SWAN: Submission to Public Consultation on the Draft Third Cycle River Basin Management Plan for Ireland 2022-2027

March 2022

Sustainable Water Network (SWAN)

Selected recommendations:

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