28th November 2011
Greater Dublin Drainage
RPS Group
West Pier Biz Pk.,
Dun Laoghaire
Co Dublin.
Dear Sir/Madam,
Skerries Sailing Club is one of the leading sailing organisations in Ireland and represents
a membership base of over 400 adults and children all of whom have a particular interest
in the quality of the local environment and in particular its coastal areas and water
quality. Indeed, Skerries Sailing Club is active in the local Adopt-a-Beach campaigns,
Bird-Watch Ireland studies and other maritime monitoring activities (such as jellyfish
population studies).
As such, this Club is opposed to the scale of the proposed massive WWTP proposed by
Fingal County Council (via Greater Dublin Drainage) and in particular the outfall
pipeline which will dispose of large amounts of secondary treated waste water into the
seas which our members use for educational & recreational use.
Our objections are based upon the following observations –
(A) SCALE
The proposal to build a plant capable of processing 700,000 population equivalents (PE)
by 2040 is excessive & based upon outdated and flawed reports. (Population equivalent
P.E. is a measure of pollution representing the average organic biodegradable load per
person per day: it is defined in Directive 91/271/EEC as the organic biodegradable load
having a five-day biochemical oxygen demand (BOD5) of 60 g of oxygen per day.) This
P.E. is not a measure of actual population but an estimate of usage of sewerage facilities.
However, in residential areas 1 P.E. corresponds to the pollution load of sewage
generated by one inhabitant. In industrial areas, PE reflects the equivalence between the
polluting potential of an industry and a certain population, which produces the same
polluting load.
The initial study GDSDS which was commissioned in 2001 completely overestimated the
growth rates of the regions population which it claimed would grow by 22% between
2002 and 2011 and by 68% by 2031 compared with 2002 figures. Households would
increase by 44% between 2002 and 2011.
The actual change in population from 2002-2011 is –
POPULATION CHANGE 2002 - 2011
2002
Ireland
% increase since 2002
2006
2011
3,917,203
4,239,848
4,580,000
16%
2006
2011
2,105,579
2,295,123
2,501,208
18%
2006
2011
1,122,821
1,187,176
1,270,606
13%
2002
Leinster
% increase since 2002
2002
Dublin
% increase since 2002
Thus, up to the present day, the GDSDS study has overestimated the population growth
be between 4-9% up to currently available data.
However, it is when one examines the forecasts which it prepared to 2031 that the
GDSDS study begins to show serious deviation from what is now expected to be the
growth pattern following recent economic & social change both in Ireland and globally.
In 2008, the CSO published a comprehensive forecast: ‘Population & Labour Force
Projections 2011-2041’. Examining both fertility rates and migration rates it prepared
several scenarios for population growth. The critical item was found to be migration
effect as it is expected that fertility rates in Ireland would continue to trend towards
European norms i.e. decreasing to 1.65 by 2016 and remaining constant thereafter.
Migration however, was forecast to account for over 90% of the total difference between
highest & lowest population levels projected for 2021.
Proected Population, 2011 -2021 (CSO)
(000's)
Year
2011
2016
2021
M1
M2
M0
4,729
5,188
5,590
4,676
5,050
5,356
4,413
4,568
4,686
Thus in 2008, the CSO had modified its National growth forecast to 2021 of between 
19.6% (M0 – zero net immigration),


37% (M2 – moderate net immigration)and
42% (M1 – high net immigration).
AS these figures were prepared in 2008, one can see that by 2011, population was already
in a downside risk, trending to lie between its M0 and M2 rates i.e. zero to moderate net
migration.
In late 2011, given the full extend of the recession in Europe, it can be assumed that the
true forecast will trend towards the CSO’s M0 prediction – 19.6% growth to 2021 from
2002 levels.
As 2011 numbers are now known, it can be extrapolated that a compound growth rate of
1.6% p.a. would give a total projected population by 2031 of 6.2M i.e. an increase from
2002 of 37% or, almost half what was predicted by the GDSDS study.
The current population of the general areas of Rush, Lusk, Skerries is only 23,057 (2006).
Indeed, CSO figure from the 2006 census indicate that the number of households in
Fingal was 80,402 with a total number of persons resident of 237,132. The CSO also
indicate that total population growth in Ireland between 2006 & 2011 was 341,421 or 8%
and for Fingal was-273,051 an increase of 13.8%.
Given these figures, coupled with the data from the 2008 CSO study, it can be predicted
that the population of Fingal will not exceed a growth rate of between 1.6% and 2%
annually. Thus the regional population is forecast to grow to just over 400,000 by 2031.
This immediately begs the questions;
(i)
(ii)
(iii)
Why is Fingal planning to build a plant far in excess of the requirements
of its own population estimates of the Fingal County area?
Why is Fingal using outdated population modeling which grossly
overstates the forecast population growth?
Given the Council estimates an area of 20ha will be required to build the
plant, why does it intend to purchase a site with an area ranging from 32ha
up to 114ha with an average area of 56ha which is more than double the
required size?
An EPA report published in 2009 (Urban Waste Water Discharges in Ireland for
Population Equivalents Greater than 500 Persons) stated that there were only 2 plants in
Ireland capable of handling in excess of 150,000 P.E. – Ringsend and Cork City and
these 2 plants represented 54.7% of total treatment for Ireland. Ringsend capacity is
currently at 1.6million P.E. with plans to expand by a further 500,000.
The proposed Fingal site will become the 2nd largest in Ireland.
The concept for this project arose during ‘the Celtic Tiger’ years from the GDSDS
project which was setup by Dublin City Council acting for Fingal, South Dublin, Dun
Laoghaire-Rathdown, Meath, Kildare & Wicklow County Councils as part of the then
National Spatial Strategy. This suggests that at best ‘Groupthink’ was the driving force
behind the outcome rather than rational analysis. In fact, the study appears to start out
from the premise of examining the concept of a regional solution rather than testing this
concept against any other alternatives such as smaller local treatment plants, possibly
interlinked via a network of smaller pipelines.
(B) JURISDICTION
The studies available on the Greater Dublin Water website indicate that Fingal County
Council is operating as a contracting authority on behalf of Meath, Kildare, Dun
Laoghaire/Rathdown, Dublin City and South County Dublin County Councils. Fingal
County Council and its councilors do not have either mandate or authority from the
residents of the Council area to act in such a manner without the permission of its
residents. Indeed, such action by Fingal could be in breach of its functions as described in
both Constitution and Statutes Article 28A of Bunreacht Na hEireann states that: “The State recognises the role of local
government in providing a forum for the democratic representation of local communities,
in exercising and performing at local level powers and functions conferred by law and in
promoting by its initiatives the interests of such communities”
In proposing to provide a WWTP which will serve areas such as Kildare, Meath, South
Dublin etc, the council is clearly exceeding its authority granted under Article 28A by
acting for areas outside its jurisdiction and by acting against the interests of its own
communities.
Section 63(1)(d) of The 2001 Local Government Act defines the function of the Local
Authority are – ‘To take such actions as it considers necessary or desirable to promote the
community interest in accordance with section 66. Section 66(4)(e) further clarifies these
actions as to ‘provide any service or other thing or engage in any activity that, in the
opinion of the authority is likely to benefit the local community’
Again, by acting for other Councils and proposing to process waste from other council
areas, FCC is clearly in breach of its defined function and its mandate to ‘act for the
benefit of the local community’.
(C) SCOPE OF STUDIES
The Scope of the study namely ‘ASA Stage 1; Preliminary Screening Outcomes Report’,
is fundamentally flawed because firstly it limits the geographical area for investigation of
‘optimum locations’ to North County Dublin and secondly, because it assumes – without
any analysis or justification, that a regional plant is the only solution to the problem of
waste treatment.
Furthermore, in Mapping of Constraints (Section 4.5 – ASA Stage 1 report), the study
omitted to consider ‘land usage’ in examining constraints. The function of land under
consideration is certainly of equal importance to such esoteric considerations as Cultural
Heritage and Ecology. Areas which are under cultivation for production of food for
human consumption are highly relevant in examining suitability constraints.
The GDSDS, from a total of 8 strategies, identified 2 potential scenarios –
Option 2B- a new development south & west of Clondalkin.
Option 2C- a new development at Portrane, with an orbital sewer serving North &
Western environs and South Dublin later.
As neither of these 2 scenarios are now being pursued by Fingal, the council has moved
outside the guidelines of its own study and is effectively ‘winging it’ from here on.
(D) BREACH OF EPA GUIDELINES
For Greenfield site development, the EPA Landfills Manual recommend a distance of
250m between housing (and similar sensitive receptors) and a landfill footprint.
However, Fingal, breaks these guidelines in its own County Development Plan 20112017 by reducing this limit to 100m which is the limit for development surrounding
existing sites only. Greenfield sites require a far larger perimeter. The reduction in the
cordon sanitaire appears to be for no other reason than to achieve a ‘fit’ for the land
parcels it plans to identify as suitable.
Whilst the ASA Stage 1 report acknowledges that the Fingal recommendations for buffer
zones of 100m are for smaller WWTP only and FCC recognizes that odor pollution can
extend for up to 1km, the objective WT01 of the Fingal Development Plan 2011-2017 (to
develop & expand WWT in an environmentally sustainable manner), is clearly
incompatible with an objective WT03 (facilitating the implementation of the Regional
WWTP).
The areas identified as Locations for the Potential Northern Outfall are extraordinary in
their failure to understand basic flow dynamics in the Irish Sea. Bounded as they are by
Designated Shellfish Waters both to the North and to the South, the assumption that
effluent from the pipelines will not encroach on these areas because they are protected by
coloured lines on a map are unfathomable. Tidal flows in the Irish Sea run both Northerly
(during flood tides) and Southerly (during ebb-tides) and carry debris and suspension
particles along the entire East coast of Ireland. Indeed, studies of jellyfish in the Irish sea
indicates that although they breed in Dundalk Bay well to the North of Skerries, the
jellyfish drift south all through the summer to end up a visible presence along the entire
coast from Dundalk through to Wicklow. Thus, any outflow from a pipeline in the
locality will inevitably effect these Shellfish Areas and our beaches and coastal water
qualities impacting our members and tourism both internal and international.
(E) SITE LOCATION
Under the ‘Proximity Principle established under Article 5 of The EU Waste Directive,
all member states must endeavor to treat its waste in the nearest appropriate location. In
other words, exporting of waste either inter-regional or internationally should be avoided
except for proven requirements for economies of scale. Hence, the imperative is for local
waste treatment unless it can be proved that this is economically unviable. Clearly this
case has not been made by FCC.
(F) PREVIOUS RECORD
The urban waste water treatment Regulations SI254 of 2001 & SI 440 2004 set the
required basic standards for Waste Water Treatment Plants. In 2009, The EPA produced
a report ‘Urban Waste Water Discharge in Ireland; For Population Equivalents greater
than 500 persons’. This report covered the years 2006 – 2007 & describes how noncompliance for very large plants (> 15,000 P.E.) had increased by 16% over the previous
reporting period which is a clear indictment of the management of these facilities. In its
Summary of the Compliance of Local Authorities with the overall requirements of the
urban waste water treatment directive, Fingal had a 100% failure rate in the category of
‘Nor of Agglomerates with secondary treatment that failed standards/guidance values.
This was at a time when the Council was only handling 171,140 P.E. in its waster water
systems.
Data obtained from South Dublin Council which owns the Ringsend WWTP indicates
that during 2007 in excess of 300 official complaints about bad odors from the plant were
logged. However, following remedial works this number had dropped to only 24 during
2010. This would indicate that it takes a council several years to get up-to-speed in
relation to managing odor pollution at a plant.
Apparently FCC does not even maintain an ‘Odor Log’ which is extraordinary given the
anecdotal evidence from local residents of an ongoing problem with odors especially
during summer months and in particular with residents living in close proximity to either
the Swords or Skerries plants.
(G) CAPITAL COSTS
According to its own website, Greater Dublin Drainage does not know how much this
project will cost! This cost cannot be determined until both location and technologies to
be used are identified. The 2005 study suggested a cost of €140m for the WWTP alone
but did not identify where such costing came from. This price excludes the additional
pipeline costs which was an additional €220m. No cost benefit analysis or comparative
costing reports for smaller localized plants appear to have been carried out.
In fact, in the initial study, the 1st of the revised options (2B – Clondalkin Project) was
the cheaper by a total of 6%. However, it reckoned that the level of ‘risk’ was lower with
the Portrane (2C) option so recommended this option.
Using the GDSDS study, the question must be asked; if the pipeline costs represented
over 60% of the total ‘estimated’ price for the project, surely any scenario which limits or
curtails this element of the cost would be financially beneficial to the overall project? To
this end, a small selection of localized, interconnected WWTP serving local communities
would be far more cost effective.
Summary
In short, Fingal County Council is acting outside its authority and against the democratic
rights of its own citizens in attempting to further this grossly overpriced and over-scaled
monster WWTP and pipeline project. The decision making process appears to have been
flawed from the outset and influenced by ‘groupthink’ and ‘outcome planning’ whilst the
studies themselves appear based upon outdated population information and flawed
scoping.
We would strongly urge Fingal County Council and Greater Dublin Drainage to consider
the wishes of its citizens via this submission and, reconsider this deeply flawed,
undemocratic process.
Yours Sincerely,
__________________
Neil Cramer
Commodore
Skerries Sailing Club