4% of the time, November 2017 no flow into Golden Falls Lake for 82.9% of the time, December 2017 no flow into Golden Falls Lake for 78.1% of the time, January 2018 no flow into Golden Falls Lake for 72.3% of the time, February 2018 no flow into Golden Falls Lake for 87% of the time, March 2018 no flow into Golden Falls Lake for 71.4% of the time, April 2018 no flow into Golden Falls Lake for 73.7% of the time, May 2018 no flow into Golden Falls Lake for 96% of the time, 1st -25th June 2018 no flow into Golden Falls Lake for 97.2% of the time.

From the 31st May 2018 to the 5th June 2018 there was no flow into Golden Falls Lake/Reservoir for 5 consecutive days. i.e. no water flow pass Blessington WWTP Discharge. Based on the above figures, how can anybody consider Golden Falls Lake a suitable location for a WWTP discharge, let alone a 9000 PE WWTP discharge?

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 4 of 18

Issue 3 – Land-use Planning Please provide your responses to any or all questions in the blank boxes below.

Q1. How can the planning system be further improved to contribute effectively to the protection and improvement of water resources in Ireland?

Listen to people on the ground who visit our rivers and lakes on a regular basis and know them intimately.

Q2. Do you have any additional comments to make on this issue?

Issue 4 – Agriculture Please provide your responses to any or all questions in the blank boxes below.

Q1. How can the agricultural sector contribute towards improving water quality?

Q2 Do you believe that CAP will have a positive or negative impact on water quality in Ireland?

Q3. Do you think CAP measures to protect water quality should be retained at a national scale or become more locally targeted?

Q4. Do you have any additional comments to make on this issue?

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 5 of 18

Issue 5 – Climate Change Please provide your responses to any or all questions in the blank boxes below.

Q1. Do you believe the links between climate change policy and water policy can be improved, and if so, have you any suggestions on how they can be improved?

Q2. Do you consider climate change to be a significant threat to water quality in Ireland?

Q3. Do you have any additional comments to make on this issue?

Issue 6 – Pollution of waters (phosphorus and nitrogen) Please provide your responses to any or all questions in the blank boxes below.

Q1. Investing in urban waste water infrastructure and providing free agricultural advisory services are two targeted ways that the last RBMP aimed to reduce nutrient losses to surface waters. What other kinds of measures could be targeted and how?

Gaining Planning Permission by furnishing false information to the Planning Authority and An Bord Pleanala must be condemned and overturned. Is a planning permission gained by furnishing false information to the Planning Authority and An Bord Pleanala legal or valid? See WCC PA Ref 18255 ABP Ref 302732-18 Q2. Do you have any additional comments to make on this issue?

Blessington WWTP Discharge Point into Golden Falls Lake/Reservoir just downstream of Poulaphouca Power Station. Lake lowered to original River level to facilitate maintenance.

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 6 of 18 Issue 6 – Pollution of waters (phosphorus and nitrogen) Please provide your responses to any or all questions in the blank boxes below.

BLESSINGTON WWTP DISCHARGE INTO GOLDEN FALLS (LAKE LOWERED TO OLD RIVER LEVEL) 30th APRIL 2016 to facilitate maintenance on Golden Falls Dam. As can be seen from the top photo the WWTP discharge is just downstream of Poulaphouca Power Station. There can be no dilution of the Blessington WWTP discharge when Poulaphouca Power Station is not operating. As we know from the ESB submission to the Planning Authority there can be no flow into Golden Falls Lake for up to five consecutive days.

Green algae pollution of Golden Falls Lake/Reservoir 13th May 2020, but does anyone in authority care?

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 7 of 18 Issue 6 – Pollution of waters (phosphorus and nitrogen) Please provide your responses to any or all questions in the blank boxes below.

Irish Water is the only company responsible for Waste Water Treatment Plant infrastructure and discharges. This should make monitoring of the discharges from WWTPs much easier than previously when all the Local Authorities were responsibly.

,

“Email from Thomas Deegan [email protected] Friday 5th June 2020 to Andrew, Michael, Brian, Tom, Joe, Michael, Gavin, Brian, Gretta, Noel, John

Blessington WWTP Discharge into Golden Falls Lake

A question for all on this World Environment Day 2020.

How was this allowed to happen?

This is what Irish Water got away with in the planning application to upgrade the Blessington WWTP to 9000 PE and for which An Bord Pleanala granted planning permission.

X marks Blessington WWTP discharge. A river is shown flowing from the Poulaphouca Dam. This was changed 80 years ago. Golden Falls Lake is now topped up intermittently (there can be up to 5 days without a water flow into Golden Falls Lake) from Poulaphouca Power Station, which is fed by underground pipelines on the opposite side of the N81 from the Dam. Golden Falls Lake is shown as only starting downstream the Water Ski Club jetty. Regards, Tommy Deegan Ballymore Eustace TSAA”

Needless to say, no one answered. Irish Water obtained planning permission to upgrade Blessington WWTP to 9000 P.E. using this false information, but does anyone in authority care? Is the planning permission obtained using false information legal or valid?

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 8 of 18 Issue 6 – Pollution of waters (phosphorus and nitrogen) Please provide your responses to any or all questions in the blank boxes below.

ESB data supplied to Wicklow County Council Planning Authority for Irish Water’s planning application to upgrade the Blessington WWTP to 9000 P.E. The Blessington WWTP discharges into Golden Falls Lake just downstream of Poulaphouca Power Station and as can be seen from the above image, Golden Falls Lake/Reservoir can have no water flowing into it for up to 5 consecutive days (ESB submission to P.A.) Does anyone in authority care?

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 9 of 18 Issue 7 - Physical Changes to surface waters / Hydromorphology (including barriers to fish migration) Please provide your responses to any or all questions in the blank boxes below.

Q1. How can natural processes in waters be protected and restored?

Q2. Do you think that natural water retention measures, ie slowing the flow, should be explored further?

Q3. How could these types of measures be implemented?

Q4. How should existing barriers to fish migration be prioritised for mitigation (either removal or modification to improve fish migration and natural processes)?

Q5. Do you have any additional comments to make on this issue?

Issue 8 - Siltation Please provide your responses to any or all questions in the blank boxes below.

Q1. Would you consider source control measures, such as catch crops for tillage and appropriate riparian margins, to prevent soil loss (silt and nutrients) from land and increase biodiversity?

Q2. Would you consider developing a land management plan to reduce silt and nutrient losses to water? This could include measures such as drainage towards naturally wet low-lying areas or the use of drain blocks/silt traps.

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 10 of 18 Issue 8 - Siltation Please provide your responses to any or all questions in the blank boxes below.

Q3. What else should we consider?

Discharges from Ballymore Eustace Water Treatment/Sludge Treatment Plant into the Liffey at Ballymore Eustace. (See attached Limnos Report ‘River Liffey at Ballymore Eustace, An Investigative Assessment’ A report to Irish Water August 2017.

Q4. Do you have any additional comments to make on this issue?

Issue 9 – Public Health / Drinking water quality Please provide your responses to any or all questions in the blank boxes below.

Q1. What can we do to improve the resilience of our drinking water supplies and their associated ecosystems?

Q2. How can climate change impact on this resilience?

Q3. Who should implement drinking water source protection?

Q4. How can a collaborative approach in the catchment be fostered?

Q5 How can we engage with landowners and the wider public?

Q6. How can we realise co-benefits from source protection including for biodiversity and climate?

Q7. How would you describe our attitudes to water usage and the values of water?

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 11 of 18 Issue 9 – Public Health / Drinking water quality Please provide your responses to any or all questions in the blank boxes below.

Q8. How could we develop in this area?

Q9. Do you have any additional comments to make on this issue?

A thorough investigation into the use of polyelectrolyte in the treatment of water and the subsequent treatment and disposal of the waste sludge from water treatment plants. Ballymore Eustace Water Treatment Plant is the largest WTP in Ireland and discharges all its aqueous effluent into the River Liffey at Ballymore Eustace in breach of its Planning Permission Condition 8, KCC PA Ref: 08/520 PL09.229575

Max. Discharge through spillway allowed under PA Ref 08/520 PL09.229575 is 3697 M3/day

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 12 of 18 Issue 9 – Public Health / Drinking water quality Please provide your responses to any or all questions in the blank boxes below.

As can be seen from the January 2020 Spillway Discharge to the Liffey, Irish Water are in serious daily breach of their planning permission. Does any one in authority care?

Why are Irish Water allowed to continuously breach their Planning Permission on a daily basis with regards to the volume of water they are discharging from the Water/Sludge Treatmet Plant at Ballymore Eustace through the spillway discharge to the River Liffey?

I recently came across a very interesting and relevant report by the EPA "EPA STRIVE Programme 2007–2013 Environmental Technology:

Development of an Alum Sludge-Based Constructed Wetland System for Improving Organic Matter and Nutrients Removal in High-Strength Wastewater (2005-ET-MS-38- M3)"

A couple of extracts from Strive Report

8.2.1 Aluminium Concentration in Regulations "Several regulations have been promulgated in relation to Al concentrations in drinking waters and effluents for discharge. In Ireland and the UK, the prescribed limit for Al discharge into all waters is 0.2 mg/L (Council Directive 98/83/EC, 1998)".

Also:

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 13 of 18 Issue 9 – Public Health / Drinking water quality Please provide your responses to any or all questions in the blank boxes below. 8.4 Polymer Monitoring and its Possible Release from the Alum Sludge Polymers or polyelectrolytes consist of simple monomers that are polymerised into high- molecular weight substances with molecular weights varying from 104 to 106 Daltons. Although such organic polymers are specifically manufactured for the water industry, the monomers used in the manufacture of many polyelectrolytes are toxic. Their global usage, particularly as a flocculant aid in conjunction with a metal salt coagulant during drinking water treatment processes, and also in sludge conditioning/flocculation, has raised increased concerns about the impacts of the polymer residuals in the surrounding environment when the dewatered sludge is recycled/reused or landfilled. Specific long-term effects of the polymer residual on aquatic organisms, human health and the biota when the sludge is disposed of are still relatively unknown.”---

“8.4.1 Concerns of Organic Polymers: Mini Review” "A review of polymers used in the water industry was given by Bolto and Gregory (2007). Unfortunately, techniques for appropriate monitoring of the polymer residual are lacking (Zhao et al., 2008b). This implies that the polymer residual in the water treatment and sludge conditioning processes is substantially unknown although the amount of the polymer addition is accurately known. Furthermore, information on the fate of the added polymers in water and sludge treatment is lacking. It has been noted that the use of polyelectrolytes in Japan and Switzerland is not permitted in the treatment of drinking water, while Germany and France have set a strict limit for such use (Bolto and Gregory, 2007). Therefore, new concepts and principles for sludge conditioning/ treatment in line with sustainable development remain a significant challenge to engineers and scientists." --- Why were Irish Water recently allowed to increase the dosage of polyelectrolyte by 50% in the Sludge Treatment Process at Ballymore Eustace. We know from the Limnos Report ‘River Liffey at Ballymore Eustace An Investigative Assessment August 2017 that the annual Phormidium filamentous algae pollution of the Liffey at Ballymore Eustace is caused by “coagulation/flocculation chemicals” but still the powers that be turn a blind eye, despite copious correspondence requesting action to be taken. (In Ballymore Eustace, we have a 'sludge from water clarification' landfill site on the bank of the Liffey where the old sludge holding lagoons were located. Has this site ever been monitored for leachate or run-off into the Liffey?)

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 14 of 18 Issue 9 – Public Health / Drinking water quality Please provide your responses to any or all questions in the blank boxes below.

Floating Filamentous Algae pollution of the Liffey at Ballymore Eustace May 20th 2020, but does anyone in authority care? The 50% increase in the polyelectrolyte coagulant dosage at the Water Treatment/Sludge Treatment Plant must be ceased at once. How has the plant operated satisfactorily (supposedly) up to now without this increase in the polyelectrolyte coagulant dosage? Also, the 24 hour composite sampling of the spillway is not giving a true picture of what's happening with discharges to the Liffey. Aluminium (and polyelectrolyte) concentration peaks each time the filters are backwashed (approx 24 times per day). Filter backwash and slipway aluminium concentration discharge curves needed to be carried out to get a true picture of what's happening. What effect is being hit 24 times per day with aluminium concentrations of 10.6 mg/l or maybe higher having on juvenile trout and salmon and invertebrates? (See attached City Analyst Report) We are acutely aware that for the past number of years there are very few spawning salmon getting upstream of Leixlip Dam. However, three electro fishing surveys of the Liffey at Ballymore Eustace in recent times counted more juvenile salmon than trout. There is something seriously wrong with the Liffey at Ballymore Eustace when more juvenile salmon than trout appear in surveys. Something urgently needs to be done. The time for sitting on hands is well and truly over.

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 15 of 18 Issue 9 – Public Health / Drinking water quality Please provide your responses to any or all questions in the blank boxes below. Also, the attached BME WWTP Monitoring Results for the year 2019 showing continuously high ammonia concentrations upstream of Ballymore Eustace WWTP, but has anyone bothered to survey to ascertain where the ammonia is coming from?

While the above is not directly related to drinking water quality, they relate to the treatment of raw water for drinking water purposes, i.e. Water Treatment Plants. The two largest WTPs in Ireland are on the Liffey.

Issue 10 – Invasive Alien Species Please provide your responses to any or all questions in the blank boxes below.

Q1. In your opinion, what invasive species are the biggest concern in Ireland?

Himalayan Balsam, Japanese Knotweed

Q2. What more could be done to help prevent the introduction and spread of riparian invasive species at a national level?

Hire properly trained crews on each river to prevent, remove and monitor invasive species.

Q3. How can awareness of invasive species at local level be improved?

Q4. Do you have any additional comments to make on this issue?

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 16 of 18

Issue 11 – Hazardous Chemicals Please provide your responses to any or all questions in the blank boxes below.

Q1. How can information on current sectoral pesticide usage statistics (Agriculture, local authorities, forestry, amenities and domestic (home and garden)) be improved to help in assessing risks to water in catchment areas?

Q2. How can citizen’s behaviour regarding the safe disposal of medication be influenced and changed?

Organise and advertise free of charge collection points.

Q3. What other measures can be taken to prevent medication from ending up in wastewater treatment plants?

Q4. How can consumers be encouraged to choose personal care products that are safe for the environment?

Advertise on TV and on social media telling people what products are safe. How are people suppose to know what the safe products are. Prevent producers of unsafe products advertising their products or ensure large warning signs are printed on the containers.

Q6. Do you have any additional comments to make on this issue?

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 17 of 18

Issue 12 – Urban Pressures Please provide your responses to any or all questions in the blank boxes below.

Q1. How can Green Infrastructure be best applied in Ireland to benefit water quality and the alleviation of flooding in towns and cities?

Q2. What are the particular issues associated with river restoration in urban rivers, and are we applying appropriate actions?

Q3. Are there any additional concerns in relation to urban pressures that are currently not being considered in Ireland?

Q4. What other actions do you think could be put in place to reduce the pollution of waters caused by urban pressures?

Q5. Do you have any additional comments to make on this issue?

Issue 13 – Any further comments Please provide your responses to any or all questions in the blank boxes below.

Q1. Do you have any additional comments you wish to make on the Significant Water Management Issues for the third cycle of the River Basin Management Plan for Ireland 2022-2027?

Unless the Department starts to listen to the people who spend time on the waterways, know them intimately and have no vested interests, then the water quality of our waterways will not improve.

Attachments

Public consultation: Significant Water Quality Management Issues for the third cycle River Basin Management Plan for Ireland 2022-2027 Page 18 of 18