Irish Water Services Strategic Plan

1. Our Customers Demonstrating our commitment to the delivery of an improved quality water and wastewater service through the appropriate management of our assets in an economic and efficient manner ensuring least cost for our customers.

2. Reducing Drinking Water Quality Problems Where water supplies are subject to Boil Water Notices, due to microbiological contamination, or have other drinking water quality problems, these must be resolved as key priorities through capital investment in infrastructure or changes to operational procedures where appropriate.

3. Achieving Compliance with the Urban Waste Water Treatment Directive Bringing Ireland into compliance with the Urban Waste Water Treatment Directive must be an immediate priority. The European Commission’s Infringement Case against Ireland for the 71 non-compliant agglomerations is likely to be progressed in 2015 and will require committed plans to meet the compliance limits on these and other schemes within a prescribed period.

4. Reducing Leakage in Water Supply Networks We are currently utilising the early returns from the water metering programme to help us refine estimates of legitimate usage and levels of leakage within customers’ properties. This will better define the size of the leakage problem, the optimum solutions and help us to determine where the largest leaks are. Works can then be prioritised which bring the largest water savings with targeted deployment of repair teams. We will also seek to reduce overall leakage within a network through better management of water pressure. We are determined to achieve the lowest level of leakage which is technically and economically sustainable, taking account of the state of the networks. 15 | Irish Water Water Services Strategic Plan - October 2015

5. Addressing Inadequate Asset Condition Information Gathering accurate information on all of our assets into a quality assured database is a strategic priority. It is an essential tool for asset management over the lifetime of this plan and we cannot function effectively without it. We have currently drawn together all asset records onto a common national database (Geographical Information System) and are improving the accuracy and quality of these records on an on-going basis.

6. Catering for Growth Irish Water will prioritise the allocation of resources to cater for growth using a risk based approach to determine which strategic assets are likely to constrain growth in the near future and taking into account the priorities set by the Minister and national planning policy. For example, the Minister has identified the need to address infrastructure constraints impacting on the delivery of housing units in urban areas as a current priority. How we will prioritise the allocation of funding. Irish Water will prepare and publish a Capital Investment Plan (CIP) and submit this to the CER for approval of funding. The CIP will be prepared on at least a five year basis and will propose investment priorities in line with the policy set by the Minister taking into account the objectives and targets identified in this and subsequent revisions of the WSSP. Our proposed investment prioritisation methodology will be set out in each CIP. Monitoring Our Performance This Water Services Strategic Plan proposes a suite of targets and indicators for each Strategic Objective presented in the later chapters. Our performance against these targets and the monitoring plan included in the SEA Statement will be assessed and reported by us within each revision of the Plan. This performance will therefore be available for scrutiny by our regulators (CER and EPA), other stakeholders and the general public. However, our progress against these targets is subject to adequate funding being available. Indicators and targets may change in subsequent revisions of the WSSP to reflect the priorities identified for the following period. Our economic regulator, the CER, has published and will maintain ‘The Customer Handbook’ which is primarily concerned with customer billing and communication. In accordance with this, we have published a set of Codes of Practice for the delivery of customer operations which will be subject to periodic revision and approval by CER. As part of our regulatory framework, and in line with our commitment to customer care, we also operate a Customer Charter relating to our provision of water services for network operations and Terms and Conditions for both domestic and non-domestic customers. These will be published and periodically updated throughout the life of this plan. Lough Gur, Co. Limerick. Photo: Alan Forsyth 16 | Irish Water Water Services Strategic Plan - October 2015 Chapter 3 Objective: Meet Customer Expectations 17 | Irish Water Water Services Strategic Plan - October 2015 Our Strategic Aim • Establish both Customer Trust and a Reputation for Excellent Service Introduction Irish Water’s first strategic objective is to meet our customers’ expectations through the provision of high quality, reliable water services, delivered through resilient systems, in an economic and efficient manner, reflecting the customer service levels expected in a modern economy. We must ensure that the need to meet higher standards for compliance in drinking water quality and wastewater discharges to the water environment is balanced against the cost of water services that we provide to our customers. Our first response to ensuring that we deliver our services in an economic and efficient manner has been to review all proposed capital investment in our water services assets, for which we took over responsibility in January 2014, to more accurately define the scope required to address short and medium term needs and ensure value for money invested. Even with this revised scope of projects, the capital investment need remains large (€5-6 Billion is estimated to be needed by 2021). The Current Situation As a new utility, we are in a period of transformation from the provision of water services by 34 (now 31) local authorities to operation and management of these services by Irish Water. Local authorities are presently working under service level agreements with Irish Water to ensure a continuity of service and a smooth transition. Our customers will continue to be served on the ground by local authority staff, operating the local treatment plants and networks. Irish Water staff will have an increasingly important role in planning and managing the provision of water and wastewater services, defining both the operational and investment strategies. We are, therefore, in a period of transformation into a more centralised and cost effective customer operation. We will develop a new water industry operating framework to deliver more services regionally, with shared cross boundary working, centres of excellence and increased specialisation. This will enable transition to a leaner customer support team with a nationally consistent approach. Key Challenges There is presently a lack of detailed knowledge of the cost and technical challenges that Irish Water face in the provision of water and wastewater services to the standards expected in a modern economy. This is because of uncertain information on the condition and performance of the assets, especially underground water distribution and sewage collection networks. Despite these limitations, Irish Water recognises that customer expectations of the quality of the service they will receive will increase following the introduction of charges. Key challenges facing Irish Water in relation to meeting customer expectations are summarised below: Identifying our customer base Water services for part of the population are provided by Group Water Schemes or private supplies, while wastewater treatment for much of the rural population is served by septic tanks. As a result, one of our earliest activities is to identify and obtain correct contact and scope of services information for all of our customers. A primary function of the domestic customer application campaign is to identify who receives their water and/or wastewater services from Irish Water and who doesn’t. This will ensure efficient delivery of services to each customer, together with accurate billing information. 18 | Irish Water Water Services Strategic Plan - October 2015 Delivering reliable water services Our water and wastewater assets have suffered from significant under-investment over an extended period of years. Consequently, water and wastewater services can be variable and inconsistent. We will prioritise investment to firstly ensure universal, basic service availability and beyond that to deliver consistent service quality equivalent to that provided by high performing utilities in other sectors. Meeting our customer service commitments and Codes of Practice We are committed to achieving the service standards set out in the Customer Handbook. These standards are approved by the Commission for Energy Regulation (CER) and are the basis of the content of Irish Water’s Customer Charter, Terms and Conditions and Codes of Practice. Delivering customer satisfaction We anticipate a high level of communication with our customers by letter, email, phone, digital channels and through the media. We are committed to handling all customer communication in the manner expected of a modern professional utility. We aspire to deliver a consistent, functional and ultimately satisfying customer communication experience in relation to operational and billing queries, complaints, service requests, new connections services and all other interactions with Irish Water staff and contractors. Establishing sustainable customer funding We are in a period of transition from water services being funded primarily through general taxation to one where direct charging of the end user provides part of the funding. As a utility increasingly dependent on the payment of water charges, it is essential that our customers recognise the importance of good water services provided efficiently. Balancing key customer objectives Irish Water must work with our economic regulator to ensure that the costs incurred to deliver necessary improvements in infrastructure, services and standards is based on efficient working (both capital and operational). 19 | Irish Water Water Services Strategic Plan - October 2015 Objectives and Strategies The proposed strategies to meet the above challenges and to achieve this objective are summarised in the table below and are detailed in the remaining sections of this chapter. Strategy Purpose Aim CE1 – Establish both Customer Trust and a Reputation for Excellent Service Create and operate a lean and effective Deliver best practice and value for money in customer CE1a Customer Operation. operations. Build and maintain accurate customer CE1b To ensure accurate customer services and billing. databases. To secure funding necessary to deliver efficient and CE1c Establish sustainable customer revenue. effective water services. To ensure that customers can communicate with us Establish effective communication channels CE1d when they need to in a manner that suits them and with customers. can be promptly informed of changes to services. Establish national customer service standards Set appropriate customer expectations and deliver to CE1e and robust customer protection measures. these. To address the comments and suggestions of the Public Water Forum in relation to the performance by Fully support the work of the Public Water Irish Water of its functions and to ensure that we are CE1f Forum and establish effective communication open and transparent in relation to our obligations with all our stakeholders. under Freedom of Information legislation and the Aarhus Convention. CE1: ESTABLISH BOTH CUSTOMER TRUST AND A REPUTATION FOR EXCELLENT SERVICE [CE1a] Create and operate a lean and effective customer operation. The employment of an effective workforce is an important part of delivering a competent customer service operation. This also requires Irish Water to establish the structure and governance procedures needed to deliver effective customer services. To ensure that the customer service operations are efficient, flexible long term service contracts with our suppliers will be required which will incorporate strict contract management systems. Irish Water is working with each local authority to ensure that effective structures, work practices, management and training of water services employees under the service level agreements is in place. It is working actively with the sector to achieve cross boundary working by local authority personnel to drive efficiency and improve service quality. 20 | Irish Water Water Services Strategic Plan - October 2015 [CE1b] Build and maintain accurate customer databases. Collating an accurate database of customers is critical to efficient delivery of services to each customer as well as Irish Water’s revenue generation capability and customer acceptance of water charges. Irish Water is currently validating its domestic customer lists whilst simultaneously working with local authorities to transfer all non-domestic customers. This will provide Irish Water with the capability to communicate with, and provide quality water services to, customers effectively into the future and to implement accurate billing. Maintenance of an accurate database is crucial to Irish Water to enable delivery of an effective water service to all customers. [CE1c] Establish sustainable customer revenue. To be willing to pay for the water and wastewater services that they are receiving, customers need to be satisfied that they are paying a fair amount for a defined service level. It is essential that Irish Water has a clear and transparent tariff structure and that we explain this clearly. We are working closely with our economic regulator (the CER) and other stakeholders on tariffs and customer protection consultations in order to achieve this objective. Customers expect to be able to pay in a way that best suits their needs. Irish Water will provide payment methods and frequency of payments that meet with customer demand. [CE1d] Establish effective communication channels with customers. A number of documents have been published setting out how Irish Water will communicate with our customers. The Customer Handbook, published by the Commission for Energy Regulation (CER) provides guidelines on the required levels of customer service. The Handbook is available at; https://www.cru.ie/home/customer-care/water/customer-protection-2/ The Codes of Practice and Customer Charter set out our commitments for effective communication with our customers. The Customer Charter (https://www.water.ie/docs/Customer-Charter.pdf) sets out the service provided and service quality levels offered to our customers. It also sets out a number of commitments where charter payments apply for domestic customers. The Codes of Practice (http://www.water.ie/our-customer-commitment/) set out the standards and conditions of service for our customers and include information on: our charging structure, payment options, customer complaint handling (including the CER’s dispute resolution role), frequency of bills and the testing of meters. They also include details on how you can expect us to communicate with customers and what we will do during planned and unplanned interruptions to the water supply. All new domestic customers are issued with a copy of our Domestic Terms and Conditions for Water Services http://www.water.ie/docs/Domestic-Terms-and-Conditions-English.pdf We understand that some of our customers have different needs when it comes to using our water services and communicating with us. We have developed a register of vulnerable customers, which includes: • a special services register for those customers who require additional support communicating or receiving services from us and; • a priority services register for those customers who are critically dependent on water for their medical needs. The vulnerable customer Code of Practice http://www.water.ie/docs/Vulnerable_Services_Booklet_ENG_web_final.pdf gives details of how we plan to respond and adapt the services and communications provided to suit the needs of customers who tell us they are vulnerable. We are committed to providing an excellent service to our customers that meets their evolving needs and requirements, while taking into account the challenges we face in establishing a modern water utility and the necessary upgrade of our assets to provide a reliable water supply. 21 | Irish Water Water Services Strategic Plan - October 2015 Our communications are intended to reach all of our customers and other interested parties and include the use of: • Our website; • Social media; • SMS messages (texts, used in clusters to communicate local operational problems); • Telephone; • Letter; and • Face to face. Irrespective of the form of communication used we will always listen to feedback from our customers. Water Treatment Plant at Dock Road, Limerick. Photo: Kieran Clancy [CE1e] Establish national customer service standards and robust customer protection measures. Irish Water is committed to providing a satisfactory standard of water services to our customers with robust customer protection measures in place. Our service standards outlined in our Codes of Practice and Customer Charter (for both domestic and non-domestic customers) are approved by the CER. Our Customer Charter originally published on the 30th September 2014 (https://www.water.ie/docs/Customer-Charter.pdf) commits us to engage with customers through a range of communication channels. It also offers a process for the resolution of Customer Complaints and sets out Guaranteed Service Standards. We operate under a range of Codes of Practice which comply with the requirements of the Water Handbook relating to: • Domestic Customer Communications Code of Practice • Domestic Metering Code of Practice • Domestic Billing Code of Practice • Domestic Vulnerable Customer Code of Practice • Domestic Network Operations Code of Practice • Domestic Complaint Handling Code of Practice • Business Customer Codes of Practice These are available from our Customer Communications team or on our website (https://www.water.ie/our-customer- commitment/). We expect our published codes and charter commitments to expand and evolve over time. 22 | Irish Water Water Services Strategic Plan - October 2015 [CE1f] Fully support the work of the public water forum. Irish Water will fully support the work of the Public Water Forum to be established under the Water Services Act,

2014. This forum represents the interests of Irish Waters’ customers. We will work with this customer consultative forum to fully understand the expectations of our customers in relation to how we perform our statutory functions. We will listen to and address the comments and suggestions coming from the forum in relation the performance of our functions. In addition to and complementing our communication channels with our customers through the strategies outlined in above and through the Public Water Forum, Irish Water will take a proactive approach to communicating with our broad stakeholder base and will fulfill our obligations under the Freedom of Information Act, 2014 and the Aarhus Convention as outlined below; Freedom of Information Act 2014 Irish Water is a listed FOI body and full information on our FOI process and approach can be found on our website: http://www.water.ie/about-us/freedom-of-information/ Aarhus Convention The aim of the Aarhus Convention is to link environmental protection with human rights by ensuring access to environmental information (AIE), public participation in decision making and access to environmental justice. Access to Environmental Information (AIE) Full information on our approach to AIE can be found on our website: https://www.water.ie/about-us/freedom-of-information/Access-to-Information-on-the-Environment_.pdf We are currently developing a facility on our website were the public can access information on the quality of drinking water in any Water Supply Zone. Results of our sampling regime of 11 drinking water parameters will be available on our website in Q3 of 2015 and the site will continue to be developed to allow the customers/members of the public to link an address to the water quality in a specific Water Supply Zone. In addition, Annual Environmental Reports (AERs) for all our licensed wastewater treatment plants are available on the EPA’s Website and Irish Water will work with the EPA to ensure this information continues to be available through access to their website and links on Irish Water’s website. Public participation in decision making There are a number of existing statutory instruments through which Aarhus is legislated for, these include Strategic Environmental Assessment (SEA) and Environmental Impact Assessment (EIA) and our national statutory planning process. Irish Water will ensure that we comply with this legislation and examine where additional public participation can be incorporated in the early phases of these processes. Irish Water has demonstrated this approach in the consultation undertaken to date on the WSSP, which has had both statutory and non-statutory consultation phases in order to ensure that the general public can participate as early as possible in the decision-making process. Environmental Justice All persons who feel their rights to access to information have been impaired (request for information ignored, wrongfully refused, inadequately answered) must have access, in the appropriate circumstances, to a review procedure under national legislation. Irish Water will, as stated above, endeavour to help people access information; however there are procedures within the legislation that a person can follow if they feel they are not satisfied. 23 | Irish Water Water Services Strategic Plan - October 2015 Indicators and Targets Indicators and targets to demonstrate that we meet this objective are presented in the table below. MEET CUSTOMER EXPECTATIONS Current End of End of Indicators Definition 2040 Target Baseline 2021 Target 2027 Target AIM CE1 Establish both Customer Trust and a Reputation for Excellent Service 80% of calls 80% of calls 80% of calls 80% of calls Call answered in less answered in less answered in less answered in less Contact answering than 20 seconds. than 20 seconds. than 20 seconds. than 20 seconds. Handling and call Less than 5% of Less than 5% of Less than 5% of Less than 5% of abandonment calls abandoned calls abandoned calls abandoned calls abandoned 90% resolution 100% 100% 100% or understood resolution or resolution or resolution or Complaint steps to understood steps understood steps understood steps Time based Handling resolution to resolution to resolution to resolution within 5 within 5 within 5 within 5 working days working days working days working days Minimum 2 day Minimum 2 day Minimum 2 day Supply Advanced advanced notice advanced notice advanced notice Not established Interruption Notice of planned of planned of planned interruption interruption interruption Accurate quarterly bills based on actual reads (for metered customers) Billing & Meet CER’s Range of customer focused payment options available Payments requirements Sympathetic handling of payment difficulty cases 24 | Irish Water Water Services Strategic Plan - October 2015 Chapter 4 Objective: Ensure a Safe and Reliable Water Supply 25 | Irish Water Water Services Strategic Plan - October 2015 Our Strategic Aims • Manage the sustainability and quality of drinking water from source to tap to protect human health. • Manage the availability, sustainability and reliability of water supply now and into the future. • Manage water supplies in an efficient and economic manner. Introduction Safe and reliable water supplies are essential to public health and to social and economic progress. The water we need must be abstracted from surface or groundwater sources and treated to a high standard before it is distributed through an extensive network of water mains to households and businesses. This chapter details the current situation in regard to water supply, the challenges that Irish Water faces and our strategies for tackling these challenges. These strategies are arranged around three key requirements of: • Quality; • Sustainability and Reliability; and • Managing Water Supplies in an Economic and Efficient Manner. Performance targets against these key requirements are also presented. The Current Situation Delivering a safe and reliable drinking water supply to over 80% of the population requires the abstraction, treatment and delivery of over 1,600 million litres of water each day. Water is delivered to each tap from a water supply zone. This is a defined supply area served by a single source or group of connected sources. Treated water is processed and transported from the water source through to each tap. The system serving the water supply zone includes one or more abstractions (where water is taken from - lake, river or groundwater), treatment plants to purify and disinfect the water, storage in a tank or reservoir and distribution through pipes. A graphical representation of a water supply zone is presented in Figure 5. There are currently around 900 separate water treatment plants and approximately 60,000 km of pipelines delivering water in Ireland. Water supply zones were historically developed within local authority boundaries rather than on a river basin or regional level. This fragmentation has resulted in a large number of small water treatment plants and water supply zones and a highly variable performance ranging from good operation in newer treatment and distribution infrastructure (e.g. pumps, plant and pipes) to periods of unacceptable performance in older systems. Smaller water sources are also susceptible to sporadic and seasonal variations in water quality and availability. Our Main Legal Obligations Legislation in relation to water services and public health dates back to the last century. The water quality standards which our treated water supplies must now meet are set by the European Drinking Water Directive and transposed into law in Ireland through the European Union (Drinking Water) Regulations, 2014. Enforcement of these regulations is the responsibility of the EPA. Amongst other requirements, the regulations set the limits of concentrations for a range of chemical and microbiological parameters in water intended for human consumption. Under the drinking water regulations, Irish Water must notify the EPA of non-compliances with these parameters. Parameters which do not impact on the wholesomeness or cleanliness of water intended for human consumption, such as colour or hardness, are not included as a required standard within the Drinking Water Directive. 26 | Irish Water Water Services Strategic Plan - October 2015 The abstraction of water from any lake, river, stream, well, or spring by a sanitary authority (Irish Water has the status of a sanitary authority) for a public water supply is governed by the Water Supplies Act, 1942. This Act requires a sanitary authority wishing to abstract water for public supply to apply to the Minister (now ABP) for a water abstraction order. When determining (i) whether or not the sanitary authority can take a supply: and (ii) the volume: and (iii) abstraction rate for that supply, ABP must consider the potential impact of the abstraction on riparian owners, on the water body itself and on the navigability of navigable rivers or canals. ABP may refuse the granting of an abstraction order or alter the terms of the abstraction. The Water Supplies Act, 1942 also allows the sanitary authority to protect the source of their abstraction from pollution or interference with the flow. Our commitments in relation to the Birds, Habitats and Water Framework Directives are detailed in the Chapter 6 – Protect and Enhance the Environment and generally relate to the preservation of sustainable ecological flows in water bodies from which we abstract and ensuring that the construction and operation of our water supply infrastructure does not impact negatively on protected areas and species. Key Challenges The challenges which face Irish Water to ensure a safe and reliable water supply to all its present and future customers are summarised in the paragraphs below. There are currently many water supply zones which fail to meet the European and Irish Drinking Water standards for microbiological and chemical parameters or have significant operational, maintenance or capacity problems at individual treatment plants, giving rise to water quality risks. This includes customers who have a Boil Water Notice due to microbiological contamination in their water supplies (approximately 23,000 customers in January, 2014). This situation is unacceptable to us and addressing it is our top priority. Protection of water sources from contamination ensures safe water supply and reduces treatment costs. However, the protection of individual water supply sources has to date been variable and risk based assessments to determine and prioritise protective measures have not been completed for all water supply sources. Water resources for supply have not, previously, been managed on a catchment, regional or national basis. Therefore, we have urban regions such as Dublin where there is a potential shortage of future water resources whilst in the west of Ireland there are catchments with a surplus of potential available resources but a deficit in treatment provision. No national rules are in place to ensure correct, safe and efficient operation of our treatment plants, storage and distribution network. In some areas there is limited knowledge of the condition, lifespan and location of our above and below ground assets (e.g. treatment plants, pipes, valves and other infrastructure). Water Treatment Plant Pipework. Photo: Maurice O’Connell 27 | Irish Water Water Services Strategic Plan - October 2015 Figure 5 Graphical Representation of a Water Supply Zone NE ZO P PLY SU CATCHMENT TER WA WATER TREATMENT PLANT STORAGE FUTURE EXPANSION RESERVOIR GROUNDWATER BOREHOLE AREA OF FUTURE EXPANSION ABSTRACTION Water flows through pipes at pressure from the treatment works to each household tap. We currently estimate that nationally we are losing approximately 49% of our treated water to leakage from the distribution network and in customer properties. This is unacceptable and reducing this level of leakage is a priority. However, with an underground network of ageing pipes and with a pressurised system including thousands of joints vulnerable to ground conditions and traffic vibrations it will never be possible to reduce water leakage to zero. Instead, our intention is to apply a best practice asset management approach in an economic and efficient manner in order to achieve the optimum water savings to achieve a sustainable and economic level of leakage. The metering of domestic and commercial properties will aid the detection of leaks within the customer’s property and alert customers to the wastage of water on their property with the potential to reduce their water bills. Water supplies also face a range of challenges from external factors outside of Irish Water’s control such as climate change and the need to maintain sustainable resources by balancing abstraction against environmental needs. Ballymore Eustace Water Treatment Plant. Photo: Irish Water 28 | Irish Water Water Services Strategic Plan - October 2015 Case Study Vartry Water Supply, a City Perspective Prior to the 1860’s in Dublin, most drinking water major reservoirs to the south of Roundwood in was sourced from the Royal and Grand Canals. Co. Wicklow, a water treatment plant, a 2.45 mile The canals were poor water sources, offering long tunnel under Callowhill, and forty miles of limited supplies of low pressure, filthy water. trunk water mains to deliver water to the city. “Drink the canal water as it is and you swallow The project was an amazing feat of engineering, filth and animal nature; boil it and you drink a with the works completed by men using picks decoction of poison” wrote one Dubliner of the and shovels, horses and carts. day, Walter Thomas Meyler. The poor quality The new supply project resulted in significant of drinking water in the city, resulted in large improvements in the quality of life for the scale outbreaks of cholera and in the 1860’s inhabitants of Dublin. In terms of public over a thousand deaths were traced directly to health, the last major outbreak of dysentery a single public water tap in Dublin which was was recorded in the late 1860’s and the Vartry contaminated with sewage. In 1852, an eminent scheme dramatically reduced the scourge of doctor John Gray, was elected to Dublin City waterborne disease in the city. Council where he gained a reputation for his interest in improving the lot of the impoverished. As a testimony to the success of the project, In 1853 he was elected to the Waterworks the original Vartry supply still provides drinking Committee, and began work on improving the water for 200,000 people or 15% of the water supply for Dublin. He identified the River population of the Greater Dublin Area. However, Vartry rising below the Sugar Loaf Mountain in the treatment plant and infrastructure has had County Wicklow, as the best potential source no major upgrade since it was first built over for the city. He sought to have a Parliamentary 150 years ago, and the supply is now in decline. Bill passed to empower Dublin Corporation to The water treatment plant does not conform to advance the works, however, he faced wide modern drinking water regulations, the tunnel is scale objections from the private owners of the in danger of collapse, and the reservoir draw- canals and there was outcry in the media at the off facilities need a to be re-built to ensure the high cost of the works and the volumes of water safety of the structure. The upgrading of the proposed. The Bill was debated for nearly five Vartry Water Supply is likely to be addressed in weeks and the first stones were turned on site in Irish Water’s National Water Resources Plan and

1862. The Vartry Supply involved building two future Capital Investment Plans. Vartry Water Treatment Plant. Photo: Nicholas O’Dwyer. Statue of Dr John Gray in O’Connell Street, Dublin. Photo: Irish Water 29 | Irish Water Water Services Strategic Plan What our customers can expect from us We will develop and implement strategies underpinned by ‘on the ground’ measures to meet water quality standards, ensure water availability and provide an acceptable level of service to our customers. We will monitor and report our compliance with these strategies. Objectives and Strategies The proposed strategies and performance targets to achieve this objective are summarised in the table below and are detailed in the remaining sections of this chapter. Strategy Purpose Aim WS1 - Manage the sustainability and quality of drinking water from source to tap to protect human health To ensure a sustainable water supply for all customers whilst maintaining sustainable ecological Prepare a National Water Resources Plan WS1a water flows, complying with water quality standards, and implement on a phased basis. identifying key strategic sources to support balanced regional development. Prepare and implement Drinking Water All water supplies are protected in accordance with WS1b Safety Plans for all Water Supply Zones. international best practice. Implement Standard Operational Procedures To ensure correct treatment of water and optimal WS1c for all water treatment plants, water storage operation of water treatment plants. facilities and distribution networks. To target investment to ensure that water supplies Develop and implement Capital Investment WS1d comply with Drinking Water Standards and meet Plans to improve drinking water quality capacity needs. To effectively address the risk of failure to comply Prepare and implement a “Lead in Drinking WS1e with the drinking water quality standard for lead due Water Mitigation Plan”. to lead pipework. Prepare and implement strategies to To address other (non-regulatory) water quality WS1f manage other quality issues in water issues such as hardness where economically feasible. supplies. 30 | Irish Water Water Services Strategic Plan - October 2015 Strategy Purpose Aim WS 2 – Manage the availability, sustainability and reliability of water supply now and into the future Implement risk assessments for all water To ensure that water supply areas have quantified risk WS2a supply areas in terms of short, medium and assessments and appropriate mitigation measures long term risks to customer supply. are in place. To ensure long term sustainability of yields is Manage existing water resources and plan considered in the management of existing and new for new resources taking a regional view of WS2b water sources to meet predicted needs while being needs and having regard to the objectives of aligned with the requirements of the WFD with the Water Framework Directive (WFD). respect to maintaining sustainable ecological flows. Develop long-term sustainable water sources To ensure all new sources are able to cope with the WS2c with resilience to climate change. potential impacts and risks from climate change. To ensure that all water supply zones have built in Develop methodologies to build strategic security and reliability, by developing larger scale WS2d resilience and network connectivity into regional solutions which offer better governance, resource planning. economies of scale in operation and can be monitored effectively Manage future regulatory requirements for To ensure security in Levels of Service for all WS2e abstraction licencing, headroom in treatment customers which take account of impacts from future facilities and population growth. regulation and population growth. Match water abstraction to availability and To ensure Levels of Service for all customers WS2f quality using surface water and groundwater accounting for seasonal and climate change sources. This is known as Conjunctive Use. variations, maximising source resilience. To reduce water leakage to a sustainable economic Prepare Regional Water Conservation WS2g level in stages through a systematic work programme Strategies and implement on a phased basis. over a reasonable period. 31 | Irish Water Water Services Strategic Plan - October 2015 Strategy Purpose Aim WS3 – Manage water supplies in an efficient and economic manner Adopt an asset management based To maximise the lifespan of assets and their WS3a approach to capital maintenance and capital performance for consistent levels of service at least investment. cost. Optimise the unit cost of water supply To minimise the unit costs of water treatment for all WS3b through proper water resource and our customers taking advantage of scale and efficient treatment planning. processes. Prepare and implement water demand To reduce the volume of water abstracted, treated WS3c management and customer education and used and therefore to reduce the cost to the strategies. customer. To ensure the maximum return and customer benefit Optimise capital and operational investments WS3d from investments through delivery of services in the in water supply. least cost manner. WS1: MANAGE THE SUSTAINABILITY AND QUALITY OF DRINKING WATER FROM SOURCE TO TAP TO PROTECT HUMAN HEALTH [WS1a] Prepare a National Water Resources Plan and implement on a phased basis. A National Water Resources Plan is a country wide assessment of water resource availability and water demand. The plan will assess the likely future demands of our customers and balance these needs against availability and sustainability of water for supply on a catchment and river basin scale. The plan will then make strategic level recommendations for the development of water supply infrastructure to meet the demands of population and economic growth in a sustainable manner. The plan will take a regional perspective supporting balanced regional development and will include for inter-region or inter-catchment water transfers where required to ensure adequate water provision into the future. Any such transfers must be environmentally sustainable and therefore cannot compromise the needs of the local catchment or region. Our National Water Resources Plan will focus on efficient, environmentally sustainable use of water and providing for reliability and security of supply (system resilience). We will improve or decommission water sources which are at risk from contamination or low flows or are causing avoidable environmental impacts. The plan will also include strategies for addressing water quality issues related to pesticides, trihalomethanes (chemical compounds formed when chlorine used to disinfect drinking water reacts with organic matter) and sludges resulting from water treatment processes (See EN3c). The plan will also include cost-effective measures to transfer water from areas that have plentiful water resources to those which have insufficient supplies to meet current demand and to support growth, ensuring that this approach meets sustainability criteria and supports balanced regional development in line with national and regional planning policy. We are targeting a rationalised approach towards fewer larger water supply zones based on sustainable water sources to provide effective, consistent service, quality and value for money to our customers. 32 | Irish Water Water Services Strategic Plan - October 2015 [WS1b] Prepare and implement Drinking Water Safety Plans for all of our Water Supply Zones. Drinking Water Safety Plans (DWSP) seek to protect human health by managing risks to water quality taking a whole catchment approach to manage risks from source through to the tap. Protection of the water source is a priority component of this risk management as ensuring a high quality source of raw water can be the most effective way of reducing the cost of water treatment. The plans assess the risks of contamination of water sources and propose mitigation measures to minimise these risks. They then propose appropriate treatment processes and preventative measures for contamination risks in the water distribution system. Both the World Health Organisation (WHO) and the EPA strongly endorse the Drinking Water Safety Plan approach to managing drinking water supplies effectively in the interests of public health. Irish Water will prepare DWSPs for all water supply zones (WSZs). All DWSPs will use an approach which is in accordance with the WHO guidelines and will ensure that protection and controls are put in place to meet health based standards. DWSPs will also consider the longer term impacts of climate change on the water sources. We will categorise each WSZ on the basis of risk, focusing on those with the greatest risk of water quality failure. We have created data capture and management systems to assess risk and support DWSP development. We expect that these pro-active plans will take over from the reactive ‘Remedial Action Lists’ used successfully by the EPA up to now as the key drivers of investment in and operational management of our water supplies. We will engage with all stakeholders, including landowners and the local authorities, in the development and implementation of measures aimed at delivering effective improvements in the quality of raw water within each catchment supporting good quality raw water sources. This approach will contribute towards sustainability and environmental gains, and potentially have a positive impact on both the cost of treating water and sustainability of yields from the catchment. The categorisation of the water supply sources nationally using DWSP’s will support the phased implementation of the National Water Resources Plan and inform where water sources should be abandoned or combined and also where treatment must be upgraded and centralised to meet water quality standards. The implementation plan for DWSPs will be published in the first quarter of 2016 covering 135 WSZs and a subsequent programme will be published in 2021 covering the remaining WSZs. [WS1c] Implement Standard Operating Procedures for water treatment facilities, water storage facilities and distribution networks. Standard Operational Procedures (SOPs) are written rules and processes for the correct operation of water treatment plants to ensure safe water supply and efficient operation. The procedures will be prepared by reference to best international practice, tailored for Irish conditions and will include staff training and maintenance regimes for all of our treatment plants, water storage facilities and distribution networks. Irish Water will develop ‘Asset Needs’ briefs for each plant which will detail the improvements required to meet the SOPs. These documents will then inform the Capital Investment Plans. We will immediately address those failures which can be removed by implementing changes to plant operations or through our minor capital programmes. We will update and maintain Drinking Water Incident Response Plans. These plans document the procedures, processes and information to support the management of a drinking water incident (unexpected event). The plans assess the risks and assign responsibilities in the event of an incident. They identify the correct communication channels and enable site and event specific arrangements to be made efficiently and effectively. We will also work with relevant statutory bodies in support of ‘A Framework for Major Emergency Management’ as published by the Inter-Departmental Committee on Major Emergencies. We will develop and maintain an Emergency Response Plan, in accordance with the framework, so that Irish Water can respond when called upon in the support of the principal response agencies in reacting to and managing major emergencies. 33 | Irish Water Water Services Strategic Plan - October 2015 [WS1d] Develop and implement Capital Investment Plans to improve drinking water quality. As we improve our knowledge of our assets, collect and interrogate data we will build up a greater understanding of our abstractions, treatment plants and distribution systems and how inadequacies in their operation, maintenance and condition contribute to water supply quality problems. We will then be able to prioritise our investment plans on the basis of risk. We are presently implementing solutions to urgently address immediate inadequacies in water supply provision and Irish Water has developed a work plan for all schemes which are currently failing to comply with microbiological or chemical quality standards. [WS1e] Prepare and implement a Lead in Drinking Water Mitigation Plan. The use of lead pipes and conduits in water supplies has been documented from Roman times. In Ireland water service connection pipes, storage tanks made of lead, lead supply pipes and internal plumbing were used in construction up until the early 1970s. Therefore, it must be assumed that the majority of older houses and public buildings may have lead supply pipes and internal plumbing, except where it has been replaced. Lead can be absorbed into solution in water from lead pipes and the solubility (plumbosolvency) is a function of the water chemistry. Drinking water treatment usually includes pH adjustment (typically using lime) in order to reduce lead solubility, but this is only partially successful. Internationally, other chemical treatments are used which deposit a coating on the pipe wall inhibiting the solution of lead into the water. The acceptable concentration of lead in drinking water is 10 µg/litre, based on standards set by the EU Drinking Water Directive, with effect from December, 2013. Prior to that date, the standard was 25 µg/l, down from 50µg/l in 2003. The general health advice, echoed by both the EPA and HSE, is that the preferred option for meeting this standard is full removal of lead from the distribution network (both public service connection pipes and private supply pipes and plumbing), but achieving this will inevitably take a considerable period of time. Figure 6 Extent of Responsibility for Household Connection Pipe PROPERTY BOUNDARY WATER MAIN This is IRISH WATER’S responsibility STOP VALVE DISTRIBUTION SYSTEM (SUPPLY PIPE) SERVICE CONNECTION This part of the pipe is This part of the pipe is YOUR responsibility IRISH WATER’S responsibility PRIVATE SIDE PUBLIC SIDE 34 | Irish Water Water Services Strategic Plan - October 2015 The Irish Water website provides advice to customers on lead, including the HSE and EPA Joint Position Paper – Lead (Pb) in Drinking Water, December 2013 which is available from the following link (https://www.water.ie/support/ questions-and-answers/lead-pipes-information-for-customers/). Irish Water is responsible for public service connection pipes up to the site boundary as shown in Figure 6. Householders are responsible for the supply pipe from outside the site boundary and internally in the property. Irish Water is currently surveying the extent of lead pipework in our system and mapping it into our Geographic Information System (GIS) using data from the metering project and local authority surveys of backyard supply pipes. Based on currently available data, we estimate that there are some 160,000 domestic properties with lead service connection pipes. There are also a further 30,000 to 40,000 domestic properties which have shared supply pipes and a proportion of these are lead pipes. IW is currently developing a Lead in Drinking Water Mitigation Plan which will include the replacement of lead service connection pipes over a 10 year period and consideration of other feasible technological alternatives to reduce lead in drinking water as quickly as possible in the short term. We aim to have this strategy in place by early 2016. We will notify households of lead exceedances in their water supply and advise households with lead supply pipes on flushing protocols and replacement options. We will also advise our customers on the appropriate Domestic Plumbing Standards Policy based on international best practice. Where a customer decides to replace their (private side) lead supply pipe, we will commit to replace the (public side) service connection pipe at the same time, if this has not already been done. [WS1f] Prepare and implement strategies to manage other quality issues in water supplies. Drinking water must comply with standards set by the Drinking Water Regulations (2014) and the strategies for meeting these standards are presented above. We will also identify water supplies that suffer from water quality issues which do not have required standards under the Drinking Water Regulations such as water hardness and discolouration due to natural sources. These problems can cause concern to customers and excessive hardness in particular can cause damage to hot water appliances. However, neither hard water nor the substances associated with hard water, such as lime, calcium and magnesium, require the restriction of a supply nor do they make water unfit for human consumption. We will continue to review our treatment processes to ensure optimum removal of colour, iron and manganese compounds and dissolved solids leading to colour. We also recognise that colour and turbidity often arise from changes in flow in old mains (notably iron pipes) and we will work to minimise this, recognising that relining or replacement of these is a long term objective. While treatment to reduce hardness in water supply is not currently a priority, it may be considered in severe cases by the CER when priority compliance issues have been addressed. WS2: MANAGE THE AVAILABILITY, SUSTAINABILITY AND RELIABILITY OF WATER SUPPLIES NOW AND INTO THE FUTURE [WS2a] Implement risk assessments for all water supply zones in terms of short, medium and long term risks to customer supply. Water sources can be susceptible to changes in river flows or lake and groundwater levels. We will prepare risk assessments for all water supply sources to determine short, medium and long term risks to water supply capacity. Based on these risk assessments, we will identify and develop our plans for sustainable water sources nationally. Measures to achieve this will include rationalisation of water supply zones to utilise larger sources and interconnection of networks to ensure security of supply. Risk assessments of all water supply zones will be completed by the end of 2017. 35 | Irish Water Water Services Strategic Plan - October 2015 [WS2b] Manage existing water resources and plan for new resources taking a regional view of needs and having regard to the objectives of the Water Framework Directive (WFD). The WFD promotes a holistic approach to the management of the water environment where all stakeholders work together. Working with the EPA, we will seek to balance the volume of our abstractions and the locations where we abstract water with the needs of the ecology supported by the water environment. We will identify opportunities for co-operation on the development of catchment management initiatives that will increase protection of drinking water sources. This will form a key part of the National Water Resources Plan and Drinking Water Safety Plans with the initial identification of appropriate measures aligned with the requirements of the WFD being completed by the end of 2017. [WS2c] Develop long-term sustainable sources with resilience to climate change. It is important that our water treatment and distribution systems are able to cope with impacts from both short term extreme weather events and longer term changes to water resources. Climate change studies indicate that extreme weather events such as droughts and flooding resulting from intense or prolonged rainfall could become more common in the future. Irish Water will seek to develop new water sources and mobilise additional sources to support those at risk, in order to make our supplies resilient to potential climate change impacts. [WS2d] Develop methodologies to build strategic resilience and network connectivity into resource planning. Water supply zones that are reliant on a single source, water treatment plant or storage, are more vulnerable to short or longer term service interruptions due to contamination of a source or failure in a treatment process. We will seek to interconnect water supply zones, where possible, or to develop back-up sources and treatment and storage facilities to ensure reliability and resilience in water supply. This will take account of the risk and impacts of supply failure and its mitigation will be a function of criticality and cost, taking account of funding available. Figure 7 Graphical Representation of a Strategic Water Supply Network KEY Current supply Future network Irish Water is developing better links between our water treatment works to enhance the resilience of water supply to our customers’ properties. 36 | Irish Water Water Services Strategic Plan - October 2015 [WS2e] Manage future regulatory requirements for abstraction licencing, headroom in treatment facilities and population growth. We will work with the EPA and the Department of the Environment, Community and Local Government to manage the regulation of our water abstractions, on the assumption that new national regulations for abstractions are likely to be introduced in the near term. In respect of any new regulations, our paramount consideration will be to ensure that Irish Water can maintain supplies to its present and future customers. The headroom capacity in some water treatment facilities, particularly in the Dublin area, is at critical levels. Irish Water has a target to maintain headroom capacity in the 10-20% range to ensure resilience of supply to meet peak demands, population growth and other demand increases. Where the scale and economic impact of supply failure is high, or the consequences to vulnerable customers would be significant, we believe that the available headroom should be at the upper end of this range, 20% over current daily need in large urban areas, 15% in regional gateway towns and 10% elsewhere. [WS2f] Match water abstraction to availability and quality using surface water and groundwater sources. Irish Water will take a full part in the process of developing river basin management plans and related programmes of measures to protect water sources from catchment impacts. These can include runoff from agriculture, forestry, tourism or other activities. Drinking water supplies are particularly vulnerable to organic pollution (leading to algal blooms) but also to other compounds such as metals, chemical or pharmaceutical residues. Within our water safety plans, we will include consideration of these risks and their mitigation. Depending on the level of risk, this may require consideration of mitigation measures such as temporary shut-down or interconnection of multiple sources, where practicable. [WS2g] Prepare Regional Water Conservation Strategies and implement on a phased basis. Leakage is an immediate priority for Irish Water. Irish Water currently estimates that, nationally, 49% of water produced is lost to leakage, with the leakage lowest in the Greater Dublin Area and greatest in rural schemes with relatively long pipeline lengths per customer served. We are currently carrying out detailed audits across the country and validation of the local area metering and valve controls forming District Meter Areas (DMAs) which have been installed since 2000 in most local authorities at a cost of over €100M. In many cases, the integrity of DMA boundaries has been compromised for local operational reasons so that accurate leakage calculations and leak targeting are not currently possible. We are working to re-establish the DMA infrastructure as a pre-requisite to a large scale programme of water conservation measures, which we plan to deliver on a regional basis. We will prepare Regional Water Conservation Strategies that will deliver a targeted programme of leakage detection, leakage control, pressure management and leakage repair. This work will be implemented in a continuous programme over a number of investment cycles to bring leakage down and maintain it at sustainable economic levels. We will introduce pressure management measures and replace or rehabilitate water pipelines as required. We estimate that 10% of our domestic customers have significant leaks, divided between internal leaks on fittings or plumbing and leaks on their external supply pipes. Our metering programme and our ‘First fix’ programme will assist in repairing the external leaks and will also encourage the repair of internal leaks by customers. We will analyse domestic metering data returns to build up a better picture of water usage and review demand calculations in all water supply zones during 2015 and 2016. We plan on reducing leakage across all schemes to less than 38% by the end of 2021, 30% by the end of 2027 and will work to achieve a sustainable economic level of leakage, by 2040. Experience from the UK indicates that an economic level of leakage is in the region of 18-22% of water treated. 37 | Irish Water Water Services Strategic Plan - October 2015 WS3: MANAGE WATER SUPPLIES IN AN EFFICIENT AND ECONOMIC MANNER [WS3a] Adopt an asset management based approach to capital maintenance and capital investment. Irish Water assets comprise our rights to abstract water from specific water bodies our reservoirs, extensive pipe networks, pumping and storage systems, treatment plants, buildings and other equipment. We recognise that robust and reliable information on the condition of our water assets, capacity and their future lifespan is vital to inform future investment plans and to ensure that assets are replaced or upgraded when necessary. We have developed a national Geographic Information System (GIS) into which all of the available water network information from the local authorities has been mapped. This is reasonably comprehensive for the public water mains following major surveys as part of water conservation studies over the past 10 years. Where data is available, it is not always complete with regard to the size, material, condition or age of assets, all of which is useful information. The presence and location of fittings (valves, hydrants, manholes) and connections is also very important. Ongoing surveys will be needed to upgrade and increase the reliability and value of these asset datasets. [WS3b] Optimise the unit cost of water supply through proper water resource and treatment planning. Minimising the unit cost of delivering water to the customer whilst meeting environmental compliance will result in the rationalisation of water supply areas over time and, subject to funding ability, will focus on a smaller number of high quality, sustainable sources with standardised treatment processes. This rationalisation approach will be developed within the National Water Resources Plan by the end of 2017. [WS3c] Prepare and implement demand management and customer education strategies. Demand management encompasses activities to manage the use of water as a sustainable resource whilst protecting the environment. As the Regional Water Conservation Strategies referred to in [WS2g] are implemented, the focus on customer demand management in combination with reduced leakage will ensure costs for water abstraction, treatment and distribution are reduced. Demand management will be facilitated through the domestic metering programme, with water use figures provided on quarterly bills and the potential for customer savings for low water use. We will support education on water usage to encourage reduced water demand across both domestic and commercial water users. This will focus on the ‘value of water’ and how our actions and activities impact on our water demand and the implications for the environment, levels of service and costs to customers. The introduction of meters to measure domestic water usage at individual properties will facilitate this. We will promote the reuse of grey water and water efficient domestic appliances, plumbing and fittings. We will also prepare and enforce standards on plumbing and fittings in relation to connection agreements. We will provide specific advice to our commercial and industrial customers on how to reduce water usage, thereby assisting our drive towards minimising abstraction. [WS3d] Optimise capital and operational investments in water supply. We will develop detailed cost benefit analysis and prioritisation models for all strategies and projects that deliver best value for our customers and satisfy our regulators (CER and EPA). The assessment of capital investment projects will follow a process with key decision points and detailed options assessment to ensure that the most cost effective alternatives are selected. Within the project planning and development process, we will engage with all stakeholders including regulators, planning authorities, landowners, fisheries, our customers and other interested parties and work with all concerned in a collaborative basis. This will assist towards delivering our projects and programmes in a timely and efficient manner, minimising add-on costs. 38 | Irish Water Water Services Strategic Plan - October 2015 Indicators and Targets Indicators and targets for ensuring a safe and reliable water supply are presented in the table below. ENSURE A SAFE AND RELIABLE WATER SUPPLY Current End of End of Indicators Definition 2040 Target Baseline 2021 Target 2027 Target Manage the Sustainability and Quality of Drinking Water from Source to Tap AIM WS1 to Protect Human Health % of national Drinking 99.82% samples meeting Water (based on microbiological Microbiological currently compliance Standards available data) 99.99% 99.99% 99.99% standards Boil Water 0 people on 0 people on 0 people on Notices Notices in place 23,000 people notices notices notices >200 days on notices (2014) Carry out 100% of Treatment Remedial Action 126 WTPs on required Plants on the at all WTPs the 2013 RAL remedial EPA 2013 RAL on the EPA’s (list Appendix 1) action 2013 RAL undertaken % of national samples meeting Drinking Water Lead Compliance Lead standards Standards Estimated 98% meeting 99%** 99.5% meeting sampled in the 85–95% meeting standard of standard of public network. standard of 10µg/l* 10µg/l** 10µg/l % of national Drinking samples meeting Water Chemical chemical 99.51% Standards compliance (based on currently 99.75% 99.90% 99.90% standards available data) % of national Drinking Water samples meeting Trihalomethane 90.3% THM compliance Standards (based on currently standards 93% 99% 99.50% available data) * To be established through a comprehensive national monitoring programme ** Based on technological alternative to lead replacement being available 39 | Irish Water Water Services Strategic Plan - October 2015 ENSURE A SAFE AND RELIABLE WATER SUPPLY Current End of End of Indicators Definition 2040 Target Baseline 2021 Target 2027 Target AIM WS2 Manage the Availability, Sustainability and Reliability of Water Supplies Now and into the Future Average hours of supply ? interruption per property served Transition from Water (per year) - hours Not currently unplanned to On track to 0.13 hours lost Supply lost due to available. planned supply achieving long per annum - Interruptions water supply To be defined by interruptions term target planned and interruption for end of 2016 with targeted unplanned 3 hours or longer reduction in interruptions (planned or number of unplanned) interruptions % of properties at or above ? From 2019, reference level Water Not currently 2% per annum On track to 99.9% (minimum of Pressure available. To be decrease in achieving long receiving 15 metre defined by end properties below term target appropriate pressure head at of 2016. pressure pressure property meter) reference level AIM WS3 Manage Water Supplies in an Efficient and Economic Manner Leakage expressed as a % of treated Achieve Leakage Sustainable water put into Approx. 49% of Less than Less than the distribution treated water 38% of treated 30% of treated Economic Level system water water of leakage (*currently considered 18 to 22% in the UK) Large number of small unsustainable Water Treatment Continue National Plants (WTPs) Rationalisation Fully implement programme of Water Implement (Circa 900 in total). of WTPs & Water NWRP target for rationalisation Resources National Water (Define the Supply Zones. optimum number base on cost Planning Resources Plan appropriate Target reduction and scale of water benefit and (NWRP) number of WTPs to 780 WTPs. treatment plants available funding based on NWRP to be developed and implemented by 2018) 40 | Irish Water Water Services Strategic Plan - October 2015 Chapter 5 Objective: Provide Effective Management of Wastewater 41 | Irish Water Water Services Strategic Plan - October 2015 Our Strategic Aims • Manage the operation of wastewater facilities in a manner that protects environmental quality. • Manage the availability and resilience of wastewater services now and into the future. • Manage wastewater services in an efficient and economic manner. Introduction Providing an effective wastewater management system for the collection and treatment of effluent is essential to protect the environment and public health. The treatment of wastewater to appropriate standards prior to its discharge to watercourses safeguards water used for drinking water abstraction, bathing, fishing and other recreational activities. A graphic illustrating the elements of a wastewater management system is presented below. This chapter details the current situation in terms of wastewater management, the challenges that Irish Water faces and our strategies for tackling these challenges. Performance targets against which our future progress can be assessed are also presented. Figure 8 Wastewater Management System WASTE WATER TREATMENT PLANT FUTURE EXPANSION TREATED DISCHARGE COMBINED SEWER OVERFLOW AGGLOMERATION FUTURE CONNECTION AGGLOMERATION 42 | Irish Water Water Services Strategic Plan - October 2015 The Current Situation Over 1,000 separate wastewater treatment plants and collection networks currently process our wastewater in Ireland. While some of our wastewater treatment plants have enough capacity to cope with their effluent loads, others do not. We have many smaller communities and a number of large coastal urban centres without any effective wastewater treatment. In addition, many communities are served by individual septic tanks or private treatment plants that are outside the scope of Irish Water’s remit. Under the previous funding model, investment in wastewater collection and treatment was the responsibility of the local authorities. This approach engendered a local focus rather than a regional or national perspective on the solution of issues. One consequence was that investment was concentrated in larger urban centres to address legislative requirements, at the expense of smaller development centres where a rapid expansion of housing had led to increased pressures and demands on outdated treatment systems. This has resulted in a large number of small schemes with either no treatment or unacceptable treatment which does not meet the requirements of the legislation. At the same time, collection systems have developed in an ad-hoc manner. Older urban areas are served by combined systems which accept stormwater run-off and foul flows. Such systems present a risk of flooding and to offset this risk, many are provided with overflows which discharge excess flows to rivers and streams in times of heavy rainfall. These are referred to as Combined Sewer Overflows (CSOs) and where the overflows spill too frequently, or where the receiving stream is too small, they can be a source of pollution. Our Legal Obligations The legislative context for provision and licencing of appropriate wastewater treatment infrastructure in Ireland is governed by the Urban Wastewater Treatment Regulations 2001 (UWWT Regulations) and the Wastewater Discharge (Authorisation) Regulations 2007. The UWWT Regulations transpose the Urban Wastewater Treatment Directive 91/271/EEC (UWWTD) of the European Commission into Irish law. The UWWTD requires that secondary treatment must be provided at all larger urban areas, i.e. all areas with a population equivalent of greater than 10,000, and areas with a population equivalent between 2,000 and 10,000 that discharge to freshwater or estuaries. The Directive sets the permissible concentration in effluent discharges for a number of parameters, including nutrients (nitrogen and phosphorus) where effluent is discharged to designated sensitive waters. Achieving the permissible discharge concentrations set by the UWWTD forms one of the measures set by the EPA for the implementation of programmes of measures under the Water Framework Directive. The Wastewater Discharge (Authorisation) Regulations 2007 require that all discharges from wastewater collection systems and treatment plants throughout the country which serve an agglomeration of greater than 500 PE (population equivalent) are issued with a Wastewater Discharge Licence from the EPA. Discharge licences set out the compliance and monitoring requirements in respect of treated effluent discharges to the receiving watercourse. All discharges from wastewater collection systems and treatment plants which serve an agglomeration of less than 500 PE (population equivalent) are required to be issued with a Wastewater Discharge Certificate from the EPA. The discharge licence/certificate sets the allowable Emission Limit Value for a discharge based on the status of the receiving water body, including its conservation status in relation to the Birds and Habitats Directives. Compliance with these Directives and resulting regulations for surface waters, groundwater and water policy is discussed further in Chapter 6: Protect and Enhance the Environment. 43 | Irish Water Water Services Strategic Plan - October 2015 Key Challenges Currently, many of the discharges from our wastewater treatment plants do not comply with standards specified either in the UWWT Directive or in our Wastewater Discharge Licences due to overloading, lack of investment and in some cases poor operational procedures. As a consequence, an Infringement Case has been initiated by the European Commission on 71 agglomerations which did not meet the requirements of the UWWTD in 2011. The most recently available EPA publication on wastewater compliance1 reported that 38 (23%) of the discharges from 162 larger urban (>10,000 PE discharging to coastal waters and >2000 PE if discharging to freshwater or estuaries) agglomerations in the country are not meeting the relevant treated effluent quality and sampling standards set by the Directive. These include seven agglomerations that have no treatment or only preliminary treatment. While 77% of the 162 agglomerations meet the relevant discharge and sampling standards, they represent only 39% of the total load (PE) discharged from these agglomerations. Meeting compliance with the UWWT Directive for all of our wastewater treatment plants and discharges is a priority for Irish Water. The upgrading of the Ringsend wastewater treatment plant will make a significant contribution to Ireland meeting its obligations under the UWWTD and increasing our compliance rate (see reference to proposals to upgrade Ringsend in Chapter 8). A key challenge is to ensure that compliance is achieved in a timely and cost effective manner through operational improvements and upgrading and replacement of assets. Investment must be prioritised to where the environmental benefit is greatest and growth is occurring. A large proportion of our urban sewer networks function as combined systems carrying both wastewater and surface water runoff from impermeable hard-standings (e.g. roads, pavements, roofs of buildings, car parks). During periods of heavy rain, excess surface water run-off mixes with effluent and this can result in discharges through combined sewer overflows (CSOs) directly into watercourses. Such discharges can cause serious pollution from intermittent wastewater spills. Our challenge is to understand how these systems are operating and to design and implement appropriate interventions to mitigate the impact of discharges on the environment. Currently, we have high volumes of infiltration of groundwater entering the wastewater collection networks due to leaky sewer pipes. This infiltration, together with peak flows in high rainfall and the variability of loads, represents a significant challenge to the efficient operation and performance of collection and treatment systems. In coastal areas, salt water intrusion has further adverse impacts in terms of plant corrosion and inhibition of the biological treatment process. The challenge of infiltration to sewers mirrors the leakage issue in water mains in that it is extremely difficult to quantify and resolve. No national Standard Operating Procedures (SOPs) are in place for the collection and treatment of wastewater and their development and implementation is a high priority. In many areas, there is limited knowledge of the location and condition of below ground assets. This requires significant surveys and upgrading of the GIS records, development of the system models and a process for keeping them up to date. Knowledge of networks is a pre-requisite for the efficient prioritisation of network improvements to deliver environmental improvement and to enable new development in a cost effective way. King John’s Castle, Limerick City. Photo: Alan Forsyth ¹ Focus on Urban Wastewater Treatment in 2013. Publ. by the Environmental Protection Agency, Dec 2014. 44 | Irish Water Water Services Strategic Plan - October 2015 Combined Sewer Overflows (CSOs) CSOs are an inherent and necessary part of our sewer network as constructed. They act as relief valves to the network during periods of heavy rainfall without which foul effluent would back-up the pipelines causing blockages and flooding of properties. While these discharges should only occur during heavy rainfall which results in dilution of the foul effluent prior to overflow many of the existing CSOs are inadequately designed to retain solid waste resulting in a threat to environmental standards. A graphic of the operation of a CSO is presented below. NORMAL CONDITIONS HEAVY RAINS Storm Drains Storm Drains Waste Water Waste water/ Storm water OVERFLOWS TO WATERWAYS Treatment Plant Treatment Plant What Our Customers Can Expect from Us In the future our customers can expect us to provide an effective wastewater collection, treatment and disposal system, which protects human health and the environment whilst providing capacity for social and economic growth. Our objective is to ensure compliance with our discharge licences, with the Urban Wastewater Treatment Regulations and other relevant legislation for all of our wastewater discharges. Recognising that the scale of the challenge will require a number of investment cycles and will involve major investment, we must ensure that the solutions are appropriate and cost effective. However, any treatment plants which are currently non-compliant with the requirements of the UWWTD or are at risk of becoming non-compliant will be included in the next Capital Investment Plan (2017– 2021) where these are not already included in the current CIP. 45 | Irish Water Water Services Strategic Plan - October 2015 Case Study Lower Cork Harbour Main Drainage Scheme The Cork Lower Harbour Main Drainage Scheme Wastewater from the Cork Lower Harbour area includes the population/industrial centres will now be transferred to a new wastewater of Cobh, Carrigaline, Crosshaven, Passage treatment plant at Shanbally (north west of West, Monkstown, Glenbrook, Ringaskiddy Carrigaline) and treated effluent discharged Shanbally and Coolmore. The existing sewer utilising the existing IDA outfall discharging to network serving the Lower Cork Harbour area the Harbour at Dognose Bank. The scheme comprises mainly combined sewer systems. includes the construction of associated Wastewater from Cobh, Carrigaline, Passage pumping stations and new/upgraded sewers, West/Monkstown and Ringaskiddy is currently rehabilitation of existing sewers and surface discharged following preliminary screening or water separation where economically viable. The untreated into the Harbour. This is in breach of scheme has been approved by An Bord Pleanála the Urban Wastewater Treatment Directive. and construction is due to commence in 2015. 46 | Irish Water Water Services Strategic Plan Objectives and Strategies The proposed strategies and performance targets to achieve this objective are summarised in the table below and are detailed in the remaining sections of this chapter. Strategy Purpose Aim WW1 - Manage the operation of wastewater facilities in a manner that protects environmental quality Contribute to the management of environmental water quality. Meet the Urban Wastewater Treatment Prepare and implement a Wastewater WW1a Directive and work towards meeting the requirements Compliance Strategy. of the Water Framework Directive River Basin Management Plans. To enable optimal operation and maintenance of Produce appropriate guidance documentation WW1b wastewater treatment facilities and collection networks and Standard Operating Procedures. to achieve the best possible outcomes. Develop and implement Capital Investment Target capital investment to progressively achieve WW1c Plans on a prioritised basis to progressively compliance with the Urban Waste Water Treatment achieve compliance. Directive and the Water Framework Directive. Improvement in environmental compliance, reduction Manage the wider potential environmental in complaints associated with construction and WW1d impacts associated with the construction and operation of wastewater treatment plants and operation of wastewater systems networks. Aim WW2 - Manage the availability and resilience of wastewater services now and into the future Implement risk assessments for all WW2a agglomerations in terms of short, medium and To ensure sustainability in customer service levels. long term risks to customer service. Manage existing wastewater assets and plan To maintain service levels in the face of changing WW2b for new assets based on short, medium and demands and asset condition, while having regard to long term sustainability. requirements under the Water Framework Directive. Identify properties at risk of flooding from Reduce risk of combined sewer flooding of properties WW2c combined sewers, and implement measures to thereby protecting public health and minimising the reduce risk on a phased basis. adverse social impact of property flooding. To build strategic resilience within the wastewater Identify and manage critical wastewater WW2d infrastructure to minimise the risk and consequence of assets. critical asset failure. 47 | Irish Water Water Services Strategic Plan - October 2015 Strategy Purpose Aim WW3 - Manage wastewater services in an efficient and economic manner Adopt an asset management based approach To optimise the lifecycle of assets, extend asset life and WW3a to capital maintenance and capital investment. reduce operating costs. Develop and implement strategies and To optimise costs and meet the various appropriate standards to minimise the unit costs of discharge requirements by availing of the WW3b wastewater treatment including standardising best technologies and extending the usage of treatment processes. standardisation, automation and control systems. To reduce energy consumption across all installations Optimise energy consumption in wastewater thereby reducing operating costs through efficient WW3c treatment plants and collection systems. plant and process selection and maximising energy recovery opportunities. Ensure adequate governance and control To ensure that discharges from the trade sector are WW3d of discharges to the sewer network, having controlled and managed to minimise loads at source, regard for best practice and value. thereby reducing loads to treatment. To give certainty with regard to customer charges and WW3e Engage with regulators and stakeholders. to develop strategies for future growth and investment in infrastructure. Optimise capital and operational investments To minimise costs while maintaining a compliant and WW3f in wastewater services. sustainable level of service. WW1: MANAGE THE OPERATION OF WASTEWATER FACILITIES IN A MANNER THAT PROTECTS ENVIRONMENTAL QUALITY. [WW1a] Prepare and implement a Wastewater Compliance Strategy. We will develop a Wastewater Compliance Strategy setting out a pathway to ensure that the discharges from the wastewater treatment plants and networks that we manage comply with the water quality standards required by the Urban Waste Water Treatment Directive (UWWTD) and support the objectives of the Water Framework Directive. We will continue to investigate all wastewater treatment plants that are failing or at risk of failing to meet the UWWTD and prioritise these for remedial work or upgrades. 48 | Irish Water Water Services Strategic Plan - October 2015 Combined sewer overflows (CSOs) will be addressed as a component of the Wastewater Compliance Strategy. We will look to international best practice to guide us in the development of design standards and will use network modelling simulation where appropriate to determine the performance and operation of CSO structures. We will then develop plans for remedial measures where required. Remedial measures will include for separating stormwater and wastewater where this is the optimal solution. Waste Water Discharge Licences control all discharge points from the agglomeration including CSOs. We recognise the challenge of achieving compliance within available funding and the need to prioritise in the early investment periods to secure the maximum environmental benefit. In our programme for short term investment, we are prioritising meeting the requirements of the UWWTD including solutions to address the requirements highlighted in the Infringement Case taken by the European Commission on the 71 agglomerations, together with the full list of urban centres currently without treatment and a number of high priority sites identified by EPA where serious pollution is noted and where designated bathing areas are affected by wastewater discharges. [WW1b] Produce appropriate guidance documentation and Standard Operating Procedures. There are currently no national Standard Operational Procedures (SOPs) to carry out maintenance, inspection and operational duties on wastewater treatment plants. This has led to inconsistencies in treatment plant performance and variations in operational costs due to the different approaches used previously by local authorities. We will develop national rules for effective wastewater system management in accordance with international best practice and will prepare SOPs including staff training and maintenance regimes across the range and scale of our wastewater treatment plants and collection networks. In developing these, we are drawing on proven processes developed in other high performing water utilities which we will adapt for Irish conditions during 2015. Unexpected wastewater incidents (for example blockages, pollution, public complaints) require planned management to correct and minimise the impact of an event. We will develop, update and maintain Wastewater Incident Response Plans for all our wastewater systems which will be managed locally through the service level agreements with local authority staff. These plans will document the procedures, processes and information to support the management of an incident. We will develop and maintain an Emergency Response Plan with regard to provision of wastewater services, in accordance with ‘A Framework for Major Emergency Management’ published by the Inter-Departmental Committee on Major Emergencies, so that we can respond when called upon to support the principal response agencies in reacting to and managing major emergencies. [WW1c] Develop and implement Capital Investment Plans on a prioritised basis to progressively achieve compliance. Where non-compliance arises from inadequate treatment processes or capacity constraints we will need to plan the necessary capital works to increase capacity and efficiency of treatment plants. Where feasible, minor capital investments focusing on process upgrades and bolt on solutions will be deployed as permanent or interim measures. Where larger capital works are required, we must have regard to the priority of compliance with the UWWTD standards, growth, available funding and the need to achieve optimum environmental benefit. We recognise that we cannot address all of the compliance issues in the short term due to funding constraints and the need for a much greater understanding of the wastewater asset base and receiving environments on which they impact. This will require major surveys of our assets and the development of models of both the networks and the receiving water bodies. By adopting this approach future investments will be targeted and efficient and will deliver optimum benefit. We will also rehabilitate, upgrade and replace wastewater collection pipelines that have significant structural and service defects which can be identified through surveys and investigations. This will be a long term programme having regard to the scale of the works, the lack of data on sewer condition and the need to prioritise critical infrastructure. 49 | Irish Water Water Services Strategic Plan - October 2015 [WW1d] Manage the wider potential environmental impacts associated with the construction and operation of wastewater systems. The construction and operation of our wastewater treatment plants and networks can result in environmental impacts due to noise, dust, odour and other factors. These can be mitigated by utilising appropriate design, construction and operational standards. Irish Water will follow a best practise standardised approach to the planning and execution of our works, including a high level of public engagement at key stages in the process. The planning and construction of all new wastewater infrastructure will undergo appropriate environmental assessment as part of the relevant statutory processes. These studies will optimise site selection, identify site specific constraints associated with sensitive receptors (for example plants, animals, built heritage and humans) and develop mitigation measure to be adopted during the construction and operation of the new plant. Robust and well- engineered solutions which are sensitive to the environmental context will enable Irish Water to develop wastewater systems that can be built and operated without excessive adverse impact on communities and the wider environment. WW2: MANAGE THE AVAILABILITY AND RESILIENCE OF WASTEWATER SERVICES NOW AND INTO THE FUTURE. [WW2a] Implement risk assessments for all agglomerations in terms of short, medium and long term risks to customer service. We will prepare risk assessments for all agglomerations served by our wastewater treatment systems to determine short, medium and long term risks to the effective provision of wastewater services. Risks include the flooding of properties, equipment failure, non-compliance of discharges, environmental pollution and capacity constraints. These risk assessments will be used to plan investment and mitigation measures. As we obtain data regarding our below ground assets, we will develop hydraulic models of all our networks so that we can simulate high flow conditions and identify bottlenecks within the system which need to be addressed. We will supplement these with internal CCTV surveys and other investigations to identify critical defects. The most persistent risks to disruption of wastewater services, particularly in urban areas, are blockages due to the accumulation of grease or non-biodegradable material. We are developing a national fats, oils and greases (FOG) strategy to effectively manage these discharges and seek to eradicate them at source. [WW2b] Manage existing wastewater assets and plan for new assets based on short, medium and long term sustainability. We will work with the EPA and other stakeholders in a catchment based approach to ensure sustainable wastewater management. This approach will consider all effluent discharges into each catchment’s water bodies (both from our wastewater discharges and from others) and the ability of the water body to receive treated effluent whilst achieving the water body objectives under the WFD. This approach recognises that water quality in catchment is impacted by multiple pressures, from various sources. Our objective will be for a balanced approach between the sectors, with impacts from wastewater services being addressed as part of a coordinated approach in each catchment, towards the achievement of agreed water body objectives. [WW2c] Identify properties at risk of flooding from combined sewers, and implement measures to reduce risk on a phased basis. Rain falling on roads, roofs and other impermeable surfaces, runs down gutters and drain pipes and into the storm drainage system. In older urban areas, developed pre 1970s, it was common to combine all drainage (foul and rainfall runoff) into a single combined sewerage system. Even where separate storm drainage is provided, it is common that a proportion of runoff is connected to the foul sewer, so that all sewerage systems have increased flows in times of rainfall. 50 | Irish Water Water Services Strategic Plan - October 2015 Increasing urbanisation combined with more frequent and intense rain storms (due to climate change) can result in the capacity of some combined sewers being exceeded. This can cause flooding of properties causing distress to some customers. Irish Water is committed to implementing mitigation measures to either reduce the probability that a combined sewer will flood or reduce the severity of the flooding where long term protection solutions aren’t economically feasible. We are putting in place a publically available register to gather and record information on flooding events from combined sewers caused by inadequate capacity and due to other causes (blockages, collapses and equipment failures). The register will catalogue the extent, frequency and cause of flooding. It will inform our investment to enable us to prioritise areas that flood more frequently and to reduce the number of incidents of flooding caused by blockages, collapses and equipment failures. Irish Water is committed to working with the key stakeholders (planners, land managers and developers) in developing long term sustainable solutions. In the longer term, Irish Water will focus on research and development, improve sewer network models and investigate (in collaboration with local authorities) the use of sustainable urban drainage systems in combined sewer areas. These measures will enable Irish Water to promote an integrated urban drainage approach and to provide a more cost effective and more sustainable wastewater collection system. This work will be carried out in close collaboration with local authorities and the OPW with whom Memoranda of Understanding are being developed. This will recognise that the operational response to flood events must be coordinated, to be led generally by the local authority, with Irish Water support. We will work with the CER to agree investment in flood risk abatement measures with a view to systematically reducing the numbers of properties at risk of flooding from our systems through each investment cycle. We will cooperate with other authorities when flood relief schemes are being developed to ensure that solutions are coordinated for effective relief for urban communities. [WW2d] Identify and manage critical wastewater assets. Sustained environmental performance depends on the reliability and robustness of each treatment plant and its associated network. Critical elements of both plants and networks have the potential to cause major impacts on services and the environment if they fail. We will identify these critical assets and prioritise their maintenance and management. WW3: MANAGE WASTEWATER SERVICES IN AN EFFICIENT AND ECONOMIC MANNER [WW3a] Adopt an asset management based approach to capital maintenance and capital investment. We recognise that robust and reliable information on wastewater infrastructure is vital to inform future investment plans and target improvements where they are most needed. Having inherited the wastewater services infrastructure from the local authorities, we have commenced the integration of wastewater asset records to our GIS system and we are in the process of collating existing hydraulic models and other records (CCTV files) where they exist. These are being assessed for reliability and we are scoping the on-going studies which will gradually improve the extent and accuracy of these vital data and analysis systems. As we develop our data systems, we will collect workflow data from the field, in conjunction with our operational and maintenance activities, which will inform the system data to enable a whole life asset management approach to strategic planning and investment decisions. 51 | Irish Water Water Services Strategic Plan - October 2015 [WW3b] Develop and implement strategies and standards to minimise the unit costs of wastewater treatment including standardising treatment processes. We will develop a number of cost reduction strategies as part of our focus on minimising the unit cost of delivering wastewater services whilst meeting environmental standards. We will strive to standardise treatment processes countrywide using best-in-class, value-for-money technology and control systems. Standardisation will support our strategy of modular development of treatment plants in sync with growth of demand. This will also enable more cost effective planned maintenance, use of spare parts and skills requirements in their operation. We will combine this approach with remote monitoring of all plants, recording critical parameters, flows, energy consumption and process indicators, enabling us to target where interventions are required and minimise plant downtime. [WW3c] Optimise energy consumption in wastewater treatment plants and collection systems. We will prepare and implement a Sustainable Energy Strategy, as outlined in under Aim EN1b of this document. Due to the energy intensive nature of pumping and wastewater treatment, we intend to implement measures to reduce power costs and carbon emissions including the delivery of “greener” technologies where possible. We will target replacement of older inefficient plant (pumps, air blowers), include variable speed controls and look to optimise energy recovery from wastewater sludge digestion. [WW3d] Ensure adequate governance and control of discharges to the sewer network, having regard for best practice and value. We will develop and publish a Wastewater Source Control and Licensing Strategy in Q1 of 2016 to regulate and license the volume and quality of wastewater that commercial customers discharge into our collection network. We will work with local authorities and the EPA in relation to granting and approval of industrial discharge licence applications currently covered by Section 16 licences and Section 99e consents to ensure that the discharged load is within the capacity of the network and treatment plant and that, where necessary, additional capacity can be planned and implemented. We will survey the wastewater treatment loads and operational practices of our industrial customers and will provide advice on initial treatment of effluent and the means of meeting their operational wastewater requirements. We recognise the need for greater control of waste loads to our sewers and plants to prevent corrosion of our assets, failure of our treatment processes and issues with extreme odour generation. We will also develop and implement a management system for the regulation of discharges of Fats, Oils and Greases (FOGs) to our networks. This will include public education and information campaigns to inform customers of the impacts of fats, oils and greases and inappropriate material such as pharmaceuticals, baby wipes, nappies and sanitary towels being discharged into the wastewater system. [WW3e] Engage with regulators and stakeholders. Through our project planning and development processes we will engage with all stakeholders including our regulators, planning authorities, landowners, our customers and other interested parties. We must balance the requirements set by both of our regulators: meeting our requirements under the UWWTD and WFD for the EPA and ensuring that our customers are receiving a quality of service in an efficient and economic manner as prescribed by the CER. To achieve these we will work together in a collaborative manner. We will agree a balanced approach to the delivery of services to both protect the customer and meet environmental objectives. This will be set out in our Wastewater Compliance Strategy. [WW3f] Optimise capital and operational investments in wastewater services. We will develop detailed cost benefit analysis and prioritisation models for all works and strategies agreed with our regulators. We will promote the use of the most cost effective measures, and timing, in planning to achieve required wastewater discharge quality, with investments benefiting from best combination of capital and operational responses. In the first instance, we will seek to maximise the capacity of existing assets through operational improvements supported by targeted capital investment. 52 | Irish Water Water Services Strategic Plan - October 2015 Indicators and Targets Indicators and targets for the effective management of wastewater are presented in the table below. PROVIDE EFFECTIVE WASTE WATER MANAGEMENT Current End of End of Indicators Definition 2040 Target Baseline 2021 Target 2027 Target Manage the Operation of Wastewater Facilities in a manner that Protects AIM WW1 Environmental Quality % of total Waste Water 39%* (based on Population Treatment - EPA’s Focus Equivalent (PE) Compliance on urban waste served by with UWWTD water treatment **WWTP compliant 90% 99% 100% Requirements report for 2013) with the UWWTD Provide the appropriate level 44 Agglomerations of wastewater Urban discharging raw treatment to the Waste Water sewage to the areas from which Treatment environment raw sewage is 100% 100% 100% (List Appendix 2) discharged (List in Appendix 2) Waste water Treatment - % of WWTPs 33%* (based on Compliance with serving >500 PE - based on Annual discharge Emission compliant with Environmental Limit Values (ELVs) EPA discharge Reports to achieve WFD licenses ELVs (AER) 2013) 60% 90% 100% Objectives Pollution Number of Incidents caused Category 2 by Irish Water (localised) pollution Waste Water incidences reported Treatment to the EPA 168 75 20 20 Systems ** Refers to large urban areas WWTP > 10,000 PE discharging to all waters and > 2000 PE discharging to freshwater bodies or estuaries. Includes WWTP discharging “raw sewage” 53 | Irish Water Water Services Strategic Plan - October 2015 PROVIDE EFFECTIVE WASTE WATER MANAGEMENT Current End of End of Indicators Definition 2040 Target Baseline 2021 Target 2027 Target AIM WW2 Manage the Availability and Resilience of Wastewater Services now and into the Future Sewer Flooding; flooding which ? occurs when Not available. Accurate The reduction The reduction the capacity Develop register of by 25% by 80% Number of of sewers is register to number of number of the number of the incidents of exceeded due record properties at properties properties sewer flooding to heavy number, cause risk of flooding which flood which flood of properties rainfall, resulting and extent from sewers. frequently frequently in flooding inside of flooding Historic, high (> once in (> once in and outside of priority flood 10 years) 10 years) buildings. sites addressed AIM WW3 Manage Wastewater Services in an Efficient and Economic Manner % of national trade effluent ? licensable load discharged to Not available. 50% of trade 75% of trade >95% of trade Licenced sewers under Commence effluent load effluent load effluent load Trade Effluent conditions establishment licensed, licensed licensed Discharges determined of register of prioritised prioritised (allowing for to Sewers by Irish Water trade effluents using a risk using a risk turnover in accordance producers & based based of small with the attribute a risk approach approach businesses) polluter pays weighting to each Pumping Station. Photo: Maurice O’Connell 54 | Irish Water Water Services Strategic Plan - October 2015 Chapter 6 Objective: Protect and Enhance the Environment 55 | Irish Water Water Services Strategic Plan - October 2015 Our Strategic Aims • Ensure that Irish Water services are delivered in a sustainable manner which contributes to the protection of the environment. • Operate our water services infrastructure in a manner that supports the achievement of water body objectives under the Water Framework Directive and our obligations under the Birds and Habitats Directives. • Manage all our residual waste in a sustainable manner. Introduction Protecting and improving the future, long term quality of the water environment is fundamental to providing safe water services and for the protection of human health and biodiversity. The water environment is inextricably linked to the wider environment and it is important to consider protection of the environment in a holistic way. Irish Water protects the water environment in its role in delivering water services, but also the broader environment in terms of the impacts of our activities, for example in our use of energy and our carbon footprint. An enhanced water environment results in a reduced requirement for water treatment and supports recreational activities, biodiversity, tourism and the natural character of our countryside. The need to protect and improve the water environment and the environment generally has been recognised in a number of European Directives that afford special protection to identified areas that are important for drinking water supply, nature conservation, bathing and fisheries. Examples include the Birds Directive, Habitats Directive, Bathing Water Directive and the Water Framework Directive (WFD). The WFD is the overarching Directive within which all matters impacting the water environment are managed. This chapter will consider the implementation of sustainable strategies and measures to support our objectives in protecting and enhancing the environment. Our Legal Obligations Irish Water has multiple environmental obligations which regulate its water services functions, operations and developments. The principal obligations result from Directives of the European Commission as detailed in the paragraphs below. Birds and Habitats Directives The Habitats Directive (92/43/EEC) placed an obligation on all Member States of the EU to establish the Natura 2000 network and require protection of defined habitats and species. The network is made up of Special Protection Areas (SPAs), established under the EU Birds Directive (79/409/EEC), and Special Areas of Conservation (SACs). The Directives were transposed into Irish national regulations and have been subsequently revised and consolidated in the European Communities (Birds and Natural Habitats) Regulations 2011. Priority Habitats have been defined for Ireland that include amongst others raised and blanket bogs and turloughs which can be impacted by water abstraction and wastewater discharges. Over 400 SACs and about 150 SPAs have been designated to date in Ireland. Article 6 of the Habitats Directive requires member states to establish necessary conservation measures to protect sites and to take appropriate steps to avoid the deterioration of (or restore) natural habitats and species. Natural Heritage Areas (NHAs) have a national designation and protect features not covered by the Directives. 56 | Irish Water Water Services Strategic Plan - October 2015 As a public authority, Irish Water has duties under the above regulations “to take the appropriate steps to avoid, in European Sites, the deterioration of natural habitats and the habitats of species as well as disturbance of the species for which the areas have been designated in so far as such disturbance could be significant in relation to the objectives of the Habitats Directive.” Water Framework Directive The Water Framework Directive (WFD) establishes a catchment based approach to the protection, improvement and sustainable use of rivers, lakes, transitional waters (estuaries), coastal waters and groundwater. It adopts the ‘polluter pays’ principle and will, over time, integrate the requirements of a number of existing directives for the protection of the water environment. It seeks to develop a holistic approach to sustainable water use, balancing social and economic factors with the need to protect and improve our water environment. The WFD is implemented through river basin management plans which assess the current status of our inland and coastal water bodies (known as characterisation and classification). Where the status of a water body is less than “Good” (for example from pollution or over-abstraction), remedial actions or measures must be proposed and implemented to achieve the objectives set for each water body. Collectively, these are known as “programmes of measures”. The river basin management plans are currently being updated and will be published in 2017. The Water Policy Regulations (S.I. No. 722 of 2003), Surface Waters Regulations (S.I. No. 272 of 2009) and Groundwater Regulations (S.I. No. 9 of 2010) govern the shape of the WFD characterisation, monitoring and status assessment programmes in terms of assigning responsibilities for the monitoring of different water categories, determining the quality elements and undertaking the characterisation and classification assessments. The Surface Waters Regulations institute a wide-ranging set of environmental standards for Irish surface waters. The Groundwater Regulations establish environmental objectives to be achieved in groundwater bodies and include groundwater quality standards and threshold values for the classification of groundwater and the protection of groundwater against pollution and deterioration in groundwater quality. Reflections in Vartry Reservoir. Photo: Jean Clarke Irish Water’s key objectives in relation to the WFD will be the implementation of measures to reduce the impact of our wastewater discharges and thus improve water quality. Our discharge licences will be reviewed on a six yearly basis (by the EPA) and will be targeted to contribute to the delivery of the programmes of measures mentioned above. Where an urban wastewater discharge is the single significant pressure on a water body in relation to achieving its quality status, compliance with our discharge licence requirements should ensure that the water body achieves “Good” status. However, where there are other significant pressures effecting water quality, compliance with the wastewater discharge licence alone may not deliver “Good” status and thus all stakeholders causing significant pressures must play their part in reducing their impact in order to improve water quality. Irish Water will also actively participate in measures aimed at protecting drinking water supply zones and in ensuring ecological flows are maintained in the water bodies we abstract water from. We will undertake monitoring of water bodies used for the abstraction of public drinking water supply and assist stakeholders in the identification of significant pressures on these water resources. 57 | Irish Water Water Services Strategic Plan - October 2015 The Current Situation The current State of the Environment Report published by the EPA (2012) reports that 29% of rivers and canals and 53% of lakes were not Good or High status under the WFD and therefore required improvement. The recent trend in river water quality indicates an overall increase in the length of river channel which is slightly polluted which is mainly due to eutrophication (over-enrichment of nutrients resulting from agriculture and other land use). However, the number of seriously polluted river sites has decreased significantly since monitoring began, reflecting investment in basic wastewater treatment and improved environmental management of agriculture and other land use activities. The number of High status water bodies with sensitive and rare ecology like the Freshwater Pearl Mussel has declined in recent years and site specific, targeted work is required to remediate these and prevent further loss. Groundwater is faring better with 85% of groundwater bodies being at good status. The principal reasons for failing groundwater bodies resulted from nutrient loading resulting from agricultural practices. A small number of water bodies failed due to site specific contamination from historical mining or other sources. There has been a general reduction in nitrate concentration in groundwater since monitoring commenced, attributed to reductions in the use of inorganic fertilisers and restrictions on land spreading in agriculture. The EPA is responsible for licensing wastewater discharges from treatment plants for large towns, and for certification of discharges from treatment plants for smaller agglomerations (under 500 Population Equivalent). Currently, water abstractions are not licenced or regulated by the EPA. Compliance with wastewater discharge licences and certificates will continue to drive improvements in treatment and water quality. The current status of wastewater compliance is outlined in Chapter 5 (Provide Effective Management of Wastewater). Irish Water is a high energy user with an annual cost estimated at €60M. In general, energy efficiency has not been a primary consideration in the construction and operation of water and wastewater treatment infrastructure in the past. What our Customers can Expect from Us Our Customers should expect that in the future, following a period of sustained increased investment, all of our operations will meet their statutory compliance requirements, in particular our wastewater discharges. We will work closely with our environmental regulator, the EPA, and other environmental stakeholders and the general public to participate fully in the process of developing river basin management plans and the associated programmes of measures in the implementation of the WFD in Ireland. Key Challenges Nationally, discharges from wastewater and agriculture are the principal activities currently impacting on the quality of the water environment and therefore we have a significant role in the protection of catchments. A balance needs to be struck between our activities that impact on the environment and the ability of the environment to sustain these impacts over both the short and longer terms. Meeting the requirements of the WFD programmes of measures with regard to the sustainability of our abstractions, discharge licences and input to catchment management planning will be a significant challenge to our new organisation. There are risks to water ecosystems outside our control from invasive species and from climate change which need to be considered in the future planning of our infrastructure. With water and wastewater services delivered across local authorities there was previously no national sustainability policy or guidance on operations. Each local authority had its own policy with regard to works design and procurement. With an ageing infrastructure, meeting our obligations for energy efficiency will require significant investment, in both the upgrade and replacement of inefficient systems whilst ensuring the best whole life options are selected for new capital investments. The provision of water and wastewater services generates a significant volume of both water and wastewater sludge which is dispersed around the many water and wastewater treatment plants and other sites we operate. Effective and safe management of this sludge, utilising its potential for energy generation or reuse where feasible, is a key challenge. 58 | Irish Water Water Services Strategic Plan - October 2015 Objectives and Strategies The proposed strategies to achieve this objective of protecting and enhancing the environment are summarised in the table below and are detailed in the remaining sections of this chapter. Strategy Purpose Aim EN1 – Ensure that Irish Water services are delivered in a sustainable manner which contributes to the protection of the environment To ensure that Irish Water services are delivered in a sustainable manner balancing the need to support the Implement a Sustainability Policy and EN1a social and economic development of the country with Sustainability Framework the need to protect water resources and the water environment. Prepare and implement a Sustainable Energy To meet our obligations under the National Energy EN1b Strategy. Efficiency Plan (2009-20). To support national objectives for climate change Prepare and implement a Climate Change mitigation and to meet our obligations under the EN1c Adaptation and Mitigation Strategy. National Climate Change Adaptation Framework to ensure the resilience and sustainability of water services. Adopt a Green Procurement Approach and To ensure that we utilise resources efficiently in our EN1d drive efficient use of all our resources. management of water and wastewater services. Adhere to environmental and planning To ensure that all future Irish Water infrastructure EN1e legislation when planning and developing meets national planning and environmental legislation water services assets. and to protect sites of natural and cultural importance. Liffey Descent. Photo: Colm Ennis 59 | Irish Water Water Services Strategic Plan - October 2015 Strategy Purpose Aim EN2 - Operate our water services infrastructure in a manner that supports the achievement of water body objectives under the Water Framework Directive and our obligations under the Birds and Habitats Directives Work effectively with other stakeholders to To contribute to the achievement of water body EN2a support a catchment based approach. objectives under the Water Framework Directive. To ensure that the operation of our water and Manage the operation of our water and wastewater infrastructure assists the achievement wastewater infrastructure towards the EN2b of water body objectives under the WFD and the achievement of water body objectives and the conservation of protected sites and species under conservation of protected sites and species. the Birds and Habitats Directives. Aim EN3 – Manage all our Residual Waste in a Sustainable Manner Develop and implement a Corporate Waste To ensure Irish Water meets its corporate EN3a Management Strategy. sustainability responsibilities. To reduce the environmental impacts from Develop and implement a National EN3b wastewater treatment by re-use and renewable Wastewater Sludge Management Plan. energy generation, where feasible. Develop and implement a National Water To reduce the environmental impacts from water EN3c Treatment Plant Sludge Management Plan. treatment processes. Gap of Dunloe. Photo: Irish Water 60 | Irish Water Water Services Strategic Plan - October 2015 EN1: ENSURE THAT IRISH WATER SERVICES ARE DELIVERED IN A SUSTAINABLE MANNER WHICH CONTRIBUTES TO THE PROTECTION OF THE ENVIRONMENT. [EN1a] Implement a Sustainability Policy and Sustainability Framework Water services face a range of environmental challenges from changing climate and extreme weather events, escalating energy costs and the impacts of demands of other stakeholders on water resources. It is important that Irish Water implements all of its operations in a way that enables long term sustainability (i.e. in a way that can continue indefinitely without long term harm to the environment). Irish Water will prepare and implement a Sustainability Policy and a Framework to support the policy. These documents will represent our long term commitment to protecting and enhancing the environment in relation to the construction and operation of our infrastructure and the delivery of our services. The eight key framework components are Resource Efficiency, Climate Change, Habitats & Wildlife, Equity & Economic Development, Health, Amenity, Social Impact and Culture & Heritage. Our commitments under each of these headings will be established and documented. We aim to continually improve our environmental performance and will ensure that its requirements are communicated to all our employees and those working on our behalf. [EN1b] Prepare and implement a Sustainable Energy Strategy The National Energy Efficiency Action Plan (NEEAP) is the Government policy setting out plans and actions to achieve energy efficiency savings across the economy. The action plan was updated in 2014 (NEEAP3) to take account of the Communication from the European Commission setting out its ambition for a 2030 Climate and Energy Policy Framework. The Commission’s proposals for 2030 include a reduction in greenhouse gas emissions (GHG) by 40% below the 1990 level, an EU-wide binding target for renewable energy of at least 27% and renewed ambitions for energy efficiency policies. The review of the Energy Efficiency Directive, published in July 2014, calls for an efficiency target of 30% in 2030. Irish Water is the largest single public user of electricity in Ireland. Our sustainable energy strategy will document how Irish Water will achieve energy efficiency through the use of technologies and initiatives designed to improve energy efficiency. The use of renewable energy sources will be considered where appropriate and economically viable. We intend to target asset investment and operational changes to meet targets for energy use, consumption and efficiency. Irish Water’s target is an improvement in energy efficiency by 33% by 2020 from the 2009 baseline. Irish Water has entered into an energy partnership with SEAI to avail of their support, resources and expertise in meeting this target. [EN1c] Prepare and implement a Climate Change Adaptation and Mitigation Strategy Climate change impacts in Ireland are expected to include more intense rainfall events as well as periods of increased drought along with a rise in sea level. These events will impact on water services through increased risk of sewer flooding, possible inundation of treatment plants and other assets; deterioration in water quality in our rivers and lower dry weather river flows reducing the water available for abstraction or for diluting treated effluent. Adapting to climate change will require careful planning, preparation, investment and management. Our strategy will address the vulnerability of water services and associated environment (including protected sites) to climate change events and identify actions to modify our infrastructure or operations. This could include, for example, the relocation of abstractions to larger more sustainable water sources, the blending of multiple sources and the implementation of flood protection measures. 61 | Irish Water Water Services Strategic Plan - October 2015 [EN1d] Adopt a green procurement approach and drive efficient use of all of our resources. We will implement a ‘green procurement’ approach and seek to reduce and remove wastage in our investment and operations decisions. We will work to ensure all goods and services are procured in accordance with the Green Procurement Guidelines. We will adopt a low carbon approach and consider the whole life carbon cost of all new investments. We will implement annual reporting of the actions being taken to improve energy efficiency. We will consider the carbon footprint in the design of our future infrastructure and seek, through value engineering, to minimise the embodied energy of each development. Irish Water will optimise use of chemicals in our treatment processes and review the use of chemicals that have the potential to impact negatively on the environment. We will strive to support the purchase of energy-efficient products and services, where possible and applicable. We will ensure that significant new capital projects are designed and optimised for energy performance as far as possible. [EN1e] Adhere to environmental and planning legislation when planning and developing water services assets. All Irish Water projects follow a systematic process to determine the appropriate strategy, option, design and method of implementation prior to construction and operation of new assets. This approach includes extensive consultation, where appropriate, with relevant planning authorities (local authorities, regional planning agencies, An Bord Pleanála) and our regulators (the Commission for Energy Regulation and the Environmental Protection Agency) in addition to key stakeholders such as government departments, non-governmental organisations, special interest groups and the general public. All our projects are designed and developed in accordance with statutory planning processes and environmental regulations from the outset. We will comply with the statutory processes relevant to our programmes and projects, including Strategic Environmental Assessment (SEA), Environmental Impact Assessment (EIA) and Appropriate Assessment (AA) under the Habitat’s Directive, ensuring the avoidance of potential significant adverse effects on biodiversity (including protected sites), human health, water, air quality, cultural heritage (including archaeology), soil and landscape and visual amenity as a result of the upgrade to/construction of new infrastructure, including potential transboundary effects. EN2: OPERATE OUR WATER SERVICES INFRASTRUCTURE IN A MANNER THAT SUPPORTS THE ACHIEVEMENT OF WATER BODY OBJECTIVES UNDER THE WATER FRAMEWORK DIRECTIVE AND OUR OBLIGATIONS UNDER THE BIRDS AND HABITATS DIRECTIVES. [EN2a] Work effectively with other stakeholders to support a catchment based approach. We will participate in river basin management planning at an international, national and river basin level for the development and implementation of programmes of measures in relation to water services in support of the WFD. We consider that each programme of measures should be proportionate to each sector, based on the polluter pays principle, and planned over a timescale which is affordable. We will work with the EPA and other relevant stakeholders to identify ‘on-the-ground’ measures to be implemented. Our approach will focus on holistic solutions for the management of the catchment which will consider impacts from all catchment land uses including water services, tourism, agriculture and industry. We will develop, collaboratively where feasible, catchment based assessments of receiving waters, identifying the impact of our operations and other impacts on water status and assess the environmental benefit of options available to us. [EN2b] Manage the operation of our water and wastewater infrastructure towards the achievement of water body objectives and the conservation of protected sites and species. Delivery of water services, particularly the abstraction of water for supply and discharges from our wastewater and water treatment plants, directly interact with the water environment which the Water Framework Directive (WFD) seeks to protect and enhance. We will plan for the development and management (construction and operation) of our water 62 | Irish Water Water Services Strategic Plan - October 2015 supply and wastewater infrastructure taking into account the whole water cycle and will target investment to meet the agreed Programmes of Measures related to treated effluent discharges set for specific water body objectives under the WFD, prioritising the greatest environmental benefit from the funding available. As part of the Wastewater Licencing process undertaken by the EPA for all of Irish Waters discharges, an Appropriate Assessment is carried out where necessary by the Competent Authority (i.e. the EPA) to ensure that our discharges do not impact on Natura 2000 sites and their nature conservation interests (including the Freshwater Pearl Mussel). We will manage our water abstractions sustainably to minimise impact on water body status, protected habitats and species and use by other stakeholders (for example, maintaining minimum environmental and navigation flows), and in accordance with current and future legislation. We will work towards meeting the requirements of the Priority Substances Directive which sets environmental quality standards (EQS) for the specified substances (i.e. pollutant chemicals) in surface waters (river, lake, transitional and coastal) and will include for targeted monitoring and compliance (where applicable) in our detailed plans and programmes. We will target our efforts in this respect to wastewater discharges to drinking water protected areas and shellfish waters. We will, where appropriate, regulate the discharge of such priority substances to our collection systems and hence to our treatment works under our trade effluent licences. EN3: MANAGE ALL OUR RESIDUAL WASTE IN A SUSTAINABLE MANNER [EN3a] Develop and implement a Corporate Waste Management Strategy. Irish Water will develop and implement a Corporate Waste Management Policy and Plan as part of the resource efficiency element of our Sustainability Framework [Strategy EN1a]. We will manage waste generation and waste streams within the organisation to promote reduction, reuse and recycling of materials. Our plans will propose suitable transportation and disposal routes for waste and require annual reporting of the waste generated and recycled onsite with on-going targets for reduction. [EN3b] Develop and implement a National Wastewater Sludge Management Plan. Irish Water will prepare and implement a national plan to manage all wastewater sludges generated by our treatment processes and where feasible, sludges generated by septic tanks serving domestic residences.. The wastewater treatment process generates sludges which require further treatment prior to re-use or disposal. There is a deficit of sludge management facilities nationally and additional facilities are required to manage wastewater sludge. We aim to treat all wastewater sludges to meet the requirements of the DECLG Code of Practice for re-use where possible as fertilizer and soil conditioner. This requires a stable pasteurised product, complying with chemical standards for safe use in agriculture or equivalent use. Irish Water will accept wastewater sludges generated by septic tanks serving domestic residences from licenced contractors at specific sludge management facilities subject to appropriate commercial agreements. The acceptance of sludge from septic tanks will depend on suitable import facilities and spare capacity being available at the WWTP where sludge is accepted. At present there is insufficient capacity to accept all the septic tank sludge generated within Ireland. Where IW does not currently have capacity to meet the demand for accepting septic tank sludge, we will investigate the feasibility of developing this capacity on a commercial basis. Development of additional capacity for septic tank sludge would be dependent on IW having secure and sustainable outlets for all IW generated sludges in the first instance. Transport and re-use/disposal of all wastewater sludges will be managed by Irish Water to ensure compliance with our standards for treatment and disposal by registered Contractors with full traceability. This will include any imported sludge from septic tanks accepted at Irish Water facilities. Re-use in agriculture or forestry will be managed in accordance with Nutrient Management Plans to ensure compliance with nitrogen and phosphorus controls. Irish Water will work with industry to develop alternatives for the beneficial re-use of wastewater sludge and the possible recovery of energy and/or constituents in a sustainable and economically viable manner. Anaerobic digestion plants reduce the organic solids and create biogas which can be used to generate electricity for use in the treatment plants. These will be developed where feasible and economically viable. 63 | Irish Water Water Services Strategic Plan - October 2015 [EN3c] Develop and implement a National Water Treatment Plant Sludge Management Plan. Sludges are also generated from the water treatment process through the removal of colour and fine sediments from the abstracted water using chemicals. These sludges contain aluminium, ferric salts or other chemical residues from the purification process and require dewatering prior to disposal. To date the sludges have limited re-use and have principally been disposed at landfill. Irish Water will work with industry to develop alternatives for the beneficial re-use of water treatment residual sludge and the possible recovery of constituents in a sustainable and economically viable manner. Landfill disposal will continue to play a major role in managing these sludges. We will ensure that transport and disposal of these wastes are carried out in compliance with waste legislation and with least environmental impact. Indicators and Targets Indicators and targets for Irish Water to protect and enhance the environment are presented in the table below. PROTECT AND ENHANCE THE ENVIRONMENT Current End of End of Indicators Definition 2040 Target Baseline 2021 Target 2027 Target Ensure that Irish Water Services are Delivered in a Sustainable Manner which AIM EN1 contributes to the Protection of the Environment Water and % compliance of treatment ? Wastewater and disposal 96% 99% 100% 100% Residual Sludge of sludges with (Best estimate Disposal Irish Standards based on available data) % increase in overall energy Baseline 2009 33% energy Meet relevant Meet relevant Energy efficiency at efficiency targets that targets that Efficiency Irish Water improvement will be will be facilities over baseline established established (by 2020) by national by national energy policy energy policy Operate our water services infrastructure in a manner that supports the achievement AIM EN2 of water body objectives under the Water Framework Directive and our obligations under the Birds and Habitats Directives Appropriate & Effective Achieve Targets for Aim WW1 Wastewater Treatment Sustainable Achieve Targets for Aim WS3 Water Supply 64 | Irish Water Water Services Strategic Plan - October 2015 Chapter 7 Objective: Support Social and Economic Growth 65 | Irish Water Water Services Strategic Plan - October 2015 Our Strategic Aims • Support National, Regional and Local Economic and Spatial Planning Policy. • Facilitate growth in line with national and regional economic and spatial planning policy. • Ensure that water services are provided in a timely and cost effective manner. Introduction The delivery of appropriate infrastructure to meet the required demand where and when it is needed is fundamental to supporting social and economic growth. Water and wastewater capacity is an important factor in maintaining Ireland’s competitiveness for industry and commercial activity and as a destination for foreign direct investment. Water stress is an increasingly critical issue in many parts of the world, whereas Ireland has an abundance of water resources, provided we manage them appropriately. Irish Water must assess where the demands for water services are most likely to arise based on national and regional spatial planning policies and plans, together with population and economic growth predictions. We will plan to ensure continuous service to all Irish Water’s existing customers whilst providing additional capacity to meet future population growth and industrial development. Our Legal Obligations The Department of Environment, Community and Local Government (DECLG) sets policies in relation to spatial planning and economic development. The DECLG also sets policy in relation to water services and the protection of the environment. Under sections 33 and 34 of the Water Services (No. 2) Act, 2013, Irish Water must be consistent as far as is practicable with national & regional spatial planning policy and have regard to local spatial planning policy when developing strategies and planning investment in water services. These sections also require Irish Water to be consistent as far as is practicable with and take account of the River Basin Management Plans in relation to the implementation of the WFD. In addition, these sections require that Irish Water consults with its economic and environmental regulators and with regional and local planning authorities before preparing its strategic and investment plans. As per the Planning and Development Regulations, 2001 (as amended) Irish Water is a prescribed body for the purpose of the making of Regional Planning Guidelines (new Regional Spatial and Economic Strategies), county development plans, local area plans and planning schemes. Irish water is also a prescribed body for development management. The DECLG will prepare Ministerial Guidelines under section 28 of the Planning and Development Act, 2000 (as amended) to guide the engagement between Irish Water and local government at a regional and local level to ensure that water services provision is aligned with the country’s spatial planning policy. The Current Situation Some 62% of Ireland’s population currently live in urban areas, with Dublin and the Mid-East being the most urbanised regions in the country. The Greater Dublin Area is the most significant area in terms of population concentration. However, in line with the objective of the current national spatial planning policy (National Spatial Strategy, NSS) for balanced regional development, economic development and growth is promoted across all regions. The NSS identifies a settlement hierarchy strategy of gateways, hubs and other towns for focused development and growth with appropriate infrastructure services. 66 | Irish Water Water Services Strategic Plan - October 2015 In rural areas away, from these settlements, the population is dispersed resulting in a large number of water supply zones and wastewater networks serving small populations. Many rural households are served by small private individual water and wastewater systems (wells and septic tanks respectively for the most part). Private Group Water Schemes have also been developed in rural areas. These private systems (individual or group) are outside the scope of Irish Water’s remit. Population growth targets for each of the state’s 8 regions under the NSS were set by the Department of Environment, Community and Local Government (DECLG) in 2010, based on a balanced regional development policy. Each of the regional authorities subsequently set population targets to 2022 for each county within their region through their Regional Planning Guidelines (RPGs). All County Development Plans prepared since 2011 have based population growth targets for their settlement strategies on the relevant RPG. The Central Statistics Office has published population growth forecasts at a national scale to 2046 and at a regional scale to 2031 based on the results of the 2011 census. These projections indicate that the national population will grow from 4.5 million in 2011 to between 5 million and 6.7 million by 2046, depending on the growth scenario used. Growth will vary across regions, with the Dublin/Mid East region likely to experience the greatest growth and the Western and Border Regions likely to experience the least growth. These forecasts indicate that in some areas, RPG targets to 2022 are unlikely to be achieved, while in other areas, targets will be surpassed. The Department of Environment, Community and Local Government (DECLG) will be preparing a new National Planning Framework to replace the NSS in the near future and the three new regional assemblies (identified in “Putting People First ”) will subsequently prepare Regional Spatial and Economic Strategies to replace the existing RPGs by 2016. Irish Water will regularly review and update our Water Services Strategic Plan to take account of the prevailing national, regional and local spatial planning policy and demographics. Key Challenges The key challenges and uncertainties in the provision of water and wastewater services to support social and economic growth are: • Uncertainty in the rate of population (domestic) growth and changing demography. • Uncertainty in non-domestic demand, from general commercial development which usually follows domestic growth, from agriculture and from industrial development which can have significant “one-off” demands for large water and/or wastewater capacity. • Balancing investment for growth with investment priorities for compliance, security of supply and operational efficiency. • The extended timetable required for the planning and implementation of new strategic water and wastewater capacity. • Funding availability for strategic capacity provision. • Impacts of climate change and socio-economic factors on the demand for water services. • Meeting environmental compliance whilst providing for growth. What our Customers can Expect from us Our primary objective is to support population and economic growth in line with national and regional spatial planning policies and objectives. Our approach to planning and providing water services for growth will be evidence based. We will focus on utilising the capacities of our existing treatment facilities and networks to best effect while matching delivery of new capacity with realistic projections of demand based on appropriate planning horizons. We will aim to provide adequate spare capacity (headroom) in strategic level infrastructure to cater for variability in demand arising from factors such as weather and operational risk and some upward variation around projected development demand. We will seek to ensure that the standard of water services to our existing customers is maintained. 67 | Irish Water Water Services Strategic Plan - October 2015 Case Study Supporting Growth in the Greater Dublin Area Over the past decade, water supply availability Over 84% of Dublin’s water treatment capacity has regularly exceeded demand requirements is now dependent upon the River Liffey, and this in the Dublin Water Supply Zone by just 1%-2% fact illustrates the vulnerability of the service, (20% excess over seasonal peak would constitute with negligible headroom, and the need for normal best practice for a large urban area). The new long term sources in planning to manage Dublin Water Supply Zone serves 84% of the risks such as unexpected population growth population of the Greater Dublin Area (based on or migration, economic growth or risks from the 2011 Census population). climate change and pollution. There have been three significant disruption Population in the Dublin Water Supply Zone ‘events’ in the past five years which have is projected to reach 1.64m by 2021*, from highlighted how finely balanced the supply- 1.52m in the 2011, and is forecast to grow to demand position is; the exceptional water 2.15m** by 2050. (The population in the GDA demand at the time of severe cold weather in itself is projected to be 1.95m by 2021*). Despite the winter of 2010, the algal bloom experienced expected reductions in leakage and developing on the Vartry Reservoir in May of 2013, and the existing sources to their sustainable limits, operational problems experienced with raw water increasing population and economic growth chemistry at the Ballymore Eustace plant in late and security of supply will result in a need October 2013 (at the time the Web Summit was for a new source by the early 2020’s. Similar hosted in Dublin). Each of these events resulted considerations apply to wastewater capacity in supply interruptions and restrictions across provision in the Greater Dublin Area. the supply area, with negative economic and reputational impacts for the area and the country. Leixlip Water Treatment Plant on the River Liffey. Photo: Irish Water *based on the 2011 Census figures and the CSO’s “most likely growth scenario “ (Modified M2F2) identified in their Regional Population Projections ** Project Need Report (2015) for the Eastern and Midlands Region Water Supply Project 68 | Irish Water Water Services Strategic Plan Objectives and Strategies The proposed strategies to meet the above challenges and to achieve this objective are summarised in the table below and are detailed in the remaining sections of this chapter. Strategy Purpose Aim SG1 - Support National, Regional and Local Economic and Spatial Planning Policy To ensure that we plan and advise coherently on future Liaise with national, regional and local development and that our infrastructure development government bodies and potential customers strategies are consistent as far as is practicable with SG1a to anticipate and plan water services in line national and regional planning policy and plans with the statutory planning policy. and have regard to local development policy and development proposals. Aim SG2 – Facilitate growth in line with national and regional economic and spatial planning policy Maximise capacity of existing assets through SG2a effective asset management and optimised Minimise requirement for additional infrastructure. operation. To ensure water services are planned at a strategic Plan water service infrastructure at national, SG2b level and can be provided where needed in line with regional and river basin level. development plans. Invest in the development of strategic SG2c To meet projected demand for our water services. networks and treatment works. Maintain appropriate headroom in strategic SG2d To facilitate growth between investment periods. water services infrastructure. Provide a high quality customer service for To promote Irish Water as a modern utility meeting SG2e new customers. published service standards to its new customers. 69 | Irish Water Water Services Strategic Plan - October 2015 Strategy Purpose Aim SG3 - Ensure that water services are provided in a timely and cost effective manner Plan for water services infrastructure Ensure that new assets are constructed to match SG3a development to meet projected demand demand and that assets are proportionate in size to facilitating delivery on a phased basis. the short and medium term demand projections. Balance investment for growth in demand with To ensure that while water services are provided for SG3b other priorities to ensure best outcome for future growth this is done in a manner that best meets customers. the requirements of existing and new customers. Operate an equitable New Connections To ensure that the cost of connecting new Charging Policy that ensures efficient service SG3c developments to Irish Water’s networks is efficient and provision to new customers with full cost is not a burden on existing customers. recovery on a least cost basis. SG1: SUPPORT NATIONAL, REGIONAL AND LOCAL ECONOMIC AND SPATIAL PLANNING POLICY [SG1a] Work with national, regional and local bodies and potential customers to anticipate and plan for water services for growth in line with the statutory planning process. Irish Water will actively engage with national, regional and local government bodies and its economic and environmental regulators in the planning and development of our strategies for the delivery of water services and our investment plans. Our method of engagement will follow the direction of the Ministerial Guidelines to be prepared by the DECLG under section 28 of the Planning and Development Act, 2000 (as amended) and the requirements of Planning and Development Regulations 2001 (as amended). We will support a collaborative approach with national, regional and local planning bodies to promote proper planning and co-ordinated development which is environmentally and economically sustainable. Water is a valuable asset necessary for the life, wellbeing and wealth of our nation. With the creation of Irish Water, we provide a coherent national focus in the discussions regarding regional and national spatial planning and in the provision of critical national water infrastructure to underpin the economy and support growth. We are committed to fulfilling our role as a statutory consultee in the preparation of regional, county and local development plans. We will support the objectives of the Government’s strategic approach to housing identified in Construction 2020 1 and will continue our participation in the Housing Supply Co-ordination Task Force for Dublin (established by the DECLG as an action under Construction 2020). We will engage with potential new industrial and commercial customers and key stakeholders such as the IDA, Enterprise Ireland, trade representative bodies and government organisations to anticipate and deliver water services infrastructure to support industrial development and job creation. We will engage directly with all inquiries for possible development and will seek to provide accurate and timely information on the capacity and likely cost of meeting requirements for water services. We recognise the need to build confidence in our ability to cater for such development, responding efficiently to opportunity, as it arises. ¹ Construction 2020; A strategy for a renewed construction sector; May 2014; Government Publication; 2014 70 | Irish Water Water Services Strategic Plan - October 2015 SG2: FACILITATE GROWTH IN LINE WITH NATIONAL AND REGIONAL ECONOMIC AND SPATIAL PLANNING POLICY. [SG2a] Maximise capacity of existing assets through effective asset management and optimised operation. Irish Water has established an asset management approach to water services investment planning, which involves mapping and modelling our existing systems in the first instance and implementing management and operational policies to ensure that they operate effectively to their design capacity. This forms the basis on which all capacity planning is carried out, with scenarios examined which take full account of how existing assets can be utilised to their optimum and how they might be cost effectively upgraded to meet the capacity need and maintain a safe headroom. [SG2b] Plan water service infrastructure at national, regional and river basin level. We are committed to providing strategic capacity to cater for domestic demand arising from population growth and non-domestic demand associated with this growth (e.g. demand from education, hospital and commercial facilities serving these populations). The objectives of the Government’s strategic approach to housing identified in Construction 2020 must be provided for in terms of both treatment and network capacity. In addition, we are committed to facilitating the requirements of commercial and industrial development for water services on the basis of full cost recovery, based on the least cost principle (lowest cost of available options to meet the capacity need). In order to deliver on this commitment we will take a national, regional and river basin perspective on the development and management of water services to meet existing and planned for demand. Through the preparation of national implementation plans such as the National Water Resources Plan we will ensure that the strategies identified in this Water Services Strategic Plan are implemented through a programme of works and subsequently through individual projects identified in our Capital Investment Plans. In the development of the National Water Resources Plan we will target a rationalised approach towards fewer schemes based on larger and more sustainable sources to provide reliability of service, network resilience and value for money to our customers. Our objective is to optimise the resources available to us, including consideration of sustainable catchment transfers, where necessary, for adequacy and security of service. Our Wastewater Compliance Strategy will focus on ensuring that wastewater treatment is provided where and when it is required and that our treatment plants achieve compliance with the requirements of the Urban Wastewater Treatment Directive and support the achievement of the quality objectives of the Water Framework Directive on a prioritised phased basis. Where investment in infrastructure is necessary in order to achieve water quality standards and wastewater compliance, we will include additional capacity to meet future planned demand where there is evidence that this demand is likely to be realised. [SG2c] Invest in the development of strategic networks and treatment works. We will adopt a strategic planning perspective in respect of the delivery of strategic infrastructure. Strategic water and wastewater service plans will be prepared to quantify existing asset capacity and utilisation and assess how future demands will impact on our assets. This assessment will be completed under various growth scenarios, based on development plan projections. The scenarios will include short, medium and long term growth horizons. Appropriate design solution options to address these impacts will be generated, evaluated and costed, based on asset management principles. A key element will be active engagement with planning authorities at an early stage in their planning process to facilitate appropriate consideration of water services and, in particular, to ensure awareness of water service related constraints that might impact on size, scale, cost and location of proposed development centres, including environmental impact. 71 | Irish Water Water Services Strategic Plan - October 2015 [SG2d] Maintain appropriate headroom in strategic water services infrastructure. A key element of Irish Water’s strategy for meeting demand is the maintenance of an acceptable level of headroom (available capacity over current demand) in our systems to allow for growth potential and capacity risks. This is a key parameter in managing risks to service and takes account of the likelihood and consequences of failure from scheme to scheme. Once this headroom falls below the specified level, it acts as a trigger to provide a further increment of capacity. Many water supply schemes currently have insufficient headroom to provide an acceptable protection against occasional loss of supply. For example, the Greater Dublin Area has regularly operated historically at headroom levels of 1-2%. Appropriate and timely investments are required to keep capacity abreast of demand and to maintain headroom for security of supply. The capacity of most systems can be increased by extending existing treatment works and upsizing key pipelines and pumping stations. It is our long-term objective to provide for and maintain capacity headroom based on the size of the of the settlement served, the economic and social impact of failure and likely growth potential in line with the settlement hierarchy identified in the NSS and its successors as follows: • Large urban settlements (Dublin, Cork, Limerick/Shannon, Galway and Waterford); 20% headroom. • Regional Gateways; (Dundalk, Sligo, Letterkenny/Derry and Athlone/Tullamore/ Mullingar); 15% headroom. • Other towns; 10% headroom. If new industries require large one-off demands, then this would be provided for by utilising available reserves coupled with upsizing of treatment plants and networks to restore system capacity. The actual cost incurred in restoring the headroom would be recovered in full from that industry in accordance with provisions of our New Connections Charging Policy. For water and wastewater networks we will develop hydraulic models to enable us to establish available capacity for growth and existing deficiencies. We will prepare strategic network development plans e.g. drainage area plans on phased basis for larger settlements which will set out how we will address existing deficiencies in capacity and cater for anticipated future growth. Growth provision will align with the prevailing “core strategies” in local authority development plans. We commit to a long term objective to maintain and publish a treatment headroom capacity register on an on-going basis. [SG2e] Provide a high quality customer service for new customers. Irish Water will provide a high quality service to new customers through our Connections and Developer Services Team which will have representatives located in each of our regional offices. Our team will consult with the developer/new customer to provide a detailed connection offer and will sign a connection agreement with the customer should the offer be acceptable. We will provide a clear set of design standards for water services infrastructure which must be implemented by the developer and inspected by Irish Water, where not directly provided by our contractors under the agreement, prior to any connection taking place. Where we receive requests for connections from beyond our networks for existing developments served by private treatment facilities (for example ribbon development served by septic tanks) we will consider these with the CER based on the costs of service and the willingness of the property owners to sign development agreements and meet the costs involved. We will work with Group Sewerage Schemes to avail of grant support from the DECLG Rural Water Programme where relevant and will cooperate in ‘Taking in Charge’ connections infrastructure constructed to our requirements and meeting all prescribed tests on completion. SG3: ENSURE THAT WATER SERVICES ARE PROVIDED IN A TIMELY AND COST EFFECTIVE MANNER [SG3a] Plan for water services infrastructure development to meet projected demand facilitating delivery on a phased basis. All Irish Water’s assets are targeted to provide an appropriate return on investment to ensure that charges to our customer base are kept as low as possible. A balanced and timely approach to meeting existing and emerging demands is required to ensure that investment is not wasted on the development of premature and oversized water services. This requires that our forward planning is comprehensive and based on accurate knowledge of our system capacity across all of our schemes. 72 | Irish Water Water Services Strategic Plan - October 2015 When planning strategic infrastructure we must take an appropriate view of the cost of future upsizing of major infrastructure. Therefore, when planning for certain “one-off” infrastructure such as long distance pipelines, outfalls or strategic crossings (rail, motorway) we will take a long term view of likely future demands based on the fact that its future upsizing is not practical or economical. Where possible, Irish Water will develop infrastructure assets, including critical national infrastructure, according to the following principles: • We will develop water services demand forecasts taking cognisance of population/growth projections and national spatial and economic planning policies. Some large scale assets, which are ‘one off’ in nature, will be delivered on the basis of long term growth forecasts. • We will review headroom in strategic infrastructure on a regular basis and consider upgrading the infrastructure if capacity has fallen below the target headroom for that facility. We will include a planned upgrade of the facility in our next Capital Investment Plan to cater for a projected growth for 5-10 years from the planned completion date of the upgrade. • Treatment plants and major pumping facilities will be planned based on a modular design and a phased approach to construction. Capacity for growth would be added in time to support development. This has the benefit that our capital is used to best advantage and provides better value for money to our customers. The land requirement to accommodate the ultimate capacity of the plant will be considered such that land availability will not compromise the development of the plant to full capacity. • New major pipelines need to be of sufficient size (diameter) so that they do not require to be augmented in the short to medium term. • Outfalls from treatment plants and combined sewer overflows may be required to be constructed on a ‘one-off’ basis, similar to major pipelines. • Crossings of major infrastructure, such as motorways, railways, or canals may also be sized for long term capacity, to avoid repeated and socially expensive disruption. • We will work with local authorities, local development groups and private investors to ensure that smaller towns and villages are appropriately supported by water services infrastructure in line with: • Planned demand; • Identification of funding sources; • Selection of appropriate technical solutions; and • Growth opportunities in towns and villages on a cluster basis. [SG3b] Balance investment for growth in demand with other priorities to ensure best outcome for customers. Irish Water faces many challenges in providing an appropriate level of water services to our customers, in achieving compliance with statutory standards and legislation and in facilitating growth while ensuring that our services are provided in an efficient and economic manner to existing and new customers. We are required to operate in a commercially viable and environmentally responsible manner and must take this into consideration when considering priorities for investment. As a national body we have the opportunity to align our capital investment in a national context and to balance our investment priorities to ensure the best outcome for our existing customers while facilitating future growth as far as is practicable. To achieve this balance we will engage with the EPA and CER to create alignment and agree priorities which support national planning policy and provide best outcomes for our customers. 73 | Irish Water Water Services Strategic Plan - October 2015 [SG3c] Operate an equitable New Connections Charging Policy that ensures efficient service provision to new customers with full cost recovery. Prior to the establishment of Irish Water, each local authority set their own connection charging policy in terms of a Connection Fee and Planning Levies. Irish Water will operate a New Connection Charging Policy at a national level which clearly sets out our charges for all new customers based on full recovery of the cost to Irish Water of connecting customers to a public water/wastewater system. Our New Connection Charging Policy will be fully approved by the CER and we expect a uniform approach across the country. Irish Water will work to ensure, through our New Connection Charging Policy and our investment plans, that the cost of developing water services and connecting to the Irish Water network is equitably apportioned between new and existing customers. Indicators and Targets Indicators and targets for the objective to support social and economic growth are presented in the table below. Primary SUPPORT SOCIAL AND ECONOMIC GROWTH Objective Current End of End of Indicators Definition 2040 Target Baseline 2021 Target 2027 Target AIM SG2 Facilitate Growth in line with National and Regional Economic and Spatial Planning Policy % of treatment plants with 20% capacity Availability of Headroom at headroom in ? large urban Water & areas, 15% Establish a 60% of plants 75% of plants 100% of plants Wastewater headroom in register of meet headroom meet headroom meet target Treatment Regional current available target target Plants to meet Gateway Towns, headroom Core Strategies 10% headroom against required at all other headroom by plants 2016. Availability of Establish a Have hydraulic Have hydraulic Have hydraulic Capacity in hydraulic register of models and models and models and Strategic models and strategic strategic strategic strategic Networks to strategic networks and network network network Support network current development development development Growth development availability of plans for large plans for plans for plans hydraulic models urban areas & settlements > settlements > for water and Gateway Towns 2000 population 2000 population wastewater networks by 2016 74 | Irish Water Water Services Strategic Plan - October 2015 Chapter 8 Objective: Invest in Our Future 75 | Irish Water Water Services Strategic Plan - October 2015 Our Strategic Aims • Manage our assets and investments in accordance with best practice asset management principles to deliver a high quality secure and sustainable service at lowest cost. • Invest in our assets while maintaining a sustainable balance between meeting customer standards, protecting the environment and supporting the economic development and growth of the country. • Establish a sustainable funding model to ensure that Irish Water can deliver the required capital investment in order to achieve the required outcomes. • Promote research and proven, innovative technical solutions to meet standards set by our regulators including our objectives for cost and energy efficiency. The Current Situation An historic under-investment in our water and wastewater networks and treatment facilities means that we now have to secure significantly increased levels of funding in order to achieve adequate standards of drinking water and wastewater compliance, to provide for renewal of assets and to support the growth of the country. A particular challenge is the lack of knowledge of the condition and risk of failure of critical assets in the system. Examples of such assets which pose a threat to service reliability and standards are: • Nineteenth century water treatment plants such as those at Roundwood (Vartry) and Cork City (Lee Road) where the original assets remain in service. • Strategic water supply pipelines in cast iron, asbestos cement and concrete construction are in service beyond the normal design life and critical to customer service. • Combined sewers in large urban centres of brick or masonry construction are known to be leaking, admitting fresh and salt water ingress, and structurally unsound (for example, Limerick and Cork City centre sewers). Irish Water has been established as a customer focussed and asset management driven organisation, in line with best international practice in the water utility sector. In developing its capability, a key focus is an asset management approach to provide a radical transformation in the water services planning and delivery model in Ireland. On the basis of a sustainable funding model, Irish Water will target the necessary levels of investment to secure the condition of our critical assets to enable the required standard of quality and reliability in water services for our customers and the national economy. An informed evidence based approach to asset management will deliver the benefits of this investment, at lowest cost. 76 | Irish Water Water Services Strategic Plan - October 2015 Key Challenges Our key challenges are: • Overcoming a deficit in knowledge of our assets location, condition, performance and life expectancy. • Implementing an asset management strategy, with a detailed asset register and clearly defined critical assets. • Investing in fixing current issues with water supply and wastewater service, targeting minor capital and improved operating programmes to overcome shortfalls and remove risks. • Engaging with our customers, regulators and other stakeholders to ensure there is a sustainable balance between the interests of our customers, the environment and the need to support the economic development and growth of the country. • Establishing a sustainable funding model to ensure that Irish Water can deliver the required capital investment in order to achieve the required outcomes for our customers, the environment and the national economy. • Implementation of innovation, research and development in support of better asset performance and least costs new infrastructure. Worker on Gantry. Photo: Maurice O’Connell What our Customers Can Expect from Us In the future, our customers can expect us to manage and obtain the best value from our existing assets and to deliver our commitments to safe water supply, environmental compliance, resilient capacity and energy efficiency. We will utilise best international practice in the delivery of our water and wastewater services, applying innovative and state of the art solutions to upgrade our assets and provide new infrastructure where these have been proven to deliver. 77 | Irish Water Water Services Strategic Plan - October 2015 Objectives and Strategies The proposed strategies to meet the above challenges and achieve this objective are summarised in the table below and are detailed in the remaining sections of this chapter. Strategy Purpose IF1 – Asset Management - Manage our assets and investments in accordance with best practice asset management principles to deliver a high quality secure and sustainable service at lowest cost. To enable the optimisation of asset performance Implement asset management systems through the optimum balance of operational, IF1a including comprehensive asset data collection maintenance and capital investment for delivery of and modelling tools. services at lowest long term costs. To deliver operational cost efficiencies, meet capacity Develop long term asset strategies and and performance needs and improve system IF1b implementation plans (Tier 2). resilience, through rationalisation and strategic forward planning. Development of initiatives such as asset To deliver continuous improvement in value for money IF1c standards and improved supply chain and reduce the cost of future investment to customers management. from standardisation of approach. IF2 – Balanced Sustainable Investment - Invest in our assets while maintaining a sustainable balance between meeting customer standards, protecting the environment and supporting the economic development and growth of the country. Engage with our customers, including To develop a balanced picture of customer concerns, IF2a households, commercial and industrial issues and priorities to inform our strategy and deliver customers. optimal outcomes which meet customer needs. Engage collaboratively with key stakeholders To achieve optimum investment outcomes for IF2b including CER, EPA, DECLG, HSE, regional and customers, the environment and the national economy local authorities. which satisfy national policy and growth projections. To ensure an appropriate balance between the Apply clear and transparent investment IF2c interests of our customers, the environment and the prioritisation criteria. need to support balanced regional development. 78 | Irish Water Water Services Strategic Plan - October 2015 Strategy Purpose IF3 - Sustainable Funding Model - Establish a sustainable funding model to ensure that Irish Water can deliver the required capital investment in order to achieve the required outcomes. Transform the water industry in Ireland to an To deliver a sustainable funding model including off IF3a efficient water utility model within a regulated balance sheet funding as required, while achieving framework. efficient capital and operational delivery. Work with regulators to achieve optimum To ensure that funding and investment plans deliver IF3b balance of cost and service standards taking the best possible outcomes taking account of cost to into account regulatory requirements. customers and the state as a key issue. To raise public awareness of the value of water Deliver on Irish Water’s commitments to raise resources and the benefits to customers, the IF3c public awareness of the value of water and environment and the national economy which Irish achievements delivered. Water delivers. IF4 - Research and Innovation - Promote research and proven, innovative technical solutions to meet standards set by our regulators including our objectives for cost and energy efficiency. Actively pursue research and development To adopt new technologies and innovation which will IF4a in water services and track opportunities to improve quality of service and/or reduce cost and develop and adopt new technologies. carbon footprint. To ensure that opportunities for innovation through Engage effectively with universities, Institutes IF4b existing and on-going research and development are of Further Education, colleges and industry. fully exploited. Develop knowledge management capability IF4c To maximise the benefits from innovative solutions. and implementation processes. 79 | Irish Water Water Services Strategic Plan - October 2015 IF1: ASSET MANAGEMENT - Manage our assets and investments in accordance with best practice asset management principles to deliver a high quality, secure and sustainable service at lowest cost. [IF1a] Implement Asset Management Systems including comprehensive asset data collection and modelling tools. Asset management is the internationally accepted basis for cost effective management of extensive and spatially distributed assets in order to deliver a consistent and adequate level of service to all connected customers. Asset management is based on robust and reliable information on infrastructure which is vital to inform critical maintenance and future investment plans and to target improvements where they are most needed. Irish Water has developed a national spatially referenced asset database in GIS format drawing together, for the first time, all available records from each of the 31 local authorities. To bring this knowledge up to the level required for asset planning and modelling, and combine this into consistent, accurate databases, we commenced a national asset data gathering and asset condition exercise in 2014 which is to be completed by 2018. In addition, the asset management function will develop consistent standards, specifications, operation and maintenance programmes to manage the asset base. This has commenced with review of relevant international practise documents from high performing water companies, which are being adapted for Irish application. We are similarly developing the technologies required for remote monitoring of critical plants and network service indicators in order to support operating staff and response to incidents. We are seeking to implement a strategy that optimises the life of our assets; balancing capital investment with maintenance and operation of the assets and thereby improving the life and safety of the assets and reducing performance risk. [IF1b] Develop long term asset strategies and implementation plans (Tier 2 plans). In order to deliver on the objectives of this WSSP, Irish Water will develop a series of implementation plans defining the programmes of work to be implemented. These plans will develop the range of scenarios and options from which the optimum approaches and prioritisation will be determined. The plans will take full account of the asset standards and policies adopted by Irish Water in shaping the strategic solutions. Where required, the plans will be subjected to Strategic Environmental Assessment and Appropriate Assessment, including public consultation. The plans will include: • National Water Resources Plan, to assess present and future needs and resources at a regional level, taking account of resource constraints, and including sustainable inter-catchment or inter-regional transfers where required for secure resilient water supplies. • Wastewater Compliance Plan, to determine the optimum strategies towards meeting compliance with license requirements while catering for future needs. • National Wastewater Treatment Sludge Management Plan to define the optimum strategy for the re-use of sewage sludge, recovery of energy and disposal of waste residues. • National Water Treatment Sludge Management Plan to develop an optimum national approach to water treatment process sludge disposal, in a sustainable cost effective manner. All of these Implementation Plans (Tier 2) will require collection of relevant data, consideration of all relevant EU and National standards and policies, development of models and consideration of all technical, environmental and economic parameters. [IF1c] Development of initiatives such as asset standards and improved supply chain management. Asset standards are the technical standards used in the design and operation of water and wastewater infrastructure, which aim to ensure that the best solutions are adopted for new assets. 80 | Irish Water Water Services Strategic Plan - October 2015 Case Study Asset Management Irish Water is responsible for operation and Irish Water has developed an assets register maintenance of several hundred thousand down to individual component level, against individual mechanical and electrical pieces of which individual standards will be put in place. equipment across around 7,000 sites required Our immediate priority is the identification to deliver water and wastewater services. of Critical Assets, being those assets whose Best practice asset management involves the failure would give rise to high customer impact care and maintenance of the assets based on on a large scale. The priority is to address comprehensive asset data so that the best value the condition and likelihood of failure and its is obtained from the assets and water services consequences. Investment plans must address are delivered at least cost. the management of these key risks. Water Supply Pumping Station: Photo: Maurice O’Connell 81 | Irish Water Water Services Strategic Plan We will develop and adopt a single set of national asset standards that will be periodically updated to reflect new innovative technology and changes in legislation. The benefits of having Irish Water asset standards will include standardisation, the selection of optimum solutions for new investment, reduced design costs and lower maintenance costs. Irish Water has established central procurement for all goods and services required in the operation and investment in the services. We will use our national buying power to procure goods and services, standardising what we buy and ensuring that our supply chain is aligned to our requirements, particularly our adopted standards for quality, reliability and energy efficiency. We will procure goods and services in the competitive market place based on international best practice complying with procurement legislation. We will purchase goods and services using frameworks (longer term relationships), call off contracts (purchasing one item at a time) or discrete one off contracts where it is commercially beneficial to do so. IF2: BALANCED SUSTAINABLE INVESTMENT - Invest in our assets while maintaining a sustainable balance between meeting customer standards, protecting the environment and supporting the economic development and growth of the country. [IF2a] Engage with our customers, including households, commercial and industrial customers. We will consult regularly with our customers and stakeholders and provide information so that all interested parties will be informed of our activities. As we develop our strategies and plans, these will be subject to consultation as appropriate, including the preparation of Strategic Environmental Assessments and Appropriate Assessments as required. Our approach to investment in infrastructure, operations and maintenance, will be directed to achieving our key objectives which are based on delivery of services to our customers. We will engage with our customers to outline the issues, explain the options and ascertain feedback and input to assist us to determine preferences. [IF2b] Engage collaboratively with key stakeholders including CER, EPA, DECLG, HSE, regional and local authorities. Our operations are regulated by both CER for economic matters and the EPA for environmental matters and water quality standards. We will liaise closely with the DECLG in relation to matters of national policy and with the Health Service Executive (HSE) in regard to public health issues. Other key statutory consultees will include the National Parks and Wildlife Service, the regional and local authorities, IDA and the Health and Safety Authority (HSA). Consultation with special interest groups and the general public will be undertaken where they are affected. [IF2c] Apply clear and transparent investment prioritisation criteria. When the level of available funding is less than the investment needed, then prioritisation criteria are required to decide which capital projects can proceed and which must be deferred until funding becomes available. We will develop clear and transparent prioritisation criteria for agreement with CER, EPA and DECLG. This should ensure that the best outcomes are delivered for our customers, the environment and the national economy. IF3: SUSTAINABLE FUNDING MODEL - Establish a sustainable funding model to ensure that Irish Water can deliver the required capital investment in order to achieve the required outcomes. [IF3a] Transform the water industry in Ireland based on an efficient water utility model within a regulated framework There has been a significant under-investment in water services infrastructure in Ireland over many decades which has resulted in current problems with water quality and reliability, high levels of leakage and below standard wastewater management across many parts of the country. From the first National Public Health Acts in 1878, to the setup of Irish 82 | Irish Water Water Services Strategic Plan - October 2015 Water, the responsibility for water services rested with Ireland’s local authorities. In that period, the requirements evolved from a low technology, labour intensive enterprise to a modern, high technology industry. The need for a national approach with central and regional structures is evident from: • The need for an integrated national set of asset data, technical models and development strategies on which all operational and investment decisions can be based. • The need to integrate capital and operational investment decision making within an asset management framework, supported by high technology analytical systems to ensure the best service outcomes at the least cost. • Developing the required technical competencies and specialisations (e.g. asset planning, process control, leakage reduction, trade discharge control, new connections and energy management) by combining local resources at central and regional sites. • Delivering economies of scale by combining procurement of both goods and services and capital delivery. We expect that this approach will enable much more effective performance in areas such as leakage reduction and energy management. • Achieving better outcomes from existing assets by introducing standard ways of working and maintaining assets and resolving customer problems. • Using detailed workflow data (capturing all operational activity onto the asset database) to transition from reactive maintenance (in response to failure) towards greater planned maintenance, which ultimately greatly reduces asset risk and therefore improves outcomes. • Deliver maximum savings in operation based on the best balance of staffing, technologies and asset maintenance, assuming that the critical investment needs are provided and the organisational transformation is completed. To address the acknowledged infrastructure deficit, capital investment of around €600M per year will be required for a sustained period, probably several decades. One of the main elements of the Government’s Water Sector Reform Programme was the establishment of a sustainable funding model which would enable this necessary capital investment to be put in place over the coming years. The main components included the establishment of Irish Water as an independent state-owned water utility, the introduction of a sustainable funding model including domestic water charges and independent regulation of water services by the CER. Irish Water is committed to continuing to work with the local authorities under the Service Level Agreements (SLA’s) to continue the industry transformation, including regional shared working across county boundaries and implementation of those initiatives required for service improvement and cost reduction. Because of the very high levels of investment required in water services infrastructure and also the significant constraints on Government borrowing, the Water Sector Reform Programme had at its core a sustainable funding model whereby Irish Water would be able to raise finance in its own capacity. In order for Irish Water to be able to raise significant finance at favourable interest rates, it will be necessary for Irish Water to demonstrate that it is an efficient water utility company operating within a stable regulatory framework with secure revenue streams. It is a core objective of Irish Water to deliver continuous improvement in water services delivery combined with cost efficiency to match international benchmark levels when the necessary structural reforms supported by investment in systems are in place. This should facilitate raising finance at favourable rates while ensuring that the overall cost is minimised. [IF3b] Work with regulators to achieve optimum balance of cost and service standards taking into account regulatory requirements For Irish Water’s investment plans to be sustainable they must be efficiently delivered at the least cost of service on a whole life basis. This consideration has to be balanced with ensuring sufficient funding to deliver the service levels required, taking account of the state of the assets and the committed costs inherited from the local authorities. To this end, Irish Water will work closely and collaboratively with our regulators, CER and EPA, to agree priorities for the available funds to enable us to deliver the best possible outcomes in terms of drinking water quality, water services reliability, environmental protection and provision for growth. [IF3c] Deliver on Irish Water’s commitments to customers and the country and raise public awareness of the value of water and achievements delivered. Ireland’s plentiful water resources are one of our most valuable national assets which provide tremendous economic, environmental and amenity value to our citizens and visitors. This natural resource, provided it is effectively managed, 83 | Irish Water Water Services Strategic Plan - October 2015 can also give us a significant advantage as we compete internationally for investment and job creation particularly in water dependant sectors of the economy. Provision of safe, secure drinking water and effective wastewater management and treatment involves complex processes and requires significant investment in capital works as well as operation and maintenance. For a modern water utility, this requires the use of modern technologies in treatment, network management and energy efficiency. It also requires an asset management capability driving workflow activity, tracking outcomes and targeting all investments with the benefit of full asset data supporting decision making. It is an objective of Irish Water to achieve public awareness of the value of water and the complexity of water services delivery. This will identify, over time, the benefits which Irish Water delivers in terms of drinking water safety and security, environmental protection and support for economic growth and development. This requires a secure revenue stream from customers which will in turn support the sustainable funding model to deliver the required levels of investment in our water services infrastructure. IF4: RESEARCH AND INNOVATION - Promote research and proven, innovative technical solutions to meet standards set by our regulators including our objectives for cost and energy efficiency. [IF4a] Actively pursue research and development in water services and track opportunities to develop and adopt new technologies. Innovation in the provision of water services will be integral to delivering benefits in efficiency, customer service and water and environmental quality. This will enable the application of the most appropriate and sustainable solutions, drawing on best international practice and the required automation and instrumentation for central monitoring and control of asset condition and performance. In addition to constant review of international practice, we will support local research and development to achieve the best outcomes for our customers and the environment. We will pursue innovation in three ways: • Collaboration with government organisations, academic institutions and other organisations to pursue research and innovation opportunities in solving technical challenges; • Research and pilot innovative technologies, processes and systems for local application to meet specific quality needs and deliver cost effectiveness; and • Collaboration with other water utilities and become a “fast follower” (i.e. learn best practices). We will investigate alternative and innovative solutions in relation to both new projects and for the upgrading of existing plants and networks. Investment decisions will be based on solutions that provide the lowest whole life cost whilst also meeting our energy and carbon commitments. [IF4b] Engage effectively with universities, Institutes of Further Education, colleges and industry. We intend to engage actively with universities, colleges and industry to ensure that new technologies and innovative techniques are given due consideration on all our projects. We will work to achieve enduring relationships with the universities and technical colleges around shared objectives. Innovation developed by industry for water services both here in Ireland and internationally can accelerate efficiencies in the delivery of our water services. Examples of this might be improvements to pump design resulting in energy efficiency, development of new wastewater treatment techniques or the reuse of chemicals to reduce our use of resources. We will work to ensure that our procurement approach is open to proven innovative options. 84 | Irish Water Water Services Strategic Plan - October 2015 Case Study Ringsend Wastewater Treatment Plant The Ringsend Wastewater Treatment Works Expansion and upgrading of the Ringsend was designed for a capacity of 1.64 million Wastewater Treatment Plant is an urgent priority Population Equivalent (PE) but is now operating for Irish Water and a revision to the approved just slightly over that capacity. To cater for the scheme to achieve required outcomes at least existing load and accommodate growth in the cost is currently being evaluated in partnership region, it is necessary to upgrade and expand with Dublin City Council. Irish Water is proposing the treatment works to its maximum capacity, an innovative wastewater treatment technology which is estimated to be c. 2.1 million PE. The for the upgrade and this innovative solution proposed upgrade must also achieve improved can result in a higher treatment standard to the treated effluent quality in terms of nitrogen and benefit of Dublin Bay and a cost saving of €170 phosphorus standards in order to conserve good million compared to previous project proposals. water quality in the Liffey Estuary and Dublin Any proposed revisions to the approved scheme Bay, based on their current designations. A will be subject to environmental/planning scheme to expand and upgrade the treatment approvals as appropriate. works has been approved by An Bord Pleanála. Ringsend Wastewater Treatment Plant and Power Station. Photo: Irish Water 85 | Irish Water Water Services Strategic Plan [IF4c] Develop knowledge management capability and implementation processes. Knowledge management is the process of capturing, developing, sharing, and effectively using organisational knowledge. It refers to a multi-disciplined approach to achieving organisational objectives by making the best use of knowledge by all parts of the organisation, including the local authority staff working under the SLAs. The management and sharing of the combined knowledge and expertise within Irish Water and the local authorities is a key objective that will lead to improved performance, innovation, the sharing of lessons learned, integration and continuous improvement of the delivery of water services. The use of knowledge management within Irish Water will mean that the benefits from innovative solutions will be adopted across the country and this will generate efficiencies and value for water customers. Indicators and Targets Indicators and targets for this Objective to Invest in Our Future are presented in the graphic below. Primary INVEST IN OUR FUTURE Objective Current End of End of Indicators Definition 2040 Target Baseline 2021 Target 2027 Target AIM IF2 Balanced Sustainable Investment Capital ? Investment Establish 100% Delivery Deliver IW Deliver IW Outcomes Plans delivered baseline of Outcomes objectives objectives of Capital (on time and conditions of identified in through through Investment within budget) critical assets Capital balanced balanced Plans within the by 2018 Investment Plan investment at investment at investment 2017 - 2021 least cost within least cost within period as agreed with approved approved the CER funding model funding model AIM IF3 Sustainable Funding Model ? Meet CER’s Develop Best Meet 100% Meet 100% Meet 100% Operational requirements Practice Asset of the of the of the and Capital for operational Management requirements requirements requirements Efficiency and capital Principles and identified by identified by identified by efficiency Systems CER with respect CER with respect CER with respect to operational to operational to operational and capital and capital and capital efficiency efficiency efficiency 86 | Irish Water Water Services Strategic Plan - October 2015 Glossary and Abbreviations Children on Beach Photo: Sinead McGinley 87 | Irish Water Water Services Strategic Plan Glossary and Abbreviations Abbreviations CER Commission for Energy Regulation DECLG Department of Environment, Community and Local Government EPA Environmental Protection Agency RBMPs River Basin Management Plans RBD River Basin District UWWTD Urban Wastewater Treatment Directive WFD Water Framework Directive WSZ Water Supply Zone 88 | Irish Water Water Services Strategic Plan - October 2015 Glossary Abstraction The removal of water from a river, lake or groundwater usually with the use of a pump. An urban settlement (village, town or city area) which is connected through a pipe network Agglomeration to a wastewater treatment plant. Agglomeration areas are defined on maps and used to plan wastewater services infrastructure. Infrastructure (e.g. buildings, treatment plants) and equipment (e.g. pumps, screens, treatment units, disinfection systems and control panels) controlled and operated by Irish Asset water to deliver water and wastewater services. We divide these into Below Ground Assets such as pipework and valves and Above Ground Assets such as treatment plants. A vertically drilled hole into the subsoils and/or bedrock which is used to monitor or Borehole abstract groundwater. A borehole is usually lined with a casing and/or screen to prevent it from collapse. Biodiversity The variety of all living things. The area of land where surface water from rainfall converges to a single point at a lower Catchment elevation, usually a point in a river, lake or an estuary. The catchment includes all drainage channels, tributaries (smaller streams) and floodplains. Catchment Boundary or The topographic line defining the catchment. Watershed Treated effluent from a wastewater treatment plant which is returned to the water Discharge environment. This is usually from a pipe and outflow structure into a river or the sea. Drinking Water European Union (Drinking Water) Regulations 2014 - S.I. No. 122 of 2014. Regulations A legal act of the European Union which requires member states to achieve a particular European Directive result. Examples are the Drinking Water Directive, Urban Wastewater Treatment Directive and the Water Framework Directive. Water located beneath the ground surface in soil and rock pore spaces and fractures within Groundwater rock formations. Spare capacity in water and wastewater infrastructure (treatment plants and networks) to Headroom cope with adverse weather conditions or unplanned incidents such as a break in a trunk main or equipment failures at a treatment plant. 89 | Irish Water Water Services Strategic Plan - October 2015 Glossary The interconnection of pipes and pumping stations used for the distribution of treated Network water and the collection of wastewater. Plumbosolvency The ability of water to dissolve lead into water supplies from lead pipes. Wastewater treatment plants are described in terms of their designed treatment capacity, which is generally expressed as population equivalents (PE). This is a measurement of total organic biodegradable load, including industrial, Population institutional, commercial and domestic organic load, on a wastewater treatment plant, Equivalent (PE) converted to the equivalent number of population equivalents (PE). One person is considered to generate 60g of BOD per day (BOD is the 5 day biochemical oxygen demand); and 1 PE is defined as being equivalent to 60g of BOD per day. Raw Water Water abstracted for drinking water purposes before treatment. Regional Planning Guidelines (RPGs) are policy documents which aim to direct the future growth of a region over the medium to long term. They appraise the critical elements involved in ensuring sustainable and good planning in the right places, and though the protection of sensitive or environmentally important locations. The Guidelines inform and direct the City and County Development Plans of each of the Councils. The Planning and Regional Planning Development Act, 2000 (as amended) requires that all Regional Authorities shall at the Guidelines direction of the Minister make Regional Planning Guidelines. Eight Regional Authorities were set up in 1994 under the Local Government Act 1991 (Regional Authorities) Establishment Order 1993. However, the 8 Regional Authorities have been reconfigured to 3 Regional Assemblies under the Local Government Reform Act, 2014 and the RPGs will be replaced by Regional Spatial and Economic Strategies to be published in 2016. The ability of a system (e.g. water supply zone or wastewater network) to cope with change or stress. In a water services context stress to the system or network could result from Resilience increased demand, partial failure of operating plant, climate change or local contamination of water sources. A group of catchments which are defined within River Basin Management Plans prepared River Basin District under the Water Framework Directive. River Basin A plan for a group of catchments which contains a range of measures (proposals) aims at Management Plans protecting and improving the use of the water environment. Standard Operating Detailed, written instructions and rules for managing and operating assets. Procedures 90 | Irish Water Water Services Strategic Plan - October 2015 Glossary The level of leakage from underground pipes where it becomes economically and Sustainable environmentally unsustainable to invest in further reductions in leakage. The cost Economic Level of (financially and environmentally) to fix the leakage is greater than the cost of water being Leakage lost. A defined section of river, lake or groundwater identified in the water body characterisation Water Body of the River Basin Management Plans developed under the Water Framework Directive. Environmental objectives set for each water body assessed within the River Basin Water Body Management Plans. The objectives could relate to achieving Good Status for the water Objectives body (requiring improvements to water quality, ecology, channelisation or other factors) or to no deterioration in status. The area supplied by an individual water supply scheme. This typically includes one or more abstractions (from a river, lake or groundwater), a treatment plant, storage in Water Supply Zone reservoirs and the distribution pipe network to deliver the water to each household or business. 91 | Irish Water Water Services Strategic Plan - October 2015 Appendix 1 - EPA Remedial Action List (2013) WATER SUPPLY Local Authority Name of Water Supply Scheme Code

1. Cavan Co.Co Kingscourt 0200PUB1015

2. Cork (West) Co.Co Castletownbere New 0500PUB4205

3. Cork (West) Co.Co Drimoleague 0500PUB4103

4. Cork (West) Co.Co Kealkill 0500PUB4105

5. Cork (West) Co.Co Schull 050PUB4503

6. Cork City Co. Cork City Water Supply 0400PUB1001

7. Donegal Co.Co Cashilard 0600PUB1106

8. Donegal Co.Co Cresslough 0600PUB1075

9. Donegal Co.Co Fintown 0600PUB1065

10. Donegal Co.Co Glenties-Ardara 0600PUB1070

11. Donegal Co.Co Gortahork-Falcarragh 0600PUB1059

12. Donegal Co.Co Greencastle 0600PUB1015

13. Donegal Co.Co Owenteskna/Kilcar 0600PUB1091

14. Donegal Co.Co Letterkenny 0600PUB1110

15. Donegal Co.Co Portnoo-Narin 0600PUB1068

16. Donegal Co.Co Rathmullen 0600PUB1053

17. Dublin City Co. Ballyboden 0700PUB1002 Ballymore Eustace-Leixlip & Vartry/Ballymore

18. Dublin City Co. 0700PUB1006 Eustace

19. Dublin City Co. Vartry-Ballymore Eustace 0700PUB1007 Dunlaoighre Rathdown

20. Stillorgan 1000PUB1001 Co.Co Dunlaoighre Rathdown

21. Roundwood 1000PUB1006 Co.Co Dunlaoighre Rathdown

22. Church Road 1000PUB1007 Co.Co 92 | Irish Water Water Services Strategic Plan - October 2015 Appendix 1 - EPA Remedial Action List (2013) WATER SUPPLY continued Local Authority Name of Water Supply Scheme Code

23. Galway Co.Co Ballinasloe Rwss 1200PUB1004 24.. Galway Co.Co Ballyconneely P.S 1200PUB1005

25. Galway Co.Co Carraroe PWS 1200PUB1009

26. Galway Co.Co Glenamaddy 1200PUB1021

27. Galway Co.Co Inishere P.S 1200PUB1025

28. Galway Co.Co Kilmor PWS 1200PUB1032

29. Galway Co.Co Kilkerrin/Moylough 1200PUB1031

30. Galway Co.Co Leenane P.S 1200PUB1035

31. Galway Co.Co Mid Galway 1200PUB1038

32. Galway Co.Co Portumna PS 1200PUB1042

33. Galway Co.Co Williamstown PS 1200PUB1049

34. Kerry Co.Co An Clochan 028D 1300PUB1027

35. Kerry Co.Co Ballinaskelligs 008H 1300PUB1049

36. Kerry Co.Co Ballymacadam 402F 1300PUB1102

37. Kerry Co.Co Barraduff 014A 1300PUB1015

38. Kerry Co.Co Caherdaniel 019H 1300PUB1051

39. Kerry Co.Co Caherciveen 017H 1300PUB1050

40. Kerry Co.Co Caragh Lake 022A 1300PUB1046

41. Kerry Co.Co Castlecove 023H 1300PUB1052

42. Kerry Co.Co Castlegregory 024D 1300PUB1026

43. Kerry Co.Co Cill Maolcheadair 047D 1300PUB1112

44. Kerry Co.Co Dingle 030D 1300PUB1034 93 | Irish Water Water Services Strategic Plan - October 2015 Appendix 1 - EPA Remedial Action List (2013) WATER SUPPLY continued Local Authority Name of Water Supply Scheme Code

45. Kerry Co.Co Dun Chaoin 034D 1300PUB1035

46. Kerry Co.Co Glen 039H 1300PUB1098

47. Kerry Co.Co Inch PWS 044D 1300PUB1040

48. Kerry Co.Co Kenmare 045A 1300PUB1058

49. Kerry Co.Co Kilgarvan 046A 1300PUB1059

50. Kerry Co.Co Kilsarkin 403F 1300PUB1103

51. Kerry Co.Co Lauragh 051A 1300PUB1060

52. Kerry Co.Co Lisarboola 404F 1300PUB1105

53. Kerry Co.Co Lisloose Reservoir 1300PUB1106

54. Kerry Co.Co Lough Guitane 400F 1300PUB1016

55. Kerry Co.Co Maulin 066H 1300PUB1115

56. Kerry Co.Co Milltown (Poulgorum) 1300PUB1118

57. Kerry Co.Co Minard No.1 (Puck Island) 1300PUB1042

58. Kerry Co.Co Mountain Stage 062A 1300PUB1119

59. Kerry Co.Co Murreigh Ballydavid 063D 1300PUB1044

60. Kerry Co.Co Portmagee 064H 1300PUB1055

61. Kerry Co.Co Shrone 078A 1300PUB1121

62. Kerry Co.Co Templenoe 073A 1300PUB1062

63. Kerry Co.Co Ventry 074D 1300PUB1045

64. Kerry Co.Co Waterville 075H 1300PUB1057

65. Kilkenny Co.Co Inistioge WS 1500PUB1009

66. Kilkenny Co.Co Kilkenny City (Radestown) WS 1500PUB1010 94 | Irish Water Water Services Strategic Plan - October 2015 Appendix 1 - EPA Remedial Action List (2013) WATER SUPPLY continued Local Authority Name of Water Supply Scheme Code

67. Laois Co.Co Portlaoise 1600PUB1004

68. Leitrim Co.Co South Leitrim Regional 1700PUB1100

69. Longford Co.Co Newtown Cashel 2000PUB1012

70. Louth Co.Co Omeath 2100PUB1012

71. Louth Co.Co Staleen 2100PUB1019

72. Mayo Co.Co Inishurk 2200PUB1031

73. Mayo Co.Co Kilmaine PS 2200PUB1016

74. Mayo Co.Co Kiltimagh 2200PUB1032

75. Mayo Co.Co Lough Mask 2200PUB1032

76. Meath Co.Co Ballinaclose 2300PUB2005

77. Meath Co.Co East Meath 2300PUB1008

78. Meath Co.Co Kells-Oldcastle 2300PUB1011

79. Meath Co.Co Navan & MidMeath PWS 2300PUB1016

80. Meath Co.Co Trim PWS 2300PUB1009

81. Monaghan Co.Co Carrickmacross 2400PUB1005

82. Monaghan Co. Co Lough Egish RWSS 2400PUB1001

83. Roscommon Co.Co Ballyfarnan 2600PUB1009

84. Roscommon Co.Co Ballinlough/Loughglynn 2600PUB1014

85. Roscommon Co.Co Boyle/Ardcarne 2600PUB1011

86. Roscommon Co.Co Boyle 2600PUB1023

87. Roscommon Co.Co. Castlerea Urban 2600PUB1016

88. Roscommon Co.Co Castlerea Regional 2600PUB1015 95 | Irish Water Water Services Strategic Plan - October 2015 Appendix 1 - EPA Remedial Action List (2013) WATER SUPPLY continued Local Authority Name of Water Supply Scheme Code

89. Roscommon Co.Co North East RWSS 2600PUB1007

90. Roscommon Co.Co Roscommon Central 2600PUB1002

91. Roscommon Co.Co SRRWSS – Killeglan 2600PUB1004

92. Roscommon Co.Co SRRWSS - Lisbrock 2600PUB1022

93. Roscommon Co.Co NRRWSS 2600PUB1012

94. Sligo Co.Co Kilaraght Public Water Supply 2700PUB2714

95. Sligo Co.Co Lough Gill Regional Water Supply 2700PUB2710

96. Sligo Co.Co Lough Talt Regional Water Supply 2700PUB2702

97. Sligo Co.Co South Sligo Regional Water Supply 2700PUB2709

98. South Tipperary Co.Co. Burncourt 2900PUB0104

99. South Tipperary Co.Co. Carrick-on-Suir (Crotty’s Lake) 2900PUB0118

100. South Tipperary Co.Co Carrick-on-Suir (Lingaun River) 2900PUB0150

101. South Tipperary Co.Co Clonmel Poulavanogue 2900PUB0109

102. South Tipperary Co.Co Cloran Regional 2900PUB0110

103. South Tipperary Co.Co Gortnapisha 2900PUB0137

104. South Tipperary Co.Co Graigue 2900PUB0205

105. South Tipperary Co.Co Mullenbawn 2900PUB0149

106. Waterford Co.Co Ballyhane 3100PUB1089

107. Waterford Co.Co Colligan 3100PUB1032

108. Waterford Co.Co Croan Upper 3100PUB1035

109. Waterford Co.Co Inchinleamy 3100PUB1054

110. Waterford Co.Co Ring/Helvick 3100PUB1084 96 | Irish Water Water Services Strategic Plan - October 2015

Appendix 1 - EPA Remedial Action List (2013) WATER SUPPLY continued Local Authority Name of Water Supply Scheme Code 111. Waterford Co.Co Smoorebeg 3100PUB1092 112. Waterford Co.Co Tallow 3100PUB1095 113. Wexford Co.Co Sow Regional 3300PUB1641 114. Wicklow Co.Co Arklow Public Supply 3400PUB1004 115. Wicklow Co.Co. Aughrim/Annacurra 3400PUB1023 116. Wicklow Co.Co Avoca/Ballinaclash Public Supply 3400PUB1024 117. Wicklow Co.Co Enniskerry Public Supply 3400PUB1024 118. Wicklow Co.Co Glenealy Public Supply 3400PUB1021 119. Wicklow Co.Co Wicklow Regional Public Supply 3400PUB1005 120. Wicklow Co.Co Windgates/Templecarrig 3400PUB1036 121. Wicklow Co.Co Bray Direct 3400PUB1001 122. Wicklow Co.Co Bray Reservoir 3400PUB1002 123. Wicklow Co.Co Greystones 3400PUB1003 124. Wicklow Co.Co Kilcoole 3400PUB1008 125. Wicklow Co.Co Kilmacanogue 3400PUB1009 126. Wicklow Co.Co Newtown Newcastle 3400PUB1010 97 | Irish Water Water Services Strategic Plan - October 2015 Appendix 2 - List of Areas from which raw sewage is discharged 7 LARGER URBAN AREAS, ABOVE THE DIRECTIVE THRESHOLDS, WITH NO TREATMENT OR PRELIMINARY TREATMENT ONLY AT THE END OF 2013 1. Cork Cobh D0054-01 2. Cork Passage West/Monkstown D0129-01 3. Cork Ringaskiddy/Crosshaven/Carrigaline D0057-01 4. Cork Youghal D0139-01 5. Donegal Bundoran D0130-01 6. Donegal Killybegs D0011-01 7. Wicklow Arklow D0006-01 28 SMALLER URBAN AREAS, IN THE SIZE RANGE 500 P.E. UP TO THE DIRECTIVE THRESHOLDS, WITH NO TREATMENT OR PRELIMINARY TREATMENT ONLY IN 2013 County/ Region Urban Area Licence Number 8. Clare Ballyvaughan D0327-01 9. Clare Clarecastle D0322-01 10. Clare Kilkee D0078-01 11. Clare Kilrush D0075-01 12. Clare Liscannor D0430-01 13. Cork Ballycotton D0516-01 14. Cork Castletownbere D0297-01 15. Cork Castletownshend D0468-01 16. Cork Ringaskiddy Village D0436-01 17. Cork Timoleague D0466-01 18. Cork Whitegate/Aghada D0423-01 19. Donegal Falcarragh D0343-01 98 | Irish Water Water Services Strategic Plan - October 2015 Appendix 2 - List of Areas from which raw sewage is discharged continued 20. Donegal Kilcar D0520-01 21. Donegal Moville D0212-01 22. Donegal Ramelton D0341-01 23. Donegal St.Johnston D0538-01 24. Fingal Rush D0119-01 25. Galway Ahascragh D0372-01 26. Galway Carraroe D0388-01 27. Galway Kinvara D0276-01 28. Galway Spiddal D0396-01 29. Kerry Ballylongford D0459-01 30. Mayo Bellmullet D0074-01 31. Mayo Killala D0067-01 32. Waterford Ardmore D0162-01 33. Waterford Dunmore East D0170-01 34. Wexford Duncannon D0245-01 35. Wexford Kilmore Quay D0232-01 99 | Irish Water Water Services Strategic Plan - October 2015

Appendix 2 - List of Areas from which raw sewage is discharged continued 9 CERTIFICATE OF AUTHORISATION AREAS (<500 P.E) WHERE WASTE WATER WAS DISCHARGED WITH NO TREATMENT County/ Region Certificate of Authorisation Site Certificate Number 36. Cork Inchigeelagh A0349-01 37. Cork Kilmacsimon A0360-01 38. Donegal Burtonport A0446-01 39. Donegal Coolatee Housing Scheme A0525-01 40. Donegal Kerrykeel A0445-01 41. Galway Roundstone A0115-01 42. Louth Omeath A0072-01 43. Wexford Arthurstown A0243-01 44. Wexford Ballyhack A0242-01 100| Irish Water Water Services Strategic Plan - October 2015 Appendix 3 - Agglomerations identified in the European Commission Infringement Case against Ireland in respect of the Urban Waste Water Treatment Directive 1. Abbeyfeale 23. Cobh 2. Abbeyleix 24. Cork City 3. Arklow 25. Courtown/Gorey 4. Athlone 26. Dundalk 5. Athy 27. Dunmanway 6. Ballincollig New 28. Enfield 7. Ballybofey/Stranorlar 29. Enniscorthy 8. Ballyragget 30. Fermoy 9. Blarney 31. Kildare Town 10. Borrisoleigh 32. Kilkenny City and environs 11. Callan 33. Killarney 12. Carlow 34. Killybegs 13. Carrickmacross 35. Kingscourt 14. Carrick-on-Suir 36. Kinsale 15. Carrigtwohill and environs 37. Letterkenny 16. Castlebar 38. Lower Liffey Valley Regional Sewerage Scheme 17. Castlebridge 39. Lusk 18. Castlecomer 40. Mallow 19. Castletroy 41. Manorhamilton 20. Cavan 42. Midleton 21. Clifden 43. Monaghan 22. Clonakilty and Environs 44 Monksland Wastewater Treatment Works 101| Irish Water Water Services Strategic Plan - October 2015

Appendix 3 - Agglomerations identified in the European Commission Infringement Case against Ireland in respect of the Urban Waste Water Treatment Directive continued 45. Mountmellick 59. Skibbereen 46. Mountrath 60. Swords 47. Navan 61. Templemore 48. Nenagh 62. Thomastown 49. Passage/Monkstown 63. Thurles 50. Piltown 64. Tralee 51. Portarlington 65. Tubbercurry 52. Rathcormac 66. Tullamore 53. Rathdowney 67. Tullow Wastewater Treatment Plant 54. Ringaskiddy 68. Upper Liffey Valley Sewerage Scheme 55. Ringsend 69. Urlingford 56 Roscommon 70. Waterford 57. Roscrea 71. Youghal 58. Shannon Town 102| Irish Water Water Services Strategic Plan - October 2015 Vartry Reservoir Offtake Tower. Photo: Jean Clarke 103| Irish Water Water Services Strategic Plan