River Basin Management Plans & Integrated Water Management

River Basin Management Plans (RBM Plans) are the key water management tools required under the Water Framework Directive. They must describe the waters of each region, their current status and the pressures on them. Crucially, they must then, based on this information, set out the measures that need to be put in place to address the pressures on our inlands and coastal waters, in order to meet the WFD objective of ‘good’ status by 2015 (aside from limited exemptions under certain very specific circumstances). A further two cycles of Plans up to 2021 and 2027 are also required, by which time all waters must be of ‘good’ status, aside from a small number of permitted, stricter exemptions.

River Basin Management Plans were published for each of seven regions (River Basin Districts) in the country for the period 2009-2015 in 2010. SWAN identified a large number of weaknesses in the Plans, outlined in our submission  to the government at the time. The most significant of these is that they do not set out clearly the specific actions which must be taken to restore unsatisfactory water bodies to WFD required standards, or to prevent deterioration. In addition, they apply exemptions to waterbodies meeting the directive’s targets without explaining the grounds for these.

Notwithstanding their many weaknesses, these Plans would have represented a modest improvement to water protection, had they been implemented. Unfortunately, for various reasons the government has not implemented them, or the measures in them.

Restructuring of fragmented water governance

For several years SWAN has highlighted the need for a restructuring of the current fragmented water governance system, if we are to deliver the integrated water management required by the WFD and River Basin Management (RBM) Plans.  This position is supported by key government bodies and water management experts including the EPA and City and County Managers Association (CCMA). The RBM Plans themselves state that because river basin management is “currently assigned across a range of organisations with no single body having ultimate responsibility” and water management is “fragmented along administrative lines” it does not “facilitate analysis, identification and implementation of the most cost-effective solutions to manage water quality” and that “there is a need to strengthen and adjust the existing administrative structures to ensure effective delivery of the plans”. To address this, the Plans contain a requirement that the (then) Department of the Environment, Heritage and Local Government would review by the end of 2010 the governance and structures for implementation of the River Basin Management (RBM) Plans.

New 3-tier water governance system

SWAN cautiously welcomes the government’s proposed new 3-tier water governance system to address these weaknesses, published three years late in 2013.  This is set out in new water policy regulations and also in the consultation document  issued by the Department of Environment, Community & Local Government (DECLG) as part of the second cycle of WFD planning (2016-2021). This includes the establishment of a high-level interdepartmental Water Policy Advisory Committee, a new WFD Integration and Coordination unit in the EPA and 3 regional WFD offices.  Because this new system is not yet fully up and running, it is too soon to assess it.  It is clear that whatever structures are now put in place must address the weaknesses in the current fragmented, unwieldy water management structures in Ireland, to provide the consolidated, integrated water management approach necessary if Ireland is to meet its WFD obligations and secure real protection for our water environment.