SKERRIES COMMUNITY ASSOCIATION
Submission on the Regional Sewage Treatment Plant, Marine Outfall
and Orbital Sewer proposed by Fingal County Council for the Greater
Dublin Drainage Project
Public Consultation Process October–December 2011
Contents
Introduction ........................................................................................................................................ 2
The Consultation Process .................................................................................................................... 4
WwTP Demand ................................................................................................................................... 5
Ringsend.............................................................................................................................................. 7
The Marine Outfall .............................................................................................................................. 8
GDSDS Sewerage Sytem Current Status ............................................................................................ 9
Conclusion ........................................................................................................................................... 9
Introduction
Skerries Community Association (SCA) is the umbrella organisation for many of the town’s
community groups, including the Board of Management of Skerries Community Centre, Skerries Tidy
Towns Committee, Skerries Town Twinning Association, Skerries Cycling Initiative, Skerries
Soundwaves Festival, Skerries RAS Endstage Committee, Crann Padraig, Sustainable Skerries and the
Little Theatre Funding Committee.
In assessing the proposal for a new regional sewage plant, marine outfall and orbital sewer, we have
availed of the consultation process, information days and a meeting with project personnel from
Fingal County Council and consultants Jacobs–Tobin. We have also reviewed the relevant reports
cited by this project proposal, including the 2005 Greater Dublin Strategic Drainage Study (GDSDS),
the 2008 GDSDS Strategic Environmental Assessment Report (SEA), and the recent preliminary
Alternative Sites Assessment (ASA) report. Where available, we have accessed the most recent
Annual Environment Reports (AERs) of the existing EPA licenced treatment plants in the GDSDS area.
We are aware of the numerous submissions that have already been sent to the project team during
the current consultation process. Some of the following listed issues may have been raised in those
submissions but we request that you include your responses to these issues in your correspondence
with the Community Association.
1. The failure to designate the sea area between Skerries and Rush as Shellfish Waters is an
error of omission or commission by the Department of the Environment and its agencies.
The marine and shellfish life is consistent for the area between Balbriggan and Malahide and
is fished in compliance with Shellfish Water Directive requirements. Implied designation
must be included as a constraint along with the Balbriggan/Skerries and Malahide
designations. In particular, the Marine Institute designation for waters between Rush and
Skerries as production areas for Ensis siliqua (Razor Clam) is absent from the listed
constraints.
2. The inconsistent exclusion and inclusion of national strategic constraints exemplified by:
o
Exclusion of a national strategic constraint for an existing national food production area
(75% of horticultural produce grown in Ireland comes from this area).
o
Exclusion of a national strategic constraint for existing energy pipeline (gas transmission
line from Interconnector 1 at Loughshinny) which crosses proposed pipeline corridors
and at least one proposed site.
o
Exclusion of a national strategic constraint for the East-West Interconnector being built
at Rush North Beach to connect the Irish power system to the electricity grid in Britain
through undersea and underground cables. This infrastructure is vital to the
development of Ireland's economy and on target for completion in 2012.
o
Inclusion of a national strategic constraint for proposed flight path zones at
Pickardstown & Kingstown and consequent removal as potential sites for the regional
sewage plant.
o
Exclusion of the recreational waters between Skerries and Rush contrary to the stated
objective to treat all recreational waters in the north Dublin area as a basis for screening
out locations for outfall pipes.
3. The lack of observation of the proximity principle as set out in Waste Management
Regulations. We consider that the proposed development of any of these sites, by reason of
their distant location from the primary and secondary load centres and the ensuing
distances and costs associated with the transportation of treated and untreated waste to
any of the proposed sites, would conflict with the proximity principle and would therefore
be contrary to the proper planning and development of the area. The granting of permission
for such development by An Bord Pleanála would be contrary to its own 2003 ruling on
waste treatment plants for the north county.
4. The absence of consideration of the current development plan zoning objective for the
selected sites. This objective is stated as ‘to protect and promote in a balanced way the
development of agricultural and rural related enterprise, biodiversity, the rural landscape,
and the built and cultural heritage’. The industrial nature of the proposed development and
its absence of any functional linkages with surrounding agricultural land use coupled with
the scale of the proposed development impact adversely on the amenities of the rural
landscape. It is our consideration therefore that the proposed development would conflict
with the provisions of the development plan zoning objective for the above sites and would
therefore be contrary to proper planning and development in the area.
5. The absence of consideration that the proposed single Wastewater Sewage Treatment Plant,
by reason of its height, scale and design, will be visually obtrusive in the rural landscape and
is out of character with the pattern of development permitted on adjoining lands of the
above sites. Any proposed development on these sites would seriously injure the visual
amenities of the area and would, therefore, be contrary to the proper planning and
development of the area.
6. There is an absence of risk assessment of failure and by-pass of the WwTP in both the SEA
and the ASA process. The awareness of risk posed by WwTPs and pumping stations is very
high in a coastal town like Skerries -which has recent experience of WwTP failure at
Barnageeragh. The resulting pathogenic contamination posed a serious risk to health and
closed the bathing and amenity waters. The potential risk from failure of large scale WwTPs
is an essential criterion for consideration. Had risk and containment been included in the
assessment, then the multiple smaller-scale treatment plants would have scored highly
relative to a single 700,000 P/E plant, and impacted on the SEA outcome. The potential
damage to coastal waters and the health of water users would have impacted on the
selected sites and outfall.
There are also several submissions detailing the redundant population growth projections that the
project has justified its conclusions on. We are also raising this issue in our submission. We are also
making a number of observations on the consultation process and the current status of certain
elements of the GDSDS sewerage system.
The Consultation Process
We would like to note that the public consultation process for this project has been significantly
impacted by the disjointed progression of the project between the SEA and the ASA. The reported
preference of the SEA, from the 16 options considered, for the upgrade and development of the
GDSDS sewerage systems, included a regional treatment plant, at a specific and named site in
Portrane. This SEA option was rendered void by the designation of this site as high amenity and EU
directives on receiving waters. The decision to progress to an ASA process, without re-considering
the remaining valid options of the SEA and the wider impact of EU directives created an anomaly for
the public consultation process, as communities impacted by the ASA were not part of the SEA
process. While the statutory and legal implications of this anomaly need adjudication, the time
allowed for the current public consultation process needs extension to afford all communities now
impacted by the ASA a fair opportunity to assess the project proposal. We strongly support the
request by the county-wide campaign group, Reclaim Fingal Alliance, for an immediate 6 month
extension to the consultation process and believe that this time should be used by the project team
to reassess the SEA options and produce a conclusion of that assessment that is valid for current
lands and water designations as well as EU directives.
WwTP Demand
The quantum increase in population, commercial and industrial activity, projected in the 2005
GDSDS for the period 2005 to the design horizon of 2031, is now accepted as incorrect. The
projection for 2011 demand is overstated by at least 500,000 P/E, and this overstatement is
compounded in the projections up to 2031. The projection assumptions are also completely at
variance with the current population and economic activity and the future target growth as
documented in the Regional Planning Guidelines (RPG) 2010. The degree of uncertainty in projecting
growth is reflected in the restriction of the RPG targets to intervals up to 2022 only. There are no
accepted projections for the 2022 to 2031 period.
In assessing the rationale therefore of the project proposal for a regional treatment plant, it is logical
to determine the actual current loading at the GDSDS treatment plants and compare that against the
design capacity of those plants. This data as reported through AER’s to the EPA is given in Table 1.
WWTP
Current
2011 P/E
Load
Design Capacity
Ringsend
1,800,000
2,100,000
110,000
200,000
80,000
70,000
55,000
13,000
42,000
60,000
130,000
130,000
65,000
20,000
70,000
90,000
2,230,000
2,805,000
Shanganagh*AER estimate of 2012 Shanganagh load
Osberstown
Leixlip
Portrane* AER estimate of 2014 Portrane load
Malahide
Barnageeragh
Swords~
Total
~Currently awaiting an EPA licence for discharge
* Plant not yet commissioned
Totals
Current Load arriving at existing plants
Design Capacity Capability of existing plants
Extra Capacity Available ( i.e. Current - Design
Capacity)
% growth that extra capacity represents
% annual growth, that extra capacity represents over
20 years i.e. 2011-2031
Table 1.
2,230,000
2,805,000
575,000
25.8
1.2
While the aggregation of the total capacity for a system of plants which are not connected is a
simplistic comparison, it does demonstrate that the inherent design capability of the combined
existing plants is sufficient for at least ten years. The existence of this capacity demands a revision of
how this network can be optimised economically and environmentally. The building of further
capacity rather than utilising these assets is unjustifiable given the economic constraints. The lack of
investigation of the impact of water metering on hydraulic load demand is an obvious omission in
any calculation of projected water treatment need. The failure to address known factors increasing
biological loading of plants, exemplified by the over use of maceration by Dublin’s food and
restaurant outlets, again questions the effort made to derive solutions based on demand reduction.
The inclination to select solutions which propose increases in capacity is evident in the project’s
published reports.
Ringsend
The evaluation and upgrade of the WwTP at Ringsend is central to the sewerage solution for the
GDSDS. The assessment of Ringsend in the GDSDS and the SEA is done without comparison to plants
in other cities of similar size to the GDA. Constraints identified by the project for Ringsend are
repeated in all reports without any obvious rigorous challenge. The acceptance that the treatment
capacity of the Ringsend site is 2.1 MP/E is not evaluated against current engineering practice of
stacking tanks and alternative nutrient abatement. The lack of space on the 15 Ha Ringsend site to
allow expansion and tertiary treatment (nutrient abatement) is difficult to accept when a plant
serving the population of 1.4M in the Hague http://www.wastewater-treatmenthague.veoliaenvironnement.com/features/geography.aspx is housed on a 5 Ha site. The Dutch plant
carries out all its primary treatment in 16 enclosed and ventilated tanks with 8 further tanks for
biological treatment. The availability of the portion of the ESB thermal plant adjacent to the WwTP is
also not considered by the project; rough estimations of the decommissioned plant area are close to
6 Ha, which is a larger area than the entire Hague WwTP.
The tertiary treatment plant in Melbourne would also have provided a valid comparison point.
http://www.melbournewater.com.au/content/current_projects
This plant demonstrates the economic value of tertiary treatment as well as the obvious
environmental value. Tertiary treatment produces a final effluent characteristic that allows
assimilation in the immediate receiving waters rather than needing an extended outfall. This is
worth considering against the proposal not to employ tertiary treatment. The consequent need is a
9Km outfall to ensure the effluent from Ringsend is discharged to a significantly large volume of
seawater, capable of diluting the substantial biological load and nutrient content of the effluent.
The proposed capacity upgrade to Ringsend for 2015 is an obvious opportunity to employ best
practice by moving to tertiary treatment with proven technology that optimizes space and economy.
There is a known need to consolidate the retrofitting of tanks to control the continuing odour
problems and to ensure operational standards are improved. The ‘future proofing’ of Ringsend from
EU Directive compliance through long expensive outfalls is a flawed and an environmentally reckless
response. The examples from cities like The Hague and Melbourne are available to the council’s
engineers and planners to upgrade and expand Ringsend capability without necessarily increasing its
footprint.
The Rejection of SEA Options 7A & 7B
Options 7A and 7B of the SEA included the construction and operation of 15 WwTP plants of varying
capacities from 20,000 to 65,000 P/E in locations close to their load generation. The rejection of 7A
is dependent on the assumption that these plants would not be designed or built for tertiary
treatment and odour abatement. The absence of examination of comparable sized WwTP in other
European urban environments is again a significant omission by the project. The absence of
comparative research on systems developed with tertiary treatment, energy efficiencies and odour
abatement for small to medium sized plants, exemplified by granular sludge technology, again
questions the methodology of the option assessment. A review of the cost benefit and
environmental benefits of improved waste treatment technologies can easily be accessed from
working examples. The Dutch town of Epe, who recently adopted this new technology
http://www.iwapublishing.com/template.cfm?name=w21prodnews220610b. have constructed an
energy efficient, tertiary treatment plant for €15M. The €500M estimated for a regional plant is
more than enough to build 15 state of the art plants should they be required. The obvious
environmental benefit of producing a BOD, COD and nutrient characteristic that can be assimilated
in the receiving waters of the Tolka, Liffey or Broadmeadow does not need elaboration.
The Marine Outfall
The approach by the project to meet the EU framework directive for receiving waters informs their
stated proposal to discharge secondary treated effluent to the coastal waters of Fingal. The stunned
reaction of the coastal communities to such a proposition is to be expected and understandable.
Following a five year study period costing €1.8M, it is entirely reasonable that the expectation of the
GDA population was a solution that encompassed innovative and best-of-breed practice, and had
compliance and environmental protection at its core. The solution they are being offered is based on
avoidance of compliance and reflects practice and thinking in waste water treatment that was outmoded twenty years ago. The ambition of the EU directive to protect water environments is widely
supported by all communities but especially those that rely on that environment for amenity and
livelihood. We had expected that the necessity to meet the EU directive would drive FCC to apply
proven systems for nutrient abatement, filtration and UV as standards for their WwTP. The rather
cynical approach of using the marine waters as a ‘work around’ for avoiding non-compliance with
the directive would be highly contentious in itself. However the use of this work around as the
corner stone of the SEA and the ASA decision, assessment and conclusion is totally unacceptable and
should be challenged on environmental and legislative fronts. The presumption that such an
approach and solution would be approved by the EPA or An Bord Pleanála is also indicative of the
project’s lack of appreciation of the remit of these independent agencies.
GDSDS Sewerage System Current Status
The current project has concentrated its efforts on the big solution and with hindsight it is easy to be
highly critical of the zoning, planning and unrealistic development projections that created this
scenario for the GDA. In the economic realities of 2011 there is an opportunity to use our limited
resources for the essential small solutions that address sustainability and resilience. In preparing this
submission, the deficiencies of the current infrastructure became apparent. It may be tangential to
the submission process, but a listing of the current status of some of the plants is worthwhile in
illustrating that both technical and financial resources need to be directed to addressing the basic
operational needs of the county, followed by emphasis on the quality of treatment of existing plants.

The 65,000 P/E plant at Portrane will not be fully operational until 2014, until then the
sewage of Rush and Lusk which are to be connected to this plant are receiving primary
treatment only.

The sewage of Loughshinny also receives primary treatment only and is dependent on an
upgrade of the Skerries pumping station to connect it to Barnageeragh for secondary
treatment.

The Sewage of Killalane is dependent on a local septic tank for treatment.

The 110,000 P/E plant at Shanganagh is not yet commissioned and the sewage of Bray
awaiting connection receives only primary treatment.

The treatment plant at Swords is yet to be licenced by the EPA and is discharging effluent
that only receives secondary treatment into the Broadmeadow estuary.

The 9C duplicate sewer, identified as essential in 2005 to correct the bottlenecks and spills
caused by the absence of adequate network to connect Meath towns to Ringsend, has
neither a capital allocation nor a planning horizon. The current solution is holding tanks in
the Tolka valley to prevent the inevitable spills to the Tolka.
Conclusion
It is our submission that this proposal and project should be halted now because the demand
justification for the proposal no longer exists. A solution to expand capacity will not be needed
before 2020 and advances in technology will render any current consultant-led proposals redundant.
We believe that the capacity constraints and operational development of tertiary treatment at
Ringsend have not been adequately researched. We question the basis of rejection of SEA options
7A and 7B in light of current available technology for small and medium plants. We strenuously
oppose the planned use of coastal waters for the discharge of secondary effluent and regard the
rationale for discharging large volumes of secondary effluent as environmentally reckless. We
believe the assessment of risk of the proposal to the coastal waters of Fingal has been inadequate
and poses an unacceptable risk to community amenity and livelihoods. We strongly encourage FCC
to divert the resources, technical and financial, engaged in this project, to address the numerous
operational deficiencies in the current system.