The draft RBMP: A Guide

Please Read SWAN’s Submission on the draft River Basin Management Plan here 

The draft River Basin Management Plan: A concise guide to where we are now and where we should be heading

Experts have long identified the EU Water Framework Directive (WFD) as the centrepiece of efforts in Europe and Ireland to address threats to our water environment. The WFD requires our rivers, lakes, groundwater and coastal water to achieve a healthy state, or what’s known as ‘good ecological status’, by 2021. The River Basin Management Plan (RBMP) is the key tool identified by the Directive to accomplish this.

Ireland’s draft RBMP was previously open for consultation through August 2017 by the Department of Housing, Planning, Communications and Local Government (which has responsibility over water). The draft Plan was expected to assess the state of our waters, identify the sources of impacts and furnish a concrete action plan toward definitive progress. SWAN is very concerned, however, that the draft Plan falls short of what’s required to hit the targets of the Directive and secure a healthy water environment for Ireland by the deadline; a weaker-than-desired Plan would leave our valuable aquatic resources inadequately protected over the duration of the Plan’s cycle, which lasts four years. What’s more, the minimalist approach outlined by the draft RBMP in its current state may be in breach of both the letter and spirit of the Directive. There is a serious risk that if the final Plan is not a significant improvement on this consultation draft, it will result in no improvement to a large number of inland and coastal waterbodies.

It is important to acknowledge that the State has made strides in improving the woefully fragmented water governance system that was previously in place, and it has also established the National Water Forum and Local Authority Water & Communities Office to facilitate better engagement with stakeholders and local communities. Additionally, the Plan utilises strong catchment science carried out by the EPA Catchment Science and Management Unit to illustrate the current status of our waters: it also identifies most of the significant pressures leading to failures. Ideally, the results of this work would then provide the evidence base from which to proceed to the third and crucial step: agreeing effective actions to address the identified problems. Unfortunately, there is a disparity between the scale, range and complexity of the problems, vs. the disproportionately weak policy response proposed to address these problems.
No matter how improved the new governance and public engagement arrangements, these cannot bring about successful improvements to a significant number of our currently unhealthy waterbodies, if the Plan itself does not set out to do this.

As it stands, the draft River Basin Management Plan is subject to a number of worrisome shortcomings. For one, no new measures have been proposed for most waterbodies, even though approximately half our rivers and lakes and more than two-thirds of our estuaries are failing WFD standards. Despite the apparent inadequacy of the status quo, the new Plan relies heavily on controls that are already in place, even when dealing with significant pressures like forestry, wastewater, physical alterations (e.g. flood defences & riverside development) and agriculture. According to the Plan, 1,301 waterbodies are currently not meeting WFD requirements, with another 216 ‘at risk’ of failing. The Plan proposes actions for less than half (600-700) of these, and estimates this approach will improve just 150. That’s a mere 12% of all the currently unhealthy rivers, lakes and coastal waters in the State earmarked for restoration during the life of this Plan; this course of action would leave us with 40% of our rivers, lakes and bays still in an unhealthy state by 2021. It’s worth reiterating that the WFD requires all waterbodies to reach good status by 2021 except under the strictest of conditions, with 2027 permitted as a final deadline. This is still only ten years away. Some of the measures will take time to bear fruit in terms of water quality improvements – all the more reason to hit the ground running with a strong and ambitious Plan which accounts for time lags in tricky areas.

Not only is the process set out in the draft Plan contrary to the procedural provisions of the Directive, as it stands, the Plan would result in an estimated 88% of our unhealthy waters still in that state at the end of the Plan’s term in four years. SWAN cannot recommend this course of action. The consultation period is open now and extends until August 31: we fervently believe that active public participation is crucial to ensuring that the value Irish people place on our wild watery places is reflected in a strong, ambitious final Plan that benefits more than just a tiny percentage of the catchments in Ireland. There are currently several submission tools online right now, so read on for a handy guide as to what each offers.

1.) Complete Friends of the Earth’s ‘Save our Rivers and Coasts’ submission tool.
In accordance with our past advocacy for enhanced public engagement approaches, SWAN is supporting our member Friends of the Earth’s online automated submissions tool, which is helping the public make their views on the Plan known to the Department. This 2 – 5 min submission tool includes opt in/opt-out template text, with the issues the form addresses corresponding directly to weaknesses in the draft Plan. The text is informative, customisable, and focused on the national level, so you can send a hard-hitting template message to the Department or change parts of it based on your own experience and views. Clicking send will email your submission to the Dept. instantaneously, so if you want to make a country-wide critique of the Plan that’s done and dusted asap, then click here.

2.) Complete the Water & Communities Office submission form.
This survey is designed to take 5 – 10 minutes, and it will count as a submission to the public consultation. However, LAWCO is also collecting all submissions made either online or at one of their many local meetings to analyse internally, paying attention to points raised. Not all issues are national, and this submission form is particularly tailored toward people who want to make comments on local issues. LAWCO will then submit all the submissions it collects in bulk to the Department by the deadline. So if you’ve got a local focus and you’d like your opinions to perform the double-duty of also informing LAWCO’s work plan, then this is the submission form for you.

3.) Consult the Department of Housing, Planning and Local Government (DHPLG)  website.
The DHPLG website is a one-stop-shop: there, you can read about the RBMP and its history, find information about the public consultation, and read the RBMP itself (or a summary of it). Now, you can also fill out this 3 – 5 min survey, which solicits ‘any quick views on local, regional or national issues about water quality. We are also interested in knowing how people get information on the environment and how citizens believe that water quality can be improved.’ Please note however that this is not actually a submission to the public consultation, more of a supplement.