Coillte Consultation Process
Standard Operating Procedure, April 2022
Inland Fisheries Ireland
National Parks and Wildlife Service
Relevant Government Depts
Sawmills and other customers
Local Government Reps.
Bat Conservation Group
Dublin Bat Group
Friends of the Irish Environment
Irish Deer Society
Irish Wildlife Trust
Tree Council of Ireland
VOICE – Voice of Irish concern for the environment
Vincent Wildlife Trust
Non-forest management activity refers to property sales, telecommunications, renewable
Comments on Ireland’s Forest Strategy Implementation Plan Draft for Public Consultation: Submission from NPWS to DAFM
AIE Request, AIE-088-2022
Western Lakes Plan: Long Term Management Plan for the Great Western Lakes
Loughs Corrib, Mask, Carra, Conn, Cullin, Arrow and Sheelin are some of the best wild brown trout fisheries in Europe and are collectively known as the Great Western Lakes.
Inland Fisheries Ireland wishes to develop a long term management plan for these lakes to address many of the factors currently impacting on the ecological wellbeing of native fish stocks in their catchments.
Heavily Modified Water Body Designations: Peatland
Why are heavily modified waterbodies on peatland not included?
The EPA review considers the following specified uses:
- Water storage and regulation (i.e. major impounding structures such as dams and reservoirs);
- Flood protection;
- The urban environment;
- Arterial drainage;
It does not appear to directly consider heavily modified water bodies in the context of peatland drainage schemes and/or peatland rehabilitation schemes
Please note two IFI submissions on BnM hydromorphological conditions which do address the issues:
Correspondence between BnM and DAFM suggest that the main heavily modified water bodies will not be remediated as part of the current PCAS programme – the programme is very much aimed at improving water chemistry, not restoring the modified watercourses. This is only addressing half the problem, heavily modified waterbodies on peatland cannot support life.
Peatland pressures are listed in EPA data, but there does not appear to be a process in place similar to LAWPRO to ASSAP Ag Referrals to address those peatland pressures. In fact, the overall enforcement regime for peatland drainage is unclear, and unlicensed drainage/unlicensed peat extraction occurs at the same time on the same sites. There are ongoing issues with digging drainage for peat extraction on SACs, and drainage for peat extraction on sites that are hydrologically connected to SACs.
SWAN: Submission to Public Consultation on the Draft Third Cycle River Basin Management Plan for Ireland 2022-2027
Sustainable Water Network (SWAN)
Actions must be specific, measurable and time-bound, with the responsible body assigned and accountable.
Nature-based, catchment-scale mitigation and adaptation solutions should be ‘main-streamed’ and adequately resourced
Establish an appropriately resourced central, WFD/RBMP project management secretariat/unit which is responsible for oversight, monitoring and assessment of WFD implementation
Initiate the medium-term process of developing a consolidated Water Act, similar to the Climate Act, with budgets, timelines and sanctions in order to mainstream water protection in government policy alongside climate and biodiversity action and to fix the fragmented water governance system.
WFD implementation must be made transparent and participative, and must be brought into compliance with the Aarhus Convention. The make-up and work of WPAC, NCMC, Regional Committees, etc., must be readily accessible, including where, and on what basis, water management decisions (including about trade-offs) are being made.
Clear mechanisms for better integrating stakeholder groups into governance and decision-making and this should be facilitated by an expanded team of a minimum of 46 Community Water Officers at catchment level.
Introduce WFD-specific risk assessments for all intensive farms, including derogation farms, through a permitting/licensing system similar to pigs and poultry.
Intensification, in particular to derogation stocking rates, should only be permitted if it can be demonstrated that it won’t impact on the WFD objectives for associated water bodies.
RBMP must provide for the monitoring and strict limiting of total catchment imported N (fertiliser and feed) in catchments already saturated, based on EPA analysis
For existing farms deemed to be a risk, regulatory, voluntary and combined measures should be implemented to reverse pollution impacts, including through herd reductions, with compensatory measures put in place to support this, where necessary
Independent review of the final CAP to assess its strengths and weaknesses to meet the WFD objectives
WFD-specific assessment in advance of developments potentially impacting waterbodies, e.g., dredging, drainage and flood protection
Prohibition on wetland drainage and commitment to a national river and wetland restoration programme
Review of the impacts of arterial drainage; and a commitment to review and amend the Arterial Drainage Act 1945 to remove the requirement to maintain drainage and to bring it into compliance with EU environmental law
All forestry planting and felling licences must include a WFD-specific assessment
Introduce a prohibition on afforestation on peat soils in acid sensitive headwater catchments, as recommended by the Hydrofor research project.
Irish Water Investment plan must include necessary work to halt sewage pollution from all wastewater treatment plants that have been identified as the main pollution source for 208 waterbodies.
Identify the pressures specific to coastal waterbodies and includes targeted measures to address them
Review of all aquaculture licences for compliance with the WFD and include a WFD-specific assessment in all new licence applications to ensure that the proposed/existing farms do not compromise the meeting of WFD objectives
Independent legal review of NPWS guidance on the licensing of aquaculture activities within Natura 2000 sites
Emergency response plans to save the 20 remaining pristine waterbodies.
Update and legally publish the sub-basin plans for the critically endangered freshwater pearl mussel.
Include measures for all waterbodies at risk from abstraction
DRAFT NORTHERN IRELAND PEATLAND STRATEGY 2021-2040
Summary of Consultation Responses
Significant Water Management Issues: Public Consultation – Analysis of Submissions
Final Summary Report
Part of the wider ongoing engagement with stakeholders and advisory groups on the production of River Basin Management Plans, each EU Member state is required to publish and make available for comments an interim overview of the significant water management issues (SWMI) identified in the river basin, at least two years before the beginning of the period to which the RBMP relates.
Of all of the priorities in the RBMP, tackling the pressures from Agriculture was seen to be the most relevant. This included reducing agricultural runoff into rivers and lakes and addressing the use of hazardous chemicals / pesticides on farms. Preventing further deterioration, investing in Urban Waste Water Treatment and the protection of Drinking Water Catchments were also commonly mentioned as being the most relevant priority.
Draft List of Proposed Measures in the Draft River Basin Management Plan for Ireland (2022 – 2027)
Appendix 2 is the important part of the draft plan.
It includes full list of the proposed measures
Implementation / Governance
- In cooperation with our northern colleagues, DHLGH will prepare a “shared waters” document that will outline the water bodies that flow into or through both jurisdictions and the work to be undertaken to ensure they meet their environmental objectives as reported in the River Basin Management Plans for Ireland and Northern Ireland.
- LAWPRO, in consultation with stakeholders, to produces templates for the catchment management plans that will be put in place for each of the 46 hydrometric catchments.
- Carry out a review of Local Authority Resources to put in place appropriate resources to support individual local authorities in fulfilling their role in water quality protection and restoration.
- The Department along with the governance groups (WPAC, NCMC and NTIG) will continually review the progress in the implementation of the programmes of measures and the distance to the 2027 target.
- Explore the feasibility of establishing a high level interdepartmental group to develop a comprehensive financing strategy to support the implementation of measures to deliver on the ambitious Water, Climate and Biodiversity objectives committed to in the Programme for Government.
- Irish Water to review and update their Water Services Strategic Plan that covers a 25 year period of water services management.
- The Department, together with the Department of Rural and Community Development, will develop and publish in 2024 a Rural Water Services Strategic Plan for the period 2025 to 2050.
- Irish Water and relevant stakeholders will work together to implement mitigation measures for abstractions determined to be significant pressures through the abstraction licensing process.
- The need for exemptions will be reviewed as the abstraction licensing process is rolled out.
- A multiagency group under the NTIG to continue a forum to co-ordinate efforts for implementation of Nature-based Catchment Management.
- Strengthening water protection provisions where necessary in relevant sectoral policies. These include; water services policy, spatial planning policy, agricultural policy and aquaculture policy.
- Identifying and embedding measures that will deliver multiple policy objectives (e.g. water, biodiversity and climate adaptation/ mitigation) into sectoral policies.
- Measures to be put in place to ensure the additional evidence required to determine if waterbodies are ‘At Risk’ can be obtained.
- Undertake a techincal Review and public Consultation on the designation of Heavily Modified Water Bodies.
- Progress further studies under the ESRI Joint Research Programme on Water.
- Review to be undertaken of the Local Authority Waters Programme and Wider Local Authority Structures to inform their evolution and identify the appropriate level of resources and involvement required from the sector to meet WFD objectives.
- DHLGH to review the outcomes of the IPA Governance Research programme on Ireland’s water governance arrangements and implement their recommendations were appropriate.
- Carry out an assessment of the Agricultural Sustainability Support and Advisory Programme (ASSAP) to review, examine, evaluate, comment and report on the rationale, efficiency, effectiveness and sustainability of ASSAP to date, along with recommendations for the future and its role and objectives under the third-cycle plan
- Working Group to be established under the National Technical Implementation Group to examine the implementation of current legislation governing activities which pose a risk to waters and to identify opportunities to improve compliance with it.
- DHLGH to provide clarification on the roles and responsibilities of the various implementation bodies, shifting emphasis from the sharing of information and the provision of updates to a more focused provision of high-level policy direction, monitoring implementation of the Plan, and project management.
- An enhanced programme of formal and scheduled monitoring and reporting of progress in respect of the implementation of the RBMP will be put in place.
- Provide a continued emphasis on the full range of the regulatory mix, from awareness and education, through to norms and enforcement, with a review undertaken to ensure there is an appropriate balance in the third cycle to ensure a greater emphasis on compliance assurance activity.
- Specific capacity building programmes of work to be put in place to encourage the transfer of learning and knowledge.
- Ensure further activation, development and support of local level initiatives (rivers trusts, catchment partnerships).
- Review the outcomes of the IPA/EPA Governance Research Programme.
- To ensure that the actions selected are effective, sustainable and cost efficient under changing conditions, a “climate check” will be required for all measures carried out under this plan.
- Update the Climate Adaptation Plan for the Water Quality and Water Infrastructure Sectors
- Examine opportunities in the monitoring programme to improve our understanding of climate change trends
- Support additional research and pilot projects in the area of climate change.
Areas for Action
- Restoration works to be advanced in 427 areas were environmental objectives are not being met.
- Protection measures to be progressed in 85 areas that are meeting their environmental objectives but require protection to ensure their water quality does not deteriorate.
- Catchment projects aimed at improving water quality to be advanced in 15 areas
- The Blue Dot Programme to draft a detailed work plan for waters with a High Status Objective, with a view to them forming part of the proposed local catchment plans.
- Evaluate the outcome of the Resilience Project for Rivers Trusts to inform future community engagement initiatives.
- Examine ways in which further support can be provided for the formation and capacity building of local forums to help identify and implement measures.
- Increase the level of funding under the Community Water Development Fund
- Explore opportunities for the development of a national citizen science programme.
- An Fóran Uisce to identify the optimum level of engagement with the implementation structures for the WFD as part of their strategic planning process.
- New GAP Regulations: The existing GAP Regulations are due to expire and be replaced at the end of 2021. The Nitrates Expert Group is working on the development of the new Nitrates Action Programme, which will be implemented by the regulations. It is expected that the new NAP will:
• Retain the existing controls on Nitrogen and Phosphorous from agriculture.
• Implement tighter controls on nitrogen and phosphorus inputs by:
» Establishing a chemical fertiliser register for farmers
» Providing for enhanced programmes of enforcement.
» Stipulating tighter controls on the use of chemical nitrogen fertilisers focussed on critical source areas
» Incorporate an industry-led initiative to reduce agricultural impacts on water quality.
- CAP Strategic Plan: New Rural Development Programme Regulations under the National CAP Strategic Plan will underpin the establishment of a new green architecture that aims to deliver and reward positive environmental outcomes, including water, biodiversity and climate mitigation and adaptation objectives.
- Teagasc will progress the development of a web-based Farm Sustainability Plan that will complement the existing Nutrient Management Planning online tool and support the wider Agricultural Knowledge and Information Systems (AKIS) programme.
- Consideration will be given to extending and expanding LAWPRO and ASSAP to support the implementation of the new CAP Strategic Plan. There will be an increased focus on sustainability across the entire farm advisory service (both Teagasc and private advisory services). This may include a role in the preparation of Farm Sustainability Plans.
- Local authorities and the EPA, through the NIECE network, will ensure that compliance assurance (including enforcement) actions for agricultural activities will be further enhanced and ensure that there is an increased targeting of inspections by local authorities based on water quality results, critical source areas and the EPA’s PIP Maps.
- DHLGH to develop a new Controlled Activities for the Protection of Waters regime to address pressures on the physical condition of waters.
- DHLGH to establish a restoration programme to mitigate the negative impact of past construction in or near water bodies.
- A pilot project will be undertaken for the Annacotty weir in County Limerick to assist with the design and implementation of the national restoration programme.
- DHLGH to oversee the implementation of the roadmap of actions to improve fish migration in the lower Shannon at the Hydroelectric scheme located around Parteen and Ardnacrusha.
- Continue to seek improvements to the licence applications process for key forestry activities
- Increase the area of forests with appropriate water setbacks through the ongoing restructuring of existing forest stands at clearfell / reforestation stage to incorporate appropriate water setbacks
- Ensure the application of water setbacks and other water-based protection during the creation of new forests, principally under the Afforestation Grant and Premium Scheme.
- Manage the application of support measures that have a clear application in relation to the protection of water, including: the Continuous Cover Forestry Scheme; the native woodland and agro-forestry options under the Afforestation Scheme, and the Native Woodland Conservation Scheme.
- Encourage uptake of the recently-revised Woodland Creation on Public Lands Scheme to deliver woodland-based solutions for the protection of drinking water sources and water in general.
- Roll-out the Woodland for Water Scheme which is focused on strategically realising native woodland in areas where such features would have a marked impact in relation the protection of water.
- Continue to address all forestry-related water incidents, as identified by DAFM Inspectors or reported to DAFM by forestors, water agencies, NGOs and members of the public.
- Further engagement between DAFM and other parties on forestry-related issues, both within the existing WFD structures and forums, and bilaterally (e.g. with Inland Fisheries Ireland).
- Deliver further training of Registered Foresters and Consultant Ecologists and of Department Forestry Inspectors and Ecologists, in relation to the design, assessment and implementation of forestry projects from the perspective of the protection environment, including water.
Urban Waste Water
- Continue investment in waste water infrastructure with Irish Water investing in 83 wastewater treatment plants and 10 collection networks at an estimated cost of €1.022bn, over the period 2020-2024.
- DHLGH to ensure ongoing engagement with Irish Water on the requirements for the next investment period (2025-2029).
- EPA to carry out a review of Waste Water Discharge Licences
- Deliver a multi-annual investment programme to provide waste water infrastructure for unsewered villages
- Irish Water’s River Basin Management Plan – Enhanced Ambition Programme to advance priority wastewater treatment plant projects whose discharges have been identified as being significant pressures on water bodies and impacting on WFD objectives.
- Complete negotiations and transposition into Irish law of the recast Urban Waste Water Treatment Directive
- Ensure development of any new standards for Combined Storm Overflows emerging from an update to the Urban Waste Water Treatment Directive.
- Continue to develop and update the Gap Analysis as a tool to deliver environmental benefits for infrastructural planning.
- Update the Nutrient Sensitive Areas designations under the Urban Wastewater Treatment Directive.
Urban Runoff Pressures
- Develop recommendations for an implementation strategy for nature based Sustainable Urban Drainage Systems on a national scale.
- Provide interim guidance documentation to the Local and Planning Authorities on measures to be implemented to support the delivery of a greater focus on nature based solutions in advance of a national implementation strategy.
- The National Bathing Water Expert Group to undertake a project to determine the most suitable approach to protecting bathers’ health outside of the current bathing season in Dublin Bay.
- DHLGH to amend the existing Bathing Water Regulations (S.I. No. 79 of 2008) to provide discretion to local authorities on determining the bathing season for individual bathing waters.
- Establish a programme for the modelling and monitoring of rainwater run-off and overflows.
- Oversee the preparation of integrated urban drainage management plans.
Domestic Waste Water Discharges
- In line with the programme for government commitment to ‘continue to help fund upgrades to domestic waste water treatment systems, DHLGH will continue to monitor the uptake of the new grant schemes to ensure adequate numbers of people are availing of this measure. A research project will be initiated under the ESRI Research Programme on behaviours and attitudes to assess the level of uptake, impediments to uptake and to make recommendations for improving uptake.
- A review of the National Inspection Plan (NIP) 2018-2021 to be completed, with the outcome informing the next NIP for the period 2022-2027. An objective of these plans is to prioritise inspections to areas of greatest environmental and public health risk and secure upgrading works where required.
- DHLGH to consider the outcomes of the research project into the application of zero discharge nature based solutions and their applicability or not within Ireland’s climatic conditions.
- Review the outcomes of the pilot projects under the first multi-annual Developer- Provided Water Services Infrastructure Resolution Programme to inform future policy considerations on resolving sub- standard developer provided infrastructure with sustainable solutions.
- The Local Authority Waters Programme will conduct assessments of water bodies with unknown pressures in priority areas for action to identify the significant pressures in these areas with a high level of confidence.
- Each local authority will conduct assessments of water bodies with unknown pressures (those not within priority areas for action) to identify the significant pressures in these areas with a high level of confidence.
- The Local Authority Environmental Services National Training Group (LAESNTG) will provide a training programme for catchment assessment and Integrated Catchment Management for the staff of local authorities and all implementing bodies.
- Relevant national authorities to ensure full implementation of the existing measures.
- Measures set out in the National Peatlands Strategy be updated into a new Implementation Plan by NPWS
- NPWS to continue driving the implementation of the various programmes to restore the raised bog SAC and NHA network
- Appropriate bodies to implement the actions arising from the CANN and CABB Interreg programmes.
- DHLGH to oversee the coordination of the Wild Atlantic Nature LIFE Integrated Project (IP), bringing together the experience and knowledge of the associated partners.
- Bord na Móna to oversee the “Peatlands and People” LIFE Integrated Project.
- NPWS and Geological Survey Ireland to fund an investigation into the causes of blanket bog landslides that occurred across Ireland in 2020, and the vulnerability of other at-risk areas to future failures.
- DAFM to oversee the implementation of sustainable management practises developed through the Blackstairs Mountains, Wicklow Mountains and MacGillycuddy Reeks Mountains EIP projects.
- NPWS to explore peatland financing options to escalate restoration efforts including public private partnerships, community trusts, offsetting etc.
Industry, Mines & Quarries
- DHLGH will examine opportunities to further support businesses in taking on a water stewardship approach in their operations.
- The EPA will establish a Working Group under the National Technical Implementation Group to examine the implementation of current legislation governing activities which pose a risk to waters and to identify opportunities to improve compliance with it. The focus will be on protecting waterbodies from pressures and activities which are resulting in deterioration of water quality.
Drinking Water Source Protection
- Drinking Water Expert Group to make recommendations to the Minister regarding a new approach to drinking water source protection as part of the transposition of the recast Drinking Water Directive.
Invasive Alien Species
- NPWS to finalise legislation for the implementation of the EU IAS Regulation
- NPWS to prepare draft management plans and priority pathway action plans for priority invasive species.
- NPWS to advance negotiations on the recruitment of additional Biodiversity Officers
- An additional €500,000 to be provided for projects tackling Invasive Alien Species under the Local Authority Biodiversity Grant Scheme
- DHLGH to provide increased funding to the Community Water Fund to allow for additional projects, including invasive species control projects, to be undertaken at community level.
- DHLGH will amend the EQS Regulations to take account of the assessment of River Basin Specific Pollutants (RBSPs) by the National Aquatic Environmental Chemistry Group (NAECG)
- DHLGH and EPA will input into the recently commenced EU work to revise the list of Priority Substances and Priority Hazardous Substances.
- Follow up scoping study on River Basin Specific Pollutants will be undertaken by the NAECG
- The NAECG will oversee a project to develop revised Environmental Quality Standards for the protection of designated shellfish waters.
- DAFM to seek to improve access to information through the launch of an online mapping viewer of licensed aquaculture sites in Ireland which will link to licence information already available online.
- Roll out of training on the new water and planning guidelines to practitioners.
- Progress amendments to the planning and development legislation to give effect to the new guidance.
- Prior to confirming the final programme of measures, the most cost effective combination of measures will be analysed.
- The economic regulator of water services (the CRU) will continue to assess and approve Irish Water’s costs and investment plans. This will include assessment of Irish Water’s investment decisions to ensure effectiveness, efficiency and economy in Irish Water’s expenditure. The CRU will continue to monitor and report on Irish Water’s delivery and performance in that context
- Irish Water to publish a National Water Resources Plan and to maintain national waste water capacity registers to ensure security of supply and sufficient capacity in drinking and waste water networks to allow for balanced regional development in line with the National Planning Framework
- Irish Water to continue to implement domestic excess use and non-domestic changing.
- Conduct a new economic assessment of the potential for a natural capital / freshwater ecosystem services approach to protecting water resources, including the need for new economic instruments and protection of freshwater and marine ecosystem services.
- Put in place a funding stream to upgrade and take in charge towns and villages without waste water networks.
- Finalise the review of rural water services and produce a rural water services strategic plan including a national rural water resources plan for the rural water sector.
EPA Public Consultation on Heavily Modified Water Bodies
Heavily modified water bodies (HMWB) are surface waterbodies that have had their physical characteristics, or hydromorphological conditions, modified by engineering works for drainage or development.
Water bodies are modified for power generation, the creation of dams for water supply, flood defences, industrial activity, to improve drainage and for navigation. These modifications prevent the river or waterbody functioning in its natural state and may impact on the diversity of fish populations and invertebrates that can live there owing to impacts on the natural conditions. This means that these waterbodies cannot reach the good ecological status required for fish and invertebrates under the Water Framework Directive. These circumstances are recognised in the Water Framework Directive and such waterbodies are designated as heavily modified and required to achieve Good Ecological Potential rather than good ecological status that needs more natural conditions. Under Good Ecological Potential standards not impacted by the modification still needs to be achieved such as good chemical and nutrient status.
Recent EU guidance to help Member States designate water bodies that have been modified has resulted in Ireland re-designating many of its water bodies.
Using the 11 step process of the new guidelines that includes (a) waterbody characterisation tests, (b) designation tests and (c) the assessment of potential objectives, Ireland has designated a total of 466 waterbodies as heavily modified. The largest contributor is the arterial drainage of rivers.
The EPA is holding a public consultation to seek views on the designation from which the EPA will make recommendations to the Department of Housing, Local Government and Heritage on the final designations for inclusion in the next River Basin Management Plan cycle
A total of 433 river, 20 lake and 13 transitional and coastal (TRAC) water bodies have been identified as Heavily Modified Water Body candidates
List is here: