SWAN’s ‘initial take’ on the Significant Water Management Issues public consultation document

Sinéad O’Brien, SWAN Coordinator – 07/02/20

At a time of multiple policy consultations, all jostling for attention, the ‘Significant Water Management Issues in Ireland (SWMI) Public Consultation Document’ (hereby referred to as the SWMI report) joins the fray. This report sets out, what, according to the state, are the main issues facing the water environment in Ireland – and asks if we agree. The temptation to succumb to consultation fatigue is high, but must be resisted!

The SWMI report marks a crucial moment for water management in Ireland, it is the start of the development of the final national River Basin Management Plan before the 2027 deadline set by the EU Water Framework Directive (WFD) to achieve healthy waters. Presently, 47% of our surface waters are failing and Irish water quality is in decline. If the issues and pressures faced by our waterbodies aren’t identified properly now, it will be impossible to determine the appropriate solutions, and therefore impossible to turn the tide of deterioration. SWAN will be analysing the SWMI report in detail between now and the June deadline, but our initial reaction is somewhat mixed.

The report clearly names the main issues facing Ireland’s surface waters are pollution from agriculture, pollution from human sewage, and physical alterations of our waterways. Forestry is also highlighted as a particular threat to our most pristine waters. The report also identifies, for the first time, silt as a ‘significant problem in many of our waterways’ as a result of dredging, drainage, forestry and peat operations. It also highlights urban pressures such as sewer overflows and contaminated surface run-offs. It stresses the importance of river restoration and green infrastructure in combatting the effects of increased urbanisation, which is most welcome.

However, clear systematic information regarding the impact of human activities on the water environment (the ‘significant water management issues’), is limited. The proportion (%) contribution of each sector to water pressures is not clearly stated and the actual impacts of each activity (e.g. agriculture, human sewage, infrastructure development and forestry) are touched on only lightly and scattered across various chapters. In contrast, much column space is given in each chapter to highlighting the work being done by various government departments and sectors to address the issues. Regrettably, this is in the absence of any accompanying assessment of the efficacy of these measures in addressing water quality declines. A concise summary of the findings of the exemplary scientific work, in particular catchment characterisation, being conducted by the EPA Catchments Unit and, more recently, the Water and Communities Office catchment assessment teams, would lead to much more meaningful and informed engagement. In order to support SWAN’s response, we will be requesting this information.

We welcome the inclusion of aquaculture as an issue which needs to be investigated further. We look forward to hearing the details of these investigations and studying their results. However, apart from this mention, the disappointing trend of almost completely ignoring our coastal waters continues in this report. Despite the fact that the WFD covers our coastal waters to one nautical mile and these waters experience very particular pressures including dredging, kelp harvesting, and aquaculture, they are barely mentioned. SWAN proposes that ‘Coastal Issues’ are identified as significant and are addressed specifically in the River Basin Management Plan.

But SWAN’s predominant and very grave concern about this report is the proposal that the measures required to fix the 47% of our surface waters that are not healthy will only be targeted at a small proportion of these ailing rivers, lakes, and bays. Waterbodies that have not been designated in a ‘Priority Area for Action’ will have to rely on basic national regulations, which to date have clearly not been effective. This ‘prioritisation’ approach would leave many communities disappointed, and is clearly as a result of a lack of political support and funding for water protection. Furthermore, this approach is clearly non-compliant with the WFD and is wholly unacceptable in our view. SWAN will continue to push for an adequately funded, nationwide, catchment-by-catchment River Basin Management Plan to stem the decline of our precious water environment.

Finally, public, stakeholder, and community engagement in this planning process is essential to ensure the success of the next River Basin Management Plan. SWAN whole-heartedly welcomes the establishment of the National Water Forum and Water and Communities Office. However, the Department’s ‘one size fits all’ public consultation approach on the SWMI report, directing the public towards a written survey, is a disappointing step backwards. SWAN urges the Department to build on this written consultation and immediately enlist expert support in designing and delivering an effective and innovative programme of public engagement, at appropriate scales (local / catchment / regional / national). If this was done well, it would play an integral role in the development of an ambitious River Basin Management Plan, supported by civil society.
To be continued ….