Shaping the Future of Water
Services
Responding to Environmental Regulation
Tom Stafford
Environmental Regulation Manager
Irish Water
Environmental Regulation
WFD
Implementation
SEA, EIA,
AA Policy
Climate
Change
Research
coordination
Environmental Policy
EU Infringement
WWDL &
Reviews
S99e
Environmental
Licensing
S16’s
DW Safety
Plans
Abstractions
Drinking
Water
Monitoring
Drinking
Water
Safety
Plans
WWD
Certs
Environmental AER
Compliance
S16
WWDL
Inspections
Audits
Incidents
Environmental Regulation IT Systems
Development
Background
EPA
Environmental
Regulation
Asset Management
Operation and
Maintenance
Local Authorities
Urban Waste Water
•
•
•
•
•
Licences
Certificates
Monitoring
Incidents
Reports and assessments
UWW Licencing
Wastewater Discharge Licenses & Certificates
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 WW Certs issued by EPA
512
No. of WW Certs to be assessed by EPA
30
Discharge to Sewer Applications Received
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
6
Sligo 2014
UWW Issues
• 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 Compliance
Complaints
Total
70
Open Closed
60
Total number of UWW incidents
2200
471
1729
50
40
Total number of UWW complaints
178
77
30
101
20
Total number of UWW compliance
investigations
10
235
150
85
0
Complaints
2012
53
Compliance Investigations
YTD
120
100
80
60
40
20
0
CI's
8
2012
78
2013
44
2014
113
2013
64
2014
56
Incidents
900
800
700
600
500
400
300
200
100
0
Incidents
2012
621
2013
785
2014
794
UWW Compliance Issues
• 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.
Drinking Water
•
•
•
•
•
Monitoring
Incidents
RAL
Drinking Water Safety Plans
Reports and assessments
Drinking Water Compliance Stats
11
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
LA
13
LA
LA
LA
LA
LA
LA
LA
LA
Analysing the problem
Implementing Systems
Finding the right solution
Harmonising & Standardising
Delivering
Better Information/Analysis
LA
14
LA
LA
LA
LA
LA
LA
LA
LA
ECJ
• Significant data collection
required to clarify situation
• Programmes of
Improvement for noncompliant 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
Where We Are
WWD
Certs
WWD
Licence
Where We Want To Be
WFD
Cycle 4
WFD
Cycle 3
Article
17
ECJ
WFD
Cycle 2
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
Moderate
435
69
62
Poor
295
37
4
Bad
18
5
Suspected Causes of Pollution (547 Sites)
4%
Ground
Total 1041
116
P Contribution (%)
4% 5%
17
Agriculture
Municipal
23
54%
33%
Forestry
Industry
EPA Water Quality Report 2007/09
Other
60
Agriculture
UWW
OSPAR Estimates
Other
The WFD Challenge
100
90
80
70
Eastern
Neagh Bann
60
North West
50
South East
Shannon
40
South West
30
Western
20
10
0
2009
2015
2021
2027
Water Quality Improvement Targets established during WFD First
Cycle
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
20
What we need
• 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’
Impact on Beneficial Use
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
Risk
Low
Medium
High
Need to Identify and Focus on Key Areas
Very High
High
Proposed WFD & Price Control Timelines
SWMI
Consultation
Start
July 2015
Q2 15
SWMI
Consultation
Close
December
2015
Q3 15
Q4 15
RBMP
Consultation
Start
December
2016
Q1 16
Q2 16
Q3 16
Q4 16
Q1 17
Consultation
Phase
Prep for 2nd
Price Control
Period
June 2015
24
Submission for
2nd Price
Control Period
June 2016
Commence
2nd Price
Control Period
January 2017
RBMP
Consultation
Close
June 2017
Q2 17
Q3 17
RBMP
Published
December
2017
Q4 17
Proposed WFD & Price Control Timelines
SWMI
Consultation
Start
July 2015
Q2 15
SWMI
Consultation
Close
December
2015
Q3 15
Q4 15
RBMP
Consultation
Start
March 2016
Q1 16
Q2 16
RBMP
Consultation
Close
September
2016
Q3 16
Q4 16
RBMP
Published
January
2017
Q1 17
Consultation
Phase
Prep for 2nd
Price Control
Period
June 2015
25
Submission for
2nd Price
Control Period
June 2016
Commence
2nd Price
Control Period
January 2017
Q2 17
Q3 17
Q4 17
Environmental Information
Systems
•
•
•
•
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 Permitting Information & Compliance
Urban Waste
Water
Licencing
Urban Waste
Water
Compliance
River Basin
Management
EPIC
Drinking
Water Safety
Plans
S16
Enforcement
Section 16
Licencing
27
Drinking
Water
Compliance
LA
EPALIMS
Maximo
Monitoring
Data
Exchange
P6/PCM
LA’s
River Basin
Management
Urban Waste
Water
EDEN
Portal
HSE
GIS
Urban Waste
Water
Compliance
River Basin
Management
DECLG
Drinking
Water
Management
Bathing Water
Management
Fisheries
Urban Waste
Water
Licencing
EPIC
Marine
An
Institute
Taisce
Drinking
Water Safety
Plans
S16
Enforcement
Service
Updates
Public
Section 16
Licencing
Oracle
Finance
Drinking
Water
Compliance
Water
Quality
FOI
Internet
Complainants
S16
Application
Billing
Stakeholders
Customer
Project
Updates
CC&B
BI
CMS
WFD
PRTR
LA
LIMS
IW
Monitoring
Data
Exchange
UWW
WISE
LA
LA’s
Other
GW
DW
Systems
BW
DEHLG
River Basin
Management
EDEN
Portal
HSE
LEMA
Marine
Institute
Bathing
Water
Management
Fisheries
GIS
Urban Waste
Water
Drinking
Water
Management
Rivers/Lak
es/C&T
BWIS
An
Taisce
LIMS
CRM/
Aquarius
Drinking
Water
DWWS
Core
Complaints
Public
Water
Quality
Complainants
Licence
Search
UWW
Bathing
Water
Sun
Internet
SPLASH
Submissions
Documentum
Stakeholders
GIS
DECLG
Teagasc
DoA
An
Taisce
LA’s
Monitoring
Data
Exchange
River Basin
Management
Urban Waste
Water
EDEN
Portal
EPA
CER
Drinking
Water
Management
Bathing Water
Management
HSE
Fisheries
Marine
Institute
CSO
Irish
Water
30
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
31
Reliable information is required!
32
Conclusion
•
•
•
•
33
Good data is key
Evidence based decision making required
Must have an agreed prioritisation approach
Challenging but realistic improvement plans