The Cork Rivers Group submission to Uisce Eireann Draft Water Services Strategic Plan 2050

The Cork Rivers Group Submission

The draft Water Services Strategic Plan 2050 (WSSP 2050)

Draft Water Services Strategic Plan (WSSP) 2050
Submission from the Cork Rivers Group – June 2024

Dear Sir/Madam,
Find enclosed a submission to the public consultation on the WSSP 2050 from the Cork Rivers Group.

Cork Rivers Group

The Cork Rivers Group brings together different community groups, organisations and stakeholders across the Cork City and County, who are actively involved, or wish to, protect and care for the rivers and water streams in their local areas.
Our Group’s vision for the future is that rivers and streams in Cork will be restored, regenerated, and protected, and that they wil become integral parts of our community environment which all citizens can access.
There is growing concern across different local areas for the state of our rivers and waterways and a strong need to take action to protect them and nurture them as part of ourselves.
Our Group welcomes the WSSP as an ambitious plan for the protection of our water habitats in Ireland. We have outlined hereafter important observations and recommendations to ensure that a clear pathway to achieve this strategy is implemented through a meaningful collaboration with local communities.

General comments

• While key definitions are presented ni the glossary, the draft does not define or outline the definition of “water” within the plan. It would be important to provide a clear definition so to frame the context and focus of the plan, and avoid skewing such focus ot some specific dimensions of water (e.g., drinkable water that is “consumed” as opposed to natural water bodies that form our environment).
– We welcome the outline of challenges for the plan, but would encourage to consider other important challenges, namely, the lack of awareness and understanding of water eco-systems both at the community and authority level, and the complexity and fragmentation of services and communication across Irish Water, EPA, local authorities, and other relevant bodies. These challenges play a crucial role ni the achievement of the plan objectives, particularly for the protection of natural environment and sustainability of actions.

• A search of the draft shows no mention or consideration of the concept of “One Health” as applied to the enhancement of water services. The World Health Organization’ defines One Health as “an integrated, unifying approach that aims to sustainably balance and optimize the health of people, animals and ecosystems”. This approach “recognizes that the health of humans, domestic and wild animals, plants, and the wider environment (including ecosystems) are closely linked and interdependent“. Given the strong ambition in the plan for sustainable and nature-based solutions to enhance and protect water, we strongly recommend that the draft demonstrates a commitment to a holistic and integrated approach to safe water, particularly in the approach section of the draft.

Strategic Objective 1- Safe and Reliable Drinking Water

• Action 1.1 “Undertake risk assessments across our supplies and implement appropriate measures ot manage risk” is welcomed, as well as the commitment to expand water stewardship programmes beyond businesses (action 1.8) and to reduce leakages (action 1.9). We would strongly encourage this section of the draft to consider how a risk assessment will address issues at the level of planning and building regulations (which are mentioned under objective 2)

• The draft mentions the exploration of technologies for rainwater harvesting. A plan should be implemented to secure city-scale resources to incentivize rainwater harvesting in industrial and residential contexts so to reduce on water usage in the summer. Importantly, we would encourage concerted work with local authority and regional assemblies to ensure the integration of rainwater harvesting with successful connectors and in large residential developments. It would be also be useful for the plan to clarify a funding structure for supporting rainwater harvesting.
Securing safe water systems should be a key priority at planning stage and thus clear engagement is needed from Irish Water with developers as well as enforcement of planning regulations both prospectively and retrospectively.

Strategic Objective 2 – Supporting our Customers, Communities and the Economy

• We note that the actions in the draft related to communication with customers are mainly focused on drinking water. We would strongly recommend that the strategic focus is broadened to consider environmental and ecological issues and opportunities associated with ensuring reliable water supplies and conserving resources.
The plan should be more ambitious in committing to meaningful engagement between Irish Water and local communities through the employment of community engagement officers for Cities and Counties. Under strategic aim “Engaging with communities”, action 2.4 “Develop community education”, ensure that resources and support are provided to embrace and elevate local knowledge and experiences of communities and catchment areas. Do not assume that there is no expertise at the local level. https://www.who.int/health-topics/one-health#tab=tab

Linked to the point above, we note that under action 2.4, Irish Water is considered the “custodian” of water, but communities are seen as “customers”. We would strongly recommend a revision of the framing of engagement in this section to highlight the importance of bidirectional and meaningful partnerships, as local communities and groups may well consider themselves (and be de facto) custodians of, and champions for, water ecosystems and resources, as well as hold local knowledge and expertise.

• We would encourage a national audit of misconnections in households carried out in collaboration with local communities. This should be based on successful local case studies such as the Dublin Urban Rivers Life project?.
• Complaint procedures need to be improved through the implementation of contact points for regional districts and local catchment areas. This will ensure that Irish Water staff can leverage local knowledge and capacity to deal with complaint and issues.
• It should also be made easier for customers and communities to object to planning proposals on the basis of environmental concerns without incurring monetary costs. Concerned citizens and groups like ours, which operate on a voluntary basis, are likely to not have sufficient financial resources for this purpose but should be able to exercise their right to raise concerns.
• An accessible spatial tool to report or map pollution or ecological issues or incidents related to waterways and rivers should be created, with quarterly updates by Irish Water on how the issues are addressed.

Strategic Objective 3 – Protect and Restore our Environment

• We welcome action 3.8 “champion nature based solutions”, but find that the definition of nature-based solutions is vague and would recommend that clear examples of such solutions are provided, together with a more expanded consideration of local opportunities and constraints.
• As co-custodians of water, recognizing and supporting local communities and groups who advocate for rivers is key to ensure local protection of water environments and ecosystems. This is not made evident under objective 4 of the plan, but we would strongly recommend that collaboration and cooperation in making decisions that
impact local rivers and waterways is a key action ni this section of the plan to frame relationships between Irish Water and communities as bidirectional and mutually fruitful.
• In line with a commitment to community engagement, the plan should make a strong commitment to educating the public to the risks of wastewater for our rivers and waterways, and ot mobilise citizens, local authorities, and politicians for the protection of rivers from wastewater. A recent analysis of the Glen River in Cork City by Dr. Simon Harrison, School of Biological, Earth and Environmental Sciences in University College Cork, revealed wastewater leakages at different points of the river, with evidence of E.Coli and other pollutants in the water. The very poor state of the river creates a dangerous ecosystem for humans, animals and plants.

Public education and support for monitoring and protection of water ecosystems, in collaboration with local groups and communities, should be a key priority in this plan.

• In addition, a commitment should be clear ni the plan with regards to: https://www.sdcc.ie/en/services/environment/dublin-urban-rivers-life/

• Carrying out a full survey and monitoring of urban rivers for pollutants including microplastics, heavy metals, microbes (e.g., E.coli), and chemicals.
• Locating all waste pipes going into rivers.
• Identifying misconnections and sewerage outflows.
• Implementing a system for funding domestic wastewater inspections and proper regulation of domestic wastewater management.
• The network does not have capacity for sewerage outputs. Sewerage pipes need to be upgraded (both network and capacity), enlarged and diverted.
• It would be important to make more accessible to the public information about the modelling used to monitor river catchments, with regards to what is measured, and the criteria based on which decisions on wastewater are made.

Strategic Objective 4 – Sustainable Services fit for the Future

• Page 10 of the draft outlines the system of plans and frameworks guiding this plan. As members of a local group who have experienced significant difficulties in accessing support and navigating regulations, we would strongly encourage to implement a plan for simplification of systems and bureaucratic complexities to futureproof water services for more accessibility and meaningful engagement with local communities.Linked to the point above, it would be important to enhance clarity for the public with regards to the different responsibilities for our water across Irish Water, the Environmental Protection Agency, LAWPRO and local authorities. Members of our group who have attempted to report issues related to waterways infrastructure and quality have been unable in some instances ot identify responsibility and see clear actions to address the issue. Asustainable plan for our water should prioritise appropriate access to relevant services and supports for concerned citizens and communities.

Yours sincerely,
Cork Rivers Group

To our Friends and fellow custodians of the water:

We will make a group online submission and urge individual groups to adapt and send either to the portal and/or via email:

https://forms.office.com/pages/responsepage.aspx?id=mHckNyz0_UKKN9SccSjTa04hYZ6ypdhItBgd-ls_xghUQU0zMlBQTkk2MloyNUlXV0ZHOUFNWU9HVi4u

The closing date for submissions is 16 July 2024.

All documents, including the Draft Water Services Strategic Plan 2050, Strategic Environmental Assessment and Natura Impact Statement are available to view and download at https://www.water.ie/wssp

This document was compiled after our sixth Rivers meeting in Cork and was generously developed with the kind support and expertise of Dr. Marica Cassarino with input from Dr Simon Harrison and all of the Cork Rivers Group members.