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Shaping the Future of Water Services. Responding to Environmental Regulation Tom Stafford Environmental Regulation Manager Irish Water. Environmental Regulation. Environmental Policy. WFD Implementation. SEA, EIA, AA Policy. Research coordination. Climate Change. EU Infringement. - PowerPoint PPT Presentation
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Shaping the Future of Water Services
Responding to Environmental Regulation
Tom StaffordEnvironmental Regulation Manager
Irish Water
Environmental Policy
Environmental Compliance
Environmental Licensing
S16 WWDL
Drinking Water
Monitoring
WWDCerts
Drinking Water Safety Plans
AER
WWDL & Reviews S99e
S16’s
AbstractionsInspections
Audits
Incidents
SEA, EIA, AA Policy
WFD Implementation
Research coordination
Environmental Regulation IT Systems Development
DW Safety Plans
EU Infringement
Climate Change
Environmental Regulation
Background
Asset ManagementOperation and Maintenance
Local Authorities
Environmental Regulation
EPA
Urban Waste Water
• Licences• Certificates• Monitoring• Incidents• Reports and assessments
UWW Licencing
No. of WW Certs issued by EPA 512
No. of WW Certs to be assessed by EPA 30
No. of WWDLs issued by EPA 363
No. of WWDL applications to be assessed by EPA 163
No. of open Requests for Information (RFIs) from EPA 84
No. of RFI’s response correspondence issued to EPA by IW 108
No. of IPPC/IED Requests from EPA in 2014 8
No. of IPPC/IED Requests from Licencees’ in 2014 7
No. of Section 16 Licence applications in 2014* 42
No. of Section 16 Licences issued in 2014 17
No. of FOG Licence applications in 2014 282
No. of FOG Licences issued in 2014 170
Wastewater Discharge Licenses & Certificates
Discharge to Sewer Applications Received
6 Sligo 2014
• Licensing– Applications now dated.– Some information is aspirational– Limits do not always reflect the
impact of the discharge• The notionally clean approach is not
always appropriate• Prefer a more holistic contribution based
approach (WFD!)
UWW Issues
UWW Compliance
2012 2013 2014
CI's 78 44 113
10
30
50
70
90
110
Compliance Investigations
8
2012 2013 2014
Complaints 53 64 56
5
15
25
35
45
55
65
Complaints
2012 2013 2014
Incidents 621 785 794
50150250350450550650750850
Incidents
Total Open Closed
Total number of UWW incidents 2200 471 1729
Total number of UWW complaints 178 77 101
Total number of UWW compliance investigations
235 150 85
YTD
• Compliance– Many of the timelines are aspirational
and unachievable based on achieving very optimistic WFD objectives.
– Many of the conditions overlap with water framework and other assessments, e.g. FPM, shellfish, drinking water abstraction.
– Sampling regime needs to be tightened.
UWW Compliance Issues
• Monitoring• Incidents• RAL• Drinking Water Safety Plans• Reports and assessments
Drinking Water
11
Drinking Water Compliance Stats
Drinking Water Issues
• Drinking water monitoring programmes need to be re-evaluated
• Taking an incremental approach to Drinking Water Safety plans– Very much integrated into our business
systems– Will depend on WFD analysis for
catchment side and implementation of suitable protection measures
13
LA LA LALALA LA LALA LA
14
LA LA LALALA LA LALA LA
Implementing Systems
Harmonising & Standardising
Better Information/Analysis
Analysing the problem
Finding the right solution
Delivering
ECJ
• Significant data collection required to clarify situation
• Programmes of Improvement for non-compliant Agglomerations
• WWTP, Collection Systems, CSO’s etc
ECJ Article 17
Article 3 12 12
Article 4 40 33
Article 5 32 8
We acknowledge a significant deficit
WWD Certs
WWD Licence
Article 17
ECJ
Where We Are
WFD Cycle 4
WFD Cycle 3
WFD Cycle 2
Where We Want To Be
Water Framework Directive
• Holistic integrated approach to Water Management
• Requires Irish Water to identify its significant pressures on the water environment
• Also requires that we identify significant pressures on drinking water resources and ensure they are protected
• There will be more measures required than we can afford to fund in the next cycle
Water Bodies Less than Good Status
Rivers Lakes C&T Ground
Moderate 435 69 62
Poor 295 37 4 116
Bad 18 5
Total 1041
54%33%
4%4% 5%
Agriculture Municipal Forestry Industry Other
EPA Water Quality Report 2007/09
Suspected Causes of Pollution (547 Sites)
6023
17
Agriculture UWW Other
OSPAR Estimates
P Contribution (%)
The WFD Challenge
2009 2015 2021 20270
10
20
30
40
50
60
70
80
90
100
Eastern
Neagh Bann
North West
South East
Shannon
South West
Western
Water Quality Improvement Targets established during WFD First Cycle
20
WFD Conundrum
• First round targets to achieve ‘good status’ were unrealistic
• These targets used to set Licence Compliance dates
• Licence Compliance requires capital investment
• Amount required not available within the timeframe of the plan
• Agreed approach for:– Identification of pressure– Quantification of pressure– Assessing its impact– Assessing its relative contribution to
the problem– Identifying appropriate measures– Prioritising investment in ‘key
measures’
What we need
Prioritisation Matrix
Very High (4) 4 8 12
High (3) 3 6 9
Medium (2) 2 4 6
Low (1) 1 2 3
Low (1) Medium (2) High (3)
Likelihood of not meeting good status or status degradation
Impa
ct o
n B
enef
icia
l Use
Risk Low Medium High
Need to Identify and Focus on Key Areas
Very High High
24
Proposed WFD & Price Control Timelines
Q2 15 Q3 15 Q4 15 Q1 16 Q2 16 Q3 16 Q4 16 Q1 17 Q2 17 Q3 17 Q4 17
Submission for 2nd Price
Control Period June 2016
Commence 2nd Price
Control PeriodJanuary 2017
Prep for 2nd Price Control
Period
June 2015
Consultation Phase
RBMP Consultation
Close
June 2017
RBMP Consultation
Start
December 2016
RBMP Published
December 2017
SWMI Consultation
Start
July 2015
SWMI Consultation
Close
December 2015
25
Proposed WFD & Price Control Timelines
Q2 15 Q3 15 Q4 15 Q1 16 Q2 16 Q3 16 Q4 16 Q1 17 Q2 17 Q3 17 Q4 17
Submission for 2nd Price
Control Period June 2016
Commence 2nd Price
Control PeriodJanuary 2017
Prep for 2nd Price Control
Period
June 2015
Consultation Phase
RBMP Consultation
Close
September 2016
RBMP Consultation
Start
March 2016
RBMP Published
January 2017
SWMI Consultation
Start
July 2015
SWMI Consultation
Close
December 2015
• Need for good data – a common thread
• Cornerstone of good decision making
• High level analysis underway• Some immediate work ongoing for
compliance data• Will work with all stakeholders to
share information
Environmental Information Systems
27
Environmental Permitting Information & Compliance
EPIC
Urban Waste Water
Licencing
Urban Waste Water
Compliance
Drinking Water Safety
Plans
Drinking Water
Compliance
Section 16 Licencing
S16 Enforcement
River Basin Management
EDEN Portal
Monitoring Data
Exchange
Urban Waste Water
Drinking Water
Management
Bathing Water Management
River Basin Management
LA LIMS
HSE
LA’s
DECLG
Fisheries
Internet
Service Updates
Water Quality
S16 Application
Project UpdatesCustomer
Billing
FOIPublic
Complainants
Stakeholders
An Taisce
EPA
MarineInstitute
EPIC
Urban Waste Water
Licencing
Urban Waste Water
Compliance
Drinking Water Safety
Plans
Drinking Water
Compliance
Section 16 Licencing
S16 Enforcement
River Basin Management
Maximo
P6/PCM
GIS
Oracle Finance
CC&B
BI
CMS
EDEN Portal
Monitoring Data
Exchange
Urban Waste Water
Drinking Water
Management
Bathing Water
Management
River Basin Management
CRM/
Aquarius
LEMA
BWIS
DWWS
Bathing WaterUWW
Drinking Water
Rivers/Lakes/C&T
WISE
WFD
UWW
DW
BW
GW
PRTRLA
LIMS
HSE
LA Other
Systems
DEHLG
MarineInstitute
Fisheries
Internet
Complaints
Licence Search
SPLASH
GIS
Submissions
Water Quality
Public
Complainants
Stakeholders
An Taisce
IW
LA’s
An Taisce
Sun
GIS
Core
Documentum
LIMS
30
EDEN Portal
Monitoring Data
Exchange
Urban Waste Water
Drinking Water
Management
Bathing Water Management
River Basin Management
EPA
HSE
LA’s
DECLG
Fisheries
An Taisce
MarineInstitute
CER
Irish Water
DoATeagasc
CSO
31
Environmental Regulation Objectives
• More extensive and robust monitoring programmes– Statically sound with good spatial
distribution
• More comprehensive and extensive audit programme
• Improved network information• Compliance metrics and
accountability included in SLA
32
Reliable information is required!
33
Conclusion
• Good data is key• Evidence based decision making
required• Must have an agreed prioritisation
approach• Challenging but realistic improvement
plans
