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3 May, 2000.
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DG ENV 27/06/00 807549 A
Mr. | Bug em ee
r Directorate General Environment ATTR: B3 1 /
BU-9 01/111 INFO:

European Commission
200 Rue de laLoi

1049 Brussels
ADMIN m rrmsı | | act] an 1

Dear’

| have been asked by my authorities to refer to the meeting held between
Mr. Noel Dempsey, T.D., Minister for the Environment and Local
Government and Commissioner Margot Wallstrom on 30 March, 2000.

In line with the commitment given at that meeting, I enclose copies of all
Measures Reports prepared by locai authorities in accordance with the Local
Government (Water Pollution) Act, 1977 (Water Quality Standards for
Phosphorus) Regulations, 1998. | also enclose a copy of the Synthesis
Report of the Measures Reports which has been compiled by the
Environmental Protection Agency.

Yours sincerely,

Environment Attachee.

266.

Ar 26 /ese Jr
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Synthesis Report ofthe Measures Reports

Under Local Government (Water Pollution) Act 1977 (Water Quality
Standards for Phosphorus) Regulations, 1998 (S.1. 258 of 1998).

 

ENVIRONMENTAL PROTECTION AGENCY
An Ghniomhaireacht um Chaomhnüu Comhshaoil

|
|
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|

Introduction

EPA monitoring and reports have indicated that eutrophication is the major threat to
water quality in Ireland. The Government published a strategy document (1997) which
set out Ireland’s pollution reduction programme in respect of phosphorus. The strategy
identified a long-term target of improving all unsatisfactory waters in rivers and lakes to a
level consistent with the beneficial uses of the water. Interim quality standards were
also identified, which are to be achieved generally over a 10-year timeframe. Statutory
effect was given to these interim quality standards under the Local Government (Water
Pollution) Act, 1977 (Water Quality Standards for Phosphorus) Regulations. 1998. The
EPA hosted a workshop in May 1999 to facilitate preparation of responses by those
involved in the implementation ofthe Regulations. Asa follow up to the workshop, the
Agency issued a Guidance Note to Local Authorities on Preparation and Submission of
the required Measures Report. Local Authorities were required to submit a Measures
Report to the EPA by 31 July 1999, outlining the measures Ihey aim to take to prevent
water pollution from phosphorus.

The EPA has received responses from all of the Local Authorities. including the
submission of 31 Measures Reports. Cork and Limerick Corporation have indicated that
they will not submit measures reports as there are no EPA samplıng stations within their
jurisdiction. Galway Corporation and Galway County Council submitted a joint
measures report.

As a first step towards evaluating the implementation of the Regulations, the Agency has
compiled the various measures being prepared by the local authorities into a synthesis
report, which summarises the measures proposed to be used. Local Authorities must
report to the EPA on progress made in implementing the Regulations by 31 Julv 2000 and
every two years thereafter. National reports on implementation. as required by ihe
Regulations. are to be published by the EPA at two-yearly intervals following receipt of
reports from the local authorities. with the first report due by 30 April 2001.

Water Qualitv

The current. status of water quality in each local authority area is presented in Table I
(rivers) and Table 2 (lakes) based on sites used in the EPA National Monitoring

Programmes. From Table 1 it is clear that certain local authorities will need tu make a
considerable effort to improve river water quality in their functional area. A large

number of sites (over 60) in Cork. Galway. Limerick. Mayo. Meath. Tıpperary North and
Wexford require improvement. In percenlage terms. a high percentage of river sites
(>60°%%) require improvement in Dublin Corporation. Dun Laoighaire Rathdow:n. Fingal.
Kildare. Kilkenny. Meath. Monaghan. Westmeath and Wexford. Counties with a
relatively large number of lakes (>?) requiring improvement are Cavan. Clare. Cork.
Longford and Monaghan. (It must be noted that there is some discrepancv between EPA
figures on number of stations in each county and local authority figures. This
discrepancy will] be addressed shortlv.)

 

ment Protesten Ayenen #2 Pe Phos Measures Reporı Santmesis Report

268.

Overall. 584 river sites. representing approximately 2.400 km of river channel are
currently classified as Q3-4 and need to be improved to at least Q4. An additional 531
sites. representing approximately 2,200 km ofrriver channel, are currently classified as Q3
and need to be improved to at least Q3-4. 158 sites, representing approximately 250 km
of river channel are currently classified below Q3 (Q1 — Q2/3) and need to be improved
to atleast Q3. Clearly significant challenges lie ahead.

Measures Reports Information

The EPA Guidance Note was used as a template for the majority of measures reports.
The local authorities generally supplied most of the information requested (Table 3). A
number of local authorities submitted water quality management plans along with or
instead of the measures reports. Clare, Longford and Roscommon submitted the Lough
Ree / Lough Derg management proposals; Kildare submitted the Boyne and the Liffey
(Three Rivers Project) monitoring and management reports; and Sligo submitted the
management plan for the Lough Gill catchment. Other measures reports made reference
to these and other water quality management plans.

Four local authorities state that they may or will need Article 3(9) extensions to comply
with the Regulations at certain sites. These are Cork, Dublin Corporation, Limerick and
Monaghan. The Regulations state, under Article 3(9), that the period set for compliance
with the Regulations (i.e. 2007) may be extended for a period not exceeding six years for
any part of arıver or lake, if, but only if, the relevant local authority or, as the case may
be, the Agency is satisfied that certain exceptional circumstances exist as laid out in the
Regulations.

The \Mleasures

AI of the local authorities that submitted measures reports have endorsed the
environmental management systems approach to the implementation of the Regulations
as recommended in the EPA Guidance Note, and two local authorities proposed the
adoption of a formal environmental management system such as EMAS / ISO 14001:
The Regulations are particularly suited to this type of approach given the requirement that
local authorities must prepare bi-annual implementation reports. It is envisaged that the
local authorities will regularly review their proposed measures in the lieht of water
quality monitoring results. New measures are likely to emerge over the coming years.
for instance. Ihrough new legislation or the creation of new initiatives. Each local
authority will need to keep abreast of changes and developments that might impact on the
Implementation of the Regulations.

The measures proposed by the local authorities (Table 4) are separated into five major
catevories:

e Planning control and enforcement measures including a) water quality management
plannina. b} planning and control measures for point sources. c) planning and control
measures for non-point sources and dı general enforcement measures

\lonitoring Meäsures

x 3 “:
an Alend ı

SEEN -  #!n Phen Phos Neasures Report Synthesis Report

269.

Consultative and Co-operative measures
Public education and advisory measures
Other aeri-environmental and miscellaneous measures

The measures include those suggested by the EPA (normal print) in its Guidance Note
and additional measures suggested by the local authorities (in italics). The additional
measures are either variations on the EPA proposals or new and innovative suggestions.
A total column is calculated in Table 4 to indicate the number of local authorities
proposing to apply a particular measure. A wide range of measures have been proposed
by the local authorities and the main points are discussed below.

Planning Control and Enforcement Measures

Water quality management planning is a key measure available to local authorities in the
implementation of the Phosphorus Regulations. It is now generally accepted that a
catchment-based approach to management is appropriate as set out in Government policy
and as proposed in the draft EU Water Framework Directivee A number of local
authorities have proposed drawing up catchment management plans (twelve),
implementing catchment management plans (ten) or reviewing catchment management
plans (eight) in the light of the Regulations. In addition three local authorities have
proposed preparing specific action plans for certain smaller, generally polluted, rivers in
their functional area. Two local authorities propose the preparation or implementation
of sludge management plans. Seventeen local authorities propose the preparation /
implementation of groundwater protection plans and two local authorities propose the
integration of groundwater and surface water protection. Five local authorities propose
to integrate the planning process and responsibilities for protecting water qualitv by
including water quality management plans in the County Development Plan and by
strengthening referral benween the Planning and Environment sections of the local
authority.

The majority of local authorities specificallv indicate that they will make greater use of
powers under the Water Pollution Acis in issuing, enforcing and reviewing section
notices and discharge licences. Almost all local authorities propose the upgrading of
wastewater treatment plants. and nineteen further propose installing phosphorus removal
facilities at a number of plants in their functional area. Sixteen local authorities have
proposed controlling septic tanks mainly through the planning process and throueh

survey and assessment. Thirteen local authorities propose to survey and uperade
surface water and foul sewer drainage systems to effectively manage urban runofl and to
rectif\ misconnections. Only two local authorities have proposed reviewing water

abstraction licences.

Farm survevs to locate point and non-point sources of pollution are proposed by twenty-
three local authorities. These surveys will generally be used to determine high risk farms

activities and to focus appropriate measures in Ihese areas. Nineteen local authorities
PrOpose assessing the need for nutrient management planning in certain areas. while
eichteen have proposed actually using nutrient management planning. As impravements

L 4! Ph Phos Measures Report Synthesis Report

TALESHIR Asian Cr

 

240.

on on-farm management are likely to be a key element in meeting the targets set by the
Regulations. nutrient management planning is recognised by the EPA as a key
implementation measure. Fifteen local authorities have proposed introducing bye-laws
under the Water Pollution Act to control agricultural activities. Bye-laws may be
adopted for individual catchments or for the entire county as required. Twelve local
authorities have proposed measures to assess and control the impact of forestry on water
quality. In certain cases, these measures include, significantly, prohibiting or
discouraging aerial fertilisation of forest plantations. Four local authorities propose the
encouragement of best farm management practices. Five local authorities propose
wetland/reedbed construction to tackle pollution from point and non-point sources.

Monitoring Measures

At present water quality monitoring in Ireland is primarily carried out by the EPA and
local authorities. Many local authorities have well established monitoring programmes
in place already. However, almost all local authorities have suggested developing and/
or review of their existing catchment monitoring programmes, primarily for phosphorus.
Twelve local authorities have indicated that they will seek to integrate their monitoring
programmes more closely with that of the EPA. Eighteen local authorities aim to
establish phosphorus loads from point/non-point sources and twelve state specifically that
they will monitor waste water treatment plants more frequently. Ten local authorities
state that they will carry out risk assessment of high risk activities within their functional
areas. The establishment and use of GIS systems for storage and analysis of data is
proposed by fifteen local authorities. This includes using GIS to interrogate river and
eroundwater monitoring results, soil phosphorus values and high-risk activities. Only
seven local authorities have proposed increasing their groundwater monitoring and only
five local authorities have proposed the establishment of a database of soil phosphorus
levels in their county.

Consultative and Co-operative Measures

The EPA considers that the sering up of consultative and co-operative structures that
involve all stakeholders is essential to the successful management of a catchment. This
is particularly important where diffuse inputs are primarily responsible for deterioration
in water quality. A range of actions across all sectors is necessary 10 reduce diffuse
losses and it is therefore important to include all stakeholders in catchment management
initiatives. Stakeholders can be viewed as those who either contribute to the water
quality problem. and therefore need to be involved as part of the solution. or those that
are beneficiaries of improvements in water quality. as well as statutory bodies with
responsibilities for protection and improvement of water quality. Thirteen local
authorities propose the establishment of multi-sectoral catchment management groups {0
tackle water qualitv problems in their areas. Ten local authorities propose the
establishment of a steering committee to oversee the implementation of the Phosphorus
Resulations. Fifteen local authorities propose the establishment of haison structures
with neiehbouring local authorities on water quality issues and fifteen local authorities
prapose liaison with other interested parties such as Teagasc. industrv. fisheries.

Pattesuggid IR 4 1. ia Phen Phos Mexsures Report Synthesis Report

remant

 
 

AL.

residents etc. Nine local authorities propose closer liaison with the EPA on facilities
licensed by the Agency. Five local authorities propose the appointment of a specialist
advisor or consultant in a particular area to help with the successful implementation of

the Regulations.

Public Education and Advisory Measures

Seventeen local authorities propose public education campaiens and six propose schools
education programmes. Five local authorities propose the appointment of an
environmental education officer or public awareness officer. Ten local authorities
propose the establishment of a sectoral education programme, primarily in the
agricultural sector.

Other Agri-environmental and Miscellaneous Measures

Sixteen local authorities propose to actively promote REPS and seven propose to promote
the Control of Farm Pollution Scheme in their functional areas. Thirteen local
authorities state that they propose to secure funding from central government to
successfully implement their programme of measures, though it is likely that all local
authorities expect to receive funding from this source.

Conclusion

EPA monitoring indicates that 40% of river sites (Table 1) and 23% of lakes (as
calculated in Table ?) are classed as unsatisfactory and require improvement. In
addition, the remaining river sites and lakes require maintenance of their water quality.
The information requested by the EPA for inclusion in the measures reports was
generally submitted (Table 3). However. in certain cases, catchment management plans
were submitted instead of measures reports.

The range of measures proposed by the local authorities to be adopted has been
documented. The individual measures for planning control and enforcement,

monitoring. consultation, co-operation. public education and other aeri-environmental
measures are listed in Table 4. The effectiveness of these measures will be evaluated in
the National Implementation Reports to be prepared by the EPA following submission of
local authority implementation reports. the first of which is due by 31 July 2000.

au

Suronmental Pratestion Auen. i L 41%, Phos Phos Measures Reporu Synthesis Report
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